Introduction

We, at Crackle Technologies PTE Limited (hereinafter referred to as ‘Crackle’, or ‘We’, or ‘Us’, or ‘Our’ or ‘Company’), know that you as a user (hereinafter referred to as ‘You‘, ‘Your’, ‘User(s)’, ‘Customer(s)’, ‘Member(s)’) care about how Your personal information is used and shared, and We take Your privacy seriously. Please read the following to learn more about Our privacy policy (“Privacy Policy”). By visiting or using Our website (www.crackle.tech) and domain name, and any other linked pages, features, content, mobile applications, or any other services or products We offer from time to time by in connection therewith (collectively, the ‘Platform‘), or by using the services / products in any manner, You acknowledge that You accept the practices and policies outlined in this Privacy Policy, and You hereby consent to the collection, usage, and sharing of Your information in the following ways. 

This document is set out in accordance with Section 21 of Personal Data Protection Act, 2012, Articles 12, 13 and 14 of the EU General Data Protection Regulation, Children’s Online Privacy Protection Rule, and LGPD; Lei 13709 / 2018. This Privacy Policy is an electronic record in accordance with the provisions of Electronic Transactions Act, 2010 and rules framed thereunder as applicable and the provisions pertaining to electronic records in various statues as amended by Electronic Transactions Act, 2010. This is an electronically generated document and does not require any physical or digital signatures. This document shall act as a binding agreement between Crackle and You in relation to the services/products being made available/provided by Crackle. The access to or use of Our Platform shall be indicative of Your unfettered consent to bind Yourself to this Privacy Policy. The Company reserves the right to update and modify the Privacy Policy at any time, without prior notice to the User. It is the responsibility of the User to be informed about the revised version of the Privacy Policy. By continuing to access or use the Platform, the User agrees to be bound by the updated Privacy Policy. 

PLEASE ENSURE THAT YOU READ AND UNDERSTAND ALL THE CLAUSES BEFORE OPTING TO AVAIL ANY SERVICE OR EXTEND YOUR USE OF THIS PLATFORM AS THE PROVISIONS OF THIS PRIVACY POLICY WILL BE BINDING ON YOU WITHOUT ANY RESERVATIONS. If You do not wish to enter into this Agreement, We would suggest not moving forward with the usage of our Platform.

What does this privacy policy cover?

This privacy policy covers Our treatment of personal information (‘Personal Information’) that We gather when You access or use Our Platform and through Uniform Resource Locator links (URLs) that We host on Our servers. This policy does not apply to the practices of companies that We do not own or control, or to individuals that We do not employ or manage.

Who does the privacy policy impact? 

This Privacy Policy impacts all Our Users. However, this Privacy Policy impacts users differently based on whether they live in Singapore or outside Singapore. Our website and URLs can be accessed anywhere. 

For users registering / purchasing / participating in Our programs, We collect the following details: Full name, mobile number, email id, education details and other details as per the different services provided on Our Platforms. We collect this information to revert to You in respect of Your specific requirements, when You apply for a job with Us and as a means of communication between You and Us.  We also collect information pertaining to the specific services that You are looking to avail from us.

What information does Crackle collect?

We gather various types of personal information from Our users, as explained in detail below. We may use this personal information to personalize and improve Our services, to allow Our users to set up a user account and profile, to fulfil requests for certain products and services, to analyse how users utilize the Platform and/or other products and services rendered by Crackle, and as otherwise set forth in this Privacy Policy. We may share certain types of personal information with third parties, however, in such a situation, You will also be covered under the privacy policy of the third party with whom We are providing the information to. We collect the following types of information:

Information You provide to Us:

Name, Email address, Phone number, Your Education details or other work experience, Company name and address, Your bank account details, Your product details (eg app store links or bundle ids of Your mobile applications, Your Company’s customer or user details (country and estimates of daily active users) and Your current ad monetisation products (mediation platform).

