Privacy policy

Effective date: 1st March 2024

Privacy Policy

BY SUBMITTING YOUR INFORMATION, SIGNING UP AND USING OUR PRODUCTS AND/OR OTHER CONFIRMATION, YOU ARE CONFIRMING THAT YOU ARE BOUND BY THIS PRIVACY POLICY. BY USING OUR PRODUCTS OR BY OTHERWISE GIVING US YOUR INFORMATION, YOU WILL BE DEEMED TO HAVE READ, UNDERSTOOD AND AGREED TO THE PRACTICES AND POLICIES OUTLINED IN THIS PRIVACY POLICY AND YOU HEREBY CONSENT TO OUR COLLECTION, USE AND DISCLOSURE OF YOUR INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY. WE RESERVE THE RIGHT TO CHANGE, MODIFY, ADD OR DELETE PORTIONS OF THE TERMS OF THIS PRIVACY POLICY, AT OUR SOLE DISCRETION, AT ANY TIME.

IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY AT ANY TIME, DO NOT USE ANY OF OUR PRODUCTS OR GIVE US ANY OF YOUR INFORMATION. IF YOU DO NOT PROVIDE US WITH SOME OR ALL OF THE INFORMATION REQUESTED OR WITHDRAW YOUR CONSENT TO US COLLECTING AND USING YOUR PERSONAL DATA AND INFORMATION, YOU MAY NOT BE ABLE TO USE OUR PRODUCTS.

IF YOU USE OUR PRODUCTS ON BEHALF OF SOMEONE ELSE (SUCH AS YOUR CHILD) OR AN ENTITY (SUCH AS YOUR EMPLOYER), YOU REPRESENT THAT YOU ARE AUTHORIZED BY SUCH INDIVIDUAL OR ENTITY TO (I) ACCEPT THIS PRIVACY POLICY ON SUCH INDIVIDUAL’S OR ENTITY’S BEHALF, AND (II) CONSENT ON BEHALF OF SUCH INDIVIDUAL OR ENTITY TO OUR COLLECTION, USE AND DISCLOSURE OF SUCH INDIVIDUAL’S OR ENTITY’S INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY.

Introduction
Types of Data this Privacy Policy Covers
How Alias Uses Data
Data Collected by Company
Transfer of Data
Data Sharing and Disclosure
Retention of Data
Your Rights
Security
Children’s Privacy
Contact Us
Changes to Our Privacy Policy

1. Introduction

ALIAS VIRTUAL TECHNOLOGIES PTE. LTD., hereinafter referred to as ("Alias", "we", "us", "our", “Company”) respect your concerns about privacy. Your privacy is paramount to us, and we are committed to protecting the personal information you share when using the Alias platform, including our related services, websites, and mobile applications (collectively, "Service", “Services”). This Privacy Policy is designed to inform you about how we collect, use, share, and protect your personal information across our Service. It also outlines your rights regarding your personal information and how you can exercise them.

Before you use our Service, we strongly recommend that you read this Privacy Policy thoroughly to understand our practices regarding your personal information. By accessing or using our Service, you acknowledge that you have read and understood this Privacy Policy and agree to the collection and use of information in accordance with its terms, as well as our Terms and Conditions and Cookie Policy. Together, these documents form the legal agreement between you and Alias.

This Privacy Policy applies exclusively to personal information collected through the Alias platform and does not cover information collected from employees, job applicants, contractors, or other individuals in a workforce context. It encompasses all personal data processing activities undertaken by us, including collecting, organizing, structuring, storing, using, disclosing, and protecting your information.

This Privacy Policy is governed by and shall be construed in accordance with the laws of the Republic of Singapore and in compliance with the Personal Data Protection Act (2012) of Singapore (the “PDPA”). Any dispute arising out of or in connection with this Privacy Policy shall be subject to the exclusive jurisdiction of the Singapore International Arbitration Centre in Singapore, in accordance with its rules in force.

If you have any questions or concerns about our privacy practices or wish to exercise your privacy rights, please do not hesitate to contact us at hello@alias.cm.

We encourage you to review this Privacy Policy periodically, as we may update it from time to time to reflect changes in our practices or legal requirements.

