This Privacy Policy ("Privacy Policy") sets forth how GNAMEHK LIMITED.com Pte. Ltd. and its affiliates (“GNAMEHK LIMITED”, “us,” “our,” “we”) collect, use, transfer, retain, secure, process, and disclose your Personal Data and/or Personal Data of your customers or end users through your use of the Website and/or the Services (as defined in our Membership Agreement accessible at <https://www.xy22.net/terms/membership-agreement> (“Agreement”)).
By accessing or using the Website and/or Services, you acknowledge that you have read, understood, and agreed to the terms of this Privacy Policy and the collection, use, disclosure and/or Processing of your personal data by us as described in this Privacy Policy. If you do not agree to be bound by this Privacy Policy, you must not access or use the Website and/or Services.
The terms of this Privacy Policy may be revised from time to time by us. We will use commercially reasonable methods to notify you of such revisions, such as by posting a revised version of this Privacy Policy on the Website, sending you letters on platform or by notifying you of the revision via email if you have provided your email address to us. Your continued access to or use of the Website and/or the Services after such notice had been given and such revised Privacy Policy had come into effect shall constitute your acceptance of the revised Privacy Policy.
1.Definitions
1.1 In this Privacy Policy, the following words and expressions shall have the meanings respectively assigned to them hereunder:
“Data Protection Laws” means all applicable laws and regulations in any jurisdiction which relate to the collection, disclosure, use and/or Processing of Personal Data, including without limitation to the PDPA, including all amendments thereto and subsidiary legislation enacted thereunder, whether now or in the future.
“PDPA” means the Personal Data Protection Act 2012 of Singapore, including all amendments thereto and subsidiary legislation enacted thereunder, whether now or in the future.
"Personal Data" means data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which a party has or is likely to have access.
“Process,” in relation to Personal Data, means the carrying out of any operation or set of operations in relation to the Personal Data, including without limitation to recording, holding, organising, adapting, altering, modifying, retrieving, combining, transmitting, erasing, or destroying, and “Processing” shall be construed accordingly.
1.2 Any capitalised term not defined herein shall have the meaning ascribed to them in the Agreement.
2. Personal Data we collect about you
2.1 We may collect and retain the following Personal Data about you when you access or use the Website and/or Services, purchase any of the Services, or when you register for an Account:
(a) Account registration information. This is the Personal Data that is provided by you or collected by us to enable you to create, log into, and access your Account, and to access or use the Website and Services. We may also use such Personal Data to verify your identity or contact you. This includes your name, email address, phone number, address, date of birth, government identification or other data that could directly or indirectly identify you.
(b) Services usage information. This can be Personal Data and other information that is collected about you when you are using the Website and/or Services, and this may include:
(i) Information about your interactions with the Website and/or Services, which includes the date and time of any information you enter the Website and/or use the Services.
(ii) Your contact details provided to our customer support team and your interactions with them.
(iii) Technical data, which may include URL information, cookie data, web beacons and other tracking technology information, your IP address, the types of devices you are using to access or connect to our Website, unique device IDs, device attributes, network connection type (e.g., Wi-Fi, 3G, LTE, Bluetooth) and provider, network and device performance, browser type, language, and operating system.
(iv) Your contact details and responses provided to us when you participate in any contests or surveys through the Website and/or Services.
(c) Payment related information. We may collect payment-related information from you to enable you to make purchases on the Website. Such payment information includes your payment instrument organisation and other information related to your payment instrument, such as your payment instrument number, security code and expiration date of your payment instrument. For more information about collection of your payment information, you may go to our Payment Service Providers’ and Processors’ website to review their privacy policies.
2.2 We may from time to time collect your Personal Data from you and other third parties to implement our risk control, fraud prevention and compliance procedures. For example, we may collect your payment information from third parties and combine it with information we collect about you for the purpose of fraud prevention and risk control.
