Accumulus Privacy Policy

Effective date: 11 October 2023

A. Introduction

This Privacy Policy (this “Policy”) describes how Accumulus Pte. Ltd., its respective subsidiaries, affiliates, associated companies and jointly controlled entities (collectively referred to as “Accumulus”, “we”, “us” or “our”) collect, use and disclose your Personal Data (as defined below), in connection with your use of our website (accumulus.sg) (the “Site”), our Atlas by Accumulus application, and any of our other applications, products, services, interfaces, tools or software (the “Software”) (the Site and the Software collectively the “Services”), regardless of how you access or use any of the Services.

Your use of any of the Services shall constitute your acceptance of this Policy, to the fullest extent permitted by law.

B. Collection of Personal Data

“Personal Data” is any information which can be used to identify you or from which you are identifiable.

We collect your Personal Data directly from you when you:

register or log into any Service;
enter, upload, transfer or submit data into any Service;
otherwise use or interact with any Service, including providing us with information via a web form, adding or updating information in your Accumulus account; or
otherwise interact with us.

Additionally, we may access and collect data from third-party services if you consent to connect them with our Services (including for avoidance of doubt our Atlas by Accumulus application). Such data includes heart rate data and sleep data on Google Health Connect (for Google Health Connect users who consent to connect their Google Health Connect data with our Services only)

The Personal Data that we collect includes but is not limited to the following:

Data you provide when using our Services

Data that identifies you, such as your username, name, address(es), nationality, telephone number, email address, your image, government-issued identification numbers, licence numbers, date of birth, employment information, job title, IP address, and device ID
Any information you provide to display on your profile, such as your work experience and skills. Please do not include any data to your profile that you would not want to be publicly available.
Financial data (e.g. bank account or credit card details, transaction details, and form of payment).
Any information you provide, post or upload to our Services, such as when you create a post, comment on a post, upvote a post or a comment.
Any information that user-generated content, search history, product interaction,
Any information that you share with other users through our messaging tools.
Any other information you may provide to us by way of your usage of any of the Services, such as search history, product interaction, feedback, other usage data, performance data, crash data, and other diagnostic data
Other data that we are required or entitled by applicable law to collect and process and that we need for your authentication or identification, or for the verification of the data we collect.

2. Data we automatically collect when you use our Services

Data that is generated through any of your actions on, interactions with or usage of our Services
Data that is generated as part of or as a result of any transaction in which you are involved or is linked to your Accumulus account, such as transaction amounts, time and location of transactions and form of payment, as well as messages or requests that you send, receive, or engage with in connection with our Services.
Computer and connection information, such as statistics regarding your use of Services, information on data traffic to and from websites, referral URL, information on advertisements, your IP address, your access times, your browser history data, your language settings and your weblog information.
(For mobile devices) location data, including your general location data (e.g., IP address) and the precise location data of your mobile device. Please note that for most mobile devices, you can manage or disable the use of location services for all applications in the settings menu of your mobile device.
Any of the data described above may be collected with the use of cookies, web beacons or similar technologies. For more information about the use of these technologies and your choices, please see the section entitled “Cookies” below.

3. Data collected from other sources or means

When you access or use the Services through social media networks or when you connect the Services to social media networks or third-party services, you are authorising us to collect, store, and use such additional information and content in accordance with this Policy.
In the event that your organisation buys or subscribes for a Service for you to use, they give us data about you and your eligibility to use such Services in such a context (e.g. that they have purchased Services for use by their employees).
Data from public sources, credit agencies or bureaus or other data providers (e.g. demographic data, identity confirmation checks, interest-based and other data that may be related to our provision of new or improved Services to you).
We may also receive access to data about you from our partners, subsidiaries, affiliates, associated companies or jointly controlled entities.

The Personal Data we collect from you may be combined, connected or associated with data obtained from other sources, and to the extent that such data may constitute Personal Data, it shall be treated in accordance with this Policy.

C. Use of Personal Data

We use your Personal Data for various purposes, including but not limited to the provision, maintenance, support, development and improvement of our existing and new Services for you and other users, to fulfil contractual or legal obligations, in the assertion or defence of Accumulus’s legitimate interests, and to detect, prevent, mitigate and investigate fraudulent or illegal activity.

