Last updated: 01 January 2025
1.1. OTT Commerce Solutions Pte. Ltd. (collectively referred to as “OTT” and “we”, “us”, or “our”) only collect and process personal data from you where it is necessary for us to do so or where it is relevant to our dealings with you. This Privacy Policy (the “Policy”) sets out our privacy practices in respect of the collection, processing, use, disclosure, transfer, retention, storage, and disposal of your Personal Data when we provide you with our services (“OTT Services”).
1.2. When you accept this Policy, you agree to the collection, processing, use, disclosure, transfer, retention or storage, and disposal of your Personal Data in the manner described below.
1.3. “Personal Data” shall refer to your personal information as an individual, whether true or not, from which you can be identified, either by itself or together with other information to which we have or are likely to have access. The Personal Data that we collect and process may include - (a) Email address; (b) Cookies and/or statistical/analytical data, such as your browsing behavior, to the extent that you may be identified through these; and (c) Any other personal information that you may provide to us in the course of using the OTT Services.
1.4. This Policy only applies to Personal Data which is in our possession or under our control.
1.5. We collect and process your Personal Data to enable you to redeem the vouchers which you have purchased from the retailer or distributor of the vouchers (the “Distributor”).
1.6 We reserve the right to amend this Policy from time to time without any prior notice to you. Any amendments will be made available and published on this website and will take effect from the date of publication. You may determine if any revision has taken place by referring to the date that this Policy was last updated, set out below. We recommend that you check this Policy periodically to review the latest version. Your continued use of the OTT Services after an amendment constitutes your acknowledgement and acceptance of such changes.
2.1. We collect your Personal Data when you use the OTT Services or communicate with us. In these instances, you may provide your Personal Data to us directly, or it may be shared with us by our affiliates or subsidiaries, or the Publishers, or the Distributors, pursuant to your consent given to these third parties.
2.2. You may also submit Personal Data to us via other methods, including:
(a) in response to our communications;
(b) through participation in an offer, program or promotion conducted by us; or
(c) when you fill in the Partnerships and Marketing enquiry on the website; and/or
2.3 We also collect transaction information, such as purchase amount, date of purchase, information about the vouchers that you are redeeming (“Redemption Data”), in order to pursue our legitimate interests and to abide by our contractual obligation to provide you access to the OTT Services. In most cases, these are not considered as Personal Data since your identity will not be apparent from them. However, to the extent that your identity may be determined from the Redemption Data, they will be considered and processed as Personal Data under this Policy. You agree to our collection of such Redemption Data from you when you use the OTT Services and/or this website.
2.4. You must provide us with information which is accurate and not misleading. In this connection, we reserve the right to request for documentation to verify the information that you provide to us.
3.1. Your data shall be processed by us or our affiliates and subsidiaries for (a) Facilitating the OTT Services; and (b) Permitted uses and disclosures.
3.2. Facilitating the OTT Services
3.2.1. OTT will use your Personal Data and share it with third parties, including our affiliates or subsidiaries, and Publishers, Distributors for the purpose of providing you with the OTT Services, or where it is a necessary part of doing business with you.
3.2.2. In particular, your Personal Data may be processed for the following:
(a) Facilitating your use of the OTT Services;
(b) Resolving any disputes in relation to your transaction;
(c) Mitigating fraud;
(d) Protecting our legitimate interests;
(e) Enforcing our contractual rights; and
(f) Providing you with information which you have requested from us.
3.2.3. Your Personal Data may also be shared for the above purposes between OTT and the Publisher or Distributor from whom you are purchasing content; and
3.3. Other Permitted Uses and Disclosures
3.3.1. You accept that we may also use your Personal Data for the following purposes:
(a) Notifying you of matters relating to your account or your transactions that may require your attention;
(b) Processing service requests, resolving concerns, and responding to queries or feedback that you may communicate to us;
(c) Managing or complying with our internal security or risk management mechanisms;
(d) Conducting statistical analysis or market and customer research, including surveys to ensure customer satisfaction. Please note that we may share your Personal Data with our third party service providers for such purposes;
(e) Improving your experiences with our customer care services; and
(f) Notifying you of material changes to this Policy or to our Terms and Conditions as may be necessary.
