1.1 Welcome to the ArenaPlus platform run by Leisure and Resorts
World Corporation (LRWC) Limited and its affiliates (individually
and collectively, "ArenaPlus", "we", "us" or "our"). ArenaPlus
takes its responsibilities under applicable privacy laws and
regulations ("Privacy Laws") seriously and is committed to
respecting the privacy rights and concerns of all Users of our
ArenaPlus website and mobile application (the "Platform") (we
refer to the Platform and the services we provide as described on
our Platform collectively as the "Services"). Users refers to a
user who registers for an account with us for use of the Services.
We recognize the importance of the personal data you have
entrusted to us and believe that it is our responsibility to
properly manage, protect and process your personal data. This
Privacy Policy (“Privacy Policy” or “Policy”) is designed to
assist you in understanding how we collect, use, disclose and/or
process the personal data you have provided to us and/or we
possess about you, whether now or in the future, as well as to
assist you in making an informed decision before providing us with
any of your personal data.
1.2 "Personal Data" or "personal data" means data, whether true or
not, about an individual who can be identified from that data, or
from that data and other information to which an organization has
or is likely to have access. Common examples of personal data
could include name, identification number and contact information.
1.3 By using the Services, registering for an account with us,
visiting our Platform, or accessing the Services, you acknowledge
and agree that you accept the practices, requirements, and/or
policies outlined in this Privacy Policy, and you hereby consent
to us collecting, using, disclosing and/or processing your
personal data as described herein. IF YOU DO NOT CONSENT TO THE
PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED IN THIS PRIVACY
POLICY, PLEASE DO NOT USE OUR SERVICES OR ACCESS OUR PLATFORM. If
we change our Privacy Policy, we will notify you including by
posting those changes or the amended Privacy Policy on our
Platform. We reserve the right to amend this Privacy Policy at any
time. To the fullest extent permissible under applicable law, your
continued use of the Services or Platform, shall constitute your
acknowledgment and acceptance of the changes made to this Privacy
Policy.
1.4 This Policy applies in conjunction with other notices,
contractual clauses, consent clauses that apply in relation to the
collection, storage, use, disclosure and/or processing of your
personal data by us and is not intended to override those notices
or clauses unless we state expressly otherwise.
1.5 This Policy applies to both buyers and sellers who use the
Services except where expressly stated otherwise.
2.1 We will/may collect personal data about you:
• when you register and/or use our Services or Platform, or open
an account with us;
• when you enter into any agreement or provide other documentation
or information in respect of your interactions with us, or when
you use our products and services;
• when you interact with us, such as via telephone calls (which
may be recorded), letters, fax, face-to-face meetings, social
media platforms and emails, including when you interact with our
customer service agents;
• when you use our electronic services, or interact with us via
our application or use services on our Platform. This includes,
without limitation, through cookies which we may deploy when you
interact with our application or website;
• when you grant permissions on your device to share information
with our application or Platform;
• when you link your ArenaPlus account with your social media or
other external account or use other social media features, in
accordance with the provider’s policies;
• when you carry out transactions through our Services;
• when you provide us with feedback or complaints;
• when you submit your personal data to us for any reason The
above does not purport to be exhaustive and sets out some common
instances of when personal data about you may be collected.
3.1 The personal data that ArenaPlus may collect includes but is
not limited to:
• name;
• email address;
• date of birth;
• billing and/or delivery address;
• bank account and payment information;
• telephone number;
• gender;
• information sent by or associated with the device(s) used to
access our Services or Platform;
• information about your network and the people and accounts you
interact with;
• photographs or audio or video recordings;
• government issued identification or other information required
for our due diligence, know your customer, identity verification,
or fraud prevention purposes;
• marketing and communications data, such as your preferences in
receiving marketing from us and third parties, your communication
preferences and history of communications with us, our service
providers, and other third parties;
• usage and transaction data, including details about your
searches, orders, the advertising and content you interact with on
the Platform, and other products and services related to you;
• location data;
• any other information about the User when the User signs up to
use our Services or Platform, and when the User uses the Services
or Platform, as well as information related to how the User uses
our Services or Platform; and aggregate data on content the User
engages with.
3.2 You agree not to submit any information to us which is
inaccurate or misleading, and you agree to inform us of any
inaccuracies or changes to such information. We reserve the right
at our sole discretion to require further documentation to verify
the information provided by you.
3.3 If you sign up to be a user of our Platform using your social
media account (“Social Media Account”), link your ArenaPlus
account to your Social Media Account or use any ArenaPlus social
media features, we may access information about you which you have
voluntarily provided to your Social Media Account provider in
accordance with such provider's policies, and we will manage and
use any such personal data in accordance with this Policy at all
times.
