Privacy Policy
Privacy Policy

COWO Privacy Policy
Last updated: 1 June, 2019

COWO Pte. Ltd. (“COWO” or “we” or “our” or “us”) is the owner and operator of https://cowo.sg (the “Website”) and the COWO mobile applications (the “Apps”), and collectively term for the Website and/or Apps is (the “Platform”) and we are committed to safeguarding your personal data. We are a private limited company registered in Singapore (Co. Reg. No.: 20191234Z). 

This Privacy Policy (together with our Terms of Service  https://cowo.sg/policy/terms-of-service and any other documents referred to in it) sets out how personal data that we collect from you, or that you provide to us, would be used, processed or disclosed by us, including how certain information would be used to personalise advertising directed at you. This Privacy Policy also sets out the types of personal data we collect, how we keep it secure, as well as how you can access or alter your personal data stored by us. This Privacy Policy covers the use of the Platform, and any other way you may connect to or interact with us through the use of our products and services, hereinafter collectively referred to as Services. 

We take our responsibilities under Singapore’s Personal Data Protection Act 2012 (the “PDPA”) seriously. Please read the following carefully to understand our policy and practices regarding your personal data and how we will treat it.

Unless restricted by applicable law, you agree that any and all personal data relating to you collected by us or provided by you from time to time may be used, processed, and disclosed for such purposes and to such persons as set out in this Privacy Policy.

We may amend this Privacy Policy at any time by posting a revised version on the Website. While we endeavor to send  an individual notice every time the policy is amended, you will be deemed to have acknowledged and agreed to the amended Privacy Policy if you continue to use the Website, the Apps or our services after the changes have taken effect. You are reminded to check this Website from time to time for updates to this Privacy Policy.

  1. COLLECTION USE AND STORAGE OF PERSONAL DATA
    You can choose to browse the Platform without disclosing your personal data. You are not required to provide personal data as a condition of using the Platform, except as may be necessary for us to be able to provide the products and services which you purchase or access through our Platform, respond to your requests, or in cases where you contact us directly.
    When you use our Services, we collect a variety of information from and about you, your devices, and your interaction with the Services. Some of this information identifies you directly or can be used to loosely identify you when combined with other data.

