Privacy Policy

Effective from 11th JUN, 2024

General

This “Privacy Policy” delineates the privacy practices of LTWORKS PTE. LTD., including its subsidiaries and affiliates (hereafter referred to as “LTWORKS,” “we,” “us,” or “our”), regarding the websites, mobile applications, email communications, and other services that we own or control, and which are linked or posted to this Privacy Policy (collectively referred to as the “Services”), as well as the rights and choices available to individuals regarding their information. In cases where we collect personal information for specific products or services, we may provide individuals with supplemental privacy policies that govern how we process the information relating to those products or services.

PERSONAL INFORMATION WE COLLECT:

We collect personal information from you through the Services or other means, which may include:

• Contact information, such as your first and last name, email address, mailing address, and phone number.
• Content you upload to the Services, such as text, images, audio, and video, along with associated metadata.
• Profile information, such as your username, password, photograph, interests, and preferences.
• Registration information, such as information related to services, accounts, or events you register for.
• Feedback or correspondence, such as information you provide when you contact us with questions, feedback, or other correspondence.
• Responses, answers, and other input, such as quiz responses and other information you provide when using the Services.
• Contest or giveaway information, such as contact information you submit when entering a prize drawing or sweepstakes we host or participate in.
• Demographic information, such as your city, state, country, postal code, and age.
• Usage information, such as information about how you use the Services and interact with us, including content you upload and information provided when using interactive features.
• Marketing information, such as communication preferences and engagement details.
• Job applicant information, such as professional credentials, educational and work history, and other resume or curriculum vitae details.
• Other information not specifically listed here, but which we will use in accordance with this Privacy Policy or as disclosed at the time of collection.

We may have pages for our Company or Services on various social media platforms such as Facebook, LinkedIn, Twitter, Google, YouTube, Instagram, and others. Interacting with our pages on these platforms means that the platform provider’s privacy policy applies to your interactions and the personal information collected, used, and processed. You or the platform may provide us with information that we will treat in accordance with our Privacy Policy. However, please note that we do not have control over the privacy practices of third-party platforms. Therefore, we encourage you to review their privacy policy and adjust your privacy settings as needed to protect your personal information.

If you choose to log in to our Services through a third-party platform or social media network, or connect your account on the third-party platform or network to your account through our Services, we may collect information from that platform or network. This information may include your Facebook username, user ID, profile picture, cover photo, and networks to which you belong (e.g., school, workplace). You may also have the option to provide us with additional information through the third-party platform or network, such as a list of your friends or connections and your email address. For more information on your privacy choices, please refer to the “Third-party platforms or social media networks” section of the “Your Choices” section.

INFORMATION WE OBTAIN FROM OTHER THIRD PARTIES:

We may receive personal information about you from third-party sources. For example, a business partner may share your contact information with us if you have expressed interest in our products or services. Additionally, we may obtain your personal information from other third parties, such as marketing partners, sweepstakes providers, contest partners, publicly-available sources, and data providers.

REFERRALS:

Users of our Services may have the option to refer friends or other contacts to us. However, as an existing user, you may only submit a referral if you have permission to provide the referral’s contact information to us so that we may contact them.

COOKIES AND OTHER INFORMATION COLLECTED BY AUTOMATED MEANS:

We, our service providers, and our business partners may automatically collect information about you, your computer or mobile device, and activity occurring on or through the Service. This information may include your computer or mobile device operating system type and version number, manufacturer and model, device identifier (such as the Google Advertising ID or Apple ID for Advertising), browser type, screen resolution, IP address, the website you visited before browsing to our website, location information such as city, state or geographic area, and information about your use of and actions on the Service, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access. Our service providers and business partners may collect this type of information over time and across third-party websites and mobile applications.

On our webpages, we collect this information using cookies, browser web storage (also known as locally stored objects, or “LSOs”), web beacons, and similar technologies. Our emails may also contain web beacons and similar technologies. In our mobile applications, we may collect this information directly or through our use of third-party software development kits (“SDKs”). SDKs may enable third parties to collect information directly from our Services.

Please refer to the Cookies and Similar Technologies section below for additional information.

HOW WE USE YOUR PERSONAL INFORMATION:

We may use your personal information for the following purposes and as described in this Privacy Policy or at the time of collection:

TO OPERATE THE SERVICES:

We use your personal information to operate our Services, which includes:

To personalize your experience and deliver content and product offerings that interest you

To respond to your requests for customer service and other inquiries and feedback

To provide, operate, and improve the Services, including administering contests, promotions, surveys, and other features of the Services

To send you periodic emails and other products and services

To offer follow-up support and email assistance

To provide information about our products and services

To establish and maintain your user profile on the Services and track any points earned from quizzes or trivia games

To facilitate login to the Services through third-party identity and access management providers such as Facebook or Google

To facilitate social features of the Services, such as suggesting connections with other users and providing chat or messaging functionality

To display leaderboards and similar features, including showing your username, trivia score, and rank to other users of the Services

To communicate with you about the Services, including sending you announcements, updates, security alerts, and support and administrative messages

To communicate with you about events or contests in which you participate

To understand your needs and interests and personalize your experience with the Services and our communications

To provide support and maintenance for the Services.