3.4 If you do not want us to collect the aforementioned
information/personal data, you may opt out at any time by
notifying our Data Protection Officer in writing. Further
information on opting out can be found in the section below
entitled "How can you withdraw consent, remove, request access to
or modify information you have provided to us?" Note, however,
that opting out or withdrawing your consent for us to collect, use
or process your personal data may affect your use of the Services
and the Platform.
4.1 As with most websites and mobile applications, your device
sends information which may include data about you that gets
logged by a web server when you browse our Platform. This
typically includes without limitation your device’s Internet
Protocol (IP) address, computer/mobile device operating system and
browser type, type of mobile device, the characteristics of the
mobile device, the unique device identifier (UDID) or mobile
equipment identifier (MEID) for your mobile device, the address of
a referring web site (if any), the pages you visit on our website
and mobile applications and the times of visit, and sometimes a
"cookie" (which can be disabled using your browser preferences) to
help the site remember your last visit. If you are logged in, this
information is associated with your personal account. The
information is also included in anonymous statistics to allow us
to understand how visitors use our site.
4.2 Our mobile applications may collect precise information about
the location of your mobile device using technologies such as GPS,
Wi-Fi, etc. We collect, use, disclose and/or process this
information for one or more Purposes including, without
limitation, location-based services that you request or to deliver
relevant content to you based on your location or to allow you to
share your location to other Users as part of the services under
our mobile applications. For most mobile devices, you are able to
withdraw your permission for us to acquire this information on
your location through your device settings. If you have questions
about how to disable your mobile device's location services,
please contact your mobile device service provider or the device
manufacturer.
4.3 As when you view pages on our website or mobile application,
when you watch content and advertising and access other software
on our Platform or through the Services, most of the same
information is sent to us (including, without limitation, IP
Address, operating system, etc.); but, instead of page views, your
device sends us information on the content, advertisement viewed
and/or software installed by the Services and the Platform and
time.
5.1 We or our authorized service providers and advertising
partners may from time to time use "cookies" or other features to
allow us or third parties to collect or share information in
connection with your use of our Services or Platform. These
features help us improve our Platform and the Services we offer,
help us offer new services and features, and/or enable us and our
advertising partners serve more relevant content to you, including
through remarketing. “Cookies” are identifiers that are stored on
your computer or mobile device that record data about computer or
device, how and when the Services or Platform are used or visited,
by how many people and other activity within our Platform. We may
link cookie information to personal data. Cookies also link to
information regarding what web pages you have viewed. This
information is used to enable our third-party advertising partners
to serve advertisements on sites across the internet, and to
conduct data analysis and to monitor usage of the Services.
5.2 You may refuse the use of cookies by selecting the appropriate
settings on your browser or device. However, please note that if
you do this you may not be able to use the full functionality of
our Platform or the Services.
6.1 We may collect, use, disclose and/or process your personal
data for one or more of the following purposes:
• to consider and/or process your application/transaction with us
or your transactions or communications with third parties via the
Services;
• to manage, operate, provide and/or administer your use of and/or
access to our Services and our Platform, as well as your
relationship and user account with us;
• to respond to, process, deal with or complete a transaction
and/or to fulfil your requests for certain products and services
and notify you of service issues and unusual account actions;
• to enforce our Terms of Service or any applicable end user
license agreements;
• to protect personal safety and the rights, property or safety of
others;
• for identification, verification, due diligence, or know your
customer purposes;
• to evaluate and make decisions relating to your credit and risk
profile and eligibility for credit products;
• to maintain and administer any software updates and/or other
updates and support that may be required from time to time to
ensure the smooth running of our Services;
• to deal with or facilitate customer service, carry out your
instructions, deal with or respond to any enquiries given by (or
purported to be given by) you or on your behalf;
• to contact you or communicate with you via voice call, text
message and/or fax message, email and/or postal mail or otherwise
for the purposes of administering and/or managing your
relationship with us or your use of our Services, such as but not
limited to communicating administrative information to you
relating to our Services. You acknowledge and agree that such
communication by us could be by way of the mailing of
correspondence, documents or notices to you, which could involve
disclosure of certain personal data about you to bring about
delivery of the same as well as on the external cover of
envelopes/mail packages;
• to allow other users to interact, connect with you or see some
of your activities on the Platform, including to inform you when
another User has sent you a private message, posted a comment for
