PDPA Policy

Privacy Policy

Effective Date:04May 2020

KESTREL INVESTIGATION & SECURITYPTE LTD(the “Company”) is the legal and beneficial owner of the website, https://www.kestrelis.com/, all material located on the website including all information, text, graphics as well as any software programmes available on or through this website (hereinafter referred to as “Kestrelis”). Kestrelis provides a platform for users to browse, obtain information and purchase security products and services online which are offered by the Company.In using our product and services, information is entrusted to us and we want to make our intentions and processes, and your options, as transparent and easily accessible as possible in clear and plain language. Our Privacy Policy will help you understand what information we collect, how it is used and the choices you have as a user.

Our Policy applies to the users in every capacity.

We will explain the following:

  • What information we collect and why we do so
  • How that information is used
  • Your options in accessing and managing that information

Information we collect

Personal Data

You may provide us with your informationincluding:

  1. Information that you give us
  2. your contact information, including your (first and last) name, identification number (where appropriate), (billing and/or delivery) address, birthdate and email address and, optionally, your mobile number. We need your e-mail address and contact numbers so that we may contact you if we have questions or information for you regarding your order or the service that we are providing or will provide to you;
  3. other information required to be able to process your order or to provide you with the service, such as information concerning the products you have ordered or the service we are providing to you, the billing and/or delivery address, banking and/or credit card details;
  • if you have created an online profile or an account through our registration process, the preferences and interests stored in such profile or account; and
  1. such other information necessary for us to carry out our specific purpose in our full range of security services.

  1. Information we collect about you.

With regard to each of your visits to Kestrelis, we may automatically collect the following information:

  1. technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
  1. information about your visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number.
  1. Information we receive from other sources.

We may receive information about you if you use any of the other websites we operate or the other services we provide. In this case we would have informed you when we collect that data, that it may be shared internally and combined with data collected on this site. We are also working closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.

The above information is used for evaluating your interaction with Kestreli such as log information and device information. In addition, we collate this data to compute the number of visitors on Kestrelis as a whole. That said, we always encourage due diligence before divulging Personal Data in any form. Other than email services pertaining to the functionality of Kestrelis, you expressly consent forKestrel touse your email address to send you marketing collaterals, promotions or corporate communications unless you have expressly agreed not to receive such materials by opting out and/or unsubscribing from the mailing list or using such other means provided to you by the Company.

Here is a breakdown of the data points collected on how we use this information:

  • Billing and other information. Forusers whosubscribe or purchase products or services onKestrelis, our corporate affiliates and third-party payment processors may collect and store your billing address and credit card information on our behalf. Our payment gateway is powered by a trusted, secured provider. This information is strictly used for billing purposes only.
  • Services usage information. This is information about how you are accessing and using Kestrelis, which may include administrative and support communications with us and information about the projects, people, features, content, links you interact with, and third-party integrations you use (if any). This information is used for internal evaluation on platform interaction patterns, engagement rates and analytics. This may also be used by Kestrel for research and development on the Company’s products and services. In the event third parties are involved, all data points are anonymized and aggregated to protect your privacy.
  • Contact information. With your permission, any contact information you choose to upload is collected when usingKestrelis. This information is used only for communications between the Company and you, andmay be used as a channel for marketing and corporate communications unless you have expressly stated your preference not to receive such communications. This information is accessible by the Company.
  • Log data. When you use Kestrelis, our servers automatically record information, including information that your browser sends whenever you visit a website or your mobile app sends when you are using it. This log data may include your Internet Protocol address, the address of the web page you visited before using Kestrelis, your browser type and settings, the date and time of your use of Kestrelis, information about your browser configuration and plug-ins, language preferences, and cookie data. This information is primarily used for internal purposes, such as establishing usage patterns, troubleshooting, interaction patterns and product development. This information may be shared with third parties to facilitate co-development or troubleshooting. In the event third parties are involved, all data points are anonymized and aggregated to protect your privacy.
  • Device information. We may collect information about the device you are usingKestrelis on, including what type of device it is, what operating system you are using, device settings, application IDs, unique device identifiers, and crash data. Whether we collect some or all of this information often depends on what type of device you are using and its settings. This information is primarily used for internal purposes, such as establishing usage patterns, troubleshooting, interaction patterns and product development. This information may be shared with third parties to facilitate co-development or troubleshooting. In the event third parties are involved, all data points are anonymized and aggregated to protect your privacy.
  • Geo-location information. Precise GPS location from mobile devices is collected only with your permission. Wi-Fi and IP addresses received from your browser or device may be used to determine approximate location. This information is used to enable certain functionalities of Kestrelis.This information is also used for internal purposes, such as establishing usage patterns, troubleshooting, interaction patterns and product development. This information may be shared with third-parties to facilitate co-development or troubleshooting. In the event third parties are involved, all data points are anonymized and aggregated to protect your privacy.
  • Services integrations. If, when using Kestrelis, you integrate with a third-party service, we will connect that service to ours. The third-party provider of the integration may share certain information about your account with Kestrelis. However, we do not receive or store your passwords for any of these third-party services.
  • Third-party data.Kestrel may also receive information from affiliates in our corporate group, our partners, or others that we use to improve Kestrelis. This might be aggregate level information, such as which IP addresses go with which zip codes, or it might be more specific information, such as the performance of an online marketing or email campaign.

