Last Updated: 14 October 2020
This Policy applies to our customers, sales agents, partners, third-party providers, vendors, suppliers and service providers (collectively “you”, “your” or “yours”). We are committed to respect your privacy and to protect your personal data. This Policy is to be read along with the Terms and Conditions of the Apps, Websites and Services stated above for your use of the Apps on your phone, computer, tablet or any other electronic device. Please read the Policy fully and carefully to understand our practices regarding your personal data and the way we treat it.
“Personal Data” is any information which can be used to identify you or from which you are identifiable. This includes but is not limited to your name, nationality, telephone number, bank and credit card details, personal interests, email address, your image, government-issued identification numbers, biometric data, race, date of birth, marital status, religion, health information, vehicle and insurance information.
We collect Personal Data about you in the ways listed below. We may also combine the collected Personal Data with other Personal Data in our possession.
You provide your Personal Data to us
We collect, use, store, translate, aggregate and transfer different types of data including but not limited to your Personal Data when you voluntarily provide it to us. For example, you may provide your Personal Data to us when you:
When our services are used
Personal Data may be collected through the normal operation of our Application, Platform, Software, Websites and Services. Some examples are:
From other sources
When we collect Personal Data from other sources, we take best endeavours to ensure that that data is transferred to us in accordance with applicable laws. Such sources include:
Sensitive Personal Data
Some of the information that we collect is sensitive in nature. This includes information such as national ID numbers, race, or marital status. We only collect this information when this is necessary to comply with legal or regulatory requirements.
Personal Data of minors
As a parent or legal guardian, please do not allow minors under your care to submit Personal Data to ETG. In the event that such Personal Data of a minor is disclosed to ETG, you hereby consent to the processing of the minor’s Personal Data and accept and agree to be bound by this Policy and take responsibility for his or her actions.
When you provide Personal Data of other individuals to us
In some situations, you may provide Personal Data of other individuals (such as your spouse, family members or friends) to us. For example, you may add them as the point of contact for the appointments. If you provide us with their Personal Data, you represent and warrant that you have and you have obtained their consent for their Personal Data to be collected, used and disclosed as set out in this Policy.
ETG may use, store, translate, aggregate, combine, transfer and process your Personal Data for the following purposes (“Purposes”).
Providing services and features
Your Personal Data will be used to provide, personalise, maintain and improve our products and services. This includes using your Personal Data to:
We use Personal Data to resolve customer support issues. For example, we may:
Research and development and security
We may use the Personal Data we collect for testing, research, analysis and product development. This allows us to understand and analyse your needs and preferences, protect your Personal Data, improve and enhance the safety and security of our services, develop new features, products and services. We may also collect aggregated data such as statistical or demographical data that may be derived from your personal data although it may not be personal data per se as we may not be able to identify you or any particular individual from the aggregated data.
We may use the Personal Data we collect to investigate and resolve claims or disputes, or as allowed or required by applicable law.
We may also use your Personal Data when we are required, advised, recommended, expected or requested to do so by our legal advisors or any local or foreign legal, regulatory, governmental or other authority.
For example, we may use your Personal Data to:
We may also use your Personal Data in connection with mergers, acquisitions, joint ventures, sale of company assets, consolidation, restructuring, financing, business asset transactions, or acquisition of all or part of our business by another company.
Marketing and promotions
We may use your Personal Data to market ETG and ETG’s partners’ and advertisers’ products, services, events or promotions. For example, we may:
We may communicate such marketing to you by post, telephone call, short message service, online messaging service, push notification by hand and by email.
If you wish to unsubscribe to the processing of your Personal Data for marketing and promotions, you may write in to ETG to make the request.
III. DISCLOSURE OF PERSONAL DATA
We need to share Personal Data with various parties for the Purposes. These parties include:
For example, if you are a customer, we may share your name and location with our sales agents or merchants.
If you are a sales agent or merchant, we may share your Personal Data with your customer including your name, profile photo and average rating where applicable.
With ETG partners at your request
For example, if you requested a service through a ETG partner or used a promotion provided by a ETG partner, ETG may share your Personal Data with that ETG partners. Our partners include partners that integrate with our App or our App integrates with, household service provider partners, or business partners which ETG collaborate with to deliver a promotion or other specialised services.
With subsidiaries and affiliates
We share Personal Data with our subsidiaries, associated companies, jointly controlled entities and affiliates.
With ETG’s service providers and business partners
We may provide Personal Data to our vendors, consultants, marketing partners, research firms, and other service providers or business partners. This includes:
With our legal advisors and governmental authorities
We may share your Personal Data with our legal advisors, law enforcement officials, government authorities and other third parties.
Additionally, we may share non-personally identifiable Personal Data with third parties, such as location data, advertising identifiers, or a cryptographic hash of a common account identifier (such as an email address), to facilitate the display of targeted advertising.
If you do not wish for your Personal Data to be collected via Cookies on the Websites, you may deactivate cookies by adjusting your internet browser settings to disable, block or deactivate cookies, by deleting your browsing history and clearing the cache from your internet browser. You may also be able to limit our sharing of some of this Personal Data through your mobile device settings.
We will take reasonable legal, organisational and technical measures to ensure that your personal data is protected. This includes measures to prevent data from getting lost, or used or accessed in an unauthorised way. We limit access to your personal data to our employees on a need to know basis. Those processing your personal data will only do so in an authorised manner and are required to treat your information with confidentiality.
Nevertheless, please understand that the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted through any online means, therefore, any transmission remains at your own risk.
VII. DATA SECURITY
We implement certain security measures including encryption and firewalls to protect your personal data from unauthorised access. However, you agree and acknowledge that the above mentioned measures do not guarantee absolute protection to the personal information and by accessing the Websites and Apps, you agree to assume all risks associated with disclosure of personal data arising from and/or due to the breach of firewalls and secure server software.
Where, if applicable, we have given you (or where you have chosen) a password that enables you to access certain parts of our Websites or Apps, you are responsible for keeping this password confidential. We require you not to share the password with anyone.
VIII. BUSINESS TRANSACTIONS
You are aware that in the event we go through a business transition, such as a merger, acquisition by another organisation, or sale of all or a portion of our assets, you personal data might be among the assets transferred.
ETG shall have the right to modify, update or amend the terms of this Policy at any time by placing the updated Policy on the Websites. By continuing to use the Application, Platform, Software, Websites or Services, purchase products from ETG or continuing to communicate or engage with ETG following the modifications, updates or amendments to this Policy, you signify your acceptance of such modifications, updates or amendments.
If you have any queries about your Personal Data, please contact our Data Privacy Officer at:
ETG Data Protection Officer
c/o ETG Pte Ltd