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PRIVACY POLICY

EFFECTIVE AS OF 3 FEBRUARY 2022.

This Privacy Policy sets out the basis which Contour Ptd. Ltd. (“Contour”, “we”,
“us ”, or “our”) collects, uses, discloses and otherwise processes the Personal
Data of our customers in accordance with the PDPA. This Privacy Policy applies
to personal data in our possession or under our control, including personal data
in the possession of organisations which we have engaged to collect, use,
disclose or process personal data for our purposes.



1. INTERPRETATION

1.1. In this Privacy Policy, the terms below have the following meaning:

1.1.1. “customer”, "you" or "your" means an individual or entity who: (a) has
entered into a contract with us for the supply of goods or services by us,
including existing Members of the Contour Network; (b) has contacted us through
any means or accessed our Website to find out more about any goods or services
we provide; or (c) been contacted directly or indirectly by us in relation to
any sales, marketing or commercial opportunities;

1.1.2. “Data Intermediary” means a third party organisation which processes
personal data on behalf of Contour but does not include an employee of Contour;

1.1.3. “PDPA” means the Personal Data Protection Act 2012 of Singapore;

1.1.4. “Personal Data” means data, whether true or not, about a customer who can
be identified: (a) from that data; or (b) from that data and other information
to which we have or are likely to have access; and

1.1.5. “Website” means Contour’s website, accessible at https://contour.network.

1.2. Other capitalised terms used in this Privacy Policy shall have the meanings
given to them in the Membership Agreement and the PDPA (where the context so
permits).

2. COMPLIANCE WITH PDPA


Contour shall comply with all of its obligations under the PDPA at its own cost.

3. COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

3.1. We may collect Personal Data from you through: (a) your use of the Contour
Application and/or Licensed Software; (b) the contact forms on our Website; and
(c) when you communicate with us (either by email, telephone, in writing, via
our Website, or in person), provided that you have been notified of the purposes
for which the data is collected and provided consent to such collection and
usage for those purposes. In certain circumstances, we may also collect and use
your Personal Data without consent where permitted or required by the PDPA or
other laws. The types of Personal Data we collect may include your name, email
address, company name, and role.

3.2. We will seek your consent before collecting any additional Personal Data
and before using your Personal Data for a purpose which has not been notified to
you (except where permitted or authorised by law).

3.3. We may collect, process, and use your Personal Data for any or all of the
following purposes:

3.3.1. performing obligations in the course of, or in connection with, our
provision of the goods and/or services requested by you, including Members who
have signed up to the Membership Agreement;

3.3.2. verifying your identity;

3.3.3. responding to, handling, and processing queries, requests, applications,
complaints, and feedback from you;

3.3.4. managing your relationship with us, including in relation to any
potential or future sales, marketing and commercial opportunities with you;

3.3.5. sending you marketing information about our goods or services including
notifying you of our marketing events, referral arrangements, initiatives and
promotions, and membership schemes;

3.3.6. if you provide us with your contacts’ information, we may process this
information to facilitate invitations to our referral programs on your behalf;

3.3.7. complying with any applicable laws, regulations, codes of practice,
guidelines, or rules, or to assist in law enforcement and investigations
conducted by any governmental and/or regulatory authority;

3.3.8. any other purposes for which you have provided the information;

3.3.9. transmitting to any unaffiliated third parties including our third party
service providers, data intermediaries and agents, and relevant governmental
and/or regulatory authorities, whether in Singapore or abroad, for the
aforementioned purposes; and

3.3.10. any other incidental business purposes related to or in connection with
the above.

3.4. We may disclose your Personal Data:

3.4.1. where such disclosure is required for performing obligations in the
course of, or in connection with, our provision of the goods or services
requested by you, including Members who have signed up to the Membership
Agreement;

3.4.1. with your prior written consent; or

3.4.2. to third party service providers, data intermediaries, agents and other
organisations we have engaged to perform any of the functions listed in clause
3.3 for us.

3.5. The purposes listed in clauses 3.3 and 3.4 may continue to apply even in
situations where your relationship with us has been terminated or altered in any
way, for a reasonable period thereafter (including, where applicable, a period
to enable us to enforce our rights under any contract with you).

