Privacy Policy

1. INTRODUCTION

This privacy policy (“Privacy Policy”) is prepared by BARRIER BREAKER PTE. LTD. (Company No. 202140469W) and its group of companies (collectively, “we”, “us” or “our”). We care about your privacy and we are committed to maintain your trust by keeping and protecting your personal data private, safe and secure.
We are an online digital platform providing anime enthusiasts with access to an extensive library of a diverse genre of anime content, including comprehensive narratives and storylines which are accessible on https://www.specialkidfactory.com/ (the “Platform”). We aim to provide high quality content and build a community among users to allow them to engage with one another through our interactive features on our Platform such as discussion forums, comment sections and social media integration.
We are a platform providing anime enthusiasts with access to synopsis and illustrations of an anime series called the “Special Kid Factory” which are accessible on https://www.specialkidfactory.com/ (the “Platform”).
This Privacy Policy sets out how we collect, process, manage, use, disclose and protect personal data belonging to our users and other persons (collectively, “you”) who access or use the Platform, any of our websites, our mobile applications and/or any of our other sites, products or services that link to this Privacy Policy. By accessing or using the Platform, you agree and give consent for us to collect, process, manage, use, disclose, keep and protect your personal data in the manner as described in this Privacy Policy.
This Privacy Policy is issued in accordance with the Personal Data Protection Act 2012 of Singapore, as may be amended or modified from time to time (“PDPA”), and it will enable you to understand the following:
the personal data that we collect and process;
the sources that we collect your personal data;
the purposes of collecting your personal data;
to which third parties and under what circumstances we will disclose your personal data;
our obligations and your obligations under this Privacy Policy;
the storage and retention of your personal data;
your rights in respect of your personal data; and
what you can do if there are any changes or if you have any questions about your personal data.
Please read this Privacy Policy carefully to understand how we are committed to protecting the privacy, confidentiality and security of your personal data.
PERSONAL DATA THAT WE COLLECT AND PROCESS
When you access or use the Platform, we may collect and process the following personally identifiable information:
your identification details including but not limited to your full name, age, date of birth, social security number, identity card number or passport number;
your residential address and/or correspondence address (which may include your office address);
your billing details such as credit card information, banking information, and/or billing address;
your contact information (e.g., email address, mobile number or fax number);
records of our communications with you, including any messages and/or emails you send to us;
information about the devices accessing the Platform such as type of device, operating system used, application information, unique device identifiers and crash data;
your transactional and usage information, such as web log data, operating system type, browser type and version, browser language, pages you viewed, how long you spent on a page, location (your IP address), access times and information about your use of and actions on our website, the frequency of your use of the Platform, error logs, and other similar information;
any other information which may be provided by you; and/or
any other information as may be required by us from time to time for the purposes specified in Clause 4.1 of this Privacy Policy.
THE SOURCES THAT WE COLLECT YOUR PERSONAL DATA
Please be informed that we may obtain your personal data from you and from other sources, including but not limited to:
your relationship with us, including without limitation to:
information provided by you when you register for an account with us;
information provided by you in any enquiry forms or customer surveys (if applicable);
information or data collected by us when you access or use the Platform; and/or
when you communicate with us through phone calls, email and/or other correspondence methods;
any interactions between you and us through:
the Platform;
our social media pages; and/or
our chat applications (if applicable);
our media launches which you may have been invited to or participated in our campaigns, competitions, activities and/or promotions where you are required to provide personal data about yourself and/or other parties (e.g., your family members and work colleagues);
third parties connected to you, such as your family members, employees, joint account holders, guarantors and such other persons (subject to your prior consent for them to disclose information relating to you);
third parties including marketers, partners, researchers, affiliates, service providers and other parties where they are legally allowed to share your personal data with us; and/or
by using Cookies (as defined below), the details of which are set out in Clause 11 of this Privacy Policy.
We may, in some instances, combine personal data about you from multiple sources, helping us improve and personalise your experience of using the Platform.
THE PURPOSES OF COLLECTING YOUR PERSONAL DATA
You hereby acknowledge, confirm and consent that we are authorised to collect and process your personal data, for any of the following purposes:
Verification
to verify your identity and any and all information provided by you; and
if applicable, to verify and confirm qualifications for soliciting or concluding any agreements that may be entered into between you and us.
Facilitation of Agreements
to facilitate the agreements to be entered into or have been entered into with us;
to facilitate communications between you and us in respect of such agreements;
to facilitate preparation of agreements by our legal and professional advisors;
to ensure proper execution and performance of an agreement entered into by us with a third party (including but not limited to our partners) in connection with any transactions;
for provision of information to relevant authorities and service providers in particular (but not limited to) for the purpose of facilitating the provision of utilities and services or as otherwise required or permitted by the applicable laws;
to transfer or assign our rights, interests and obligations under any of the agreements between you and us; and
to protect or enforce our rights to recover any debt owing to us (if applicable).