    1. Information you willingly provide. When using our Services, you may be asked to provide personal information about yourself, such as your name, contact information, payment information, your profession or your work location preferences. This may occur, for example,
      1. when you carry out transactions with us on or in relation to the Platform;
      2. when you register COWO account on the Platform;
      3. when you contact our customer service or sales people by email, telephone, or in person, to resolve any issues that you may be facing or with inquiries or requests; and
      4. when you subscribe to the services that we are providing on the Platform, or for our email notifications, and/or newsletters.
      5. when you complete other forms or transactions, such as a request for more service information or an appointment booking.
      6. you may also provide information about a third party through the Services, for example, if you share a coworking listing or service with a recipient via email or sms. Some information you provide through our Services is collected and processed by third parties (such as google analytics) on our behalf.
    2. Cookies, Pixels and other tracking mechanisms. We may use cookies to identify you from other users, in conjunction with the Platform to obtain information. Your browser may allow you to set how it handles cookies, such as declining all cookies or prompting you to decide whether to accept each cookie. But please note that some parts of the Platform may not work as intended or may not work at all without cookies. We may also allow our business partners to place cookies on your device. For example, we use Google Analytics for web analytics, and so Google may also set cookies on your device. As further explained below, Third Parties may also place cookies on your device for advertising purposes. There are two types of cookies used on the Platform, namely “persistent cookies” and “session cookies”. Session cookies will normally expire when you close your browser, while persistent cookies will remain on your device after you close your browser, and can be used again the next time you access the Platform.
    3. Other technologies The Platform may also use other technologies with similar functionality to cookies, such as web beacons and tracking URLs to obtain Log Data about users. We may also use web beacons and tracking URLs in our messages to you to determine whether you have opened a certain message or accessed a certain link.
    4. Uses for COWO cookies COWO uses cookies and similar tracking technologies for a number of purposes, such as the following:
      1. to enable, facilitate and streamline the functioning of the Platform across different web pages, devices and browser sessions.
      2. to simplify your access to and use of the Platform and make it more seamless.
      3. to monitor and analyze the performance, operation and effectiveness of the Platform, so that we can improve and optimize it.
      4. to show you content (which may include advertisements) that is more relevant to you.
      5. for fraud detection and prevention.
    5. Uses for Third-Party cookies Our partners’ cookies are intended to obtain information to help them provide services to COWO. For example, Third Parties we engage to provide services to us may track your behavior on our Platform to market and advertise COWO listings or services to you on the Platform and Third-party websites, or to help us detect or prevent fraud or conduct risk assessments. Third Parties websites that use cookies and other tracking technologies to deliver targeted advertisements on our Platform and/or Third-Party websites may offer you a way to prevent such targeted advertisements by opting-out at the websites of industry groups such as the Network Advertising Initiative and/or the Digital Advertising Alliance. You may also be able to control advertising cookies provided by publishers, for example Google’s Ad Preference Manager. Please note that even if you choose to opt-out of receiving targeted advertising, you may still receive advertising on or about the Platform – it just will not be tailored to your interests. In addition, Facebook places a cookie via the Platform that allows Facebook to obtain aggregated, non-Personal Information to optimize their services. For example, if a user clicks on an advertisement for the COWO mobile app on Facebook and subsequently installs the app, this cookie will inform Facebook that a user (who is not personally identified) has installed the app after clicking on the advertisement. This cookie may also inform Facebook that a user is using the app, without identifying the specific actions taken by the user in the app.
    6. Disabling Cookies Most browsers automatically accept cookies, but you can modify your browser setting to decline cookies by visiting the Help portion of your browser’s toolbar. If you choose to decline cookies, please note that you may not be able to sign in, customize, or use some of the interactive features of the Platform. Flash cookies operate differently than browser cookies, and cookie management tools available in a web browser will not remove flash cookies. To learn more about how to manage flash cookies, you can visit the Adobe website and make changes at the Global Privacy Settings Panel.
    7. Changes to this Cookie Policy We can change this Cookie Policy at any time. If we make material changes to the Cookie Policy, we will let you know either by posting the changed Cookie Policy on the Platform or by sending you an email. It’s important that you review the changed Cookie Policy. If you do not wish to agree to the changed Cookie Policy, then we cannot continue to provide the Platform to you, and your only option is to stop accessing the Platform and Services and deactivate your COWO Account.
    8. Mobile device and mobile browser information. You may adjust the settings on your mobile device and mobile browser regarding cookies and sharing of certain information, such as your mobile device model or the language your mobile device uses, by adjusting the privacy and security settings on your mobile device. Please refer to the instructions provided by your mobile service provider or mobile device manufacturer.
    9. Location Data. If you enable location services on your mobile device, COWO with your permission may collect the location of your device, which we use to provide you with location-based information and advertising. If you wish to deactivate this feature, you can disable location services on your mobile device.
