1. Introduction

Sustainability is our thing! It is extremely important to us that you not only have a pleasant experience sharing on our platform, but also that you feel comfortable and safe while doing so.

This Privacy Policy supplements our Terms of Service and explains how ShareLeh, handle information collected and received in the course of your use of our websites, mobile application and services (collectively, the “Services”). It also governs the collection, use and disclosure of your information. 

2. Information we collect and receive

We may collect and receive information from you in the following situations:

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• When you register for an account with us (“Account”).

• When you choose to connect your Account with an external third party service or application, such as Facebook.

• When you use the features and functions available on our Services, for example, by creating listings, interacting with other users through our chat feature, or transacting with other users.

• If you contact us, for example, with a query or to report a problem.

• When you register for a survey, campaign, contest and/or lucky draw with us.

• When you interact with us offline or through an external third party.

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You are under no obligation to provide the information to us. However, if you choose to withhold the information or to revoke permission for us to receive the information, we may be unable to provide certain aspects of our Services to you.

By providing us with any information relating to a third party (e.g. information of your spouse, children, parents, and/or employees), you represent to us that you have validly obtained the consent of the third party to provide us with their information for the respective purposes.

We may collect and receive the following information. Please note that not all of our Services collect all of the information listed below:

• Account credentials such as username.

• Profile information such as, name, gender, email address, profile photo, mobile number, date of birth, address.

• Location information such as last known location, meet-up location.

• Any other information disclosed by you in any of the above-mentioned methods and/or through the use our Services.

• Aggregate data collected through the use of our Services.

• Any communications between you and another user of our Services.

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3. Your interactions with others

Our Services offer features which allow users to connect and communicate in groups which are public or semi-public, and to share information with each other to complete a transaction. Please use common sense and exercise good judgement when sharing information in these groups or with others. We generally do not monitor or remove the information which you share and such information may remain available on our Services after your Account has been deactivated, terminated or is otherwise closed. You are responsible for the information you choose to share in these groups or with other users.

4. Why we collect the information and how we use it

We may use the information collected and received from you for the following purposes:

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• To verify your identity, update our records and generally maintain your Account with us.

• Provide our Services and customise the content shown to you.

• Develop, operate, improve, deliver and maintain our Services.

• To process transactions.

• To process or arrange payment and/or shipping services.

• To process or resolve any dispute arising from or in connection with any transactions, in accordance with our Terms of Service.

• To detect or monitor any frauds or other prohibited content, businesses or activities.   

• Responding to your queries and resolving complaints.

• To facilitate, confirm and/or provide updates or notifications in relation to any transactions.

• Carry out polls, surveys, analysis and research on how our Services are being used and how we can improve them.

• To update you on your listings and our Services (e.g. new offers, new chats, new feedback, new comments). These updates will be sent by email and/or through push notifications and you can choose to unsubscribe from these updates at any time through the “Settings” page of your Account.

• To send you marketing and/or promotional materials on the latest products and services of ShareLeh or carefully selected third parties. These updates will be sent by email and/or through push notifications and you can choose to unsubscribe from these marketing communications via the link in the email you have received and/or through the “Settings” page of your Account. These marketing communications may also be communicated to you through text messages and/or voice calls if you have indicated that you wish to receive such updates through these methods. For more information on anonymous advertising, including to understand what opting-out means and your opt out choices, please see the Section 5 below.

• To send you service-related messages including, without limitation, a welcome/confirmation email when you register your Account and to enforce our Terms of Service and other policies. These messages are not promotional in nature. These messages will be sent by email and/or through push notifications and you may not opt-out of receiving service-related messages from ShareLeh, unless you deactivate your account. 

• Perform functions or services as otherwise notified to you at the time of collection such as to publish and/or use for our marketing purposes, your feedbacks and stories.

• To provide you a more tailored online advertising experience. ShareLeh has in place, tools and services are used to create advertisements, to deliver advertisements to devices on behalf of advertisers, to monitor the success of

• and manage advertising campaigns, and to present you with advertisements that are more likely to be interesting and relevant to you. Delivering relevant ads that are tailored to users’ interests is known as “interest based

• advertising” (sometimes also referred to as “behavioural advertising”). For more information on interest-based advertising, including to understand what opting-out means and your opt out choices for your devices, including

• computer browsers and mobile browsers and devices, please see the Section 10 “Shareleh Opt-Out” below.

• If you are a member of our survey panel, your information may also be used to manage your panel membership; send you service-related messages, new survey opportunities and, updates on your rewards and incentives. These updates will be sent by email and/or through push notifications and you can choose to unsubscribe from these updates through the relevant email and/or “Settings” page of your Account. These updates may also be communicated to you through text messages and/or voice calls if you have indicated that you wish to receive such updates through these methods.

