TycheGo Privacy Policy

1.1 This is the privacy policy for the TycheGo application and website (collectively referred to as our "Platform"), operated by LEAL PTE.LTD. (referred to as "we" or "Tyche Go"), a company registered in Singapore with its registered office at 111 SOMERSET ROAD #09-06.

1.2 If you have any questions or requests regarding this privacy policy or how we handle your data, please contact our general customer service team at: services@tychego.com.

1.3 Please read the following carefully to understand our views and practices regarding your personal data and how we handle it.

1.4 By using our services, you acknowledge that you have read and understood this policy.

2.1 As part of our commitment to customer and platform visitor privacy, we want to clarify the types of information we will collect from you.

2.2 We collect your personal information when you interact with us or use our services, such as when you place an order on our platform. We also gather insights on how visitors use our platform to help us improve services and optimize the customer experience. We collect information:

• (a) When you create an account with us or change your account settings;
• (b) When you place an order with us and during the ordering process.
• (c) When you contact us directly via email, phone, mail, messaging, or through our chat feature;
• (d) When you browse and use our platform (before and after creating your account).

2.3 Information We Collect from You

• (a) When you access the platform or place an order, you will be asked to provide information about yourself, including your name, contact details, address, order details, and payment information, such as credit or debit card details, as well as any further information you provide at the time of ordering.
• (b) We also collect information about you from any messages you post on the platform or when you contact us or provide feedback, including via email, letters, phone, or chat. If you contact us by phone, we may record the call content for training and service improvement purposes, as well as any information related to your call.

2.4 Information We Collect Automatically

• (a) We collect technical information from your mobile device or computer, such as its operating system, device and connection types, and the IP address you use to access our platform.
• (b) We also gather technical information regarding your usage of our platform via mobile devices, such as carrier, location data, and performance data (e.g., mobile payment methods), and interactions with other retail technologies (e.g., using NFC tags, QR codes, and/or mobile vouchers).
• (c) Unless you choose to remain anonymous through your device and/or platform settings, we may automatically collect and use this information when you use the service via any TycheGo mobile application, mobile browser, or other means.

2.5 With your permission, we collect your images, photos, etc. These images and photos will be used for the following purposes:

• (a) You will need to upload an image or photo when you register your account to set your profile picture, homepage information, etc.
• (b) After completing an order, you can upload product images for reviews.
• (c) You need to use them to communicate with others (e.g., customer service representative).
• (d) Failure to use images and photos may affect our ability to provide services to you.

3.1 We will only process the data we collect about you when there is a legitimate reason and in accordance with applicable data protection laws. Your information will be processed based on the following legal grounds:

• (a) If we need to process your information in order to provide you with the services you requested or to enter into a contract;
• (b) We have obtained your consent;
• (c) We have a legitimate reason and it aligns with our legitimate interests to process your data;
• (d) We have a legal obligation to do so.

3.2 When we need to provide you with the requested services or enter into a contract, we will use your information to:

• (a) Provide you with access to relevant parts of the platform;
• (b) Deliver the service you requested;
• (c) Enable us to charge you for transactions;
• (d) Contacting you when necessary regarding our services, such as resolving any issues you may encounter with your order.

3.3 We may process your data after obtaining your consent (or, in certain circumstances, for our legitimate interests), such as:

• (a) Sending you direct marketing information, promoting our services, and providing you with updates about our services;
• (b) Including content on topics we believe may interest you and informing you of new features or services.

3.4 We may also process your data when there is a legitimate reason that aligns with our interests, such as personalizing our services, including processing data to facilitate a smoother and quicker ordering experience. The reasons for this are outlined below:

• (a) To enhance the efficiency and quality of our services for customers in the future;
• (b) To customize the content shown to you by us or our third-party service providers or advertising partners, for example, we can display services available in your area based on your indicated location;
• (c) To enable our customer support team to assist you with inquiries or complaints in the most effective manner;
• (d) To contact you for your views and feedback on our services, and to inform you of any important changes or developments regarding the Platform or our services, including notifying you if we expand our services to new areas, where you asked us to do so;
• (e) To analyze your activities on the platform for managing, supporting, improving, and developing our business, as well as for statistical and analytical purposes, and to help prevent fraud;
• (f) To enforce the contractual terms with you and any other agreements, as well as to exercise or defend legal claims and protect the rights of TycheGo, our partners, or others (including preventing fraud);
• (g) If you provide feedback or comments about the platform and services, we may use such comments and feedback on the platform and in any marketing or advertising materials. For this purpose, we will identify you only by your name and your city of residence.
• (h) When we rely on legitimate interests as the basis for processing your personal information, we will conduct a "balancing test" to ensure that our processing is necessary and that your fundamental privacy rights are not overridden by our legitimate interests.

3.5 When we have a legal obligation to do so, we may use your information to:

• (a) Create and store records of your orders;
• (b) Comply with any legal obligations or regulatory requirements we are subject to.

4.1. Where permitted in our legitimate interest or with your prior consent where required by law, we will use your personal information for marketing analysis and to provide you with promotional updates communications about our products or services.

4.2 You can opt out of further marketing at any time by selecting the "unsubscribe" link at the end of any marketing and promotional update communications we send you.

5.1 We will not retain your information for longer than we deem necessary.

5.2 Information that we collect will be retained for as long as needed to fulfil the purposes outlined in the 'How & why we use your information' section above, in line with our legitimate interest or for a period specifically required by applicable regulations or laws, such as retaining the information for regulatory reporting purposes

5.3 In determining the appropriate retention period, we will consider the following factors:

• (a)our contractual obligations and rights in relation to the information involved;
• (b)legal obligation(s) under applicable law to retain data for a certain period of time;
• (c)statute of limitations under applicable law(s);
• (d)our legitimate interests where we have carried out balancing tests (see section on 'How we use your personal information' above);
• (e)(actual or potential) disputes;
• (f)the establishment, exercise or defence of any (actual or potential) legal claim; and
• (g)guidelines issued by relevant data protection authorities.

