ECRUU COMMODITIES MEDIA MONITORING PTE. LTD. (“our Company”, ‘we’, ‘our’, or ‘us’) respects your privacy when you communicate
(whether online or offline) with us through our website at www.ecruu.com (“our Website”), our ECRUU news update mobile application and other
applications made available by our Company (collectively “App”), email, telephone, text messaging and/or offline programmes and events
(collectively “Communication Channels”)
In order to provide you with appropriate customer service, we require infor-mation from you and/or your organization, some of which may be
considered as personal data pertaining to individuals or confidential information of your or-ganisation respectively. We have therefore set out
follows so that you may be reassured that we take data protection seriously:-
Commu-nication Channels, or otherwise howsoever providing us with your personal data, you are agreeing to our collection of your information
your access of our Website, App and/or other Communication Channels.
B. In order for you to maximise the utility of our Website and App, access our services, products, news summaries, request information from us,
take-part in our promotions, text messaging programmes, telephone promotions, of-fline and online programmes and other events, receive our
marketing mate-rials, newsletters or updates for information and/or promotion regarding our services, our products, our subscription plans, and
other related matters (our newsletters, news summaries, news extracts, blog, updates and/or promotions shall be collectively referred to as our
“Updates”), your Personal Data (as defined in clause 1.2 below) and/or your Confidential Information (as defined in clause 1.4 below) has to be
provided to us, and we will need to keep and use your Personal Data and/or Confidential Information in order to fulfil the purpose for which you
have contacted us, subscribed to our App, our Website, Updates and/or services.
time without pri-or notice to you, and you agree that your continued access to and/or use of our App, our Website, blog, social media channels
and/or other Communication Channels, your continued desire to receive our Updates and email us, take part in text messaging programs, liaising
with us via the telephone, offline and online programs, events and/or utilise any of our Communication Channels constitutes your unconditional
1. Types of Data Collected
1. When you visit or access our Website, App, social media channels, other Communication Channels, sign-up for any of our Updates, email us, call
us, take part in our text messaging programmes and/or in offline or online programmes and events, we collect Personal Data and Anony-mised
1.2 “Personal Data” refers to information, whether true or otherwise, with personal identifiers that can be used separately or collectively to
identify an individual, such as name, address, NRIC or other identification num-ber, mobile number, phone IMEI, email address, birthdate,
gender, in-come range, trading preferences, trading accounts, residency status, bank account details, and credit card details, but excludes
information that is publicly available (including but not limited to Social Media Data).
1.3 “Anonymised Data” refers to information that is not associated with or linked to your Personal Data and cannot be used to
identify individual persons.
1.4 “Confidential Information” refers to sensitive or proprietary information of an organization (incorporation, partnership, or other similar
forms of legal entity) that is not available in the public domain, such as the annual turnover of an exempt private company, or information of
an individual that is private but does not constitute Personal Data.
1.5 “Social Media Data” refers to information that would have been deemed as your Personal Data but is generally not protected as such due to
your voluntary disclosure of such information to the public domain via a social media platform (example, Facebook, Twitter and LinkedIn),
including but not limited to your social media accounts’ information such as name, birthdate, email address, list of friends, and any other
additional infor-mation or activities that you permit the third party social media platform to share with us.
2. Collection of Anonymised Data
2.1 When you access our App, our Website, and/or email us, we collect Anonymised Data about you via the application of generally acceptable web
technologies including but not limited to “web beacons”, “cookies”, “clear GIFs”, “widgets”,
“online evaluations”, “surveys”, “HTML5”, “dy-namic device identifiers”, and third-party web analytics such as “Google
analytics” (collectively, “Acceptable Technologies”). This automatic col-lection of non-personal information includes (without limitation)
collec-tion of your IP Address, the web browser software that you used, the type of smart phone or tablet that you may be using, the operating
soft-ware/platform of your device, your sign-up(s) for any Updates or infor-mation via our Website and/or App, the specific pages of our Website
viewed by you, the specific categories or features in our App accessed by you, any third party application used in conjunction with our App,
your downloading of related applications, and third party websites that you may have visited prior to our Website. Our purpose for the aforesaid
collection of information is for us to understand the preference of our visitors and users so as to enhance and facilitate the ease with which
you are able to access or use our Website and our App.