2. Types of Data this Privacy Policy Covers

This Privacy Policy covers information we collect from you through our Services. Some of our Services’ functionality can be used without revealing any Personal Data, though for certain features, Personal Data is required. If you do not use these specific features, then the only information we collect will be “Non-Personal Information” (i.e., information that cannot be used to identify you). Non-Personal Information includes information such as the web pages that you have viewed. In order to access certain features and benefits on our Services, you may need to submit “Personal Data” (i.e., information that can be used to identify you). Personal Data can include information such as your name and email address, among other things. Any collection, use and disclosure of your Personal Data requires your express consent. By providing any information to us through the use of our Services, you agree to expressly consent to the collection, use and disclosure of your Personal Data according to this Privacy Policy and our Terms of Service. If you do not agree with these terms, then please do not provide any Personal Data to us. If you refuse or withdraw your consent, or if you choose not to provide us with any required Personal Data, you may not be able access certain Services.You are responsible for ensuring the accuracy of the Personal Data you submit. Inaccurate information may affect your ability to use the Services, the information you receive when using the Services, and our ability to contact you. For example, your email address should be kept current because that is one of the primary manners in which we communicate with you.

This information collected from you may constitute Personal Data under the PDPA. “Personal Data” is defined under the PDPA to mean any data, whether true or not, about an individual who can be identified from that data or from that data and other information to which an organization has or is likely to have access. This would include, without limitation, information such as name, address, telephone number, e-mail address, credit card details and any other personal information.

We will be free to use, collect and disclose information that is freely available in the public domain without your consent. Information that is business contact information such as your name, position name or title, business telephone number, business address, business electronic mail address or business fax number and any other similar information about you, which are not provided by you for personal purposes, will not be regarded as Personal Data under the PDPA. Your consent to us collecting, using and disclosing any business contact information will not be required. Information you voluntarily provide to us through our Services shall be deemed to be collected with your permission. Such information may include any Personal Data or other information necessary to the use of Services.

Non-Personal Information

When you use our Services, we may track, collect and aggregate Non-Personal Information indicating, among other things, which pages were visited, the order in which they were visited, when they were visited, and which hyperlinks were “clicked.” We also collect information from the URLs from which you linked to our Services. Collecting such information may involve logging the IP address, operating system and browser software used by each user of the Services. Although such information is not Personal Data, we may be able to determine from an IP address a user’s internet service provider and the geographic location of his or her point of connectivity.

We also use or may use cookies and/or web beacons to help us determine and identify repeat visitors, the type of content and sites to which a user of our Services links, the length of time each user spends at any particular area of our Services, and the specific functionalities that users choose to use. Essentially, cookies are a user’s identification card for our servers. Web beacons are small graphic files linked to our servers that allow us to track your use of our Services and related functionalities. Cookies and web beacons allow us to serve you better and more efficiently, and to personalize your experience. Cookies and web beacons are not used to retain Personal Data. From time to time we may also use additional typical methods of collecting data. Please see our Cookie Policy for additional details.

You should be able to control how and whether cookies will be accepted by your web browser. If you reject our cookies, many functions and conveniences of our Services may not work properly.

Personal Data

We collect Personal Data that you provide to us when you register for an account, update or change information to your account, utilize the Services, sign-up for email updates, participate in our public forums, and send us email messages. We may use the Personal Data that you provide to respond to your questions, provide you the specific Services you select, send you updates or other events, and send you email messages about Services maintenance or updates. The Company will be the controller of your Personal Data.

3. How Alias Uses Data

Non-Personal Information

We use Non-Personal Information to build higher quality, more useful Services by performing statistical analyses of the collective characteristics and behavior of our users, and by measuring demographics and interests regarding our Services. We may also use it for other legitimate business purposes.

Personal Data

Except as set forth in this Privacy Policy or as specifically agreed to by you, we will not disclose any Personal Data we gather from you. In addition to the other uses set forth in this Privacy Policy, we may disclose and otherwise use Personal Data as described below. We may also use it for research and other legitimate business purposes, including improving and customizing the Services. In any event, use of your Personal Data will be governed by what a reasonable person would consider appropriate under the circumstances.

We shall not, as a condition to using our Services, require consent to such collect, use or disclosure beyond what is reasonable to achieve such purpose. We shall not obtain or attempt to obtain your consent for collecting, using or disclosing Personal Data by providing false or misleading information with respect to the collection, use or disclosure of your Personal Data, or use deceptive or misleading practices.

We use the information we collect about you or that you provide to us, including any personal information, for various purposes, including:

To Provide and Improve Our Services

Service Delivery: We process information to provide the Services you have requested, including creating and maintaining your account, providing customer support, processing transactions, and fulfilling orders.

Personalization: To offer personalized content, features, and advertising (with your consent where required), and to understand how you interact with our Services to improve your experience.

Product Development: For research and development purposes, to improve our Services, develop new features, and ensure the quality and safety of our service.

Communication: To communicate with you about your account, our Services, changes to our terms, policies, and to respond to your inquiries.