    10. Email Management. You may receive email from COWO for a variety of reasons – for example, if you took an action through the Services, you signed up for a regular report, or you posted your requirement for contact and a service provider sent you a message. If you have an account with COWO, you may edit your preferences through your account settings. Also, you can manage your receipt of some types of communication by following the instructions included in the email we send you. Please note that, even if you unsubscribe from certain email correspondences, we may still need to email you with important transactional or administrative information.
  2. PURPOSES FOR WHICH WE COLLECT, USE OR DISCLOSE YOUR PERSONAL DATA
    1. COWO will/may collect, use, disclose and/or process personal data that you provide to us, for one or more of the following purposes, but is not limited to the following:
      1. administering the Platform;
      2. improving your browsing experience by personalising the Platform;
      3. enabling your use of the services available on the Platform;
      4. providing you the products and services that you have specifically requested;
      5. responding to your enquiries or requests pursuant to your emails and/or submission of form(s) on the Platform;
      6. responding to and taking follow-up action on complaints regarding the use of the Platform or any product or service provided by us;
      7. sending you general (non-marketing) commercial communications;
      8. performing office and operational administrative matters; and
      9. providing third parties with statistical information about our users. Such statistical information may be used to personalise advertising on the Platform, but cannot be used to identify any individual user. For details on how to opt out of personalised advertising, please refer to section 4 of this Privacy Policy.
    2. We will not, without your express consent, disclose your personal data to third parties for the purposes of direct marketing. Consent for disclosure of personal data to third parties, for the purposes of receiving marketing communications, is given through our registration form, either online or on paper. You can withdraw your consent by contacting our customer service: hello@cowo.sg.  If you have given your consent when registering as a member on the Platform, you can also withdraw your consent by emailing us too.
  3. SECURING YOUR PERSONAL DATA
    1. Security is a high priority. We take appropriate actions to protect personal data from loss, misuse, unauthorised access or disclosure, alteration or destruction using the same safeguards as we use for our own proprietary information. All information you provide to us is stored on our secure servers and any payment transactions will be encrypted using SSL or equivalent technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Platform, you are responsible for keeping this password confidential. You agree not to share the password with anyone.
    2. We cannot accept liability for loss of personal data due to causes beyond our control or omissions of other users or third parties who may misuse your personal data which they collect from the site.
    3. We will put in place measures such that your personal data in our possession or under our control is destroyed and / or anonymized as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes.
  4. THIRD PARTY WEBSITES AND RESOURCES
    1. The Platform will contain links to other websites not owned or controlled by COWO. COWO does not have any control over Third-Party websites. These other websites may place their own cookies, web beacons or other files on your device, or collect and solicit Personal Information from you. They will have their own rules about the collection, use and disclosure of Personal Information. We encourage you to read the terms of use and privacy policies of the other websites that you visit.
  5. DISCLOSURE OF PERSONAL DATA
    1. In order to manage and operate the Platform, we may disclose your personal data to any member of our group, which means our affiliates and subsidiaries. We may also disclose your personal data to third parties such as our service providers and professional advisors for the following purposes:
    2. to comply with any legal requirement;  to enforce or apply our Terms of Service https://cowo.sg/policy/terms-of-service and other agreements; 
    3. to protect our rights, property, and safety, and the rights, property and safety of our affiliates and subsidiaries, other users of the Platform, and others; 
    4. in connection with any legal proceedings or prospective legal proceedings; and
    5. in connection with a business asset transaction (i.e. the purchase, sale, lease, merger or amalgamation or any other acquisition, disposal or financing of an organisation or a portion of an organisation or of any of the business or assets of an organisation) to which we are a party or a prospective party.  
  6. INTERNATIONAL TRANSFER OF PERSONAL DATA
    1. COWO operates and potentially operates in many countries and may temporarily store, process or transfer your personal data between any of the countries in which we operate in order to enable us to use your personal data in accordance with this Privacy Policy and our Terms of Service https://cowo.sg/policy/terms-of-service and other agreements; 
    2. We will take all steps reasonably necessary to ensure that your personal data is treated securely and in accordance with this Privacy Policy. 
  7. COMPLIANCE OR CORRECTION
    1. Our Data Protection officer is responsible for ensuring that requests for compliance or correction to personal data and amendment of personal data are properly dealt with in accordance with the procedures specified herein.
    2. Please note that we will only accept and act on requests in the English language that comply with this Privacy Policy, Any request that does not comply with the above will be rejected, and we will not take any action in relation to such rejected requests.
    3. For the avoidance of doubt, in the event that Singapore personal data protection law permits an organisation such as us to collect, use or disclose your personal data without your consent, such permission granted by the law shall continue to apply.
    4. All requests for information or requests for the amendment of personal data held by us shall be made via email to hello@cowo.sg
  8. CONTACT US
    1. Your opinion matters to us! If you’d like to provide feedback to us about this Privacy Policy, please email us at hello@cowo.sg.
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