2.2 As part of the Anonymised Data that we collect, when you access our Website via your mobile device or tablet, we will also collect
information regarding the type of mobile device or tablet that you are utilising so that our Website and/or App can provide you with the version
of our Website and/or App best suited for access via your mobile device or tablet.
2.3 If you do not consent to our collection of Anonymised Data, please adjust the settings on your computer, tablet and mobile device to block or
disable our use of the Acceptable Technologies. In the event that you choose to access our Site without blocking or disabling or opting out of
the Acceptable Technologies, such access by you will constitute your consent to our use of the Acceptable Technologies and our collection of
2.4 To better assist you in understanding the generally accepted technology used in our collection of Anonymised Data:-
2.4.1 “IP Address” refers to a number that is automatically assigned to your computer when you access the Internet. Under certain
cir-cumstances, your IP Address remains the same from browser session to browser session. However, in the event that a con-sumer Internet access
provider is utilised, your IP Address will likely vary from session to session. We track IP Addresses solely in conjunction with session cookies
to analyse the flow of webpages on our Website.
2.4.2 “Cookies” refer to small pieces of data that a website sends to your computer’s hard drive or mobile device’s internal storage while you
are viewing the said website. Our Website utilises both session cookies (they expire the moment your Internet browser is closed) and persistent
cookies (they will remain in your computer and your mobile device until you actively take steps to delete them) so as to provide you with a more
personalised and interac-tive experience on our Website. By changing the options on your Internet browser and adjusting the settings in your
mobile device (subject to your version of operation system and your device’s features), you can control whether to accept or decline cookies.
2.4.3 “Clear GIFs” refer to clear electronic images that are used to track your opening of webpages on our Site and your pattern of brows-ing our
webpages, for the purpose of allowing us to assess the at-tractiveness of the content on our Site, and the flow of webpages and layouts that
appeal to you. Clear GIFs are also commonly known as “web beacons” and may be included on our Site, and generally works in
conjunction with cookies to identify users and user behaviour. Some of our HTML based emails also utilise Clear GIFs in order for us to assess
what are the emails we sent that have been opened and acted upon. Clear GIFs collect only limited data, such as a cookie number, the time and
date of when a particular webpage on our Site is accessed, and a description of the webpage on Our Site in which the clear GIF resides. Such
col-lected Anonymised Data helps us to determine the effectiveness of the way our webpages are arranged on Our Site, our modes of communications
and promotional campaigns.
2.4.4 “Third-party web analytics” refer to services provided by third party service providers for the assessment, analysis,
measurement and reporting of the behaviour of visitors to a website in order to assess and improve the effectiveness of the website. One of the
most well-known third-party analytics service is “Google Analytics”.
2.4.5 “HTML5 local storage” refer to caching services utilizing primarily a cache manifest file, which allows for storage of your preferences
offline which will then be updated and synchronized when you go online.
2.4.6 “Dynamic device identifiers” refer to “identifier for advertisers” or “IFA”, which is a random, anonymous number assigned to a user of the
iPh-one or iPad and is temporary, allowing it to be blocked like a cookie. When a user views an application or browses the internet, the user’s
presence generates a call for an advertisement as the publisher’s site that the user is viewing will pass the IFA to the ad server and the
adver-tiser is then able to serve the user with an advertisement relevant to the topic being viewed. IFA can also be used to identify whether
the adver-tisements resulted in users downloading applications or purchasing products that were advertised. The IFA does not identify the user
per-sonally, it provides an aggregated audience data that advertisers can target with advertisements. IFA can be opted out of via the settings
in the user’s device (by default, the IFA is enabled), subject to the availa-bility of such options in the version of your operating system and
the features of your device.
3. Your Consent to our Collection, Retention and Use of Personal Data and Confidential Information
3.1 In order for our Company to provide you with our services and products, you agree and consent to our Company collecting, using and retaining
your Personal Data and/or Confidential Information as follows:-
(i) When you sign up for our Updates, or you email or call us with any queries, you will be required to provide us with your Personal Data
and/or Confidential Information in order for us to add you to our mailing list, or to revert to your queries.