We receive and store any information You knowingly provide to Us. For example, We collect personal information such as Your name, personal email address, corporate email address, residence and office address, bank details (for Your payments), educational qualifications (when You apply for a job with Us). We may collect other information as Our services and products are further developed. You can choose not to provide Us with certain information, but then You may not be able to register with Us or to take advantage of Our products / services.

What are Your rights?

Your rights as a User include the following:

    • Being informed by Crackle of the personal data collected, including the purpose, use, retention and sharing;
    • Having a right to delete the personal data shared;
    • Having a right to correct inaccurate personal information; 
    • Having a right to access the personal information collected;
    • Having a right to lodge a complaint with the relevant supervisory authority after exhausting Our grievance redressal mechanisms.
    • Having a right to know what information is shared and to whom; and
    • Having a right to opt out of sharing of personal information.

Information collected automatically:

Whenever You interact with Our Platform, We automatically receive and record information mentioned below on Our server logs: 

  • IP address
  • Location
  • Cookie 
  • AdID
  • User Agent
  • Device make, model, and operating system;
  • Device properties related to screen size, orientation, audio, battery, device memory usage, settings, and boot time;
  • Device settings related to accessibility features, font size, and theme; 
  • Carrier;
  • Operating system;
  • Name and properties of mobile application through which a consumer interacts with the Services;
  • Country, time zone, and locale settings (country and preferred language);
  • City- and/or country-level or other coarse geolocation data;
  • Network connection type and speed;
  • IP Address;
  • Internet browser user-agent used to access the Services;
  • HTTP header information;
  • Advertising IDs (IDFA/GAID/Amazon FOSAID);
  • Vendor IDs (IDFV);
  • App Set IDs; and
  • Advertising and tracking preferences and restrictions.
  • Session Durations
  • Session Activities
  • Logs Information

We may obtain additional information about You from third parties such as marketers, partners, researchers, and others. We may combine information that We collect from You with information about You that We obtain from such third parties and information derived from any other subscription, product, or Service We provide.

When We collect usage information (such as the numbers and frequency of visitors to the Platform), We only use this data in aggregate form, and not in a manner that would identify You personally. For example, this aggregate data tells Us how often users use parts of the Platform, so that We can make Our Platform perform better. We may also provide this aggregate information to Our partners; Our partners may use such information to understand how often people use Our Platform, so that they, too, can provide better performance and experience. We never disclose aggregate information to a partner in a manner that would identify You personally, without Your consent. 

If You are using Our products and/or services, You understand and acknowledge that, any information, data or readings from such products and/or services, or collected from Your use thereof, will be automatically uploaded to Your account with Us. To the extent these automatically collected readings can be used to personally identify You, these readings are personal information for the purposes of this privacy policy.

Who can access Crackle products and services?

Individuals over 13 years old can access Our services. Companies registered anywhere in the world can access Our corporate solutions / services. In no event will We knowingly provide Our Services or sell any of Our products to anybody under the age of 13 without the participation of a legal guardian. We ask that anybody under the age of 13 ask and get permission from a parent or guardian before using Our Services. You hereby represent and warrant that You are at least 13 years old, or that You are using Our Services offered with the supervision and involvement of a parent or guardian who is at least 13 years old. If You are under the age of 13, You must immediately leave this site. Any information We learn a child under 13 has provided to Us without parental authorization will be deleted. Please get in touch if You learn We have collected or received personal data from a child under the age of 13.

What channels will Crackle use to provide its products and services?

We will primarily employ Our website, Our dashboard and Our applications or platforms. For a few services, We would also employ third party applications like digital marketing or social media platforms.

Internet bandwidth is a prerequisite to access many of Our services. We will not be held liable for slow / non-response of Platform / Our services /third party services due to slow / patchy internet services.

How will Crackle use the information it collects?

We will only use Your information in certain ways and for certain purposes, as stated in this Privacy Policy.

Without Your consent, We will not share, sell, or divulge any information that identifies You to any third party. 

Payment processing, email automation, app diagnostics, analytics, advertisements and other services are some of the many areas where We rely on third-party service providers. Therefore, some of these third-parties may handle Your personal data.