Otherwise, we securely erase your information where we no longer require your information for the purposes collected.

6.1 The information we collect about you will be transmitted and stored on our servers located in Singapore. We are very cautious and transparent regarding whether your information is shared with others.

6.2 Internal Sharing of Your Information We only share your information with other TycheGo platforms when necessary for the purposes outlined in Section 4.

6.3 Sharing Your Information with Third Parties We share your information with third-party service providers. The types of third-party service providers with whom we share your information include:

• (a) Payment providers (including online payment providers and fraud detection providers): to provide services to us, such as processing credit card payments on our behalf, providing you with support services, or performing fraud checks;
• (b) Information technology service providers (including cloud service providers): for purposes of data storage and analysis;
• (c) Service partners: with whom you place orders, so they can fulfill your orders, understand any needs you voluntarily communicate to them, and resolve issues or enhance their services;

Tyche Go will take all reasonable and necessary measures to ensure that your data is securely processed when transferred to third parties and complies with this privacy policy.

6.4 If our business enters into a joint venture with, purchase, or is sold to or merger with another business entity, your information may be disclosed or transferred to the target company, our new business partners or owners or their advisors.

6.5 We may also share your information in the following circumstances:

• (a) If we are obligated to disclose or share your information to comply with (and/or if we believe we are obligated to comply with) any legal obligations or regulatory requirements. This includes exchanging information with other companies and organizations to protect and prevent fraud;
• (b) To enforce the terms of contracts and any other agreements we have with you;
• (c) To protect the rights of TycheGo, our partners, or others, including preventing fraud.

7.1 The data we collect from you may be transferred to, and stored at, a destinations outside of Singapore, which may not be subject to equivalent data protection laws.

7.2 Where your information is transferred outside the United States, we will take all steps reasonably necessary to ensure that your data is subject to appropriate safeguards, such as relying on a recognised legal adequacy mechanism, and that it is treated securely and in accordance with this privacy policy.

7.3 We may transfer your personal information outside of Singapore for the following reasons:

• (a) in order to store it.
• (b) to enable us to provide services and fulfill contracts with you or your company. This includes order fulfillment, payment processing, and the provision of support services.
• (c) where we are legally required to do so.
• (d) As part of normal application operations and processing.
• (e) in order to facilitate the operation of our group of businesses, where it is in our legitimate interests and we have concluded these are not overridden by your rights.

8.1 The payment details you provide will be encrypted using Secure Socket Layer (SSL) technology before being submitted to us over the internet. Payments made on the platform are processed through our payment gateway providers, including Alipay, Worldpay, Stripe Connect, or other FCA-regulated third-party payment gateways that Tyche Go may cooperate with from time to time through our platform ("Payment Gateway(s)"). You will provide your credit or debit card information directly to the Payment Gateway(s), which operate secure servers to process payment details, encrypting your credit/debit card information and authorizing payment. The information you provide to any Payment Gateway(s) is not within our control and is subject to each Payment Gateway's own privacy policy and terms and conditions.

9.1 We adopt robust technologies and policies to ensure the personal information we hold about you is suitably protected. Any payment transactions will be encrypted using SSL technology.

9.2 We take steps to protect your information from unauthorised access and against unlawful processing, accidental loss, destruction and damage.

9.3 Where you have chosen a password that allows you to access certain parts of the Sites, you are responsible for keeping this password confidential. We advise you not to share your password with anyone.

9.4 Unfortunately, the transmission of information via the internet is not completely secure. Although we will take steps to protect your information, we cannot guarantee the security of your data transmitted to the Sites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.

10.1. Under data protection law, you may in certain circumstances have a number of rights concerning the data we hold about you. If you wish to exercise any of these rights, please contact our Data Protection Officer using the contact details set out above. For additional information on your rights please contact your data protection authority and see below:

• (a)The right to be informed. You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we're providing you with the information in this policy.
• (b)The right of access. You have the right to obtain access to your information (if we're processing it). This will enable you, for example, to check that we're using your information in accordance with data protection law. If you wish to access the information we hold about you in this way, please get in touch (see Contact Details).
• (c)The right to rectification. You are entitled to have your information corrected if it is inaccurate or incomplete. You can request that we rectify any errors in information that we hold by contacting us (see Contact Details).
• (d)The right to erasure. This is also known as 'the right to be forgotten' and, in simple terms, enables you to request the deletion or removal of certain of the information that we hold about you by contacting us (see Contact Details).
• (e)The right to restrict processing. You have rights to 'block' or 'suppress' further use of your information. When processing is restricted, we can still store your information, but will not use it further.
• (f)The right to data portability. You have the right to obtain your personal information in an accessible and transferrable format so that you can re-use it for your own purposes across different service providers. This is not a general right however and there are exceptions. To learn more please get in touch (see Contact Details).
• (g)The right to lodge a complaint. You have the right to lodge a complaint about the way we handle or process your information with the national data protection authority.
• (h)The right to withdraw consent. If you have given your consent to anything we do with your information (i.e. we rely on consent as a legal basis for processing your information), you have the right to withdraw that consent at any time. You can do this by contacting us (see Contact Details). Withdrawing consent will not however make unlawful our use of your information while consent had been apparent.
• (i)The right to object to processing. You have the right to object to certain types of processing, including processing for direct marketing and profiling. You can object by changing your marketing preferences as set out above.

We welcome your feedback and questions. If you would like to contact us, please send us an email at services@tychego.com

Any changes to our privacy policy will be posted to the Sites and APPs. This privacy policy was last updated: 25 December 2024