Data Protection Policy
Last Updated: 8/21/2024
Data Protection Notice for Users
This Data Protection Notice (“Notice”) sets out the basis which Pentatonic Y Pte Ltd located at 30 Cecil St, #19-08, Prudential Tower, Singapore 049712 (referred to as "Y-Cucumber", “we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of our customers in accordance with the Personal Data Protection Act 2012 (“PDPA”). This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.
By using the associated features, functions and services accessible from the Y- Cucumber website as described in the Terms and Conditions (collectively, referred to as the "Services"), you consent to the data practices described in this Notice.
Personal Data
As used in this Notice:
(a) “customer” means an individual who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us;
(b) “personal data” means data, whether true or not, about a customer who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access; and
(c) For the purposes of this provision, “processing”, in relation to personal data, means the carrying out of any operation or set of operations in relation to the personal data, and includes any of the following: recording; holding; organisation, adaptation or alteration; retrieval; combination; transmission; and erasure or destruction. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include name, residential address, email address, telephone number, nationality, gender, date of birth, marital status, financial information and occupation and service preferences.
Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include name, residential address, email address, telephone number, nationality, gender, date of birth, marital status, financial information and occupation and service preferences.
(a) “customer” means an individual who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us;
(b) “personal data” means data, whether true or not, about a customer who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access; and
(c) For the purposes of this provision, “processing”, in relation to personal data, means the carrying out of any operation or set of operations in relation to the personal data, and includes any of the following: recording; holding; organisation, adaptation or alteration; retrieval; combination; transmission; and erasure or destruction. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include name, residential address, email address, telephone number, nationality, gender, date of birth, marital status, financial information and occupation and service preferences.
Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include name, residential address, email address, telephone number, nationality, gender, date of birth, marital status, financial information and occupation and service preferences.
Consent
By using our app, registering an account, or engaging with our Services, you hereby consent to Y-Cucumber using, disclosing and/or processing personal data relating to the you for legal, personnel, administrative and management purposes, including monitoring and recording any use that you make of our app and its associated Services for the purpose of ensuring that the Company’s policies are being complied with and for legitimate business purposes.
Collection and Use of Personal Data
We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
We may collect and use your personal data for any or all of the following purposes:
(a) performing obligations in the course of or in connection with our Service;
(b) verifying your identity;
(c) to understand how you use our platform, including across your devices;
(d) to allow you to participate in features of our app and its associated Services;
(e) to improve and develop our app, website and Services and conduct product development;
(f) to ensure content is presented in the most effective manner for you and your device;
(g) to communicate with you, including to notify you about changes in our Services;
(h) responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
(i) managing your relationship with us;
(j) processing payment or credit transactions;
(k) complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
(l) any other purposes for which you have provided the information;
(m) transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
(n) any other incidental business purposes related to or in connection with the above.
We may collect and use your personal data for any or all of the following purposes:
(a) performing obligations in the course of or in connection with our Service;
(b) verifying your identity;
(c) to understand how you use our platform, including across your devices;
(d) to allow you to participate in features of our app and its associated Services;
(e) to improve and develop our app, website and Services and conduct product development;
(f) to ensure content is presented in the most effective manner for you and your device;
(g) to communicate with you, including to notify you about changes in our Services;
(h) responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
(i) managing your relationship with us;
(j) processing payment or credit transactions;
(k) complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
(l) any other purposes for which you have provided the information;
(m) transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
(n) any other incidental business purposes related to or in connection with the above.
Disclosure of Personal Data
We do not sell, trade, or otherwise transfer personally identifiable information to third parties without user consent, except as described in this Notice.
We may disclose your personal data:
(a) where such disclosure is required for performing obligations in the course of or in connection with our Services; or
(b) to third party service providers, agents and other organisations we have engaged to perform any of the functions with reference to the above mentioned purposes, including but not limited to assisting us in operating our website, conducting our business, or servicing users, as long as those parties agree to keep this information confidential and comply with applicable data protection laws; or
(a) where such disclosure is required for performing obligations in the course of or in connection with our Services; or
(b) to third party service providers, agents and other organisations we have engaged to perform any of the functions with reference to the above mentioned purposes, including but not limited to assisting us in operating our website, conducting our business, or servicing users, as long as those parties agree to keep this information confidential and comply with applicable data protection laws; or
(c) for keeping record in case of an abuse of the platform; or
(d) where necessary to enforce our site policies or protect our or others’ rights, property, or safety; or
(e) where such disclosure is required by law, by an order of a court or tribunal of competent jurisdiction or by a regulatory authority or securities exchange having jurisdiction over us to disclose; or
(f) which is disclosed in confidence to our advisers for the purposes of obtaining advice or assistance in connection with this Notice. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under a contract with you).