Marketing and Promotions: To market and advertise our Services, including sending you promotional materials or notifications about services we think may be of interest to you, subject to your consent where applicable.

For Security and Legal Compliance

Security: To maintain a safe and secure environment, prevent fraud, detect security incidents, and protect against illegal or harmful activities.

Legal Compliance: To comply with applicable laws, regulations, and legal processes, and to respond to requests from public and government authorities.

Dispute Resolution: To resolve disputes, enforce our agreements, and protect the rights, property, or safety of Alias, our users, or others.

With Your Consent

Additional Uses: For any other purpose we may specify when you provide the information and for which we obtain your consent.

Advanced Monitoring and Prevention

Content Scanning: We employ advanced tools to scan content, such as uploads and exchanges through our Service, to detect and prevent violations of our terms, policies, or illegal or other harmful activity. This includes automatic scanning and, where necessary for legal, safety, or security reasons, manual review of content.

Data Analytics and Business Operations

Analytics: To analyze and monitor the usage of our Service and for internal purposes to help us improve our services.

Business Operations: To manage our relationship and contracts with you, including billing, compliance with contractual obligations, and related administration.

Interactive Features: To allow you to participate in interactive features of our Service when you choose to do so, such as live events, webinars, and forums.

Rewards and Notifications: To provide prizes or rewards to event winners or participants and to send notifications about changes to our Service or your account.

4. Data Collected by Company

In order for you to fully utilize the Services, you will need to create a user profile. Our Services provide users many different functionalities and need to collect and process certain information from you to do the same. You are free to provide as much or as little information to us as you would like. However, the level of information you provide may affect your ability to utilize our Services.

Information You Provide to Us Directly

Identification and Contact Information: Including but not limited to your name, phone number, address, email address, and social media account information.

Account Information: Your email, password, profile settings and preferences, demographic information, and any audio and visual content you share.

Social Media: Social media account and identifier to link account.

Event and Survey Participation: Information you provide when participating in our events or surveys, such as contact details and responses.

Customer Service Interactions: Any information you share when contacting customer service.

Payment Information: Details provided for processing payments through our Service.

Information Collected Automatically

Service Usage Data: Details on how you interact with the Service, including dates, times, your unique Alias account ID, avatar usage and customizations, mouse movements, clicks, keystrokes or actions (such as mute/unmute or video on/off) and other user inputs that help Alias to understand feature usage, improve product design, and suggest features, virtual currency transactions, and specific interactions.

Device and Log Information: Device type, operating system version, IP address, device settings, geographical location (country or state), and network information.

Purchase History: Records of purchases made through the Service, including technical details shared by payment partners.

Cookies and Tracking Technologies: Usage of cookies, web beacons, and other technologies for statistical analysis, preference saving, and providing personalized offers. Note that disabling cookies may affect Service functionality.

We use technology to animate avatars based on facial expressions without storing any camera images or facial tracking data. This data is used in real time and is not recorded.

Legal Basis for Processing

Our collection and processing of personal data are based on:

The need to fulfill our contractual obligations to you.

Our legitimate interests in managing our relationship with Service platform providers, ensuring quality service provision, maintaining IT system security, and optimizing our services through analytics.

Compliance with legal obligations and defense of our rights in legal proceedings.

Improving the Service provided.

5. Transfer of Data

In the course of providing our Service, Alias operates on a global scale. This means that your personal data may be transferred to, stored, or processed in countries outside of your country of residence, including but not limited to the United States, Germany, Singapore, Ireland, Australia, countries within the European Economic Area (EEA), Japan, and the Republic of Korea. These international transfers are essential for the efficient, reliable, and secure delivery of our services to you, wherever you may be located.

Compliance with Data Protection Laws

Alias is committed to ensuring that all international transfers of your personal data comply with applicable data protection laws. We implement robust safeguards to protect your data during cross-border transfers, including Standard Contractual Clauses (SCCs), adherence to certification procedures such as the EU-U.S. Privacy Shield Framework (where applicable), and employing encryption technologies. These measures are designed to ensure an adequate level of data protection across our global operations.

Third-Party Service Providers

Our service delivery involves working with third-party service providers who perform various functions such as hosting, data storage, analytics, and cookie and similar technologies analysis. These providers may access, process, or store personal data in the course of providing their services, potentially involving transfers to countries outside of the EEA. Alias ensures that such transfers are conducted in accordance with this policy and that adequate guarantees, such as SCCs, are in place to protect your personal data.

User Consent

By using our Service, you consent to the transfer, storage, and processing of your personal data as described in this policy. Alias recognizes the importance of your privacy rights and will obtain additional consent where required by law for certain data transfers.