2.3 We use cookies and other similar technologies on our Website. A cookie is a text file for the Website to track your browsing behaviour, links clicked, Services purchased, your device type, and to collect various data, including analytics, about how you use and interact with our Website and Services. We may gather your Personal Data such as the date and time of your access and/or use, your operating system, your navigation history, and your IP address. We use this information for our internal security audit logs, trend analysis, and system administration, and to gather broad demographic information about you. We may also associate this general information with your other Personal Data .
3. How We May Use Your Personal Data
3.1 We may collect, use, disclose and/or Process your Personal Data for any or all of the following purposes:
To process your registration for an Account.
To provide you with access to the Website and/or Services.
To communicate with you and provide the Services to you and/or your end users.
To perform obligations in the course of or in connection with our provision of our Services requested by you.
To process your payments or purchases on the Website.
To respond to, handle and process your queries, feedback, requests, applications and complaints.
To process, administer, or manage your Account, to verify your identity and to assess your suitability and/or eligibility for our Services.
To perform research, statistical analysis, and development activities (including but not limited to data analytics, surveys and/or profiling) in order to identify any security risks, errors, fraudulent activities and to improve our Website and Services.
To manage your relationship with us.
To contact you in order to provide you with information or services where required by law or that you request from us;
To analyse and utilise Personal Data in order to present content and information on the Website in the most suitable manner for users and the equipment and devices from which users view the Website.
To personalise or customise the content and services that we provide to you, including providing you with location-based or traffic-based services;
To store, host and/or back up Personal Data for disaster recovery purposes, whether in Singapore or other jurisdictions.
To respond to any legal processes, pursue legal rights and remedies, and manage any complaints or claims, whether in Singapore or other jurisdictions.
To respond to requests (whether to us directly or through our affiliates or thirty party service providers) for information from competent courts, public and governmental/regulatory authorities, statutory boards, and/or related companies, whether in Singapore or other jurisdictions.
To comply with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement or investigations conducted by any governmental and/or regulatory authority, whether in Singapore or other jurisdictions.
To transmit to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or other jurisdictions, for the aforementioned purposes.
To achieve any other incidental business purposes related to or in connection with the above.
3.2 With your consent (or where otherwise permitted by applicable law in your jurisdiction), We may use your name, phone number, address, email address and fax number (which may incorporate personal data) to provide notices, surveys, product alerts, related communications and other marketing and promotional materials to you relating to Services offered by us.
3.3 If you access and/or use the Website and/or Services from a country other than the country where our servers are located, your Personal Data may be transferred across international borders.
3.4 You acknowledge and agree that Personal Data provided to us by you may be disclosed and/or transferred to the following third parties, and used or Processed by such third parties, whether within or outside Singapore, for the purposes set out above or otherwise permitted/ required by law.
(a) Our Affiliates. We may share your Personal Data with our affiliates to enable us to provide you with the Services.
(b) Service Providers. We use third party service providers to operate and maintain the Website, store our data, and otherwise provide the Services. We may share your Personal Data with our service providers to provide you with access to and use of the Website and/or Services. Examples of such service providers include financial institutions, credit card companies, payment processors, technical support services providers, customer relationship management service providers, SMS delivery service providers, collections agencies, UDRP dispute providers, Whois data escrow providers, ICANN and the relevant domain name registrars/registries.
(c) Governmental and regulatory authorities. We may share your personal information with third parties, including law enforcement agencies and governmental or regulatory authorities, whether in Singapore or abroad, where required by applicable laws (including to respond to valid legal process such as a search warrant or a court order), where it is necessary in connection with the Website and/or Services or where we have another legitimate interest in doing so.
(d) Buyer or successor of our business. We may share your Personal Data with any buyer or successor in the event of a merger, reorganisation, dissolution, or other sale or transfer of title.
(e) Our advisors, including auditors and lawyers. We may share your Personal Data with or disclose your Personal Data to our advisors in the course of seeking professional advice.
3.5 We may continue to use and disclose your personal data for the purposes as set out above, notwithstanding any termination of your relationship with us or withdrawal of your consent, to the extent required or permitted by applicable laws.
4. How We Secure Your Personal Data
We will take appropriate administrative, physical, and technical measures to safeguard your Personal Data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, and the loss of any storage medium or device on which Personal Data is stored.