you on the Platform or connected with you using the social
features on the Platform;
• to conduct research, analysis and development activities
(including, but not limited to, data analytics, surveys, product
and service development and/or profiling), to analyze how you use
our Services, to recommend products and/or services relevant to
your interests, to improve our Services or products and/or to
enhance your customer experience;
• to allow for audits and surveys to, among other things, validate
the size and composition of our target audience, and understand
their experience with ArenaPlus’s Services;
• for marketing and advertising, and in this regard, to send you
by various mediums and modes of communication marketing and
promotional information and materials relating to products and/or
services (including, without limitation, products and/or services
of third parties whom ArenaPlus may collaborate or tie up with)
that Arena Plus (and/or its affiliates or related corporations)
may be selling, marketing or promoting, whether such products or
services exist now or are created in the future. You can
unsubscribe from receiving marketing information at any time by
using the unsubscribe function within the electronic marketing
material. We may use your contact information to send newsletters
or marketing materials from us and from our related companies;
• to respond to legal processes or to comply with or as required
by any applicable law, governmental or regulatory requirements of
any relevant jurisdiction or where we have a good faith belief
that such disclosure is necessary, including, without limitation,
meeting the requirements to make disclosure under the requirements
of any law binding on ArenaPlus or on its related corporations or
affiliates (including, where applicable, the display of your name,
and contact details);
• to produce statistics and research for internal and statutory
reporting and/or record-keeping requirements;
• to carry out due diligence or other screening activities
(including, without limitation, background checks) in accordance
with legal or regulatory obligations or our risk management
procedures that may be required by law or that may have been put
in place by us;
• to audit our Services or ArenaPlus's business;
• to prevent or investigate any actual or suspected violations of
our Terms of Service, fraud, unlawful activity, omission or
misconduct, whether relating to your use of our Services or any
other matter arising from your relationship with us;
• to respond to any threatened or actual claims asserted against
ArenaPlus or other claim that any Content violates the rights of
third parties;
• to store, host, back up (whether for disaster recovery or
otherwise) of your personal data, whether within or outside of
your jurisdiction;
• to deal with and/or facilitate a business asset transaction or a
potential business asset transaction, where such transaction
involves ArenaPlus as a participant or involves only a related
corporation or affiliate of ArenaPlus as a participant or involves
ArenaPlus and/or any one or more of ArenaPlus's related
corporations or affiliates as participant(s), and there may be
other third party organizations who are participants in such
transaction. A “business asset transaction” refers to the
purchase, sale, lease, merger, amalgamation or any other
acquisition, disposal or financing of an organization or a portion
of an organization or of any of the business or assets of an
organization; and/or;
• any other purposes which we notify you of at the time of
obtaining your consent.
(collectively, the “Purposes”).
6.2 You acknowledge, consent and agree that ArenaPlus may access,
preserve and disclose your Account information and Content if
required to do so by law or pursuant to an order of a court or by
any governmental or regulatory authority having jurisdiction over
ArenaPlus or in a good faith belief that such access preservation
or disclosure is reasonably necessary to: (a) comply with legal
process; (b) comply with a request from any governmental or
regulatory authority having jurisdiction over ArenaPlus; (c)
enforce the ArenaPlus Terms of Service or this Privacy Policy; (d)
respond to any threatened or actual claims asserted against
ArenaPlus or other claim that any Content violates the rights of
third parties; (e) respond to your requests for customer service;
or (f) protect the rights, property or personal safety of
ArenaPlus, its users and/or the public.
6.3 As the purposes for which we will/may collect, use, disclose
or process your personal data depend on the circumstances at hand,
such purpose may not appear above. However, we will notify you of
such other purpose at the time of obtaining your consent, unless
processing of the applicable data without your consent is
permitted by the Privacy Laws.
7.1 We implement a variety of security measures and strive to
ensure the security of your personal data on our systems. User
personal data is contained behind secured networks and is only
accessible by a limited number of employees who have special
access rights to such systems. However, there can inevitably be no
guarantee of absolute security.
7.2 We will retain personal data in accordance with the Privacy
Laws and/or other applicable laws. That is, we will destroy or
anonymize your personal data when we have reasonably determined
that (i) the purpose for which that personal data was collected is
no longer being served by the retention of such personal data;
(ii) retention is no longer necessary for any legal or business
purposes; and (iii) no other legitimate interests warrant further
retention of such personal data. If you cease using the Platform,
or your permission to use the Platform and/or the Services is
terminated or withdrawn, we may continue storing, using and/or
disclosing your personal data in accordance with this Privacy
Policy and our obligations under the Privacy Laws. Subject to
applicable law, we may securely dispose of your personal data
without prior notice to you.