(ii) When you sign up for any Updates, register for any accounts, sub-scribe to our services, enroll for any membership or loyalty pro-gramme,
utilise any of our Communication Channels, participate in text messaging programmes, enter into a subscription plan, or other promotional
campaigns, offline and online programmes and events that we provide, we will require your Personal Data and/or Confidential Information in order
to keep a record of and provide you with the benefits that accompany your subscription plan, mem-bership programme, text messaging programmes,
and/or promo-tional campaigns (whether online or offline). Unless you terminate your subscription plan, withdraw from our membership programme
or promotional campaigns, or our relevant promotional campaign ends, we will keep your Personal Data for as long as you are still part of a
subscription plan, our membership programme and/or promotional campaigns (whichever is the later) so that we can pro-vide you with the relevant
benefits. In relation to your Confidential Information, we will retain them for as long as we are of the reason-able opinion that you may still
be interested in our Company’s products services so that our Company can be expeditious in the provision of our services whenever you should
seek a delivery of any of our products or our assistance.
(iii) In the event where we should use Google ads and wWhen you click on any of our Company’s Google ads or other internet based adver-tisements
for more information regarding our services or our Web-site or our mobile application, we collect the Personal Data and/or Confidential
Information that you provide in order to follow up with you pertaining to your interest in our products, services and/or our Website.
2. In addition, we will retain your Personal Data and/or Confidential Infor-mation where necessary and for such duration as may be required in
or-der for our Company to comply with applicable laws and regulations, assist in any legal investigations, meet the demands from any regulatory
or law enforcement bodies, for utilization in legal proceedings, minimiz-ing fraud, collection of debts, repayment of loans, resolving disputes,
identifying issues, enforcing contractual breaches and/or claiming for damages.
4. Disclosure of Personal Data and Confidential Information
4.1 We may need to disclose your Personal Data and/or Confidential Infor-mation to:-
(i) third party service providers in order for us to facilitate your access to and use of our Website, utilise our App, access our text
messag-ing programme, for us to contact you as you may have requested via our Website or telephone, for us to maintain and update your records
to ensure that you receive our replies to your queries, for us to follow up on any delivery of news summaries, products or services that you may
have requested for, and to provide you with any other updates and perks accompanying your participation in our subscription plan, membership
programme and/or promotional campaigns. The aforesaid third party service providers have a con-tract with us to perform the services necessary
for you to use our Website, our App, receive Updates and/or our services or products that you might have ordered, and such third party service
providers therefore include but is not limited to webhost companies, website maintenance companies, database storage companies, membership
programme service providers, app stores, app maintenance providers, companies that assist to perform mass mailing on our behalf, courier and
logistics companies, etc.;
(ii) our book-keepers, accounting firms, audit firms, law firms and/or other professional advisory firms who are maintaining our records in
accordance with legal requirements;
(iii) governmental, regulatory or law enforcement bodies who have a legal right to demand for your Personal Data and/or Confidential
(iv) credit bureaus, credit rating agencies and fraud preventing compa-nies for the purpose of minimizing fraudulent activities via your Personal
Data and/or Confidential Information; and
(v) our affiliated or related companies and/or third parties to whom we may sell, divest, transfer, assign, share or otherwise engage in a
transaction that involves, some or all of our Company’s assets (which may include your Personal Data), in the course of a corpo-rate
divestiture, corporate restructuring, merger, acquisition, joint venture, bankruptcy, dissolution, reorganisation, or any other simi-lar
transaction or proceeding.
Except as provided above, we do not sell, rent, licence or otherwise disclose your Personal Data and/or Confidential Information to third parties
or our affiliated companies. We are careful in our selection of third party service providers, and all such third party service providers as
well as our abovementionedabove-mentioned affiliated companies are bound by obligations of data protection (pursuant to contracts and/or
collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us.
5. Transferring Personal Data out of Singapore
5.1 Pursuant to the purposes and activities as set out in sections 3 and 4 above, it may be necessary for us to transfer your Personal Data out
of Singapore. You hereby agree and consent to the aforesaid transfer, on the understanding that the recipients of such Personal Data are also
sub-ject to applicable laws or contractual obligations similar to the obliga-tions as set out in the Personal Data Protection Act 2012.
