Privacy Policy

Privacy Policy

 

THIS POLICY DESCRIBES OUR POLICIES AND PROCEDURES FOR COLLECTION, TRANSMISSION, STORAGE, PROCESSING, DISCLOSURE AND PROTECTION OF ANY DATA, INCLUDING, BUT NOT LIMITED TO, PERSONAL DATA PROVIDED BY YOU AS A USER WHILE USING THE SERVICE. USER SHALL MEAN ANY PERSON/ PERSONS, WHO VISITS, USES, DEALS WITH AND/ OR TRANSACTS THROUGH WAY FENGSHUI GROUP (“PRIVACY POLICY”). PLEASE ALSO READ OUR TERMS OF SERVICE (“AGREEMENT”) WHICH SETS OUT THE TERMS GOVERNING THE SERVICES. THE TERMS AND CONDITIONS, PRIVACY POLICY AND ANY OTHER TERMS AND CONDITIONS AS MAY BE APPLICABLE SHALL HEREINAFTER COLLECTIVELY BE REFERRED TO AS “AGREEMENT” OR “CONTRACT”.

 

IMPORTANT NOTE:

  1. If You are less than 18 years of age, please read through the WAY Privacy Policy and the WAY Terms of Service with Your parent or legal guardian or check with Your Institution to understand eligibility before use.
  2. All registration information you submit to us directly is truthful and accurate and that you agree to maintain the accuracy of such information. Please do not share any other Personal Data or any other sensitive data when You using the Services. Any such data is shared by You at your sole discretion. We shall not be held liable.

 

PLEASE TAKE TIME TO REVIEW THE FOLLOWING DATA CAREFULLY.

 

Introduction

Welcome to Way Fengshui Group, the mobile and online service of Way OnNet Group Private Limited (hereinafter “WAY” “We”, “Us”, or “Our”). When you as a Data Subject (“User”, or “You/r”) use WAY’s Services, You trust us with Your Data. This Privacy Policy governs Your use of the Services or mobile based software application (hereinafter the “Service” or “WAY App”) created by Way Onnet Group Private Limited. This Privacy Policy along with WAY Terms of Service constitutes a legal agreement between You and WAY.

This Privacy Policy (“Policy” or “Privacy Policy”) has been drafted in accordance with the Personal Data Protection Act 2012 (“the Act”). For the purposes of processing Your data, Way Onnet Group Private Limited, will act as the Data Controller. WAY is a private limited company, incorporated and existing under the laws of Singapore and having its registered office at 149 Rochor Rd, #02-11 Fu Lu Shou Complex, Singapore 188425.

 

What does this Privacy Policy apply to?

This Privacy Policy applies to the data You provide Us when You Use the WAY Services. This Privacy Policy is meant to help You understand what data We collect, why We collect it, what We do with it, how You can manage and control the Use of Your data and the rights You have to access and control Your Personal data. Please read the definitions in the next section to understand the terminologies used in this Privacy Policy.

We will always respect and protect Your privacy, and this forms a part of Our guiding principles. We have policies and procedures in place to protect the privacy and security of Your Personal data. Your trust means a lot to Us. We take utmost precautions to protect Your data during transmission and storage.

Your use of the WAY Services will be governed by this Privacy Policy as applicable to the WAY App together with all policies, notices, guidelines, disclaimers that are published and shared with You from time to time including but not limited to WAY Terms of Service.

WAY reserves the right to make changes to this Privacy Policy and to make such changes effective for all data We may already have collected from You. We will notify You via in-app notifications when We make any changes to the Privacy Policy.

Please note that by using WAY Services and installing WAY App, You acknowledge and agree that You have read and understood this Privacy Policy.

 

Definitions

Personal data or Personal Information means data relating to an identified or identifiable natural person who can be directly or indirectly identified by reference to an identifier such as full name, identification numbers, location address, online identifier and other identifiers within the definitions of The Personal Data Protection Act 2012 (“the Act”).

