Updated: Effective on December 10, 2020

Structure:

1. WHAT personal data we collect
2. HOW we collect and process the data
3. For WHAT purposes we process your personal Data
4. Choice
5. Data Subject Rights
6. Information About Children
7. Data Retention
8. Passive Collection
9. Cookies and Tracking Technologies
10. Interest-Based Advertisements
11. Mobile Application
12. Gift Card
13. Sharing your Personal Data
14. Security of your Personal Data
15. Linked websites and third party services
16. Reviews and Photos
17. Message feature
18. Security of your Personal Data
19. Transfer and Storage of Personal Data
20. Mediavine Programmatic Advertising
21. Contact Us

Cookly Pte. Ltd. (“Cookly”) is committed to protecting your privacy and ensuring you have a positive experience on our website and mobile application in using our services. This policy covers the Cookly website https://www.cookly.me/ and mobile application (Services) and is applicable worldwide.

This policy outlines our handling practices and how we collect and use the Personal Data you provide during your online and offline interactions with us. As used in this Privacy Policy, ”Personal Data“ means any information that can be used to individually identify a person, and may include, but is not limited to, name, email address, country of origin, credit or debit card number and other personally identifiable information.

If you reside in the European Union (“EU”), United Kingdom, Lichtenstein, Norway, Iceland or Switzerland, you may have additional rights with respect to your Personal Data, as further outlined below. These rights may include rights under the EU’s General Data Protection Regulation (“GDPR”), if you are a resident of the EU, United Kingdom, Lichtenstein, Norway or Iceland.

Cookly Pte. Ltd. will be the controller of your Personal Data that is provided, collected and/or processed pursuant to this Privacy Policy, except where otherwise expressly stated below. If you have any questions about whether any of foregoing applies to you, please contact us using the information set forth in the “Contact Us” section below.

This policy may be updated from time to time for reasons such as operational practices or regulatory changes, so we recommend that you review our Privacy Policy when returning to our website.

WHAT personal data we collect

We collect the following categories of Personal Data about you when you visit the Services:

• Cookies, as further described in the “Cookies” section below
• Facebook profile information (when you use Facebook to log-in to our Services or to create an account for our Services)
• IP addresses and other information collected passively, as further detailed in the “Passive Collection” section below
• Device identifiers, as further described in the “Mobile Application” section below

In addition we collect the following categories of Personal Data about you make a purchase or attempt to make a purchase through the Services:

• Name
• Email address
• Mobile telephone number (optional)
• Country of origin
• Encrypted Credit/debit card information
• Facebook profile information (when you use Facebook to log-in to our Services or to create an account for our Services)

HOW we collect and process the data

We collect and/or process your Personal Data in connection with the below activities related to our Services:

• Account registration
• Generating reports based on information collected from use of our Services
• Requesting service and support for our Services and providing such support
• Placing transactions or orders
• Participating in an online survey
• Billing and collecting payments for our Services
• Registering for newsletter subscriptions
• Customizing the advertising and content you see

For WHAT purposes we process your personal Data

We will use your Personal Data only in accordance with our Privacy Policy. If you do not wish us to continue using your Personal Data in this manner, you can request that your account be deactivated by contacting us as specified in the “Contact Us” section.

We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity (i.e. processing that is necessary for the performance of a contract with you, such as your user agreement with us that allows us to provide you with the Services) and our “legitimate interests” or the legitimate interest of others (e.g. our users) such as:

• Personalizing, improving or operating our Services and business
• Better understanding your needs and interests
• Fulfilling requests you make related to the Services
• Providing you with information and offers from us or third parties
• Complying with our legal obligations, resolving disputes with users, enforcing our agreements
• Protecting, investigating and deterring against fraudulent, harmful, unauthorized or illegal activity

We process Personal Data for purposes such as:

• To process your orders and deliver the Services that you have ordered
• To provide reports based on information collected from use of our Services
• To keep you up to date on the latest Services announcements, system enhancements, and other information
• To provide support and assistance for our Services
• To provide the ability to contact you and provide you with booking and billing information
• To provide customer feedback and support
• To provide and administer opt-in contests, sweepstakes or other marketing or promotional activities or newsletters on the Services or affiliate websites
• To the extent you choose to participate, to conduct reviews and surveys in order to provide better experiences to our customers and end users
• To personalize marketing communications and website content based on your preferences, such as in response to your request for specific information on Services and services that may be of interest

Choice

You can choose whether to provide Personal Data to Cookly, but note that you may be unable to access certain options, offers, and services if they require Personal Data that you have not provided. You can sign-up and agree to our Privacy Policy and agree to receive email or newsletter, promotional communications from us. If you would like to discontinue receiving these communications, you can update your preferences by using the “Unsubscribe” link found in such emails or by contacting us using the information in the “Contact Us” section of this policy.