Your Rights

You retain rights over your personal data, regardless of where it is transferred, stored, or processed. These rights include access to your data, correction, deletion, and the right to transfer your data. Alias provides mechanisms to exercise these rights easily and transparently.

Security Measures

The security of your personal data is paramount. Alias employs industry-standard security measures to safeguard your data against unauthorized access, disclosure, alteration, and destruction, irrespective of where your data is stored or processed.

Changes to Our Data Transfer Policy

This data transfer policy may be updated periodically to reflect changes in our practices, legal requirements, or advances in privacy and security standards. We encourage you to review this policy regularly to stay informed about how we protect your personal data across our global operations.

6. Data Sharing and Disclosure

This section outlines how we share and disclose information collected through our Service. We ensure that any sharing of information aligns with the practices described in this policy and adheres to applicable laws and regulations.

Categories of Shared Information

We may share the information we collect with affiliated corporations, subsidiary companies, service providers, business partners, and third parties as necessary to provide our Service efficiently and to achieve the purposes outlined in Section 4.

Publicly Available Information

Information you have elected to share publicly, including your nickname, profile, and any content shared with a public audience, can be seen by anyone. Certain account creation information may be public by default.

Service Providers & Business Partners

We disclose your information to companies assisting in our Service operations, including customer service, advertising, customer satisfaction surveys, billing, and email communications. These entities are contractually restricted from using your information for any purposes other than providing services for Alias.

Business Transfers and Affiliates

Your information may be shared with or transferred to our affiliates, subsidiaries, or third parties in the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of our business or assets.

Payment Partners

Payment and purchase information is processed by our payment partners for payment processing and fraud prevention purposes.

Legal and Law Enforcement Requirements

We may disclose your information to comply with laws, respond to legal processes, enforce our policies, or protect the rights, property, or safety of Alias and our users.

Consent and Requests

With your consent or at your request, we may share your information with third parties beyond the disclosures described in this policy.

Third-Party Links

Our Service may contain links to third-party websites. We are not responsible for the privacy practices of these external sites and encourage you to read their privacy policies.

Consent and Opt-Out Options

You have the right to consent to or opt out of certain uses of your data, especially for marketing purposes. Detailed instructions on managing your preferences are available within our Service or by contacting us.

7. Retention of Data

Alias understands the importance of privacy and is committed to retaining personal information only as long as necessary to fulfill the specified purposes in our Terms of Use and Privacy Policy, as well as to comply with our legal obligations and resolve disputes.

Retention Periods

Account Information: Personal information provided during account signup and usage will be retained until the user deletes their account. After account deletion, a safety retention window is applied:

Safety Retention Window: To protect against unauthorized access, enable account recovery and ensure user safety, we observe a safety retention window of 90 days after account deletion.

Service Usage Records: Information related to the provision of goods or services and user interactions with our Service will be retained until the completion of the transaction or service provision, followed by:

Post-Service Retention: Certain data may be retained for an additional 3 years for resolving any disputes or liabilities connected with the services provided.

Inquiries and Support Communications: Records of user inquiries or support services will be kept until the issue has been resolved to ensure satisfactory user support.

Special Circumstances for Extended Retention

Legal and Regulatory Requirements: In case of ongoing investigations or as required by law, data may be retained beyond the standard periods until such processes are completed.

Dispute Resolution: Information may be held for up to 3 years post the termination of the contractual relationship to address any potential disputes or liabilities.

Compliance with Laws: Compliance with applicable laws may necessitate longer retention periods, such as for tax, anti-fraud, and other financial regulations.

Criteria for Determining Retention Periods

Our data retention periods are based on:

The duration of your relationship with us (e.g., as long as you maintain an account or use our Services).
The presence of a legal or business need to retain the data.
The relevance of the data to our service improvement, security measures, and legal compliance.

Usage and Analytics Data

Short-Term Retention: Usage data is generally kept for shorter periods unless needed to improve service security or functionality, or to comply with legal obligations.

Anonymized Data: We may indefinitely retain data in an aggregated or anonymized form for analytics and service enhancement, which does not identify individual users.

Enhancements for User Data Management

User Control: We empower our users with tools to access, amend, or delete their personal data through their account settings, reinforcing our commitment to user privacy.

Transparency: We commit to maintaining transparency about data retention practices and will notify users of any significant changes to this policy.

Review and Adjustment of Retention Periods

Alias will regularly review and adjust our data retention periods to ensure they remain appropriate for our business needs and comply with current legal standards and best practices.

8. Your Rights

Depending on your jurisdiction, you may have various rights concerning your personal data.