4. WITHDRAWING YOUR CONSENT

4.1. The consent that you provide for the collection, use and disclosure of your
Personal Data will remain valid until such time it is being withdrawn by you in
writing. You may withdraw consent and request us to stop using and/or disclosing
your Personal Data for any or all of the purposes listed above by submitting
your request in writing or via email to our Data Protection Officer at the
contact details provided in clause 11.

4.2. Upon receipt of your written request to withdraw your consent, we may
require reasonable time (depending on the complexity of the request and its
impact on our relationship with you) for your request to be processed and for us
to notify you of the consequences of us acceding to the same, including any
legal consequences which may affect your rights and liabilities to us. In
general, we shall seek to process your request within ten (10) business days of
receiving it.

4.3. 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 our goods or services to you and we shall, in such
circumstances, notify you before completing the processing of your request.
Should you decide to cancel your withdrawal of consent, please inform us in
writing in the manner described in clause 4.1 above.

4.4. Please note that withdrawing consent does not affect our right to continue
to collect, use and disclose personal data where such collection, use and
disclose without consent is permitted or required under applicable laws.

5. ACCESS TO AND CORRECTION OF PERSONAL DATA

5.1. If you wish to make: (a) 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
use or disclose your Personal Data; or (b) a correction request to correct or
update any of your Personal Data which we hold about you, you may submit your
request in writing or via email to our Data Protection Officer at the contact
details provided below.

5.2. 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 PDPA).

6. PROTECTION OF PERSONAL DATA

6.1. To safeguard your Personal Data from unauthorised or accidental access,
collection, use, disclosure, copying, modification, disposal or similar risks,
we have implemented various technical and organisational measures (including,
where appropriate, physical, administrative, procedural and information &
communications technology measures) such as: (a) up-to-date antivirus
protection, encryption and the use of privacy filters to secure all storage and
transmission of Personal Data by us; and (b) disclosing Personal Data both
internally and to our authorised third party service providers and agents only
on a need-to-know basis. For current Members of the Contour Network, a more
detailed description of these technical and organisational measures is set out
in the Support Handbook.

6.2. 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 information and
are constantly reviewing and enhancing our information security measures.

7. ACCURACY OF PERSONAL DATA

Before you provide any Personal Data to Contour, you shall make a reasonable
effort to ensure that such Personal Data is accurate and complete. We shall put
in place adequate measures to ensure that Personal Data in our possession or
control remains or is otherwise accurate and complete. In order to ensure that
your Personal Data is current, complete and accurate, please update us if there
are changes to your Personal Data by informing our Data Protection Officer in
writing or via email at the contact details provided below.

8. RETENTION OF PERSONAL DATA

8.1. We may retain your Personal Data for as long as it is necessary to fulfil
the purpose for which it was collected (e.g. to provide the services to you
under our Membership Agreement), or as required or permitted by applicable laws.

8.2. 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 (e.g. to provide the services to you under our Membership Agreement),
and is no longer necessary for legal or business purposes.

9. TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE

9.1. In some circumstances, we may transfer your Personal Data to Data
Intermediaries located outside of Singapore in order to process Personal Data on
your behalf.

9.2. With the primary exception of clause 9.1, we generally do not transfer your
personal data to countries outside of Singapore. However, if we do so, we will:

9.2.1. take steps to ensure that your personal data continues to receive a
standard of protection that is at least comparable to that provided under the
PDPA; and

9.2.2. remain responsible for such Data Intermediary's compliance with the
obligations of this Privacy Policy and for any acts or omissions of such Data
Intermediary that causes Contour to breach any of its obligations under this
Privacy Policy.

9.3. A full list of the Data Intermediaries currently engaged by Contour and
their locations are available here.

10. NOTIFICATION OF BREACH

We will as soon as reasonably practicable notify you if Contour becomes aware of
any breach of our obligations in clauses 3 to 9 of this Privacy Policy.

11. DATA PROTECTION OFFICER

You may contact our Data Protection Officer if you have any enquiries or
feedback on our personal data protection policies and procedures, or if you wish
to make any request, at the following email address: legal@contour.network

12. CHANGES TO NOTICE

We may revise and update this Privacy Policy from time to time, in our sole
discretion, without any prior notice to you. All such changes to the Privacy
Policy are effective immediately when posted to the Website and apply
immediately to our customers thereafter. Your continued use of our services
constitutes your acknowledgement and acceptance of such changes.


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