Data Subject Rights

You have certain rights with respect to your Personal Data as set forth below. Please note that in some circumstances, we may not be able to fully comply with your requests, or we may ask you to provide us with additional information in connection with your request, which may be Personal Data, for example, if we need to verify your identity or the nature of your request. In such situations, however, we will still respond to let you know of our decision.

To make any of the following requests, contact us using the contact details referred to in the “Contact Us” section of this policy.

• Access: You can request more information about the Personal Data we hold about you. You can also request a copy of the Personal Data.
• Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data. Please contact us as soon as possible upon noticing any such inaccuracy or incompleteness.
• Objection: You can contact us to let us know that you object to the collection or use of your Personal Data for certain purposes.
• Erasure: You can request that we erase some or all of your Personal Data from our systems.
• Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
• Portability: You have the right to ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another entity where technically feasible.
• Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
• Right to File Complaint: You have the right to lodge a complaint about Cookly’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State.

Information About Children

If you are under 16 years old, we ask that you do not use our Sites or give us your personal information. If you are from 16 to 18 years, you can browse the Sites but you’ll need the supervision of a parent or guardian to become a registered user. It’s the responsibility of parents or guardians to monitor their children’s use of our Sites.

Data Retention

We retain your personal information for as long as is necessary to provide the services to you and others, and to comply with our legal obligations. If you no longer want us to use your personal information or to provide you with the Cookly Services, you can request that we erase your personal information. Please note that if you request the erasure of your personal information we will retain information from deleted accounts if necessary for our legitimate business interests, to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce the terms of service and take other actions permitted by law. The information we retain will be handled in accordance with this Privacy Policy.

Passive Collection

Cookly and our third party service providers automatically collect some information about you when you use our Services, using methods such as cookies and tracking technologies (further described below). Information automatically collected includes Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the website and/or Services.

In addition, when you use some of our Services,, network information is transmitted back to us such as Services usage information. This information is transmitted back to us so we can determine how users are interacting with our Services, to assist us with improving our Services, and to correct any problems that may occur.

Cookies and Tracking Technologies

Cookly and our partners use cookies or similar technologies to analyze trends, administer the website, track users’ movements around the website, and gather information about our user base, such as location information based on IP addresses. Users can control the use of cookies at the individual browser level. For more information about cookies please visit our cookies policy page, and how to disable cookies, visit http://www.allaboutcookies.org.

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. As for now, we don't respond to the ''Do Not Track" signal that may be activated on your browser, for more information about the “Do Not Track” all about do not track

Interest-Based Advertisements

We partner with third parties to either display advertising on our website or to manage our advertising on other sites. Some of our third party partners use technologies such as cookies and other technologies to gather information about your activities on this website, our affiliates’ websites, and unaffiliated websites in order to provide you advertising based upon your browsing activities and interests. We also use Google Analytics to help us understand how our customers use the Site--you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/.
You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

We use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising by:
FACEBOOK ADS
GOOGLE ADS
INSTAGRAM ADS

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

If you wish to not have information about your online activities over time and across different websites used for the purpose of serving you interest-based ads, you can opt-out by clicking here and here (or if located in the EU click here). Please note that (1) this does not opt you out of being served ads, and even if you opt out of interest-based ads, you will continue to receive generic ads and (2) we store your opt-out preference for interest-based ads in a cookie on your device, and therefore you may have to opt out again if you delete your cookies.

Mobile Application

When you download and use our Services, we automatically collect information on the type of device you use, operating system version, and the device identifier (or ”UDID“). We send you push notifications from time-to-time in order to update you about any events or promotions that we may be running. If you no longer wish to receive these types of communications, you can turn them off at the device level. To ensure you receive proper notifications, we will need to collect certain information about your device such as operating system and user identification information.

Gift Card

If you choose to use our Gift Card service to give a voucher to a friend to use with our Services, you represent that you have their consent to provide us your friend’s name and email address. We will automatically send your friend a one-time email with the Gift Card information to him or her to make a purchase on our Services if him or her agrees with this Privacy Policy. Unless we are authorised by your friend, we will only use your friend’s name and email address for the purposes of sending this one-time email and maintaining an activity log of our Gift Card program.

Sharing your Personal Data

We do not sell or rent your Personal Data to third parties for marketing purposes unless you have granted us permission to do so.

We share Personal Data within Cookly and its affiliated companies, and with third party service providers for purposes of data processing or storage.

We also share Personal Data with business partners, suppliers, service vendors and/or authorised third-party agents or contractors in order to provide requested services or transactions, including processing orders, processing credit card transactions, hosting websites and providing customer support. We provide these third parties with Personal to complete/utilize the requested service or transaction.

In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Data as set forth in this policy. As required by law, we may respond to subpoenas, court orders, or similar legal process by disclosing your Personal Data and other related information, if necessary. We also may use Personal Data and other related information to establish or exercise our legal rights or defend against legal claims.

We collect and possibly share Personal Data and any other additional information available to us in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Cookly's terms of service, or as otherwise required by law.

