Privacy Policy

We are Reveliio Technologies Pte. Ltd. (202440932G) trading as www.reveliio.com ("Reveliio").

Protection of your Personal Data is important to us. This Privacy Policy ("Policy") outlines how we manage the Personal Data we hold. Please read and review this Policy, which will detail how we collect, use, process and disclose your Personal Data. We may also collect and process your Personal Data under any exceptions to applicable laws, which are not set out in this Policy.

Definitions

Capitalised terms used in this Policy shall have the following meanings:

• "Personal Data" means any data, whether true or not, which is: (a) about an individual who can be identified (i) from that data; or (ii) from that data and other information to which we have or are likely to have access and would include data in our records as may be updated from time to time, or (b) defined as "personal data" or "personal information" under any applicable laws.
• "Platform" means collectively Reveliio's Social Media and Website, and any other websites, platforms or applications which we may own, manage or operate from time to time;
• "Services" means our services accessible from and on our Platform;
• "Social Media" means Reveliio's pages and accounts on any third party social media platforms such as Instagram, Facebook, Twitter, Pinterest, discord and any and all other community channels that may be used;
• "Third Party" means any third party to which you provide access to your user account or for which you use and access our Platform and Services to collect information on such party's behalf;
• "Website" means the web and mobile versions of the Reveliio website accessed at the following address at www.reveliio.com; and
• "we", "us", or "our" means Reveliio.

This Policy applies in conjunction with other notices, contractual clauses and 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 them unless we state expressly otherwise.

Personal Data We Collect

During our relationship with you, we may collect Personal Data from you. Such Personal Data include:

• Identity data, such as your name, passport and any other unique identification numbers
• Contact data, such as mailing, delivery and billing addresses, email address and phone numbers
• Transaction data, such as details about your proof of purchase and uploaded receipts which may contain transaction, payment and/or credit card information
• Technical data, such as network and device data (including your internet protocol (IP address and device or advertising identifiers), login data, browser type and version, time zone setting and location, browser plug-in types and versions, device identifier, and other information and technology on the devices you use to access our Platform
• Profile data, such as your username and password, interests, preferences, feedback and survey responses
• Usage data, such as information on how you use our Platform and Services or view any content on our Platform
• Marketing and communications data, such as your communication preferences
• Any other personally identifiable information which you have provided us in any forms you may have submitted to us, or in the course of any other forms of interaction between you and us

If you provide us with Personal Data relating to a Third Party by submitting such Personal Data to us, you hereby represent, warrant and undertake to us that you have obtained the consent of the Third Party to provide us with their Personal Data for the relevant purposes and to the terms herein.

We may update this Policy to ensure that it is consistent with industry trends and/or any changes in relevant legal or regulatory requirements. We reserve the right to amend the terms of this Policy at our absolute discretion. Subject to your rights at law, you agree to be bound by the prevailing terms of this Policy as updated from time to time on our Platform. Any amended Policy will be posted on our Platform along with an updated version note and can be viewed at www.reveliio.com/privacy. By continuing to use and access our Platform after this Policy has been amended, you hereby agree to be bound by the terms of such amended Policy.

You are encouraged to visit our Platform from time to time to ensure that you are well-informed of our latest policies in relation to Personal Data protection.

Collection of Personal Data

We collect Personal Data from you when:

• you register an account on our Platform;
• you access, use or interact with our Platform;
• you otherwise interact with us via an external service or application (such as Facebook or Google);
• you browse our Services or use any of our related services, such as subscribing to our newsletter and marketing collaterals;
• you use any of the features or functions or Services available on our Platform;
• you accept our cookies on your device;
• you interact with our designers or other representatives, for example, where you provide comments and feedback on our Services;
• you interact with us on our Social Media, such as liking or commenting on our posts, private or direct messaging us on our Social Media;
• your authorised representative submits your Personal Data to us for any purpose reasonably authorised by you;
• you participate in our promotions, lucky draws, giveaways, initiatives or any request for additional Personal Data such as customer surveys;
• our third-party service providers provide your Personal Data to us, which was collected and processed by them and disclosed to us pursuant to their separate privacy policies; or
• you voluntarily submit your Personal Data to us for any other reason.

We may also collect your Personal Data in circumstances where such collection does not require consent under applicable laws.

Please ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure to do so may result in our inability to provide or continue providing you with the Services.