Some ways in which we may use your Personal Data are set out below:

Our interaction with you: We use your contact information to communicate with you, including to provide updates on existing, upcoming or new Services (including to investigate, respond to or resolve service issues), for customer service or research purposes, or to contact you in relation to your account, profile or any action, interaction or transaction related to your account on any Service. We may also send you reminders, suggestions, and promotional messages from us or our partners. We may also use your Personal Data in the enforcement of this Policy, the User Agreement and any other policies, agreements or rules which may apply to you through your use of any Service.
Facilitate discovery and connections: We use your Personal Data (such as your profile and profiles you have viewed to help others find your profile, and to help suggest other users that you should follow or connect with.
Interaction with other users: We enable interaction and communications between you and other users through our Services, such as the viewing of profiles and related information, and the sending and receiving of requests and messages between users. Given the social nature of some of our Services, do note that other users may have access to some of your Personal Data (including your activity as a user of any relevant Service) through their valid use of such Services, and they use or retain such Personal Data, or disclose such Personal Data to other third parties (e.g. if you engage in a business transaction with another user that is a company or a professional, they may need to (for their legal or professional compliance purposes) record or archive their communications with you). Please also be mindful of this when considering your activity on our Services. We may also review or check messages to protect our legitimate interests, such as to protect against activities that may be fraudulent, suspicious, or in violation of the User Agreement, any other policies, agreements or rules which may apply to you through your use of any Service, or any relevant law.
Security and fraud prevention: We may use your Personal Data for security purposes (e.g. to detect, prevent or investigate possible fraud or any other prohibited or illegal activity, anything that could harm you, us or any other person/entity), detect, prevent or investigate any violation or threatened violation of the User Agreement, any other policies, agreements or rules which may apply to you through your use of any Service, or any relevant law, or to assert or defend the legitimate interests of Accumulus or third parties (e.g. your employer or agency). We may also use or disclose your Personal Data with our legal advisors, law enforcement officials, government authorities or other third parties for the purposes of complying with any law or legal obligation to which we may be subject, including fulfilling any valid information requests from third parties based on any legal requirement (e.g. in the event of any potential intellectual property infringement by a user, or where it is necessary to respond to an emergency that threatens the life, health or safety of a person).
Publicity and community: As part of our community building and promotional efforts, we may publicise or promote certain relevant Personal Data, such as your listings or profile page, to other users and potential users of our Services.
Disclosure to service providers and business partners: We may also use, process or disclose your Personal Data in pursuit of the legitimate interests of us or a third party, to the extent permitted by applicable laws, such as for the analysis, enhancement or development of existing and new Services, or the offering of shared content and services with our affiliates or partners.
Disclosure to your employer: Your data may be shared with your employer if they offer you access to our enterprise services.
International data transfer: Your Personal Data may be stored and processed in your region or in any other country where Accumulus or its affiliates, subsidiaries, partners, or service providers are located or maintain facilities. If we provide any of your Personal Data about you to any such entities, we will take appropriate measures to ensure such entities protect your information adequately in accordance with this Policy and applicable law.
Merger or sale: In the event that Accumulus, or some or all assets related to the Services are acquired by, merged with or otherwise transferred to a third party entity in connection with a contemplated change of ownership or other corporate transaction, we reserve the right, in any of these circumstances, to transfer or assign any Personal Data that we have collected from users as part of that merger, acquisition, sale, or other change of control event (including any action in preparation of such event).

D. Cookies

Accumulus, as well as third party service providers or partners that we work with, may use cookies or similar technologies (“Cookies”) in connection with your use of the Services. These Cookies serve various functions, including enabling us to provide you with Services, to help us optimise our Services or to improve your user experience.

Cookies may have unique identifiers, and reside, among other places, on your device, in emails we send to you, and on our web pages. Cookies may transmit Personal Data about you and your use of the Service, such as your browser type, search preferences, IP address, data relating to advertisements that have been displayed to you or that you have clicked on, and the date and time of your use. Cookies may be persistent or stored only during an individual session.

In certain cases, third parties (e.g. social networks that you connect your Accumulus account to) may use Cookies in our Services to collect Personal Data and non-personally identifiable data, and they may be able to associate the Personal Data they collect with other Personal Data they have about you from other sources. In general, we do not have access to or control over the Cookies they use, or what they do with the Personal Data.

Depending on the device and operating software that you are using, you may be granted the option to disable our use of certain Cookies.