While navigating Cookly's website or Services, you may be directed to content or functionality that is hosted by a third-party. When information is collected on behalf of Cookly exclusively, Cookly's Privacy Policy will be referenced and will govern how your information is used. For other, non-Cookly sites , the site/service owner's privacy policy will be referenced. You should review such third party’s privacy and security policies prior to use.

Security of your Personal Data

Cookly is committed to protecting the Personal Data you share with us. We utilize a combination of industry-standard security technologies, procedures, and organizational measures to help protect your Personal Data from unauthorized access, use or disclosure. When we transfer credit card information over the Internet, we protect it using Secure Sockets Layer (SSL) encryption technology.

We recommend you take every precaution in protecting your Personal Data when you are on the Internet. For example, change your passwords often, use a combination of letters and numbers when creating passwords, and make sure you use a secure browser. If you have any questions about the security of your Personal Data, you can contact us at hello@cookly.me.

Linked websites and third party services

Our websites and services may provide links to other third-party websites and services which are outside our control and not covered by this policy. We encourage you to review the privacy policies posted on these (and all) sites you visit or services you use.

Reviews and Photos

If you make a review and submit your photos on Cookly Services, you should be aware that the information you provide there will be made broadly available to others, potentially inside or outside the Cookly Services. Each review should not be considered as reflecting the opinion of Cookly.

Message feature

If you use the message feature of the Services that allows you to message the service vendor, we collect information from you that you provide in connection with such use, to the extent you provide it to us. This information may include Personal Data, if you provide us with Personal Data.

Transfer and Storage of Personal Data

Our Services are hosted in U.S. through our services providers that are certified and comply with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. You can learn more about the Privacy Shield Framework by visiting: https://www.privacyshield.gov/welcome. We may transfer your Personal Data to the U.S., to any Cookly affiliate worldwide, or to third parties acting on our behalf for the purposes of processing or storage. By using any of our Services or providing any Personal Data for any of the purposes stated above, you consent to the transfer and storage of your Personal Data, whether provided by you or obtained through a third party, to the U.S. as set forth herein, including the hosting of such Personal Data on U.S. servers.

Mediavine Programmatic Advertising (Ver 1.1)

The Website works with Mediavine to manage third-party interest-based advertising appearing on the Website. Mediavine serves content and advertisements when you visit the Website, which may use first and third-party cookies. A cookie is a small text file which is sent to your computer or mobile device (referred to in this policy as a “device”) by the web server so that a website can remember some information about your browsing activity on the Website.

First party cookies are created by the website that you are visiting. A third-party cookie is frequently used in behavioral advertising and analytics and is created by a domain other than the website you are visiting. Third-party cookies, tags, pixels, beacons and other similar technologies (collectively, “Tags”) may be placed on the Website to monitor interaction with advertising content and to target and optimize advertising. Each internet browser has functionality so that you can block both first and third-party cookies and clear your browser’s cache. The "help" feature of the menu bar on most browsers will tell you how to stop accepting new cookies, how to receive notification of new cookies, how to disable existing cookies and how to clear your browser’s cache. For more information about cookies and how to disable them, you can consult the information at All About Cookies.

Without cookies you may not be able to take full advantage of the Website content and features. Please note that rejecting cookies does not mean that you will no longer see ads when you visit our Site. In the event you opt-out, you will still see non-personalized advertisements on the Website.

The Website collects the following data using a cookie when serving personalized ads:

• IP Address
• Operating System type
• Operating System version
• Device Type
• Language of the website
• Web browser type
• Email (in hashed form)

Mediavine Partners (companies listed below with whom Mediavine shares data) may also use this data to link to other end user information the partner has independently collected to deliver targeted advertisements. Mediavine Partners may also separately collect data about end users from other sources, such as advertising IDs or pixels, and link that data to data collected from Mediavine publishers in order to provide interest-based advertising across your online experience, including devices, browsers and apps. This data includes usage data, cookie information, device information, information about interactions between users and advertisements and websites, geolocation data, traffic data, and information about a visitor’s referral source to a particular website. Mediavine Partners may also create unique IDs to create audience segments, which are used to provide targeted advertising.

If you would like more information about this practice and to know your choices to opt-in or opt-out of this data collection, please visit National Advertising Initiative opt out page. You may also visit Digital Advertising Alliance website and Network Advertising Initiative website to learn more information about interest-based advertising. You may download the AppChoices app at Digital Advertising Alliance’s AppChoices app to opt out in connection with mobile apps, or use the platform controls on your mobile device to opt out.

For specific information about Mediavine Partners, the data each collects and their data collection and privacy policies, please visit Mediavine Partners.

Contact Us

To address your individual rights or if you have any privacy-related questions or comments related to this privacy policy, please send an email to hello@cookly.me. You can also contact us by writing to this address:

Cookly Pte. Ltd.

Attention: Cookly

160 ROBINSON ROAD, #14-04, SPORE BUSINESS FEDERATION CTR, SINGAPORE (068914)