• To provide and carry out cross-application and cross-device advertising (i.e. advertising across browsers and applications on a single device, as well as cross-device advertising), advertising delivery and reporting. Information include information described above and data and collected from a particular computer, browser or device and may be used with another computer, browser or device that is linked to the computer, browser or device on which such data was collected.

• To to generate a "Lookalike audience" or "similar audience" of prospective users through the Facebook or Google advertising platforms and/or similar service providers. This allows us to deliver targeted advertisements on their networks to potential users, where such potential users may have shared interests or similar demographics to our existing users, based on the data of these advertising platforms. We typically do this by uploading a list of email addresses in a secured manner. Facebook's policy is to irreversibly hash (encrypt) such lists locally and prior to uploading. Facebook will then match the hashed data against their own user and generate the lookalike audience. The uploaded list will then be deleted and will note be used for any other purposes. ShareLeh will not have access to the identity of any user in the lookalike audience, unless such individual chooses to click on the advertisements we deliver.  If you wish to opt out of "similar audiences" in Google, you can do so through your Google Ads Settings. 

• To comply with applicable Anti-Money Laundering and Countering the Financing of Terrorism regulations and other applicable laws and regulations.

5. Who we share your information with

We may share information about you in the following ways:

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• When you register for an Account, the information which you make available on your profile may be viewed by other users of our Services. Other users of our Services would also be able to view the content which you upload and share on our Services.

• We may share the information with our affiliates and with third party service providers who assist us in performing certain aspects of our Services on our behalf, such as processing transactions, payment or shipping services, fulfilling requests for information, receiving and sending communications, updating marketing lists, analysing data, providing support services or in other tasks. Such service providers will only have access to your personal information to the extent necessary to perform their functions.

• We may share the information with our potential partners, investors and other parties with a view to a potential business partnership, collaboration, joint venture or otherwise in furtherance of our business.

• We may share any information collected in accordance with this Privacy Policy with: (i) governmental and other regulatory authorities or the courts in any jurisdiction; or (ii) any third party claimants or potential third party claimants; or in connection with a transaction using our Services in accordance with our Terms of Service.

• In addition to other information described in this Privacy Policy, we may collect and share with third party data management platforms or advertising and analytics partners precise location information. This location information may be used by itself, aggregated, or combined with mobile identifiers (such as IDFAs and Android IDs), and shared with third parties for purposes related to advertising, analytics, attribution (e.g., measuring ad performance), analytics and market research. We have included the links to their privacy policies below.

• We may disclose your personal information if required to do so by law or if we believe that such action is necessary to prevent fraud or crime or to protect our Services or the rights, property or personal safety of any person.

The third party data management platforms or advertising and analytics partners we work with are:

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• Facebook

• Instagram

• SingPost

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Other third party service providers we work with includes:

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• First Mobi Solutions

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You may click on the names of these third parties to access their privacy policies. We respect your privacy and we will not sell your personal information to any third party. We may disclose data and aggregate statistics about users of our Services and sales to prospective partners , advertisers, sponsors and other reputable third parties in order to describe our Services, deliver targeted advertisements or for other lawful purposes but these data and statistics will not include information which can be used to identify you. From the "Settings" page of your Account, you may opt out of us sharing to anonymous information listed above.

6. Transfer of information

By using our Services, you authorise us to use your information in Singapore. We will ensure that your information is transferred in accordance with this Privacy Policy and protected in accordance with applicable laws on personal
data protection (including, but not limited to, the Personal Data Protection Act 2012 of Singapore). If you are a user located in Australia, the following information will apply to you:

  (a)  your information will no longer be governed by Australian law;
  (b)  you will not be able to seek redress under Australian law; and
  (c)  foreign laws will govern the handling of information collected and received in the course of your use of our            Services and also governs the collection, use and disclosure of your information.

7. Protecting your information

The security of your information is important to us. We have security measures in place to protect against the loss, misuse and alteration of information under our control.  We also follow generally accepted industry standards to protect the information transmitted to us over the Internet, both during transmission and once we receive it. Sensitive information (such as credit card numbers) are encrypted using secure socket layer technology
(SSL). However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security.

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It is important that you protect against unauthorised access of your Account and information by choosing your password carefully, and keeping your password and Account secure (e.g. by signing out after using our Services).

8. Accessing and updating your information

You may access and update your information within our Services through the “Settings” page of your Account.
Where you provide personal information about yourself to us, you are responsible for providing accurate, not misleading, complete and up-to-date information about yourself and any other person whose personal information you provide us, and to update this personal information as and when it becomes inaccurate, misleading, incomplete or out-of-date.

In certain circumstances, you may need to provide to us personal information about someone other than yourself. If so, we rely on you to inform these individuals that you are providing their personal information to ShareLeh to make sure they consent to you giving us their information and to advise them about where they can find a copy of this Privacy Policy. If you wish to:

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• apply for a copy of the information we hold about you; or 

• withdraw consent you previously provided to us to use, collect or disclose the information we hold about        you, please contact our Personal Data Protection Officer at the contact details set out in Section 13 below. Please allow us a reasonable period of time to respond to any request and effect any change. We may ask to verify your identity and for more information about your request. Where we are legally permitted to do so, we may refuse your request and may give you reasons for doing so. Where you have requested for a copy of the information we hold about you, we may charge a reasonable administrative fee to cover the costs of responding to your request. If we decide to do so, we will provide you with a written estimate of such fee beforehand.