E. Retention of your Personal Data

Accumulus retains your Personal Data for as long as it is required to fulfill the relevant purposes described in this Policy, for as long as may be required (or permitted) by law such as for tax and accounting purposes or for our legal or business obligations or requirements, or as otherwise communicated to you. When this is no longer the case, we will delete your Personal Data or take steps to properly render any or all of your Personal Data anonymous.

F. Protection of your Personal Data

We will use a variety of reasonable legal, organisational, technical and physical measures to protect the integrity and security of your Personal Data, which will vary depending on the sensitivity of the respective Personal Data.

However, we seek your understanding that the transmission of any information over the internet is not completely secure, and that there is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of measures. Therefore, we cannot ensure or guarantee the security of any Personal Data transmitted through any means, and any such transmission is at your own risk.

G. Use, retention and protection of your Personal Data by third parties

This Policy only governs your Personal Data that is in our possession. Our Services may link to third party websites or services, which may receive or collect Personal Data from you, and the privacy practices of these third parties in respect to your Personal Data in their possession are not governed by this Policy. We encourage you to review the privacy policies or notices of these third parties to understand their practices.

For example, if you link your Accumulus account or otherwise connect to a third party service, you are authorising and directing us to share with or grant access to such third party service your Personal Data and other relevant information that we have, on your behalf.

H. Your rights with respect to your Personal Data

In accordance with applicable laws and regulations, you may be entitled to various rights with respect to your Personal Data.

You may decline to share certain Personal Data with us, but please note that this might affect our ability to provide any or all of our Services to you. You may also update the Personal Data you share with us through our Services (depending on the Service) from time to time.

To the extent where we have to rely on your consent to use any particular Personal Data, you have the right to decline such consent. If you had provided your consent but later choose to withdraw it, we will respect that choice in accordance with our legal rights and obligations.

You may also request that we delete some or all of your Personal Data, although please note that there may still be certain cases in which we may need to continue processing your information (e.g. where there are legitimate interests to uphold, or if we need to comply with other legal obligations). To make a Personal Data deletion request, please contact contact_us@accumulus.sg. Please note that, to protect your privacy and the security of your Personal Data, we may take steps to verify your identity before proceeding with the deletion of your Personal Data.

Please be reminded that your choice to not share Personal Data, grant us consent (or to withdraw your consent) regarding the use of any particular Personal Data, or to request the deletion of your Personal Data may prevent us from the provision (or continued provision) of certain Services to you.

I. Your responsibilities with the Personal Data of others

When you interact with another user through our Services, we will provide you with the other user’s Personal Data to varying levels of detail, depending on the type of interaction with such other user.

When you receive another user’s Personal Data through our Services, you are the controller of such data and therefore solely and independently responsible for any subsequent use, processing or disclosure of such data that you may perform, in accordance with not only this Policy, the User Agreement, as well as any relevant law (e.g. local data protection law) that may apply to you. You are hereby reminded that any Personal Data of another user that you may receive through any Service shall only be used for the purposes of any interaction with such other user through any of the Services, and for purposes expressly consented by such other user. Using Personal Data of any other user for any other purpose shall constitute a violation of our User Agreement.

Accordingly, regardless of how you are using our Service, you should always take such measures that are necessary for you to protect or to prevent compromising any Personal Data of other users that may be in your possession.

If you are using our Services as part of your business (whether or not as an individual or as an organisation) we recommend that you notify other users of how you may use their Personal Data through your own privacy notice.

If you provide us with Personal Data relating to another person (e.g. any employee or contractor engaged by you), you must obtain the consent of such person, or you must ensure that the use and disclosure of such Personal Data is otherwise legally permissible. It is your sole responsibility to inform such other person of how we will use their Personal Data in accordance with this Policy.

J. Amendments

Accumulus reserves the right to modify, update, amend, or otherwise change the terms in this Policy at any time. It is your responsibility to review this Policy regularly. Your continued use of our Services following the posting of any change to this Policy, whether or not you have reviewed such changes, shall constitute your binding acceptance of such change.

K. Translations

The original of this Policy is written in the English language. In the event of any conflict between the English and other language versions, the English version shall prevail.

L. Enquiries

Please contact us at contact_us@accumulus.sg if you have any questions or issues regarding this Policy.

We will endeavour to respond to your enquiry as soon as practicable, and we seek your understanding that our response time may be affected by the nature of your inquiry.

Depending on the nature of your enquiry, we may require you to provide us with supporting information necessary to confirm your identity and/or verify your authority before responding to your request