Our Cookie Policy

Kestrelis uses cookies and similar technologies, such as single-pixel gifs and web beacons, to record log data. We use both session-based and persistent cookies.

Cookies are small text files sent by us to your computer or mobile device, and from your computer or mobile device to us each time you visit our website or use our desktop application. They are unique to your account or your browser. Session-based cookies last only while your browser is open and are automatically deleted when you close your browser. Persistent cookies last until you or your browser deletes them or until they expire.

Some cookies are associated with your account and personal information in order to remember that you are logged in and which projects you are a part of. Other cookies are not tied to your account but are unique and allow us to carry out site analytics and customization, among other similar things. If you access Kestrelis through your browser, you can manage your cookie settings there. However, if you disable some or all cookies, Kretrelis may not function as intended.

The Company sets and reaches out to our own cookies on the domains operated by Kestrelisand its corporate affiliates. In addition, we use third parties including but not limited to certain providersfor website analytics. You may opt out of third-party cookies from these services by visiting their websites. We do not currently recognize or respond to browser-initiated Do Not Track signals as there is no consistent industry standard for compliance.

How we use your information

We use your information to provide and improve the Compannyand Kestrelis.

We use other kinds of information in providing our services and products, specifically:

  • To understand and improve Kestrelis. We carry out research and analyze trends to better understand how users are interacting with Kestrelis and improve on feedback.
  • To communicate with you by:
    1. Responding to your requests. If you contact us with a problem or question, we will use your information to respond.
    2. Sending emails and Kestrelis-related messages. We may send you emails and messages as necessary for the full functionality and performance of the Kretrelisas intended. We may also contact you to inform you about changes in Kestrelis, Kestrelis offerings, and important Kestrelis-related notices, such as security and fraud notices. These emails and messages are considered part of the Kestrelis platform.
  • Billing and account management. We use account data to administer accounts and keep track of billing and payments. This information is also used to communicate with you for invoicing and payment matters.
  • Marketing and corporate communications. We may need to contact you for marketing and corporate communications such as product updates, new offerings and promotions. Unless you have expressly stated your preference to opt out, we may also use your information to send marketing collaterals or for advertising purposes.
  • Security and keeping your information safe. We work hard to keep the Kestrelis platform secure and to prevent abuse and fraud. From time to time, your information may be accessed by personnel of Kestrelis to facilitate this process.

Your choices

Deleting of Personal Information

At any given time, if you do not wish to share your information, you may delete your account by:

You will be required to specify your email address, full name, and any additional information to facilitate identification and deletion of your Personal Data.

Our Data Protection Officer will contact you regarding your request and will ensure that all personal information associated with you including but not limited to name, address, phone number, credit card details will be permanently deleted, without undue delay.

However, you may indicate that you wish to remain in our mailing list by email, asthe Companyis constantly updating andevaluating their services and offering new and improved product recommendations.

