🔒Privacy Policy

Updated: January 17th 2023

This Privacy Policy explains how Spartan Labs Pte. Ltd. and our affiliates as well as their respective representatives, agents and/or service providers (collectively referred to as “we”, “our,” or “us”) collects, uses, and shares information about you when you access or use our website available at [insert website address] and services (collectively, the “Site”). We take your privacy seriously.

This Privacy Policy supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your information, and your consents herein are cumulative and additional to any rights which we may have at law to collect, use, share and/or process your information. This Privacy Policy does not affect any rights which we may have at law in connection with the collection, use, disclosure and/or processing of your information.

We may update this Privacy Policy from time to time, and in our sole and absolute discretion, to ensure that this Privacy Policy is consistent with our future developments and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of this Privacy Policy as updated from time to time on our Site. Please check the Site regularly for updated information on the handling of your information.

A. COLLECTION OF INFORMATION

1. INFORMATION YOU PROVIDE TO US

We collect information you provide directly to us. For example, we collect information when you sign up to receive updates, request information, fill out a form, communicate with us via third party social media sites, request support, send us an e-mail, allow us to access laboratory results in connection with our services and with your consent, or otherwise communicate with us. The types of information we may collect include your name, identification numbers, work permit and birth certificate, residential address, contact information (such as email address, postal address, and phone number), credit card and other payment information (although payment information may be collected directly by a third-party processor), and any other information you choose to provide. We collect this information to help better provide you services.

If you provide us with any information relating to a third party, by submitting such information to us, you represent and warrant that the collection, use, disclosure and/or processing of that information by us for the purposes set out below, is lawful, and you have obtained the consent of the third party to provide us with their information.

2. AUTOMATICALLY COLLECTED INFORMATION

When you access or use our Site, we may automatically collect non-identifying information about you, including your log and usage information, device information, and location information.

3. Information Collected by Cookies and Other Tracking Technologies

We use different technologies to collect information, including cookies. Cookies are small data files stored on your hard drive or in device memory that help us improve our Site and your experience, see which areas and features of our Site are popular, and count visits. For more information about cookies and how to disable them, see Your Choices below.

B. USE OF INFORMATION

We may use the information we collect to:

• Provide, maintain, and improve our Site;

• Provide and deliver the information you request, including our Services;

• Send you technical notices, updates, security alerts, and support and administrative messages and provide technical support;

• Verify your identity;

• Respond to your e-mails, submissions, comments, questions and requests;

• Communicate with you about our Services, such as sending you information to keep you informed about various news and information we think will be of interest to you (see Your Choices below for information about how to opt out of these communications at any time);

• Monitor and analyze trends, usage, and activities in connection with our Site;

• Personalize the Site and provide advertisements, content, or features based on your preferences, and interests;

• Detect, investigate, and prevent fraudulent transactions and other illegal activities;

• Carry out any other purpose described to you at the time the information was collected, and for purposes which are reasonably related to the aforesaid.

C. DISCLOSURE OF INFORMATION

We may share information about you as follows or as otherwise described in this Privacy Policy:

• When we believe in good faith that we are lawfully authorized or required to do so or that doing so is reasonably necessary or appropriate to comply with the law or legal processes or respond to lawful requests, claims or legal authorities, including responding to lawful subpoenas, warrants, or court orders;

• If we believe your actions are inconsistent with the spirit or language of our policies, or to protect the rights, property, and safety of our staff or others;

• With your consent or at your direction;

• In accordance with the permission granted by Data Protection Laws to collect, use, disclose and/or process your information without your consent.

As used in this section, "Data Protection Laws" means any applicable law relating to the protection, privacy and security, collection, use, disclosure and/or processing of sensitive or other personally identifiable information, including the Singapore Personal Data Protection Act 2012.

D. WITHDRAWING YOUR CONSENT

The consent that you provide for the collection, use, disclosure and/or processing of your information will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using, disclosing and/or processing your information for any or all of the purposes listed above by submitting your request in writing or via email to us using the contact details set out at section N below.

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 will seek to process your request within ten (10) business days of receiving it.

Whilst we respect your decision to withdraw your consent, please note that if you withdraw your consent to any or all use of your information, depending on the nature of your request, we may not be in a position to continue to provide its Services to you, or administer any contractual relationship in place, which in turn may also result in the termination of any agreements with us, and your being in breach of your contractual obligations or undertakings. Our legal rights and remedies in such event are expressly reserved in this regard.

Please also note that withdrawing consent does not affect our right to continue to collect, use, disclose and/or process information where such collection, use, disclosure and/or processing without consent is permitted or required under Data Protection Laws.