Non-Personal data or Non-Personal Information means any data that does not reveal Your specific identity either directly or indirectly.

Data or Information under this Privacy Policy means Both Personal and Non-Personal data or information.

A Cookie is a small amount of data generated by a website and saved by Your Web browser. Cookies are used to store User preferences for a specific site. Use of cookies makes Web-surfing easier. You may refuse to accept Cookies by activating the setting on Your browser which allows You to refuse the setting of Cookies.

Web browser is a software program that allows User to access, retrieve and view data on the World Wide Web. Examples of browsers include Internet Explorer, Firefox, Google Chrome and Safari.

 

What Data (“User Data”) do We collect and how do we use it?

 

  • Personal Information You disclose to Us
  1. When You sign up for the Service (by using Facebook, Google or registration form), We will process Your name, email address, mobile phone number, date and time of birth, and location address.
  2. We collect personal information that You voluntarily provide to Us, when express an interest in obtaining information about Us or Our Service, when You participate in activities on the Service or otherwise when You contact Us. The personal information that we collect depends on the context of your interactions with us and the Service, the choices you make and the features you use. Throughout your use of the Service, we will process the chat messages, posts, contributions, search phrases, and reactions to content that you provide. Depending on what you choose to provide, these may include special categories of data that you provided in your posts and contributions, such as data concerning health, political opinions, religious or philosophical beliefs. We will also process your user notification preferences which indicate which notifications you wish to receive from the Service.
  3. You are not legally obligated to provide or give access to any personal data, but we do need this information to provide you the Service.

 

  • Information automatically collected

We automatically collect certain information when You visit, use or navigate the Service and our website. This information non-personal in nature and does not reveal your specific identity (like Your name or contact information) but may include device and usage information, such as Your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when You use our Service and other technical information. This information is primarily needed to maintain the security and operation of Our Service, and for Our internal analytics and reporting purposes.

Like many businesses, We also collect information through cookies and similar technologies.

The information we collect includes:

  1. Log and Usage Data.Log and usage data is Service-related, diagnostic, usage and performance information our servers automatically collect when You access or use Our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about Your activity in the Application (such as the date/time stamps associated with Your usage, pages and files viewed, searches and other actions You take such as which features You use), device event information (such as system activity, error reports (sometimes called ‘crash dumps’) and hardware settings).
  2. Device Data. We collect device data such as information about Your computer, phone, tablet or other device You use to access the Services or App. Depending on the device used, this device data may include information such as Your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model Internet service provider and/or mobile carrier, operating system and system configuration information.
  3. Location Data.We collect location data such as information about Your device’s location, which can be either precise or imprecise. How much information We collect depends on the type and settings of the device You use to access the Services. You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device.

 

  • Information collected through our Application

If you use our Application, we also collect the following information:

  1. Mobile Device Access. We request access or permission to certain features from Your mobile device, including your mobile device’s camera. If You wish to change our access or permissions, You may do so in Your device’s settings.
  2. Mobile Device Data. We automatically collect device information (such as Your mobile device ID, model and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server).
  3. Push Notifications. We request to send You push notifications regarding Your account or certain features of the App. If You wish to opt-out from receiving these types of communications, You may turn them off in Your device’s settings.

This information is primarily needed to maintain the security and operation of our Application, for troubleshooting and for our internal analytics and reporting purposes.

 

  • How do We use the collected User Data?

