Privacy Policy

1. Introduction

Kaddra Pte. Ltd. with a place of business at 8 Cross Street, Manulife Tower, #18-01, Singapore 048424 ("we", "us", "our") are committed to protecting and respecting the privacy of our members and other users of our Services. In order to provide the best possible service and experience, we will collect, use and disclose personal data about you, and this privacy notice ("Notice") explains how and why we do so when you use the website www.kaddra.com ("Website"), the Kaddra app ("App") or any of the services we offer accessible through the Website or App or otherwise (collectively referred to as "Services"). Please read this Notice carefully so you are aware of our practices regarding your personal data, before becoming a member or using any of our Services.

2. What personal data do we collect and process about you?

Our business ambition is to provide our members with an efficient, tailored and unique experience. When using our Services we collect and process the following personal data (including, where applicable, sensitive personal data) about you. Information is either collected directly from you or is automatically collected through your use of the Services:

We may receive information about you from other sources such as:

Any information we collect may be combined with other information we collect from you.

If you provide us with information about other people (such as family members, friends and your chosen supplementary members), you confirm that you have their consent to provide us with that information.

We use third party analytics tools, log files and other methods, and cookies on our Website and App when you sign up to become a member via our Website or App or you otherwise use our Website or App, to collect usage and activity information and to distinguish you from other users of our Services and for other purposes, including (with your consent, where required by applicable law) marketing purposes. Cookies are small text files containing small amounts of information which are downloaded and may be stored on any of your internet enabled devices. We will process cookies in accordance with our separate Kaddra cookie and identifier policy which contains details of the types of cookies collected and the purpose for which we use them.

In order to use our Services, you must provide us with the information requested on the member registration pages (except those preferences marked as voluntary), otherwise we will not be able to process your membership application or provide the full range of functionality of our Services. You are able to set and disable certain in-App permissions via your device settings. Our App does not recognise browser or device-level do-not-track requests.

3. How will your personal data be used?

Your personal data will be used by us in connection with the following purposes:

For the performance of our agreement with you:

For our legitimate commercial interests, in order:

For use of information based on your consent, so that we can:

To comply with legal obligations to which we are subject:

If, at any time, you prefer not to receive direct marketing communications from us in any form, you will have the ability to unsubscribe from such communications by selecting a link at the bottom of every communication that is sent to you by us. Alternatively you may also update your settings within your Membership Profile at any time, or you may contact us and we will deal with your request promptly.

4. Automated profiling

In order to ensure the content displayed through our Services is specifically customised for you, we will carry out profiling using automated processing to evaluate, analyse and predict your preferences, personality type and interests. We will use personal data collected from you directly, or through the use of the Services to complete automated profiling in order to communicate and highlight the types of Services which may be of interest to you, relative to your previous choices and current location. Automated profiling is a critical feature of the Services, and is necessary in order for us to deliver the Services to you and provide you with tailored Services.

5. Who will have access to your personal data?

In order to provide you with a seamless experience, we will share your personal data with the following persons:

The Website may contain links to and from the websites of our partners and other affiliated and third parties. If you access other sites using the links provided, please be aware they may have their own privacy policy, and we do not accept any responsibility or liability for these policies or for any personal data which may be collected through these websites. Please check those policies before you submit any personal data to these websites. your request promptly.

6. Your California privacy rights

California residents may request a list of certain third parties to which we have disclosed personally identifiable information about you for their own direct marketing purposes. You may make one request per calendar year. In your request, please attest to the fact that you are a California resident and provide a current California address for your response. You may request this information in writing by contacting our Data Protection Officer. Please allow up to thirty (30) days for a response.

7. Where will we store your personal data?

The data we collect from you will be transferred to, and stored at, locations in and outside of Singapore, and so may be transferred to and stored outside of, your country of residence. It will also be processed by our personnel and the employees of our partners, clients and third party service providers, who operate outside of Singapore. These persons may also be engaged in order to provide the Services to you, including fulfilling requests, confirming reservations or processing your payment details. Your personal data will only be transferred to locations outside of Singapore where we are satisfied that adequate levels of protection equivalent to those in Singapore are in place to protect any personal data held in that location.

8. How do we keep your personal data secure?

We take your data security very seriously.

For users outside the US: we have reasonable technical and organisational security measures in place and invest appropriate resources to protect your personal data from deliberate or accidental manipulation, destruction, loss, misuse, unauthorised access, disclosure, copying and modification. We take reasonable steps to ensure that our systems, and those of our affiliates, partners, clients and third party service providers, are appropriately secure for processing your personal data, and that the risks of your personal data being unlawfully used, amended, deleted, lost or stolen are minimised. We ensure that we have in place appropriate contractual agreements with third parties to ensure adequate safeguards are in place, and that such third parties will act at all times in compliance with applicable personal data protection laws.

For users in the US: we have implemented security measures to protect your personal data from deliberate or accidental manipulation, destruction, loss, misuse, unauthorized access, disclosure, copying and modification.

9. For how long do we keep your personal data?

We take steps to periodically review the information we collect, and we will destroy or anonymise any personal data if it is no longer needed for the purposes for which it was collected (as set out in this Notice) or otherwise after you cease to be member or cease using your account, or longer if required for any other legal purposes.

10. Changes to this notice

We may amend this Notice from time to time. Thereafter every time you use our Services, please read and check this Notice to ensure you are aware of the conditions which apply at that time. In case we make significant changes to this Notice, we will inform you thereof.

11. Your rights, further information and to contact us

You may have the right under applicable data privacy laws to request access to personal data we hold about you and information about how we have used that data (including, where applicable under applicable laws, the legal basis); to correct any errors or omissions in your personal data; to rectification; to erasure; to object against profiling; and to data portability.

You may also have the right under applicable data privacy laws to withdraw your consent to receiving direct marketing communications, or more generally to our processing of your personal data, at any time; however, you may be unable to access some of the features of our Services if you entirely withdraw your consent to the terms of this Notice. Due to the nature of the App, you will be unable to access any of the features of the App if you entirely withdraw your consent to the terms of this Notice.

To make these requests, or if you have any questions or complaints about how we handle your personal data , or would like us to update the data we maintain about you and your preferences, please contact our Data Protection Officer by emailing DPO@kaddra.com or writing to our address set out above (or (if in Hong Kong) to 15/F, The Pemberton, 22-26 Bonham Strand, Sheung Wan, Hong Kong).

For users in the EU: please contact our Data Protection Officer by emailing DPO@kaddra.com for details of our EU representative for GDPR purposes.