6. Accurate and Complete Personal Data and Confidential Information
6.1 In order for us to provide you with access to our Website, our App, our text messaging programme, our other Communication Channels and all
their respective associated functions, our services and our products, and to perform the activities as set out in sections 3, 4 and 5 above, you
warrant that the Personal Data (and/or Confidential Information) that you provide to us is accurate, and that all Personal Data (and/or
Confidential Information) as may be relevant for that particular purpose/circumstance has been provided.
7. Do-Not-Call (“DNC”) Provisions and Registries
7.1 We respect your selections in relation to the channels via which you wish to receive our Updates. Therefore, if you have registered your
telephone and/or fax number with the Do-Not-Call Registries in relation to telephone calls, text or fax messages, we will not send you any
Updates via the channels that you have opted out of by registering with the Do-Not-Call Registries. However, if you have previously consented to
our sending you Updates via your telephone number (calls or text messages) and/or facsimile number, we will continue doing so until you withdraw
your consent by contacting our Data Protection Officer at email@example.com[insert email address, eg. firstname.lastname@example.org]
8. Withdrawal of Consent
8.1 You may at any time withdraw your consent to our use, retention, disclo-sure or transfer of your Personal Data and/or Confidential
email@example.com]firstname.lastname@example.org. Howev-er, please note that any such withdrawal of consent may result in us be-ing unable to continue providing
our services or fulfilling our contractual obligations with you, including but not limited to termination of your ac-cess to our Website and
App, cancellation of any subscription plan and thereby all deliverables that would have been provided thereunder, ter-mination of membership
programme benefits that would otherwise have been available to you, cessation of your access to our text messaging programme, termination of
delivery of news summaries to you, inability to provide you with the opportunity to participate in promotions, inability to fulfil any request
for information that you may have submitted to our Company, inability to fulfill any purchaser orders, and potentially inability of third
parties to provide you with their services or products as you might have contracted with them through our Website or App. Accord-ingly, your
withdrawal of consent may also lead to the termination of any contract(s) that you may have with our Company, as well as termination of any
contracts with any third parties engaged through our Website or App, for which our Company expressly reserves its rights and remedies thereto.
Our Data Protection Officer will further advise you on the legal consequences that may ensue should you contact her to withdraw your
8.2 Should you wish to unsubscribe to our email updates, please click the “unsubscribe” option made available in our emails to you.
Please note however that this may result in our being unable to make available to you updates on our products and services, your benefits under
our member-ship programme and any ongoing promotions.
8.3 Should you wish to unsubscribe to any of our mobile applications or text messaging programmes, please utilise the “unsubscribe” or
“termina-tion” option that may be available on the application itself. If such option is not available, kindly email us at [insert email
address, eg. email@example.com]firstname.lastname@example.org
9. Access and Correction of Personal Data and Confidential Information
9.1 Should you wish to access, update or make corrections to your Personal Data and/or Confidential Information held with us, or if you wish to
re-ceive further clarifications on your Personal Data and/or Confidential In-formation held with us, please email our Data Protection Officer at
[insert email address, eg. email@example.com]firstname.lastname@example.org.
9.2 There will be no administrative fees or other charges levied for any re-quest to correct or update your Personal Data and/or Confidential
Infor-mation. However, for all other requests such as accessing your Personal Data and/or Confidential Information held with us, obtaining a
record of when you accessed our Website or App, the date of your requests for in-formation, etc., a reasonable administrative fee may be levied
depending on your request as time and resources will be spent in accommodating your requests.
Infor-mation as registered with us, or in relation to our Company’s use, reten-tion, disclosure or transfer of your Personal Data and/or
Confidential In-formation, or should you desire to learn more about our data protection policies and security measures, please email our Data
Protection Officer at [insert email address, eg. email@example.com]firstname.lastname@example.org.
10.1 Our Website, our App, our Updates and our services are not meant for persons who may be defined as minors under applicable law. We do not
knowingly collect Personal Data from minors, however, through the in-ternet, we are not able to ascertain on our end whether such individuals
are minors. It is thus the responsibility of parents or guardians to ensure that their minors do not access our Website, download or access our
App, email us, or provide us with Personal Data without their paren-tal/guardian’s consent. If a parent or guardian becomes aware that his
or her minor has accessed our Site or provided us with Personal Data with-out his/her consent, he or she should contact our Data Protection
Officer at [insert email address, eg. email@example.com]firstname.lastname@example.org promptly. If we become aware that a minor under 18 has provided us with
Personal Data without their parent or guardian’s consent, we will delete such information from our records.