We use personal information collected via our Services for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below:

  1. To facilitate account creation and logon process. We use Your username, email address and password for User registration and logon.
  2. Request feedback. We may use your information to request feedback and to contact You about Your use of Our Services.
  3. To manage user accounts. We may use Your information for the purposes of managing Our account and keeping it in working order.
  4. To send administrative information to you. We may use Your personal information to send You product, service and new feature information and/or information about changes to Our terms, conditions, and policies.
  5. To protect our Services. We may use your information as part of Our efforts to keep Our Services safe and secure
  6. To enforce our terms, conditions and policies for business purposes, to comply with legal and regulatory requirements or in connection with our contract.
  7. To respond to legal requests and prevent harm. If We receive a subpoena or other legal request, We may need to inspect the data We hold to determine how to respond.
  8. Fulfil and manage the Services. We may use Your information to fulfil and manage the Services you engaged.
  9. To deliver and facilitate delivery of services to the user. We may use Your information to provide you with the requested service.
  10. To send notifications: We may process the User Data in order to send notifications and updates about the Service and the content You may be interested in on the Service. You can control the notification and updates You receive through the designated menu of the Service.
  11. We will also use the User Data to detect and handle inappropriate user content. This may lead us to restrict the inappropriate user’s access to the Service, by way of issuing the user a warning, suspending the user temporarily, or banning the user from the Service altogether.
  12. To respond to user inquiries/offer support to users. We may use Your information to respond to Your inquiries and solve any potential issues You might have with the use of Our Services.
  13. To send you marketing and promotional communications. We and/or our third-party marketing partners may use the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt-out of our marketing emails at any time by writing to us at [email protected]
  14. Deliver targeted advertising to You. We may use Your information to develop and display personalized content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.
  15. For other business purposes. We may use your information for other business purposes, such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns and to evaluate and improve our Services, products, marketing and your experience. We may use and store this information in aggregated and anonymized form so that it is not associated with individual end users and does not include personal information. We will not use identifiable personal information without your consent.

 

  • Do We use Cookies?

Cookies are text files, comprised of small amount of data, that are saved on Your device when You use the internet.

The information that the cookies maintain is read by the online service You visit, during the session of Your visit (these are called ‘session’ cookies), and when You return to visit it again (these are called ‘persistent’ cookies).

Subject to Your consent, We use cookies and similar technologies to customize content and advertising, to provide social media features and to analyse traffic to the Service. You may opt-out from such use at any time by contacting us at: [email protected]

 

  • Do We collect Passive Sensing data from Your mobile device?

When You Use the Service or the App, WAY does not passively collect nor process any data from Your mobile device sensors, including accelerometer, ambient light readings and screen on/off readings and call logs.

 

  • Do We process Your location data?

WAY does not process Your Geolocation at a level that makes Your data personally identifiable. WAY may infer Your location through Your timezone or other means at a country or state level to provide You appropriate resources.

 

  • When and How We share User Data with others?

We will share Your personal information with Our service providers who assist Us with the internal operations of the Service and other aspects of our business. These include:

Amazon Web Services, Inc. for cloud storage and processing

Google LLC. for web and app analytics

Facebook Analytics for marketing analytics

These companies are authorized to Use Your personal information only as necessary to provide these services to Us and not for their own promotional purposes. We do not sell Your personal information to third parties. Subject to your consent, we share information about Your use of our Service with Facebook and other advertising and analytics partners. The purpose for which such third parties process this information is for marketing and advertising. You may opt-out from such sharing at any time by contacting us at [email protected]

If You have seriously abused your rights to use the Service, or violated any applicable law, We will share your information with competent authorities and with third parties (such as legal counsels and advisors), for the purpose of handling of the violation or breach. If We are required to disclose Your information by a judicial, governmental or regulatory authority. If the operation of WAY or the Service is organized within a different framework, or through another legal structure or entity (such as due to a merger or acquisition), we will share your information to enable the structural change.

We also retain the right to share the User Data with our service providers, to enable them to provide services to us, as and when they join us. This is done to ensure smooth internal management and business growth.

 

How do We handle Your Payment data?

If You choose to subscribe to WAY App by means of in-app purchases via iTunes or Google Play, or If You choose to engage Our Service, by a point of sales (POS) purchase or by PayPal, We do not collect, retain and store Your personal, financial and credit/debit card data. This is because Your card settlements including card and personal details will be handled by appropriate third-party payment agencies.