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 Personal Data, and are constantly reviewing and enhancing our security measures.
5. Your rights and options regarding your Personal Data
5.1 Withdrawing Consent
You may withdraw your consent and request us to stop collecting, using, disclosing and/or Processing your Personal Data for any or all of the purposes listed above by submitting your request via submitting the worksheet on our Website.
Upon receipt of your written request to withdraw your consent, we may require a reasonable period of time to process and respond to your request.
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 access to the Website and/or our Services to you. For example, you are supposed to cancel all your service provided by GNAMEHK LIMITED, including transfer the domain names, otherwise we will take necessary steps to delete such domains. We will, in such circumstances, notify you before completing the processing of your request.
Please note that withdrawing consent does not affect our right to continue to collect, use, disclose or Process your Personal Data where such collection, use, disclosure, and Processing without consent is permitted or required under applicable laws.
5.2 Accessing and Correcting your Personal Data
If you wish to make
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 had used or disclosed your Personal Data in the one (1) year prior to the date of your request, or
a correction request to correct or update any of your Personal Data which we hold about you,
you may contact the online costumer service for detailed instruction.
Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) 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 applicable laws).
5.3 Accuracy of Personal Data
Where you submit Personal Data through the Portal, you should ensure such Personal Data is accurate and true. You should also review your Personal Data from time to time and let us know if there are changes or updates to your Personal Data so that we do not hold any inaccurate Personal Data about you.
You can update your Personal Data at any time by contacting our online customer service and get detailed instruction.
6. Third Party Links and Collection of Personal Data by Third Parties
The Website may from time to time, contain links to other websites, such as our affiliates, advertisers, or other third parties (collectively, “Third Party Websites”). Certain functions and features on our Website (such as the payment function) and Services may be provided by third parties (such as payment service providers) (such functions and features being “Third Party Services”). Third Party Websites and Third Party Services are operated by third parties (“Third Party Service Providers”). When you access or use such Third Party Services, or when you click on the link to Third Party Websites, your Personal Data may be collected directly by such Third Party Service Providers.
As these Third Party Websites and Third Party Services are not owned or operated by us, we do not assume any responsibility or liability for such Third Party Websites and Third Party Service, or the collection of your Personal Data by such Third Party Service Providers. Your access to such Third Party Websites and Third Party Services, and provision of Personal Data to these Third Party Service Providers are entirely at your own risk. Please check the privacy policies that apply to such Third Party Websites and Third Party Services carefully before you provide any Personal Data to such Third Party Service Providers.
By accessing or using Third Party Websites and/or Third Party Services, or providing your Personal Data to Third Party Service Providers, you acknowledge and agree that:
you have read and understood such Third Party Service Providers’ privacy policies, and consent to the collection, use, disclosure and/or Processing of your Personal Data by such Third Party Service Providers pursuant to their privacy policies;
we do not control such Third Party Service Providers, and the manner in which and purposes for which your Personal Data may be collected, used, disclosed and/or Processed is determined solely by such Third Party Service Providers as data controllers (as defined under applicable Data Protection Laws); and
to the maximum extent permissible by law, we shall not be liable for any liabilities, losses or damages that may be incurred by you as a result of your use of any Third Party Websites and/or Third Party Services, or the collection, use, disclosure and/or Processing of your Personal Data by any Third Party Service Providers.
7. Age Restrictions & Children
You must be at least twenty-one (21) years old to register an Account or to purchase or otherwise use our Services. If you are under twenty-one (21), you may use our Services only with consent or under the supervision of a parent or guardian. GNAMEHK LIMITED does not knowingly collect information from children who are younger than the age required by applicable law. If you know of or have reason to believe that anyone under the age of 21 has provided us with any personal data, please contact us via our online Customer Service.
8. How long 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. Contact Us
If you want to contact us with specific queries or concerns in relation to this Privacy Policy, or if you have any questions or complaints as to how your Personal Data is collected, used, disclosed and/or Processed by us, please contact us at legal@GNAMEHK LIMITED.com.