Services and Support
to operate the Platform in a proper and efficient manner, including maintaining, debugging and developing the Platform;
to exercise our rights and/or fulfil our obligations under any agreements which we have entered into with you or under the applicable laws;
to respond and follow up on any queries, complaints or requests by you or other users may have;
to be used in, to provide and/or to improve the services provided by us, analyse customers’ choices, conduct market surveys, processing invoices and payments; and
we use Cookies to enhance our processes, advertising, notifications, authentication, security and compliance, analytic and preference management (details of usage are specified in Clause 11 of this Privacy Policy).
Marketing
to contact and provide you information regarding our various products, services, new launches, upcoming events, promotions, advertising, marketing and commercial materials and such other information as may be determined by us to be of interest to you (via emails, text messages or other communication methods);
to conduct marketing surveys and questionnaires, and
to conduct research and development of products and services.
Compliance with Laws and Regulations
to comply with our obligations, compliance requirements and disclosure requirements under the applicable laws;
secure our business secrets, intellectual property and general service delivery by detecting and preventing threats and abuses;
for audit, compliance and risk management purposes;
to assess financial and insurance risks;
to detect, investigate and prevent fraudulent transactions or unauthorised or illegal activities; and
for prevention of crimes, bribery, fraud and money laundering.
Internal Records and Technical Issues:
for our internal record keeping in the ordinary course of business;
to maintain, update, consolidate and improve the accuracy of our database records;
to produce data, reports and statistics which have been anonymised or aggregated in a manner that does not identify you as an individual;
to conduct research for analytical purposes but not limited to data mining and analysis of your transactions with us; and
to detect, prevent and address technical issues.
In connection with the purposes set out in Clause 4.1 above, you hereby give your consent to us to disclose your personal data, to the relevant authorities, our successors-in-interest, sponsors, advertisers, lawyers, insurers, adjusters, other advisers, suppliers, contractors and/or service providers, partners and other carefully selected third parties in accordance to Clause 5 of this Privacy Policy.
DISCLOSING YOUR PERSONAL DATA
We do not sell any of your personal data to any party whatsoever. However, we may use third-party service provider to help us to provide services or administer activities on our behalf. For these reasons, we reserve the right to disclose your personal data to carefully selected third parties set out as follows:
on a need-to-know basis, to:
our subsidiaries, related and associated companies;
our parent company including its subsidiaries, associated and related companies; and
our affiliates including our business partners (some of whom may be outside Singapore and undertake administrative, management and operational functions for or on behalf of us in respect of or arising from any commercial transaction or to support sales, marketing, promotion and/or advertising efforts);
companies and/or organisations who assist us including but not limited to our successors-in-interest, sponsors, advertisers, suppliers, contractors, payment gateway service providers (if applicable) and other third-party service and/or product providers;
companies and/or organisations who act as our strategic partners which include parties that we collaborate with for certain events, programmes, activities or to provide any services and/or products;
companies and/or organisations who assist us in providing you value-added services and/or products as may be requested by you;
our legal and professional advisors including but not limited to our lawyers, insurers, adjusters, accountants and/or financial advisors authorised by us;
your legal and professional advisors including but not limited to your lawyers, insurers, adjusters, accountants and/or financial advisors authorised by you;
any person authorised by you;
any rating agency, insurer, insurance broker and/or direct or indirect provider of credit protection;
any financial institutions, merchants VISA International Services Association, MasterCard International Incorporated and/or other card associations in relation to any credit card and/or debit card issued to and used by you;
any person connected to the enforcement or preservation of any of our rights under the agreements between you and us;
relevant government entities or departments, agencies, statutory authorities and/or industry regulations authorities in connection with any investigation or enquiries;
fraud and crime prevention agencies for the purposes of assessing the risk of crime, fraud and money laundering (this forms a condition of us entering into any agreement with you);
our marketing, research, and communications agencies;
the regulatory authorities and government agencies, where applicable; and
other parties where required by the applicable laws.
In the event of a sale of business, disposal, acquisition, merger, joint venture, debt financing, reorganisation, insolvency, bankruptcy or receivership involving us or our assets to another third party, your personal data may be required to be disclosed and/or transferred to the third party as part of our business assets. You acknowledge and authorise us to release your personal data to the third party including its advisers and representatives, and that the other party has your consent and shall be authorised to process such personal data.
Clauses 5.1 and 5.2 above shall, at all times, be subject to the compliance of relevant laws applicable to us and our business in all jurisdictions.