Use of Personal Data

We may use and disclose your Personal Data for purposes necessary to provide you with our Services, including to:

• facilitate your use of and access to our Platform;
• register and maintain your user account verify your identity or age;
• process your order for our Services, process or collect your payment for the order;
• communicate with you in relation to: (a) your queries, requests and feedback, (b) material changes to this Policy and/or our Terms of Service, and (c) matters relating to the operation of your account;
• monitor and enforce compliance with our Terms of Service, including dispute resolution;
• comply with: (a) internal risk controls, (b) the terms of our access to payment processing, financial or banking services such as credit card disputes, fraud, billing errors; or (c) any applicable law;
• ensure our Platform functions properly and to improve its performance, by carrying out activities such as debugging, statistical analyses for optimizing our Platform;
• provide you with any add-on or premium Services we may develop or initiate from time to time;
• process your participation in and otherwise administer our promotions, contests, lucky draws, initiatives or any request for additional Personal Data such as customer surveys;
• manage the administrative and business operations of Reveliio and comply with internal policies and procedures; and
• any specific purpose in relation to a particular Service, which we may separately notify you on the page relating to such Service.

(collectively, the "Purposes").

We may also use your Personal Data: (a) for other purposes which are reasonably related to the Purposes; or (b) in circumstances where such use does not require consent under applicable laws. The above Purposes are not exhaustive and depending on the nature of your relationship with us, we may collect, use and disclose your Personal Data for additional purposes which you will be notified of, in accordance with applicable terms and conditions.

In addition to and without prejudice to the Purposes, we may, in the legitimate interest of Reveliio, use and/or disclose any Personal Data about you or your use of our Platform without your prior permission if we have a good faith belief that such action is necessary to: (i) protect and defend the rights, property or safety of us or our partners, employees, affiliates, other users of the site or the public; (ii) enforce our Terms of Service; or (iii) respond to claims that any content violates the rights of third parties or is otherwise unlawful.

Please note that if you withdraw your consent for us to use and process your Personal Data the Purposes, we may no longer be able to provide you with the related benefits associated with such Purposes.

Sharing of Personal Data

We will not sell, exchange or otherwise distribute your Personal Data without your consent, except to the extent required by applicable law, in accordance with your instructions, or as identified in this Policy. In relation to our use of your Personal Data for the Purposes, we may disclose your Personal Data to our:

• overseas offices. We may share or transfer your Personal Data within the organisation as required, subject to the local applicable data protection laws;
• payment processors, who process your payment on our Platform;
• professional advisers and consultants such as our auditors and lawyers;
• agents, contractors, affiliates or service providers who provide operational services to us, such as online cloud storage and processing, marketing optimisation, information technology, telecommunications, security or other relevant services which require their collection, use or disclosure of your Personal Data. Such partners and service providers shall be responsible for the information in their possession and that information will be subject to any privacy policies that such partners or third parties may have in place. We are not responsible for the use or misuse of your Personal Data by any such partner or third party;
• prospective acquiror or parties related to a transaction. In the event of a merger, acquisition, takeover, bankruptcy, liquidation, transfer of the business, shares or assets of Reveliio, we may disclose, share or transfer your information to the prospective acquiror and/or other relevant third parties. We will make sure that any such transfer is done in a secure way. You acknowledge that such transfers may occur, and that any acquiror of us or any of our assets may continue to use your Personal Data as set forth in this Policy; and
• any other party whom you authorise us to disclose your Personal Data to.

We may also disclose your Personal Data: (a) for other purposes which are reasonably related to the Purposes; or (b) in circumstances where such disclosure does not require consent under applicable laws.

We do our best to minimise the disclosure of your Personal Data to the information necessary to perform the related Purpose. We will also require that such organisations or persons to whom such disclosure is made as service providers to us acknowledge the confidentiality of such Personal Data, undertake to respect any individual's right to privacy and comply with applicable laws.

How Long We Retain Your Personal Data

We will retain your information only for so long as necessary for the purposes set out in this Policy, i.e. for as long as your account is active, or as needed to provide the Services to you. In addition, we will also retain and use your Personal Data to the extent necessary to comply with our legal obligations, e.g. for record retention purposes as required by applicable laws, to resolve disputes or to enforce our agreements.

You may close your account if you no longer want us to use your Personal Data to provide the Services. Please note that we may continue to retain log files for internal record, analysis and regulatory purposes even after you close your account.

Your Rights Over Your Personal Data

You have several rights under applicable laws, including, under certain circumstances to request:

• access to your correction of your Personal Data. Please see below for more information;
• erasure of your Personal Data. You have the right to request deletion of your Personal Data we have in our possession, subject to other record retention obligations we may have;
• restriction of processing of your Personal Data;
• the transfer of your Personal Data. In some circumstances, you may request that the information which you have provided to us is provided to you, so you can transfer it to another data controller;
• object to processing of your Personal Data. You have the right to object to the processing of your Personal Data which is processed on the grounds of legitimate interest;
• human intervention for automated decision making. In the event of any automated decision making about you based on your Personal Data, you may request human intervention in the decision making. For the avoidance of doubt, we do not use any automated decision making.

If you wish to exercise any of these rights, please email our Data Protection Officer at privacy@reveliio.com and we will do our best to respond to your requests within 30 days.