We do not collect any personal data from the play stores post-purchase. Only the payment confirmation and subscription details get collected from the play store and processed (collect, transmit and store) by Us. Processing of this data is for Our Legitimate Interest to support You for any payment or subscription related requests, issues or clarifications.

 

How do we Secure and Retain User Data?

We retain user data for the duration needed to support our ordinary business activities operating the Service. Thereafter, we will still retain your personal information as necessary to comply with our legal obligations, resolve disputes, establish and defend legal claims and enforce our agreements.

We implement measures to reduce the risks of damage, loss of information and unauthorized access or use of information, such as encrypted transmission of the data we communicate to and from users.

However, these measures do not provide absolute information security. Therefore, although efforts are made to secure your personal information, it is not guaranteed, and you cannot expect that the Service will be immune from information security risks.

It is your responsibility to ensure the privacy and security of your email account and phone messages so they cannot be accessed by third-party. WAY will use one or both of these channels to communicate with you regarding a range of information related to your Service. WAY shall not be liable for any breach in confidentiality, should your email or text messages be accessed by a third-party, with or without your consent.

 

Concerns and Complaints

If You have any concerns or grievances about this Privacy Policy You will need to send an email request to [email protected]. We will respond to You within 48 hours and help resolve Your concerns or complaints.

Subject to applicable law, you have the right to lodge a complaint with your local data protection authority.

 

Third party links

The Service may contain links to other third party sites. The third party sites are not necessarily under the control of WAY. Please note that WAY is not responsible for the privacy practices of such third party sites. WAY encourages You to be aware when You leave the platform and to read the privacy policies of each and every third party site or mobile application that collects Personal Information. If You decide to access any of the third-party sites linked to the platform, You do this entirely at Your own risk. Any links to any partner websites is the responsibility of the linking party, and WAY shall not be responsible for notification of any change in name or location of any information on the websites. WAY is not responsible for the use of any Personal Information that you voluntarily disclose through a forum or through the platform.

 

Changes to this Privacy Policy 

We may modify Our Privacy Policy from time to time for various reasons including to improve Our privacy practices, to ensure Our Users Right to be Informed, to reflect changes to Our Service, and to comply with relevant laws. If and when this policy is changed, We will post the new notice on our Website and App and notify You through an in-app notification automatically or as otherwise required by relevant law. It is Your responsibility to check Our Website and App periodically for updates or changes to Our policy. We encourage You to review changes carefully. If You agree to the changes, then please continue to Use Our Service. If You, however, do not agree to any of the changes and You no longer wish to Use Our Service, You may choose to unsubscribe Service or uninstall Our App. Continuing to Use Our Service after a notice of change has been communicated to You or published on Our Service constitutes Your acceptance of changes and consent to the modified Privacy Policy.

 

Severability and Exclusion 

We have taken every effort to ensure that this Privacy Policy adheres with the applicable laws, including Data Protection Laws. The invalidity or unenforceability of any part of this Privacy Policy shall not prejudice or affect the validity or enforceability of the remainder of this Privacy Policy. This Privacy Policy does not apply to any data other than the data collected by WAY while providing the Services.

 

Governing Law and Dispute Resolution 

This Privacy Policy shall be governed by and construed in accordance with the laws of Republic of Singapore. The courts at Singapore shall have exclusive jurisdiction in relation to any disputes arising out of or in connection with this Privacy Policy. WAY is a company based in Singapore. By browsing or using the Services, You hereby acknowledge that WAY is not responsible or liable in any manner to comply with any local laws of Your territory except Singapore.

 

Contact Information

If you have any questions, comments, or concerns about this Agreement or our other privacy policies or practices, please contact our Data Protection Officer at [email protected] or +65 63383800 or by writing to:

 

Data Protection Officer

Way Onnet Group Pte Ltd
149 Rochor Rd,
#02-11 Fu Lu Shou Complex,
Singapore 188425