These rights include:

Right of Access: You can request access to your personal data that Alias processes. If the data is inaccurate or incomplete, you have the right to request its correction.
Right of Deletion: You may request the deletion of your personal data, subject to legal requirements for data retention.
Right to Restrict Processing: You have the right to request restrictions on the processing of your personal data under certain conditions.
Right to Object: You can object to the processing of your personal data, especially for direct marketing purposes.
Right to Data Portability: You may request your data in a structured, commonly used format, and we can transfer it to another entity where technically feasible.
Right to Withdraw Consent: You can withdraw consent for data processing at any time, without affecting the lawfulness of processing based on consent before its withdrawal.
Right to Automated Decision-Making and Profiling: You have rights related to not being subject to decisions based solely on automated processing, including profiling, that have legal or similarly significant effects on you.
Right to Lodge a Complaint: If you are in the EU, EEA, UK, or California, you have the right to lodge a complaint with the appropriate data protection authority.

If you are a resident of the European Union (EU) and European Economic Area (EEA), you have certain data protection rights, covered by GDPR. – See more at https://eur-lex.europa.eu/eli/reg/2016/679/oj.

If you are a California resident, you are entitled to learn what data we collect about you, ask to delete your data and not to sell (share) it. Your data protection rights, described above, are covered by the CCPA, short for the California Consumer Privacy Act. To find out more, visit the official California Legislative Information website. The CCPA took effect on 01/01/2020.

To exercise any of these rights, you may contact us through the details provided in the "Contact Us" section of this policy or directly through your account settings. This includes updating your communication preferences, managing cookie settings, and linking/unlinking social media accounts. We hope to enable the ability to exercise these rights via a ‘My Account’’ section on the Alias platform in the near future. As an account owner or a user under a licensed account, you may also take steps to affect your personal data by visiting your account and modifying your personal data directly.

Please note, we may need to verify your identity before processing your request, to protect your privacy and security. While we aim to accommodate all requests, there may be circumstances where we are legally required to retain data or where requests cannot be fulfilled due to technological constraints or other legal obligations.

You can also unsubscribe to emails by clicking the ‘unsubscribe’ link at the bottom of emails sent to you by Alias. Unsubscribing will result in a cessation of emails relating to the topics you unsubscribed from being sent to you.

9. Security

We are committed to employing robust safeguards to protect the data we collect through our Service. This dedication is reflected in our rigorous security measures, which are designed to guard against unauthorized access, disclosure, alteration, and destruction of information entrusted to us.

Despite our efforts, it is important to acknowledge that no method of transmission over the Internet or electronic storage system can be guaranteed to be entirely secure. Therefore, while Alias strives to utilize commercially acceptable means to protect your Personal Data, we cannot assure its absolute security. We continuously evaluate and update our security practices to address evolving threats and vulnerabilities.

You play a crucial role in protecting your own personal information. We urge you to be vigilant in maintaining the secrecy of your unique password and account information. Be aware that your privacy settings and the security of your data can also be impacted by changes to the social media services you connect to our Service. It is important to review the privacy policies and security measures of those external services, as Alias cannot control or be held responsible for the privacy or security practices of any other organization.

10. Children’s Privacy

Our Services are intended for general audiences. We do not knowingly collect or otherwise process any personal information of children under 13 or equivalent minimum age as prescribed in the laws in the relevant jurisdiction. If Company obtains actual knowledge during the course of business, that the app has collected personal information from a child, all information will be deleted from our records and the account will be closed.

If any party becomes aware that a child under the age of 13, or equivalent minimum age in the relevant jurisdiction, has provided us with personal information, they should contact us using the contact details provided in the ‘Contact Us’ section below.

11. Contact Us

If you have any questions, concerns, or inquiries about our Privacy Policy, how we handle your personal information, or if you wish to exercise your rights as a data subject, please do not hesitate to get in touch with us. Alias is committed to ensuring the privacy and security of your personal information and is available through the following means to address your needs:

Email Communication: hello@alias.cm

Alias takes your privacy seriously and aims to respond to your inquiries promptly and comprehensively. We will get back to you as soon as we are able to do so properly.

12. Changes to Our Privacy Policy

Alias reserves the right to update or modify this Privacy Policy at any time and for any reason to reflect changes in our information practices concerning the Service, or changes in the applicable law. To keep you fully informed, we will post a notice on our Service or email you to notify you in advance of material changes to our Privacy Policy, and we will also indicate at the top of the notice the date when it was most recently updated. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy will become effective when they are posted on this page. By continuing to access or use our Service after those revisions become effective, you agree to be bound by the revised policy.