We may release personal data to establish, exercise, or defend Our legal rights. Information may also be disclosed if We determine that such disclosure is required to investigate, prevent, or take action related to possible fraud, illegal activity, or violations of Our conditions.

In the event of a business sale, merger, acquisition, consolidation, asset sale, reorganisation, or similar event, We may disclose Your personal information to the acquiring, merging, or surviving entity. Your privacy and the security of Your data are of the utmost importance to Us, and We will never compromise either.

E-mail and other communications:

We may contact You, by email or other means; for example, We may communicate with You about Your use of the Platform. Also, We may receive a confirmation when You open an email from Us. This confirmation helps Us make emails more relevant for You and improve Our services.

Is personal information about me secure?

Our Platform is equipped with standard security features to protect the confidentiality and security of Your information. We shall maintain and implement reasonable and appropriate security procedures consistent with prevailing industry standards and all applicable laws to protect personal data from any unauthorized access or use. We shall maintain adequate physical controls and protections for any server or system on which any data may reside, encrypt any data that is in transmission, and encrypt any data located on any storage media.

However, as effective as encryption technology is, no security system is impenetrable. We cannot guarantee the security of Our database, nor can We guarantee that information You supply won’t be intercepted while being transmitted to Us over the internet. Any transmission of information by You to Our Platform or otherwise is at Your own risk. In the event of a security breach, We will use diligent efforts to promptly remedy and prevent any continuation or recurrence of any unauthorized access or use.

Our Platform may contain links to other sites and other services. We are not responsible for the privacy policies and/or practices on other sites or apps. When following a link to another site You should read that site’s / app’s privacy policy.

What personal information can I access?

Through Your account settings, You may access, and, in some cases, edit or delete the following information You have provided to Us. The information You can view, and update may change as the Platform changes. Please note that any information that is automatically uploaded from a product to the Platform, or collected otherwise from You by Us, cannot be later changed or updated.

We will redress Your grievances and concerns surrounding usage of services within specified timelines as per applicable law. If You have any questions about viewing or updating information We have on file about You, or if You wish to raise any complaint/grievances, please contact Us at corporate@crackle.tech or reach out to Our Grievance Officer, whose contact information is detailed below:

Name: Jaivir Singh Nagi

Email: corporate@crackle.tech  

Postal address: 200 Jalan Sultan, #11-01, Textile Centre, Singapore 199018

Deleting Your profile and information

You can always opt not to disclose information to use, but keep in mind some information may be needed to register with Us or to take advantage of some of Our Platform features. We will retain Your personal information for a reasonable period or as long as the law requires. If You would like Us to delete/modify information that You have provided via the Platform or otherwise to Us, please contact Us at corporate@crackle.tech and We will respond in a reasonable time. You may be able to add, update, or delete information as explained in section above. When You update information, however, We may maintain a copy of the unrevised information in Our records. Please note that some information may remain in Our private records after deletion of such information from Your account. We may use any aggregated data derived from or incorporating Your personal information after You update or delete it, but not in a manner that would identify You personally.

Changes to this privacy policy

We may amend this privacy policy from time to time. Use of information We collect now is subject to the privacy policy in effect at the time such information is used. If We make changes in the way We use personal information, We will notify You by posting an announcement on Our Platform or by sending You an email. You are bound by any changes to the privacy policy when You use the Platform or the Product after such changes have been first posted.

Limitation of liability

We value Your trust in providing Us Your personal information, thus We will use commercially acceptable means of protecting it. But no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and We cannot guarantee its absolute security. You agree and acknowledge that We will not be liable for any claims in relation to the use of the App / website / URL, including but not limited to (a) Your inability to access or use the App / website / URL or the services; (b) the failure of the App / website / URL or the services to accurately identify persons in Your proximity; (c) any unauthorised access to Your information or modification thereof (d) behaviours of others on Our platform. If You have any concerns or questions in relation to this policy, please address them to corporate@crackle.tech.