(d) where necessary to enforce our site policies or protect our or others’ rights, property, or safety; or
(e) where such disclosure is required by law, by an order of a court or tribunal of competent jurisdiction or by a regulatory authority or securities exchange having jurisdiction over us to disclose; or
(f) which is disclosed in confidence to our advisers for the purposes of obtaining advice or assistance in connection with this Notice. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under a contract with you).
Cookies
We may use cookies to help us remember and process your information, understand and save your preferences for future visits and compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. We may contract with third-party service providers to assist us in better understanding our site visitors. These service providers are not permitted to use the information collected on our behalf except to help us conduct and improve our business.
You may be able to refuse or disable cookies by adjusting your device browser settings. Because each browser is different, please consult the instructions provided by your browser. Please note that you may need to take additional steps to refuse or disable certain types of cookies. For example, due to differences in how browsers and mobile apps function, you may need to take different steps to opt out of cookies used for targeted advertising in a browser and to opt out of targeted advertising for a mobile app, which you may control through your device settings or mobile app permissions. In addition, your opt-out selection is specific to the particular browser or device that you are using when you opt out, so you may need to opt-out separately for each of browser or device. If you choose to refuse, disable, or delete cookies, some of the functionality of our app, the website and our Services may no longer be available to you.
You may be able to refuse or disable cookies by adjusting your device browser settings. Because each browser is different, please consult the instructions provided by your browser. Please note that you may need to take additional steps to refuse or disable certain types of cookies. For example, due to differences in how browsers and mobile apps function, you may need to take different steps to opt out of cookies used for targeted advertising in a browser and to opt out of targeted advertising for a mobile app, which you may control through your device settings or mobile app permissions. In addition, your opt-out selection is specific to the particular browser or device that you are using when you opt out, so you may need to opt-out separately for each of browser or device. If you choose to refuse, disable, or delete cookies, some of the functionality of our app, the website and our Services may no longer be available to you.
Reliance on Legitimate Interests Exception
In compliance with the PDPA, we may collect, use or disclose your personal data without your consent for the legitimate interests of Y-Cucumber or another person. In relying on the legitimate interests exception of the PDPA, Y- Cucumber will assess the likely adverse effects on the individual and determine that the legitimate interests outweigh any adverse effect. In line with the legitimate interests’ exception, we will collect, use or disclose your personal data for the following purposes:
(a) fraud detection and prevention; or
(b) detection and prevention of misuse of services; or
(c) network analysis to prevent fraud and financial crime, and perform credit analysis; or
(d) collection and use of personal data on Y-Cucumber’s devices to prevent data loss.
Withdrawing Your Consent
The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.
Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within seven (7) business days of receiving it.
Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 8 above.
Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within seven (7) business days of receiving it.
Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 8 above.
Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
Storage of Personal Data
Your information may be stored on servers located outside the country where you live, such as in Singapore, or other locations where Amazon Web Services (“AWS”) stores data. AWS maintains servers in various countries to bring you our services globally and continuously. See for example: https://aws.amazon.com/about-aws/global-infrastructure/localzones/locations/.
Access to and Correction of Personal Data
If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
We will respond to your request as soon as reasonably possible. In general, our response will be within three (3) business days. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).
Protection of Personal Data
To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as authentication and access controls (such as good password practices, need-to-basis for data disclosure, etc.), minimised collection of personal data, encryption of data, regular patching of operating system and other software, securely erase storage media in devices before disposal, web security measures against risk, usage of end-to-end encryption/ one time password(otp)/2 factor authentication (2fa)/multi-factor authentication (mfa) to secure access, and security review and testing performed regularly.
You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
Least Privilege Principle
We implement fine-grained access control mechanisms to allow granting rights to any party using our app and the app’s authorised operators following the principle of least privilege. Any access to information will be granted on a "need-to-know" basis.
Accuracy of Personal Data
We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.
Retention of Personal Data
We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.
Transfers of Personal Data Outside of Singapore
We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.
Business Transfers
As we continue to develop our business, we might sell or buy other businesses or services. In such transactions, customer information generally is one of the transferred business assets but remains subject to the promises made in any pre-existing Notice (unless, of course, the customer consents otherwise). Also, in the unlikely event that Y-Cucumber, or substantially all of its assets are acquired, customer information will be one of the transferred assets.
Data Protection Officer
You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:
Name of DPO : Penny Chin Poi Yen
Contact No. : +6017-2166149
Email Address : pennyc@ycucumber.com
Effect of Notice and Changes to Notice
This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Y-Cucumber encourages users to periodically review this Notice to be informed on how we protect, use, collect and store your data/information. Continued use of our Services shall constitute your acknowledgement and acceptance to be bound by the terms of the updated Notice.
Contacting Us
If you choose to use our Services, your use and any dispute over your data use, collection, disclosure and/or storage is subject to this Data Protection Policy, including limitations on damages, resolution of disputes, and application of the law of Singapore.
If there are any questions regarding this Data Protection Policy, you may contact us at pennyc@ycucumber.com.
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