Your privacy is important to Stickler Pte Ltd, our subsidiaries and affiliates (Stickler, We, Us or Our). Stickler is committed to protecting your privacy and complying with its obligations under the relevant data protection regulations, in particular the regulations of the EU General Data Protection Regulation (GDPR) and Singapore Personal Data Protection Act (PDPA).
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If the term You or Your is used in this policy without referring to a specific category of person, it is deemed to refer to all individuals who interact with us. Otherwise, the term You or Your should be read as referring to the category of an individual as specified. Other capitalised terms are as defined in our Stickler Terms of Service which are available at www.stickler.live. Queries on this policy should be addressed to privacy@stickler.live.
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This Privacy policy (Policy) governs Stickler’s process, storage, use and disclosure of your personal information and covers the choices you can make about the way your information is collected.
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We collect, process and use personal information from (a) individuals who visit our websites (Visitors), including www.stickler.live and www.livescope.ai app.stickler.live (Websites); (b) Service users and end-consumers based on contract terms and conditions.
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By visiting our Websites, using the Service, engaging with integrated applications or services, or otherwise providing Stickler with your personal information, you consent to your personal information being collected, stored, used and disclosed as set out in this Policy or as otherwise disclosed by us at the time of the collection. Partners (and not us) are responsible for seeking the consent of end-consumers to the collection, storage, use and disclosure of their personal information by us for the purposes set out in this Policy.
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Stickler has no direct contractual relationship with end-consumers, or with any other individuals whose personal data we may process on our Partner’s behalf.
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Stickler supports industry self-regulation and adheres to applicable industry guidelines.
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We may update this Policy from time to time. You can find the most current version on our Websites.

1. What Kinds of Personal Information do we Collect?
1.1. Partners and Visitors
The personal information we process and hold about Visitors and Partners will depend on the nature of your interaction with us.
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For Partners, We collect information about you and your company as you register for an account, create or modify your profile, and interact with the Services or Platforms that are the subject of the Services. Information we may collect includes:

• Contact information such as, but not limited to, name(s), email address(es), business mailing address, and phone number
• Billing information such as, but not limited to, credit card details and billing address
• Profile information such as, but not limited to, name, username, and job title

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For website Visitors, we only collect and use personal data of Visitors to the extent necessary to provide a functional Website as well as our contents and services. The collection and use of personal data of Visitors only takes place if the processing of the data is permitted by legal regulations or with the Visitor’s consent.
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1.2. Partners’ Customers
For Partners who use our Service, we will record the end-consumer social media identifier or email address for all engagement through a monitored Platform irrespective of whether they enter into a Transaction.

2. What Kinds of Non-personal Information Do We Collect?
2.1. Visitors and Partners
We use data collection services called “cookies” and data collected by other technologies that allow us to track Visitors’ use of the Websites and Partners’ and end-consumers’ activity on the Service. The technical data is used to determine visitor traffic, trends, remember your preferences, deliver personalised content to you while you are using the Websites and to improve our Service.
We may also share aggregated, non-personally identifiable information publicly, for example, to show trends about the general use of the Websites and Service.

3. How Do We Collect Personal Information?
‍3.1. Visitors and Partners
We endeavour to only collect personal information about an individual from that individual. There are some circumstances when we may need to collect your personal information from third parties, such as the Platforms. We may also collect personal information from publicly available records.
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We may hold your personal information in electronic or hard copy form, or a combination of both.
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Stickler collects personal information from Visitors and Partners directly, if you choose to provide it through one of the following means:

3.1.1. Data Obtained Through Cookies When You Use the Website and Creation of Log Files

Please refer to the Cookie Policy

Personal data is also stored in the log files of our system. This data is not stored together with other personal data of the Visitor.

b) Legal basis for data processing
The legal basis for the temporary storage of personal data and log files is “Consent” as per point (a) of Art. 6 (1) GDPR. This is achieved via the Pop-Up alert that is displayed directing the website user to our Cookie Policy and settings when they first visit the site.

c) Purpose of data processing
The personal data is stored in log files to ensure that the Website functions properly. In addition, the data helps us optimise our Website and serves to ensure the security of our information technology systems.

d) Duration of storage
The personal data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected. If the personal data are stored in log files, this is the case after 30 days at the latest. Further storage is possible. In this case, the IP addresses of the Visitors are deleted or anonymized, so that the data can no longer be attributed to the Visitor.

e) Possibility of objection and elimination
The collection of personal data for the provision of the Website and the storage of personal data in log files is necessary for the optimal operation of the Website. The visitor can object and prevent the cookies by selection at their discretion.