8.1 In conducting our business, we will/may need to use, process,
disclose and/or transfer your personal data to our third-party
service providers, agents and/or our affiliates or related
corporations, and/or other third parties, which may be located in
Singapore or outside of Singapore, for one or more of the
above-stated Purposes. Such third-party service providers, agents
and/or affiliates or related corporations and/or other third
parties would be processing your personal data either on our
behalf or otherwise, for one or more of the above-stated Purposes.
We endeavor to ensure that the third parties and our affiliates
keep your personal data secure from unauthorized access,
collection, use, disclosure, processing or similar risks and
retain your personal data only for as long as your personal data
is needed for the above-mentioned Purposes. Such third parties
include, without limitation:
• our subsidiaries, affiliates and related corporations;
• other users of our Platform for one or more of the above-stated
Purposes;
• contractors, agents, service providers and other third parties
we use to support our business. These include but are not limited
to those parties which provide administrative or other services to
us such as mailing houses, logistics service providers, financial
services providers, advertising and marketing partners,
telecommunication companies, information technology companies, and
data centers;
• governmental or regulatory authorities having jurisdiction over
ArenaPlus or as otherwise permitted under Section 6.2;
• a user in the event of a merger, divestiture, restructuring,
reorganization, dissolution or other sale or transfer of some or
all of ArenaPlus’s assets, whether as a going concern or as part
of bankruptcy, liquidation or similar proceeding, in which
personal data held by ArenaPlus about our Service Users is among
the assets transferred; or to a counterparty in a business asset
transaction that ArenaPlus or any of its affiliates or related
corporations is involved in;
• and third parties to whom disclosure by us is for one or more of
the Purposes and such third parties would in turn be collecting
and processing your personal data for one or more of the Purposes.
8.2 We may share user information, including statistical and
demographic information, about our Users and information about
their use of the Services with advertising partners and third
party suppliers of advertisements, remarketing, and/or other
programming. We may share user information, including statistical
and demographic information, about our Users and information about
their use of the Services with advertising partners and third
party suppliers of advertisements, remarketing, and/or other
programming.
8.3 For the avoidance of doubt, in the event that Privacy Laws or
other applicable laws permit an organization such as us to
collect, use or disclose your personal data without your consent,
such permission granted by the laws shall continue to apply.
Consistent with the foregoing and subject to applicable law, we
may use your personal data for recognized legal grounds including
to comply with our legal obligations, to perform our contract with
you, to achieve a legitimate interest and our reasons for using it
outweigh any prejudice to your data protection rights, or where
necessary in connection with a legal claim.
8.4 Third parties may unlawfully intercept or access personal data
transmitted to or contained on the site, technologies may
malfunction or not work as anticipated, or someone might access,
abuse or misuse information through no fault of ours. We will
nevertheless deploy reasonable security arrangements to protect
your personal data as required by the Privacy Laws; however there
can inevitably be no guarantee of absolute security such as but
not limited to when unauthorized disclosure arises from malicious
and sophisticated hacking by malcontents through no fault of ours.
8.5 As set forth in ArenaPlus’s Terms of Service, Users (including
any employees, agents, representatives, or any other person acting
for such User or on such User’s behalf) in possession of another
User’s personal data through the use of the Services (the
“Receiving Party”) hereby agree that, they will (i) comply with
all applicable Privacy Laws with respect to any such data,
including any collection, processing, storage or transfer of such
data; (ii) allow ArenaPlus or the User whose personal data the
Receiving Party has collected (the “Disclosing Party”) to remove
his or her data so collected from the Receiving Party’s database;
and (iii) allow Arena Plus or the Disclosing Party to review what
information has been collected about them by the Receiving Party,
in each case of (ii) and (iii) above, in compliance with and where
required by applicable laws.
8.6 Notwithstanding anything set forth herein, Users (including
any employees, agents, representatives, or any other person acting
for such User or on such User’s behalf) shall comply with all
applicable Privacy Laws and, in respect of any user’s personal
data received from ArenaPlus, (i) are not permitted to use such
user’s personal data except as reasonably necessary to respond to
users’ enquiries and to carry out respond to, process, deal with
or complete a transaction without the users’ and ArenaPlus’s prior
written consent; (ii) should refrain from contacting users using
such information outside of the ArenaPlus platform; (iii) are not
permitted to disclose such user’s personal data to any
unauthorized third parties without the buyer’s and ArenaPlus’s
prior written consent; (iv) shall employ sufficient security
measures to protect each ArenaPlus user’s personal data in their
possession, retain such data only for as long as necessary for the
purposes above and in accordance with the Privacy Laws, and to
delete or return such data to ArenaPlus upon any request from
ArenaPlus or as soon as reasonably possible upon completion of the
transaction; and (v) to inform ArenaPlus’s official mail at
[email protected] , in the event of any potential data breach or
other loss of such user’s data.