11. Security Measures for Protection of Personal Data and Confidential In-formation
11.1 We ensure that our Website and App are protected by reasonable securi-ty measures afforded by current technology, and that all our data
hosts and servers are similarly protected by such security measures, including but not limited to firewalls.
11.2 Your Personal Data and Confidential Information is kept securely and protected against unauthorized access and disclosure. We utilise
securi-ty means such as (without limitation) password protection, encryption, locked and restricted access. We have strict policies in place
restricting access to Personal Data and Confidential Information to only our author-ized personnel on a need-to-know basis.
long as is necessary for fulfilling the purposes for which you have entrusted us with your Personal Data, or as may be required for legitimate
business or legal purposes, whichever is the latest.
12. Third Party Sites, and Social Network Sites
12.1. Our Website, App, text messaging programme and other Communica-tion Channels may contain hyperlinks to websites operated by third parties.
data security of such third party websites, even if they are co-branded with our Company name or logo, or our Website or App displays products
or services that originate from such third par-ties. As such, we urge you to learn about the privacy policies of these third party websites
before accessing or using them, and to be careful about providing any Personal Data and/or Confidential Information to such third party
websites. We seek your understanding that we are not liable for any acts or omissions or any loss or damage that you may suffer due to your use
or access of such third party websites.
11.2 Our Company may utilise reputable social media/network sites such as, but not limited to Facebook, Twitter, Instagram, Pinterest and
LinkedIn (collectively the “Social Media Sites”) so as to connect to your social networks. In order to generate interest in our
Website and App, our products and services amongst the contacts in your social networks and to allow you to share your interest in our Website,
App and/or our prod-ucts and services, we provide access to our Website and App to the third party Social Media Sites, and there are links on
our Website and App to such Social Media Sites. The aforesaid association with the Social Media Sites does not constitute any endorsement or
privacy policies of the Social Media Sites before you use or access such Social Media Sites in con-junction with our Website or App or any of
our promotions and our prod-ucts or services made available via any Social Media Sites.
11.3 The association of our Website and App with the Social Media Sites makes available certain features which when used by you, may result in
information being made available from your accounts with the Social Media Sites to our Company. Such information which we collect about you
shall constitute public information that is available in the general domain because such information was made publicly available by the Social
Media Sites. Should you prefer that we do not collect your infor-mation from the Social Media Sites, please (i) do not use the features or links
that associates our Website and/or App with the Social Media Sites; and (ii) adjust the settings in your accounts with the Social Media Sites to
prevent the sharing of your information with our Site and mobile ap-plication. Please note that our Company cannot control nor is our Com-pany
howsoever responsible for the sharing of your information by the Social Media Sites with third parties.
11.4 One of the features which you may see available on our Website and App in association with the Social Media Sites, is the “like” feature by
Face-book, and other similar functions provided by other Social Media Sites. When you “like” our Website or App or our products or services,
infor-mation about our Website or App, our products and services will be made known to your network within your Social Media Sites’ accounts via
a variety of methods employed by the relevant Social Media Site. Your information may also be made known alongside with our products or services
that you have liked pursuant to the methods/channels made available by Social Media Sites in relation to such features. If you are not agreeable
to the aforegoing, please instruct the relevant Social Media Site or adjust your account settings with the Social Media Site. Please note
however that we are not obliged to display on our Website or any re-lated webpages (whether on Social Media Sites or otherwise) any of your
information, including but not limited to your photo or name, even if you “like” our Website, our App, our products or services. In the event
that any of your information, product or service endorsements (including your liking of our Website, our App, any of our Company’s products or
services, or third party products or services featured on our Website or App) appear on our Website or any related webpages (whether on Social
Media Sites or otherwise), we shall have the right in our sole discretion to remove such information or product/service endorsements from our
Website or any related webpages.
12. Governing Law and Jurisdiction
email@example.com]firstname.lastname@example.org regarding your concern and use your best endeavours to amicably settle any dispute in good faith. We on our
part will also use our best endeavours to amicably settle your concerns in good faith. However, if no amicable resolution is reached within 30
days, you agree to submit to the exclusive jurisdiction of the Courts of Singapore.
Version: 1 September 2016