3.1.2. Contact Forms
a) Description of data processing
Contact forms are available on our Websites that can be used for connecting with Stickler, signing up for Services and otherwise engaging with us. If a Visitor uses this option, the personal data entered in the input mask (mandatory fields and optional information) will be transmitted to us and stored. These input fields for example are:
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• First and last name
• Job title
• Business email
• Company
• Phone number
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b) Legal basis for data processing
The legal basis for the processing of data is Consent, as defined in point (a) of Art. 6 (1) GDPR. If the contact is for the purpose of the conclusion of a contract or a contract-like obligation, then the legal basis for the processing of this data is Contract, as per point (b) of Art. 6 (1) GDPR.

c) Purpose of data processing
The processing of this data solely serves to handle your inquiry. This also constitutes the necessary legitimate interest in the processing of personal data.
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d) Duration of storage
The personal data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected. For the personal data entered in the contact form, this is the case when the conversation with the Visitor or the contractual relationship with the Visitor, whichever is applicable, is finished and no legal retention period exists.

e) Possibility of objection and elimination
The Visitor can object to the storage of its personal data at any time. If the personal data is required to fulfil a contract, premature deletion of the data is only possible insofar as contractual or statutory obligations do not prevent the data from being deleted.

3.2. End-consumers
Stickler may process personal (and non-personal) information about end-consumers when they engage with a Platform or service integrated with our Service.

4. How Do We Use Your Personal Information?
4.1. Visitors and Partners
Stickler uses the personal identifiable information (which is not sensitive information) of Visitors and Partners it collects for the purposes for which it was provided to Stickler and for related secondary purposes, to carry out Stickler’s business purposes, to fulfil its legal obligations, other related purposes or as permitted or required by law.
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In particular, Stickler may use your personal information to (a) verify your identity; (b) provide products and services that you have requested, and respond to your enquiries; (c) recommend products and services that may be of interest to you, based on your transaction history and preferences (consent); (d) manage your Account Details and provide you with customer support; (e) provide you with information about our events or our services that may interest you, and more generally, to maintain our relationship with you (consent); (f) send promotional offers and marketing material to you (consent); (g) maintain a database of registered users and Partners of the Service; (h) enhance your experience of the Websites and the Service and make the Websites easier for you to use, including remembering your preferences and personalising your experience on the Websites and in the Service; (i) plan our product and service development in accordance with the needs of our Partners and other customers; (j) facilitate our business operations.
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You do not have to provide personal information to us if you do not wish to, but if you do not do so, it may affect our ability to provide you with our goods and services and with information about them.

4.1.1 Legal Basis for Data Processing
Insofar as we obtain the Visitor’s consent for the processing of personal data on our Website, point (a) of Art. 6 (1) GDPR serves as the legal basis for the processing of personal data.
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For the processing of personal data required for the performance of a contract to which the Visitor is a party, point (b) of Art. 6 (1) GDPR serves as the legal basis. This also applies to processing operations that are necessary for the performance of a contractual obligation or pre-contractual measures.
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Insofar as the processing of personal data is required to fulfil a legal obligation to which our company is subject, point (c) of Art. 6 (1) GDPR serves as the legal basis.
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If processing is necessary to protect a legitimate interest of our company or a third party and if the interests, fundamental rights and freedoms of the data subject concerned do not outweigh the legitimate interest mentioned above, point (f) of Art. 6 (1) GDPR serves as the legal basis for data processing (so-called “weighing of interests”).
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In addition, there are other legal bases for the processing of personal data that we have specifically listed below, where relevant.

4.1.2. Storage Period
Visitor’s personal data will be deleted as soon as the purpose of storage ceases to apply. Furthermore, personal data may be stored if this has been provided for by laws or other regulations to which our company is subject. The personal data will also be blocked or deleted where a storage period prescribed by the aforementioned standards expires unless there is a need for further storage of the personal data for the conclusion or fulfilment of a contract.


4.2. End-consumers
Stickler may use end-consumers’ personal information in connection with (a) your engagement with a Partner in which our Service is used (legitimate interest and compliance with a legal obligation); (b) produce anonymised data and aggregated data (legitimate interest). By way of example, such data may be used to support the diagnosis of server problems, to identify and create new service offerings and features and to improve our Service offerings.
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4.3. Legal basis for data processing
Stickler processes such data under the direction of our Partners.
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5. How Do We Use Sensitive Information?
Sensitive information is a type of personal information that includes information about an individual’s criminal record, racial or ethnic origin or sexual orientation or practices. We do not collect or record such information.

6. Who Do We Disclose Your Personal Information To?
Stickler will not disclose your personal information to any other third parties unless you have consented to such disclosure. Such consent may be given expressly or it may be implied by conduct.
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In particular, your personal information may occasionally be disclosed to (a) our directors, officers, employees and related entities (including entities located overseas), for the purpose of our business and marketing purposes only; (b) subsidiaries and/or affiliates, third party contractors or service providers that we use in the ordinary course of our business to assist with the delivery of our products and services (on a confidential basis and such service providers (so-called “processors”) will be limited in their use of the information to the purpose of our business only); (c) specialist advisers who have been engaged to provide us with legal, administrative, financial, insurance, research, marketing or other services; and (d) any other person authorised, implicitly or expressly, when the personal information is provided to or collected by us.
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Some of Stickler’s related entities, or third-party service providers to whom we may disclose your personal information, may be located in countries and regions outside Singapore or may hold your data on servers located outside of Singapore, including but not limited to, Australia, China, Hong Kong, Indonesia, Malaysia, Philippines, Singapore, the United Kingdom, and the United States of America. We will endeavour to take reasonable steps to ensure that these parties handle such information in a manner that is consistent with the Australian Privacy Principles, with the CCPA, with the GDPR provisions on the transfer of personal data to so-called “third countries” where applicable, with the PDPA and this Privacy Policy.
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Stickler reserves the right to disclose any personal information to law enforcement or other government officials where we reasonably believe that this may be necessary or appropriate, or where it will prevent or lessen a serious and imminent threat to somebody’s safety, life or health.​