9.1 The Services are not intended for individuals under the age of 21. We do not knowingly collect or maintain any personal data or non-personally-identifiable information from anyone under the age of 21 nor is any part of our Platform or other Services directed to individuals under the age of 21. We will close any accounts used exclusively by such individuals and will remove and/or delete any personal data we believe was submitted under the age of 21.
10.1 Our Platform uses Google Analytics, a web analytics service
provided by Google, Inc. ("Google"). Google Analytics uses
cookies, which are text files placed on your device, to help the
Platform analyze how Users use the Platform. The information
generated by the cookie about your use of the Platform (including
your IP address) will be transmitted to and stored by Google on
servers in the United States. Google will use this information for
the purpose of evaluating your use of the Platform, compiling
reports on website activity for website operators and providing
other services relating to website activity and Internet usage.
Google may also transfer this information to third parties where
required to do so by law, or where such third parties process the
information on Google's behalf. Google will not associate your IP
address with any other data held by Google.
10.2 We, and third parties, may from time to time make software
applications downloads available for your use via the Platform or
through the Services. These applications may separately access,
and allow a third party to view, your identifiable information,
such as your name, your user ID, your device’s IP Address or other
information such as any cookies that you may previously have
installed or that were installed for you by a third party software
application or website. Additionally, these applications may ask
you to provide additional information directly to third parties.
Third party products or services provided through these
applications are not owned or controlled by ArenaPlus. You are
encouraged to read the terms and other policies published by such
third parties on their websites or otherwise.
11.1 WE DO NOT GUARANTEE THE SECURITY OF PERSONAL DATA AND/OR
OTHER INFORMATION THAT YOU PROVIDE ON THIRD PARTY SITES. We do
implement a variety of security measures to maintain the safety of
your personal data that is in our possession or under our control.
Your personal data is contained behind secured networks and is
only accessible by a limited number of persons who have special
access rights to such systems, and are required to keep the
personal data confidential. When you place orders or access your
personal data, we offer the use of a secure server. All personal
data or sensitive information you supply is encrypted into our
databases to be only accessed as stated above.
11.2 In an attempt to provide you with increased value, we may
choose various third-party websites to link to, and frame within,
the Platform. We may also participate in co-branding and other
relationships to offer e-commerce and other services and features
to our visitors. These linked sites have separate and independent
privacy policies as well as security arrangements. Even if the
third party is affiliated with us, we have no control over these
linked sites, each of which has separate privacy and data
collection practices independent of us. Data collected by our
co-brand partners or third-party web sites (even if offered on or
through our Platform) may not be received by us.
11.3 We therefore have no responsibility or liability for the
content, security arrangements (or lack thereof) and activities of
these linked sites. These linked sites are only for your
convenience and you therefore access them at your own risk.
Nonetheless, we seek to protect the integrity of our Platform and
the links placed upon each of them and therefore welcome any
feedback about these linked sites (including, without limitation,
if a specific link does not work).
12.1 Withdrawing Consent
12.1.1 You may withdraw your consent for the collection, use
and/or disclosure and/or request deletion of your personal data in
our possession or under our control by sending an email to our
official mail at [email protected] , and we will process such
requests in accordance with this Privacy Policy and our
obligations under the Privacy Laws and other applicable law.
However, your withdrawal of consent may mean that we will not be
able to continue providing the Services to you and we may need to
terminate your existing relationship and/or the contract you have
with us.
12.2 Requesting Access to or Correction of Personal Data
12.2.1 If you have an account with us, you may personally access
and/or correct your personal data currently in our possession or
control through the Account Settings page on the Platform. If you
do not have an account with us, you may request to access and/or
correct your personal data currently in our possession or control
by submitting a written request to us. We will need enough
information from you in order to ascertain your identity as well
as the nature of your request so as to be able to deal with your
request. Hence, please submit your written request by sending an
email to our official mail at [email protected].
12.2.2 We reserve the right to refuse to correct your personal
data in accordance with the provisions as set out in Privacy Laws,
where they require and/or entitle an organization to refuse to
correct personal data in stated circumstances.
13. QUESTIONS, CONCERNS OR COMPLAINTS? CONTACT US
13.1 If you have any questions or concerns about our privacy
practices, we welcome you to contact us by e-mail at
[email protected]