E. ACCURACY OF PERSONAL DATA

We generally rely on information provided by you (or your authorised representative). In order to ensure that your information is current, complete and accurate, please update us if there are changes to your information in writing or via email to us using the contact details set out at section N below.

F. DATA RETENTION

We store the information we collect on you for as long as is necessary for the purpose(s) for which we originally collected it, including for the continuing provision of the Services, or for other legitimate business purposes.

G. LINKS TO OTHER WEBSITES

The Site may contain links to other websites. Any personal information you provide on such linked pages is provided directly to that third party and is subject to that third party’s privacy policy, and not this privacy policy. We encourage you to learn about their privacy and security practices and policies before providing them with personal information.

H. SOCIAL SHARING FEATURES

The Site may offer social sharing features and other integrated tools, which let you share actions you take on our Site with other media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on your privacy settings for the relevant social media site. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of the entities that provide these features.

I. TRANSFER OF INFORMATION OUTSIDE SINGAPORE

Where we transfer your information to countries outside of Singapore, we will take steps to ensure such transfer is in accordance with Data Protection Laws, including ensuring that organisations provide a standard of protection to information so transferred that is comparable to the Data Protection Laws.

J. YOUR CHOICES

1. PROMOTIONAL COMMUNICATION

We may send promotional e-mails or text messages. You may opt out of receiving promotional emails or text messages from us by following the instructions in those emails or text messages. If you opt out, we may still send you non-promotional emails, such as those about your use of the Site.

2. ACCESS TO AND CORRECTION OF INFORMATION

You may update and correct certain information you provide to us by emailing us using the contact details set out at section N. If you wish to delete information we have collected from you, please email us using the contact details set out at section N, but note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for as long as necessary for our business purposes.

If you wish to make (a) an access request for access to a copy of the information which we hold about you or information about the ways in which we use or disclose your information, or (b) a correction request to correct or update any of your information which we hold about you, you may submit your request in writing or via email to us using the contact details set out at section N below.

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. In general, our response will be within thirty (30) business days. 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 information 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 Data Protection Laws).

K. COOKIES

When you visit or interact with our websites and/or services, we or our authorised service providers may use cookies, web beacons, and other similar technologies for collecting and storing information to enhance your user experience.

The information collected by us or our authorised service providers may recognise a visitor as a unique visitor and may collect information such as how a visitor arrives at our websites, a visitor's IP address, what kind of web browser a visitor is on, what operating system a visitor is using, the domain name of a visitor's internet service providers, data on the number of visitors visiting our websites and a visitor's click stream information and time stamp (for example, which pages or articles they have visited and the length of visit).

The use of cookies, web beacons and similar technologies by us on our website has different functions. They are either necessary for the functioning of our services, help us improve our performance, or serve to provide you with extra functionalities. They may also be used to deliver content that is more relevant to you and your interests, or to target advertising to you on or off our sites.

Certain site features and services are available only through the use of these technologies. You are always free to block, delete, or disable these technologies if your browser so permits. However, if you decline cookies or other similar technologies, this could affect the availability of our Site. For more information on how you can block, delete, or disable these technologies, please review your browser settings.

L. MOBILE PUSH NOTIFICATIONS / ALERTS

With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device. You can deactivate these messages at any time by changing the notification settings on your mobile device.

M. PROTECTION OF INFORMATION

We adopt appropriate data collection, storage and processing practices and security measures to protect your information.

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.

N. CONTACT US

If you have any questions or comments about our Privacy Policy, the ways in which we collect and use your personal information, or your choices and rights regarding such use, please do not hesitate to contact us as follows:

By mail:

Attention: Data Protection Officer, Spartan Labs Pte. Ltd.

Spartan Labs Pte. Ltd. Address: 14 Robinson Road, #14-01, Singapore 048545 Email: [e-mail]

By email:

[e-mail] Attention: Data Protection Officer

O. GOVERNING LAW

This Privacy Policy shall be governed by and construed and enforced in accordance with the laws of the Republic of Singapore, without regard of conflict of law rules.

P. EFFECT OF NOTICE AND CHANGES TO NOTICE

This Privacy Policy applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use, disclosure and/or processing of your information by us.

We shall have the discretion to update this Privacy Policy at any time without prior notice. You may determine if any such revision has taken place by referring to the date on which this Privacy Policy was last updated. You acknowledge and agree that it is your responsibility to review this Privacy Policy periodically and become aware of modifications. Your continued use of the Services constitutes your acknowledgement and acceptance of such changes.