If your personal data is processed by any of the aforesaid third parties, we will request for such third party to adhere to our standards and all applicable laws but we bear no responsibilities and shall not be liable for any losses, damages, claims, costs and expenses of whatever nature resulted from and/or in connection to the non-compliance by such third party.
Except as set out above, we will never sell, distribute or disclose any of your personal data (except anonymous aggregate information) to any third party without your express consent.
USE OF PERSONAL DATA FOR MARKETING PURPOSES
By accessing or using the Platform, you are deemed to have consented for us to contact you via phone calls, text messages, emails and/or other electronic methods in future by using the data provided by you.
The consent, as specified in Clause 6.1 above, shall include consent to receive pictures, videos, online messages and/or emails about our, our business partners’, strategic partners’, sponsors’ or advertisers’ products, services, promotions, special offers, events and/or activities that may be of interest to you.
For the avoidance of doubt, you acknowledge and consent to us sharing anonymised information such as but not limited to in the following circumstances:
Aggregated Information – We may conduct joint data analytics projects with selected third-party providers using anonymised information to predict user interests and provide users with more targeted and/or relevant information based on aggregated information about that user’s activities outside the Platform.
Behavioural-based Advertising – We may collaborate with selected third parties using anonymised information to derive certain models that would facilitate more accurate advertising to selected users.
You may elect to opt out from receiving any newsletters, updates, promotional materials, festive greetings (if applicable) or other communications, in part or in whole, for general purposes or for marketing purposes set out in this Clause 6, by following the “unsubscribe” links or instructions within the email we send you at any time. In any event, your latest written instructions to us will prevail.
THE CIRCUMSTANCES WHICH WE MAY DISCLOSE YOUR PERSONAL DATA
Other than those set out in Clauses 5 and 6 above, we will treat your personal data as private and confidential and will not disclose your personal data to any third party unless any of the following events arises:
you have given us prior permission to disclose your personal data;
we are required or permitted to do so under the applicable laws;
we are required to fulfil our obligations as specified in this Privacy Policy;
we are required or authorised by any order of court, tribunal or authority, whether governmental or quasi-governmental or requests from law enforcement or any other government agencies with jurisdiction over us; and/or
we are required to transfer our rights and obligations under this Privacy Policy.
If there are any complaints or enquiries with regard to the disclosure of your personal data to any third party under this Privacy Policy, you may contact us at the addresses specified in Clause 16 of this Privacy Policy.
OUR OBLIGATIONS AND YOUR OBLIGATIONS
Our Obligations
The security of your information is our priority. We will keep, protect and process your personal data in a secure manner by maintaining physical, electronic and procedural safeguards, in compliance with the applicable laws and regulations.
We will ensure that the access of our employees to the personal data which you have provided to us is limited to authorised employees who are trained in handling your information. These authorised personnel are required to ensure the confidentiality of your information and to respect your privacy at all times.
Your Obligations
In order for you to access or use the Platform, it is obligatory for you to provide us with complete and accurate personal data and keep us updated on your personal data, failing which we may not be able to process your personal data to fulfil the purposes in Clause 4.1 above.
In the event that you need to provide any personal data for or on behalf of such other persons, or you represent such organisations or companies, you covenant that:
you have obtained consent from such other persons and necessary authorisation from such organisations or companies that the personal data is given voluntarily, accurately and complete;
you are authorised to receive any privacy notice and other related information on his/its behalf; and
you have been given consent and/or authorisation to transfer his/its personal data abroad,
failing which you shall indemnify and keep us indemnified against any claims from such other persons or organisations or companies.
If there are any changes to your personal data, you hereby acknowledge that you have the obligation to inform us immediately, in any event not more than seven (7) calendar days after such changes arise. You shall send us a written notice (by mail or email) in respect of such changes, in which we will update your personal data within twenty-one (21) calendar days upon receipt of your written notice.
Without contrary to Clause 8.2.3 above, if you do not wish for any part of your personal data to be used by us for any of the purposes set out in this Privacy Policy, you are required to notify us by emailing us at the email address specified in Clause 16 of this Privacy Policy.
Incomplete Personal Data
Where the personal data is requested for the purposes in Clause 4.1 above, you, or any such other persons or organisations or the companies represented by you have the option not to provide additional personal data requested by us other than the information which we have indicated as necessary to facilitate any commercial transaction. If the personal data provided by you is incomplete, we will not be able to process your personal data for the purposes outlined in this Privacy Policy and may not be able to offer the services and/or to fulfil your request (if applicable).
STORAGE AND RETENTION OF PERSONAL DATA
Your personal data may be stored either:
in hard copies in our offices;
in soft copies stored in servers located in Singapore; or
other information technology storage facilities and servers situated in other countries outside Singapore as some of our digital storage facilities, servers, and service providers may be located in such other places.