Other information

If you have any questions about your information, our use of this information, your rights or anything pertaining to your data and how its managed, reach out to us at joey.tham@kestrelis.comor atal.chiang@kestrelis.comor call us at 6744 3238

Other Choices

In addition, the browser you use may provide you with the ability to control cookies or other types of local data storage. Your mobile device may provide you with choices around how and whether location or other data is collected and shared. Kestrel does not control these choices, or default settings, which are offered by makers of your browser or mobile device operating system.

Sharing and Disclosure

There are times when information described in this Privacy Policy may be shared by the Company. This section discusses only how Company may share such information. While the Company holds third parties to the same standards of data protection as we do, the Company does not control howthird parties choose to share or disclose Content.

We will not share this data with anyone unless you explicitly consent to us doing so. We respect your rights to privacy and will comply with your wishes to remove your data from our systems if so required.

Based on the information you provide to us, we may create or append other information to your profile in the interest of better serving you (for example, your interests). As is the case with all data we collect, this will be kept private and for our business purposes only.

Information

The Company may share other information as follows:

  • With third-party service providers and agents. We may engage third-party companies or individuals, such as third-party payment processors, to process information on our behalf. Any Personal Data that is being shared with third-party service providers and/or agents is clearly communicated to you through our Privacy Policy and will not be used for purposes other than what has been expressed.
  • With affiliates. We may engage affiliates in our corporate group to process other information. All Personal Data will be anonymized and aggregated.

Other types of disclosure

The Company may share or disclose Content and Personal Data as follows:

  • During changes to our business structure. This includes but is not limited to a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of the Company's assets, financing, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities (e.g. due diligence). In such an event, we will contact you and inform you of the impending data transfer and we will provide a reasonable timeframe for you to withdraw your Personal Data should you wish to do so.
  • To comply with laws. To comply with legal or regulatory requirements and to respond to lawful requests, court orders and legal proceedings.
  • To enforce the rights of all stakeholders, prevent fraud and for safety. To protect and defend the rights, property, or safety of Kestrel, our users or third-parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud.

We may occasionally disclose or use anonymized and aggregated information; for instance, information may be shared with our partners or affiliates for business or research purposes involving data points, or partnering with research firm or academics to explore questions about enhancing the Company and its potential.

Security, Accountability and Governance

We take various steps to protect information you provide to us from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the information we collect, process and store, and the current state of technology.

You shall maintain a written record of processing activities carried out.

The Company does implement appropriate measures to:-

  • ensure that only personal data that is necessary for the specific purpose is processed;
  • an assessment of the impact of processing on the protection of personal data in certain circumstances (particularly new technologies) is likely to result in high risk to the rights and freedom of individuals; and
  • appoint / designate a Data Protection Officer if required, to monitor, review and assess your data processing procedures, aiming to minimize date processing and retention of data, and building in safeguards. Our Data Protection Officer shall notify you on becoming aware of any personal data breach without undue delay.

External Websites

The Company does not take any responsibility for the content and privacy policies of any external website linked through Kestrelis. We advise you to click on any external links at your own discretion and to take note of the privacy policies on such external websites to protect yourself.

Data Breach Notification

In the case of a personal date breach, the User must:-

  1. Notify us without undue delay, but not later than 72 hours where feasible; and
  1. Notify the individual without undue delay, if the personal data breach is likely to result in a high risk to the rights of the user, in appropriate circumstances.

Changes to this Privacy Policy

We may change this policy from time to time and if we do, we will post any changes on this page and in certain circumstances, a notification will be made available to you informing you of the changes. If you continue to use Kestrelis after those changes are in effect, you agree to the revised policy.

Amendments to Personal Data Protection Policy

Our use of your personal information will always be governed by the latest version of this Privacy Policy, which will always be made accessible to you. By continuing to access or utilize Kestrelis following these changes, you agree to be bound by the revised Privacy Policy.

Contacting The Company

Please feel free to contact us if you have any questions aboutour Company’s Privacy Policy. You may contact us atjoey.tham@kestrelis.comor atal.chiang@kestrelis.comor call us at 6744 3238

-The Kestrel Team-

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