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9. Tracking technologies

We use tracking technologies on our Services. These enable us to understand how you use our Services which, in turn, helps us to provide and improve our Services. However, the tracking technologies do not access, receive or collect information which can be used to identify you. We have listed below some examples of the tracking technologies used on our Services:

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• Cookies. A cookie is a small data file sent from a website to your browser that is stored on your device. Cookies are used for a number of purposes, including to display the most appropriate content based on your interests and activity on our Services, estimate and report our Services total audience size and traffic, and conduct research to improve our Services. You can configure your device's settings to reflect your preference to accept or reject cookies. If you reject all cookies, you will not be able to take full advantage of our Services.

• Pixels. We may from time to time use certain Facebook Business Tools such as the Facebook Pixel. This tool allows ShareLeh to keep track of what users do after they see or click on a Facebook advertisement and enables us to monitor the effectiveness of Facebook ads for purposes of statistics and market research. ShareLeh will be able to better understand and deliver ads and make them more relevant to you. The collected data remains anonymous and ShareLeh cannot see the personal data of any individual user. However, the collected data is saved and processed by Facebook. Facebook may be able to connect the data with your Facebook account and use the data for their own advertising purposes and in accordance with Facebook’s Data Use Policy. Facebook has ultimate control of the information gathered through the Facebook Business Tools and communications. You can opt-out of Facebook’s use of cookies and Facebook Pixel through settings on your Facebook Account or withdraw your consent here. Data collected in this way is anonymous to us, which means we cannot see the personal data of individual users. However, this data is saved and processed by Facebook. Facebook can connect this data with your Facebook account and use it for its own advertising purposes, in accordance with Facebook’s Data Policy which can be found at https://www.facebook.com/about/privacy/. You can allow Facebook and its partners to place ads on and outside of Facebook. A cookie can also be saved on your device for these purposes. Please click here if you would like to withdraw your consent.

• Flash cookies. We use Flash cookies (a.k.a local shared objects or LSOs) to store some of your viewing preferences on our Services. These are used to collect and store information, but differ from browser cookies in the amount, type and manner in which data is stored.

10. ShareLeh Opt-Out

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We may deliver personalised and/or targeted advertisements (each, a “Targeted Ad”) to you in the course of your use of our Services and/or though a variety of advertising networks and exchanges. From the “Settings” page of your Account, you may opt out of behavioural tracking and/or interest-based advertising through our Platforms. Your changes to such opt-out setting may take 24 hours to become effective. Please note that if you choose to “opt out”, we will not use information we have collected about you to deliver Targeted Ads, but it does not opt you out of seeing advertisements. You will still see generic, non-targeted advertisements which are served without the use of any information we have collected about you. You may still be served advertisements for other reasons, such as:

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• General advertisements served to all users of our Platforms. 

• Personalised and/or targeted advertisements from other third parties and not delivered by ShareLeh through your mobile and/or web activities. Please also note that even though ShareLeh does not share your personal data (other than hashed or device identifiers, to the extent they are personal data in some countries) with any advertising networks and exchanges without your consent or unless as specified in this Privacy Policy, when you view or interact with an advertisement via any of your devices, an advertiser or advertising network or exchanges can infer that you are within their target audience; or when you click on an advertisement, the publisher and/or advertiser will know you visited the page that you clicked on and may still be able to associate personal data collected by such third parties directly from you through their cookies and similar tracking technologies.

11. Changes to this Privacy Policy

We reserve the right to make changes to this Privacy Policy at any time and all changes will be posted here. If we believe that the changes are material, we will notify you of the changes by posting a notice on our Services or by
email. You are responsible for reviewing the changes which we make this Privacy Policy. Your continued use of our Services constitutes your acceptance of the updated Privacy Policy.

12. Third party sites and resources

Our Services may, from time to time, contain links to external sites or resources which are operated by third parties. We have no control over the content and privacy practices of such sites or resources. You are advised to
review the privacy policies of these sites and resources operated by third parties and understand how your information may be used by those third parties.

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13. Contact us

If you have any questions, complaints, concerns or comments on our Privacy Policy, we welcome you to contact us by sending an email to customerservice@share-leh.com. Your indication at the subject header would assist us in attending to your email speedily by passing it on to the relevant staff in our organisation. For example, you could insert the subject header as "Accessing Personal Data". ShareLeh does not: (a) offer goods or services to, or monitor the behaviour of, European Union data subjects; and (b) process and/or hold the personal data of data subjects residing in the European Union.