In the event that your personal data is transferred out of Singapore to third parties in a jurisdiction other than Singapore, we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to such protection provided under the PDPA. You hereby expressly consent to and authorise us to transfer your personal data outside of Singapore for the purposes stated in Clause 5.1.
We will only retain your personal data for so long thereafter as is necessary for us to fulfil the purposes as set out in this Privacy Policy.
When we have no ongoing legitimate business need to process your personal data, we will either delete or anonymise it or, if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible.
Notwithstanding the above, we may need to retain your personal data for a longer period if it is necessary for us to:
comply with our legal obligations;
to respond to any disputes, claims or complaints made related to you; and/or
to enforce and execute our legal agreements and policies.
YOUR RIGHTS
Your rights under the applicable laws in relation of your personal data retained by us are set out as follows:
right to access your personal data that is retained by us with reasonable notice (subject to the exceptions referred to in section 21(2) of the PDPA) and payment of the relevant processing fee (if applicable));
right to update, change, delete, amend or correct your personal data;
right to request restrictions on the processing of your personal data; and
right to object the use of your personal data for marketing purposes.
Pursuant to your right to access your personal data in Clause 10.1.1 above:
you also have the right to receive a copy of your personal data in an electronic format. However, this right is limited to personal data that you have provided to us and is processed based on your consent. It does not cover personal data that we may have received on other grounds or from other sources; and
we may withhold your request to access your personal data in certain circumstances, including but not limited to (a) when we are unable to confirm your identity; (b) where such personal data requested is of a confidential nature; or (c) when we receive repeated requests for the same data. In any event, we will promptly notify you of the reason(s) for not being able to accede to your request.
Subject to your requests pursuant to Clauses 10.1 and 10.2 above, we reserve all our rights to reject any or all your requests or require further documentary evidence for reasons permitted by the applicable laws.
COOKIES
We may use cookies, advertising identifiers, web beacons, tags, scripts, local shared subjects such as HTML5 and Flash or Flash cookies including other similar technology (“Cookies”) on the Platform for the purpose of recognising your device upon your access to the Platform which we may deliver tailored information to you that matches your account, interests and preferences.
The Cookies have unique identifiers which may be stored on the Platform, on the device you use to access the Platform, and/or in emails we send to you. The Cookies may transmit information about you and your use of the Platform, including but not limited to the period of usage, your search preference, browse type, IP address, and/or data relating to advertisements displayed and clicked in by you.
Without contrary to any other provisions under this Privacy Policy, third parties may use the Cookies on the Platform to collect the same type of information for the same purpose as specified in Clause 11.1 above. Such third parties may associate the information about you obtained from the Platform or from any other resources for their other purposes, in which we do not have any responsibility, access nor control in regard to the usage of such information.
We may share non-personally identifiable information from or about you with third parties, including but not limited to location data, advertising identifiers, or a cryptographic hash of a common account identifier (such as email address) to facilitate the display of targeted advertising.
In any event, you may disable, block or deactivate Cookies at any time by adjusting your Internet browser setting to disable such Cookies. You may also limit our sharing of your information through mobile settings.
LINKS TO THIRD-PARTY WEBSITES
The Platform may contain links or advertisements to third-party websites. These third-party websites are not related to, associated with us or under our control. Therefore, we are not responsible or liable for their privacy policy regarding any collection, usage, maintenance and/or sharing of personal data of such third-party websites. We reserve the right to disable any links to any third-party websites in our sole discretion.
MINOR’S PRIVACY
The Platform do not address anyone below the age of eighteen (18) (“Minor”).
We do not and will not knowingly collect personal data from any Minor. If you are a parent or guardian and you are aware that your Minor has provided us with any personal data, please contact us immediately. If we become aware that we have collected personal data from any Minor without verification of parental consent, we will take necessary steps to remove all information relating to such Minor from our storage facilities and servers.
CHANGES TO THIS PRIVACY POLICY
We may, from time to time, modify, update or amend the terms of this Privacy Policy to reflect changes in the applicable laws, our group of companies, the Platform, our data collection use and practices. We will post the modified, amended or updated Privacy Policy on the Platform which shall be effective immediately upon being posted.
Our use of the personal data we collect is subject to the Privacy Policy in effect at the time such personal data is used. Please take note to periodically review this Privacy Policy and carefully review any changes made to this Privacy Policy.
HOW TO CONTACT US
If there are any changes to your personal data, and/or if you have any question in respect of the collection, use, processing, keeping, disclosure and/or transfer, of your personal data, and/or you would like to exercise any of your rights as set out in this Privacy Policy, you may contact us at:
Email address
:
contact@specialkidfactory
For the attention of
:
[ATTN] SKF Privacy Policy
Last Update: 19th March 2023
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