Privacy Policy

We understand that your privacy is important and we endeavour to protect your personal information.

1. Purpose of Privacy Policy

This Privacy Policy is designed to assist you in understanding how we may collect, use, record, hold, store, use, disclose or otherwise process personal information you provide to us in accordance with the Personal Data Protection Act (“PDPA”), and in making informed decisions when you are using our website or any other means through which you disclose your personal data to us. Our policy applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.

By interacting with Flying Fish Lab or through the Flying Fish Lab platform (collectively, the “Platform“), as well as its respective representatives and/or agents (collectively referred to herein as “us“, “we” or “our“), submitting information to us, subscribing or registering for a user account (“Account“) with us (“subscribers“) though the Platform, providing us with your personal data or submission or provision of your work or services offered by us (“Work”), you agree and consent to our Processing of your Personal Data and the terms of our Privacy Policy.

For the avoidance of doubt, your consents given under this Privacy Policy supplement (do not supersede or replace) any other consents that you may have previously provided or will provide to us, and are additional to any rights which we may have at law to collect, use or disclose your Personal Data.

We may update this Privacy Policy from time to time through our Website in accordance with future developments and/or changes in legal or regulatory requirements. By continuing to interact with us, you consent to be bound by the prevailing terms of our Privacy Policy as updated from time to time, subject to applicable law.

As used in this Policy:

“member” means an individual who has registered on the Flying Fish Lab platform online or through our app; and

“personal data” means data, whether true or not, about a member who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include your name and contact information such as your address, email address or telephone number, nationality, gender, date of birth, photographs and other audio-visual information, employment information and financial information such as credit card numbers, debit card numbers or bank account information. Personal data also includes any such information as we deem necessary or appropriate from time to time in connection with your commercial relationship with us.

2. What information do we collect?  

When you visit our platform online, such as when you browse our site, by registering for an account with us, registering with us generally, enquiring into our services or projects,  you may be providing us with the following information:

a. personal data you voluntarily choose to disclose to us, e.g., your name, mailing and email addresses, bank account number, identity document, telephone number and any other which you provide to us;

b. website use information collected on an aggregate basis as you and others browse our website.

c. information gathered through promotional activities;

d. other information which includes personal data of others provided or submitted by you through the use of the Platform or submission of your work.

2.1 In certain situations, you may be providing us with Personal Data relating to other individuals, e.g. your employees, spouse, children, etc., such as when you register for a user account on our platform on their behalf. Where you provide us with any Personal Data relating to a third party, you warrant and represent to us that you have obtained the consent of that third party to provide us with that party’s Personal Data in accordance with our Privacy Policy.

2.2 You should ensure that all Personal Data submitted to us is complete, accurate, true and correct to the best of your knowledge. 

3. What do we use your personal information for?

The personal information we collect from you may be used in one of the following ways:

a. To perform obligations in the course of or in connection with our provision of the products and/or services provided and/or requested by you, in particular, to ensure that your banking information are accurate so that you can be paid on time;

b. To verify your identity;

c. To respond to, handle, and process queries, requests, applications, complaints, and feedback from you;

d. To manage your relationship with us;

e. To process payment or credit transactions;

f. To send you information about new projects on our platform and about our products or services (and those of our sponsors/partners) including notifying you of new features or changes to your membership;

g. Any other purposes for which you have provided the information;

h. To improve our website;

i. meeting any legal or regulatory requirements relating to our provision of services and products and to make disclosure under any statutory legislations, court order, by-laws and relevant regulations applicable to us.

j. Any other incidental business purposes related to or in connection with the above.

k. Prevention or detection of crime, for the purposes of investigations, apprehension or prosecution of offenders, or assessment or collection of any tax or duty or other similar impositions

l. use for internal purposes such as auditing, data analysis, and research to improve the platform and customers’ communications.

m. conducting marketing, promotional and user profiling activities in connection with our services or projects.

The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).

4. Will your personal information be passed on to any third parties?

We do not disclose, sell or share your Personal Data with any third parties (except where permitted or required by law), but you hereby consent and authorize use to provide and/or disclose your Personal Data to the following categories of parties:

a. where such disclosure is required for performing obligations in the course of or in connection with our provision of the products or services provided and/or requested by you; 

b. to third party service providers, agents and other organisations we have engaged to perform any of the functions listed in Section 3 above for us;

c. any person to whom we are compelled or required to do so under law or in response to a legitimate instruction from a competent or government agency;

d. our auditors, consultants, accountants, lawyers or other financial or professional advisers; 

e. other members in the Flying Fish Lab community as we may determine to be necessary or appropriate whether within or outside of Singapore.

We will only disclose the minimum amount of information which we deem necessary for the purpose and that we will take all appropriate safeguards to ensure the integrity and security of the personal data.

5. Will you be able to withdraw your consent earlier provided to us?

Absolutely! The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.

Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request not more than twenty (20) business days of receiving it.

Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our products or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described above.

6. Can you access, update, correct your personal data which we hold about you?

Yes, you may do so.

If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.

We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) calendar days after receiving your request, we will inform you in writing within thirty (30) calendar days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA)

7. How do we protect your personal data?

The security of your personal information is our utmost priority. To safeguard your personal data against accidental loss, theft, misuse, unlawful processing and damage as well as from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis.

You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

8. How long do we retain your personal data?

We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.

We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.

9. What else should you know about data protection?

We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below. We do not assume responsibility for the publication of the information due to errors during transmission or due to unauthorised access by third parties.

10. TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE

We do not transfer your personal data to third party that situated in the countries outside of Singapore for any commercial profits purposes and/ or other purposes that do not fall under clause 4 of this Privacy Policy. However, if we do so, typically in cases where provision of the products and/or services requested and/or provided by you requires us to do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA. 

11. Cookies

A cookie is a small piece of data that a website can store on your computer. We may use cookies on our Website for the purposes of (i) enabling or facilitating certain features and functions of our Website in the provision of our online services to you, or (ii) tracking the use of links between our Website and the websites of our partners or affiliates. You may choose to configure your internet browser settings to manage or restrict the use of cookies, but this may result in delay or loss of functionality in the use of our Website.

12. Third Parties

We may also occasionally include or offer third party products, services or links on our Platform Each of these third parties/their sites has its own separate and independent privacy policy. We are not responsible for any such third parties, the content and activities of their sites, or any Personal Data that you may provide to them.  

13. EFFECT OF NOTICE AND CHANGES TO NOTICE

This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.

Should we revise this Notice and our Privacy Policy, we will update you using the email you have provided us. You may then determine if you want to continue or stop usage of our services by terminating your membership. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.

This Privacy Policy is governed by the law of Singapore. We reserve the right to add to, revise or delete any part or all of this Privacy Policy as permitted under the applicable laws of these jurisdictions.