3.3.2. You understand and accept that we may also disclose your Personal Data to our affiliates or subsidiaries, Publishers, Distributors, or other parties as permitted or required by applicable law, such as government authorities or regulators, or other necessary persons, inter-alia for the following purposes:
(a) For or in connection with the negotiation of any merger, sale of company stock or assets, financing, acquisition, divestiture, or dissolution of all or a portion of our business; or
(b) If we believe that disclosure is reasonably necessary to (i) comply with any applicable law, regulation, legal process, or governmental request; (ii) assist in any investigations or proceedings; and (ii) protect the security or integrity of the OTT Services, us, or any of our users or the public from harm or illegal activities.
4.1. You have the right to have your Personal Data removed or withdraw consent to its processing, where we or our affiliates and subsidiaries are processing your Personal Data solely on the basis of your consent. If you wish to have your Personal Data removed, or do not wish to have your Personal Data used or processed for the purposes above, please contact us. However, please note that if your Personal Data is removed or you withdraw your consent for any of the purposes stated above, depending on the nature of your request, we may not be in a position to continue providing the OTT Services to you, or process and complete the transactions you wish to make on this website.
4.2. You have the right to access, update, or request correction of the Personal Data that you have provided to us at any time. If you would like to access the Personal Data that we have on file about you or request that we update or correct your Personal Data, you may contact us.
Your Personal Data will be retained for as long as is necessary to fulfil or complete the purpose for which it was collected and until it is no longer necessary for any other legal or business purposes. Thereafter, we or our affiliates and subsidiaries dispose of your Personal Data in a manner that prevents further access or processing, including but not limited to deletion or irreversible anonymization.
OTT makes reasonable efforts to safeguard your Personal Data, in order to protect against loss, misuse, modification, unauthorised or accidental access or disclosure, alteration, or destruction. Unfortunately, no data transmission or storage over the Internet can be guaranteed as totally secure. Nonetheless, we have adopted and currently practice administrative, organizational, technical, and physical security measures to protect your Personal Data to the best of our reasonable capacity, including but not limited to the following:
(a) Limiting Personal Data access to authorized and/or necessary personnel;
(b) Implementing technical solutions to ensure information security;
(c) Continuous monitoring and review of Personal Data protection measures; and
(d) Other security measures, as may be required by the laws and regulations applicable in the country where you are located.
7.1.1. OTT operates internationally. You therefore accept and understand that we may store your data in different countries depending on applicable data localisation regulations, or share your Personal Data with recipients (such as the Publishers, Distributors or OTT affiliates/subsidiaries) who are located in countries other than the country in which your Personal Data was originally collected, in order to provide the OTT Services to you, process and complete the transactions you wish to make on this website, or for any other purposes set out in this Policy.
7.1.2. In such circumstances, we take steps to ensure that overseas recipients shall provide a standard of protection to the Personal Data transferred that is comparable to the protection under the local data protection laws applicable in your jurisdiction.
8.1. We collect, and also allow third parties (including but not limited to Amazon Web Services, Facebook, and Google) to collect statistical information relating to your website use and online activities as you interact with us, using “cookies” and similar technologies. Such statistical information is anonymous in nature and does not identify who you are. They include page visits, access times and dates, and browser type. This information is collected for analysis and evaluation to help us improve this website and the OTT Services.
8.2. “Cookies” are a feature on your Internet browser which store small amounts of data on your computer when you visit a website. They allow us to recognise a particular device or browser so that we can personalise and curate content to your preferences and make our services and Platform more useful to you. “Cookies” do not tell us who you are unless you specifically give us personally identifiable information. You may be able to manage and delete “cookies” by selecting certain options on your browser.
9.1. The OTT Services are not directed to persons under the age of majority in your country (a “minor”). If you are a minor, you may use the OTT Services and/or this website only with the consent, permission, and supervision of your parent or guardian, subject to the specific age restrictions on digital content that may be imposed by the government in your country.
9.2. If you are a parent or guardian supervising a minor who wishes to use the OTT Services, and you accept this Policy and on their behalf, you consent to the processing of their Personal Data in accordance with this Policy.
This website may contain links to other websites which are not maintained by us. Therefore, when visiting these third-party websites, you should read their respective privacy policies, which will apply to your use of their websites. We are not responsible for the content, use, or privacy practices of these websites.
11.1. To contact us on any aspect of this Policy or your Personal Data, including but not limited to withdrawing consent, opting out of receiving gifts and prizes, opting out of receiving marketing and promotional communications, requesting access to your Personal Data, requesting an update or correction to your Personal Data, or exercising any of your rights under this Policy or applicable data protection laws, you may contact our Data Protection Officer at dpo@ottcommerce.com.