Accessing or Correcting Personal Data

If you would like assistance in accessing and/or correcting your Personal Data, you may request to access and correct such Personal Data by submitting a written request to us by emailing our Data Protection Officer at privacy@reveliio.com. We may need to request additional information from you to confirm your identity before providing the access or making the correction.

We will do our best to respond to Personal Data access and correction requests within 30 days. Where we are unable to meet this timeline, we will update you with the soonest possible time within which we can provide the information or make the correction.

We reserve the right to charge a reasonable administrative fee for retrieving your Personal Data records and/or handling and processing your Personal Data access request, to the extent permitted by applicable laws. If so, we will inform you of the fee before processing your request.

We will take steps to send your corrected Personal Data to every other person or entity to which such Personal Data was disclosed by Reveliio within the year after the date of the correction, unless such person or entity does not need the corrected Personal Data for any legal or business purpose.

Request to Withdraw Consent

If you wish to withdraw your consent for us to send you sales, marketing or promotional information, please email our Data Protection Officer at privacy@reveliio.com.

Once we receive notification of your intention to withdraw your consent, it may take up to 30 days for your withdrawal to be reflected in our systems. During this interim period, you may still receive marketing or promotional materials or communications.

You may withdraw your consent for the collection, use and/or disclosure of any of your Personal Data in our possession or under our control by submitting a written request via email to our Data Protection Officer at privacy@reveliio.com. Depending on the nature of the consent withdrawal, we may not be able to continue to provide you with the related benefits associated with the Purposes. We will process such a request within a reasonable time from the date we receive notice from you of your withdrawal of consent. Once processing is complete, we will no longer collect, use and/or disclose your Personal Data, except to the extent we retain your Personal Data for compliance, regulatory or other legal purposes.

Administration and Management of Personal Data

We will make reasonable efforts to ensure Personal Data likely to be used by us or disclosed by us to another organisation is accurate and complete. However, you should update us of any changes in your Personal Data. We will not be responsible for relying on inaccurate or incomplete Personal Data if you have not updated us of changes.

We will also put in place reasonable security arrangements to ensure that your Personal Data is adequately protected and secured. This includes putting in place reasonable measures to prevent any unauthorised access, collection, use, disclosure, copying, modification, leakage, loss, damage or alteration of your Personal Data, such as restricting access to Personal Data to individuals who require access, maintaining technology products to prevent unauthorised computer access and using 128-bit SSL (secure sockets layer) encryption technology when processing your financial details. We will require any third party who is contracted to process your Personal Data on our behalf to have security measures in place to protect your Personal Data and to treat such Personal Data in accordance with applicable laws. However, we will not be responsible for any unauthorised use of Personal Data by third parties which is attributable to factors beyond our control.

When Personal Data in our possession is: (a) no longer required for any reason connected to the purpose it was originally collected; or (b) retention by us is no longer necessary for any other legal or business purposes, we will exercise measures to ensure such Personal Data is either destroyed or anonymised.

Children

Our Platform is directed towards and designed for use by persons aged 18 or older. We do not knowingly collect, maintain or use Personal Data from children under 18 years of age. We protect the Personal Data of children along with the necessary parental consent in the same manner as we protect the Personal Data of adults.

For residents of the European Union, the United Kingdom and Switzerland, where processing of Personal Data is based on consent, we will not knowingly engage in that processing for users under the age of consent as established by applicable laws. If we learn that we are engaged in such processing, we will halt such processing and take reasonable measures to promptly remove applicable information from our records.

Transfer of Personal Data

Your Personal Data may be stored in external servers located overseas. In addition, in carrying out our business, it may be necessary to share information about you with and between our related corporations and affiliates, and third party service providers, some of which may be located in countries outside your country of residence. Such countries may not afford a standard of protection similar to those in your country of residence. However, we will take reasonable steps to ensure that your Personal Data transmitted outside of your country of residence is adequately protected. In addition, we will ensure that such transfers comply with the requirements of the applicable data protection laws.

Third Party Cookies

Reveliio or its authorised service providers may implement cookies, web beacons and other similar technologies for storing data on our Platform. When you visit our Platform through any device with internet connectivity, our computer servers will automatically record data including your IP address, browser type, webpage you were visiting before you came to our Platform, the pages within our Platform which you visit, and the time spent on those pages, items and data searched for on our Platform and other statistics.

You may manage and/or reject cookies through the settings on your browser or device. Note that this may result in the loss of Platform functionality, restrict your use of our Platform, or delay or affect the way in which our Platform operates.

Right to Disclose Personal Data

Governing Law

This Policy shall be governed by and construed in accordance with the laws of the Republic of Singapore.

Contact Us

For any questions relating to your Personal Data or about this Policy, if you have a complaint regarding the collection, use or handling of your Personal Data by us, or a question about how we are complying with applicable laws, you may contact our Data Protection Officer in writing at privacy@reveliio.com.

If you wish to raise a concern about our Personal Data protection practices, you have the right to do so with your local supervisory authority.