7. Our Commitment to Data Security
Stickler takes the security of your personal information very seriously. We take reasonable steps to protect the personal information we hold, whether in electronic or another form, from misuse, interference and loss and from unauthorised access, modification or disclosure.
Stickler may retain any personal information you provide during the use of the Websites and Service, for as long as you remain a user of the Service or user of the Websites, or until you tell us that you no longer wish for us to retain such information and otherwise to the extent permitted by applicable law. We will take reasonable steps to destroy or permanently de-identify personal information we hold if it is no longer needed for Stickler’s business purposes and it is permissible by law to do so. If requested or authorised to do so, we may shorten the retention period.
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We may also retain and use your personal information to fulfil our legal obligations, resolve disputes, enforce any agreements to which we are a party, and protect the legal rights and legitimate interests of others and ourselves.​

8. Access to Personal Information
8.1. Visitors and Partners
You have the right to obtain confirmation as to whether or not personal information concerning you is being processed; where this is the case, you have the right to request access to personal information that Stickler holds about you in writing or via email by using the contact details below. Stickler aims to acknowledge receipt of your request within a maximum of 30 working days after your written request / email has been received.

We aim to comply and deliver on any request to provide a copy of the personal data which is undergoing processing from the controller, further copies may result in the charge of an administrative fee that will cover the costs of verifying the application and retrieving the information requested by the controller. If Stickler denies an access request, it will provide reasons for doing so.

8.1.1. Restriction of processing
You have the right to obtain the restriction of processing, where you have objected to the processing, pending the verification of whether the objection should be upheld.

8.1.2. Erasure
You have the right to obtain the erasure of personal data concerning yourself without undue delay where the personal data are no longer necessary for the purposes for which they were collected and the legal retention regulations do not hinder an erasure.

8.1.3. Data Portability
You have the right to receive the personal data concerning yourself, that you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data yourself or – where technically feasible – to have this data transferred by us to another controller.

8.1.4. Object
You have the right to object, on grounds relating to your particular situation, at any time to the processing of personal data concerning yourself.

8.1.5. Withdraw the data protection declaration of consent
You have the right to withdraw at any time the data protection declaration of consent with which you provided us. The withdrawal of the declaration of consent does not affect the legality of processing performed on the basis of the consent prior to its withdrawal.

8.1.6. Rights in cases of automated decisions
To the degree that we, on an exceptional basis, make decisions in individual cases on an automated basis – including profiling – we are obligated to make provisions so that you may influence the decision.

8.2. End-consumers
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You are able to access, update or erase data held concerning you.
If your relationship with Stickler is via Partners or other companies that use our Services, all requests other than Objection to Processing requests must be submitted directly to them. Stickler processes data as a service provider on behalf of those companies. That means they are responsible for authenticating your request and ensuring it is communicated to all service providers.
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Stickler is committed to working with our partners to honour data subject requests to the full extent required by GDPR, PDPA and other applicable privacy legislation.



 

9. Correction of Personal Information
Stickler will take all reasonable steps to ensure that the personal data we hold and disclose is accurate, up-to-date, and complete. As such, we may contact you from time to time to check that your personal data is still correct. However, please let us know using the contact details below, of any changes to your personal data as soon as you can so that we can maintain the accuracy of your information.

If you request us to, we will take reasonable steps to correct the personal information we hold about you so that it is accurate, complete and up to date, or will provide reasons for not doing so.
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You have the right to obtain without undue delay the rectification of inaccurate personal data concerning yourself as well as, where appropriate, the right to have incomplete personal data completed (Art. 16 GDPR).
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10. Complaints
If you wish to make a complaint about a breach of this Privacy Policy, or the Data protection provisions, you can contact Stickler using the contact details below. You will need to provide sufficient details regarding your complaint, as well as any supporting evidence and information.
Your complaint will be reviewed by our Data Protection Officer, who will investigate the issue and determine the steps that Stickler will take to resolve your complaint. Stickler will contact you if it requires any further information from you and will notify you in writing of the outcome of the investigation.

If you are not satisfied with our response to your complaint, you may contact us to discuss your concerns, or contact the relevant Data Protection Regulators, e.g. the Singapore Personal Data Protection Commissioner

11. Changes to this Policy
We may alter or update this Privacy Policy from time to time to stay abreast of statutory and market changes. Stickler reserves the rights to make changes to this policy at any time and advise you of any such alterations or updates by posting an updated version of the policy to this website.

Your continued use of our website, services, or further provision of your personal data constitutes your deemed acceptance of the revised Privacy Policy.

12. Contact Details
Stickler Pte Ltd
Address: 160 Robinson Road, #14-04, Singapore 068914
Attention: Data Protection Officer
Email: privacy@stickler.live