TO DISPLAY ADVERTISEMENTS:

We partner with advertising partners and other third parties that collect information across various channels, both online and offline, to display advertisements on our Services or elsewhere online and deliver more relevant advertising to you. Our advertising partners deliver these ads and may target them based on your use of our Services or your activity elsewhere online.

Our partners may use your information to recognize you across different channels and platforms, including computers and mobile devices, over time for advertising (including addressable TV), analytics, attribution, and reporting purposes. For instance, they may deliver an ad to your web browser based on a purchase you made in a physical retail store or send you a personalized marketing email based on your website visits.

For more information about your choices regarding advertisements, please refer to the Targeted Online Advertising section below.

TO SEND YOU MARKETING AND PROMOTIONAL COMMUNICATIONS:

We may send you marketing communications in accordance with applicable law. You may opt-out of our marketing and promotional communications by following the instructions in the Opt-out of Marketing section below.

FOR RESEARCH AND DEVELOPMENT:

We analyze the use of our Services to improve them, develop new products and services, and study user demographics and use of the Services.

TO MANAGE RECRUITING AND PROCESS EMPLOYMENT APPLICATIONS:

We use personal information, including information submitted in job applications, to manage our recruiting activities, process employment applications, evaluate job candidates, and monitor recruitment statistics.

TO COMPLY WITH LAW:

We may use your personal information as necessary or appropriate to comply with applicable laws, lawful requests, and legal process. This may include responding to subpoenas or requests from government authorities.

FOR COMPLIANCE, FRAUD PREVENTION, AND SAFETY:

We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to:

• Protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims)
• Enforce the terms and conditions that govern the Services
• Protect, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity
• Maintain the safety, security, and integrity of our Services, products and services, business, databases, and other technology assets
• Audit our internal processes for compliance with legal and contractual requirements and internal policies

WITH YOUR CONSENT:

In some cases, we may ask for your explicit consent to collect, use, or share your personal information, such as when required by law.

TO CREATE ANONYMOUS, AGGREGATED, OR DE-IDENTIFIED DATA:

We may create anonymous, aggregated, or de-identified data from your personal information and that of other individuals we collect personal information from. We may do this by removing information that makes the data personally identifiable to you. We may use this anonymous, aggregated, or de-identified data and share it with third parties for our lawful business purposes, including analyzing and improving the Services and promoting our business.

COOKIES AND SIMILAR TECHNOLOGIES:

We use “cookies,” small text files that a site transfers to your computer or other Internet-connected device, to help us understand your preferences based on previous or current site activity. Cookies allow us to provide you with improved services and compile aggregate data about site traffic and interaction. We also use cookies to track points earned from our quizzes and trivia games.

We may also use browser web storage or LSOs for similar purposes as cookies. Web beacons, or pixel tags, are used to demonstrate that a webpage was accessed or certain content was viewed, often to measure the success of our marketing campaigns or engagement with our emails and compile statistics about usage of our websites. We may also use third-party software development kits (SDKs) in our mobile applications for a variety of purposes, including analytics, social media integration, adding features or functionality, and facilitating online advertising.

Web browsers may provide users with the option to disable certain types of cookies on our websites or mobile apps. However, disabling cookies may impact the functionality and features of our websites. To learn more about how to exercise choice regarding the use of browsing behavior for targeted advertising, please refer to the Targeted Online Advertising section below.

HOW WE SHARE YOUR PERSONAL INFORMATION:

We do not share your personal information with third parties without your consent, except in the following circumstances and as otherwise described in this Privacy Policy:

Affiliates. We may share your personal information with our subsidiaries and affiliates for purposes consistent with this Privacy Policy.

Service providers:

We may share your personal information with third-party companies and individuals that provide services on our behalf, such as customer support, hosting, analytics, email delivery, marketing, and database management services. These third parties may use your personal information only as directed by us and in accordance with this Privacy Policy. They are prohibited from using or disclosing your information for any other purpose.

Advertising Partners:

We may share your personal information with third-party advertising partners that we work with or enable to collect information directly via our Services using cookies and similar technologies. These partners may collect information about your activity on our Services and other online services to serve you advertisements, including interest-based advertising, and use hashed customer lists that we share with them to deliver ads to similar users on their platforms.

Sweepstakes and Joint Marketing Partners:

We may share your personal information with other partners in order to provide you with content and other features through our Services, and such partners may send you promotional materials or otherwise contact you regarding products and services that they offer. When you choose to enter a contest or sign up for a sweepstakes, we may share the personal information you provide as part of the offer with the named co-sponsors or other third parties affiliated with such offer.

Third-Party Platforms and Social Media Networks:

If you have enabled features or functionality that connect our Services to a third-party platform or social media network (such as by logging in to the Services using your account with the third-party, providing your API key or similar access token for the Services to a third-party, or otherwise linking your account with the Services to a third-party’s services), we may disclose the personal information that you authorized us to share. However, we do not control the third party’s use of your personal information.

Other Users of the Services and the Public:

We may provide functionality that enables you to disclose personal information to other users of our Services or the public. For instance, you may be able to maintain a user profile with information about yourself or your use of the Services that you can make available to other users or the public. You may also be able to submit content to the Services, such as comments, questions, stories, reviews, surveys, blogs, photos, and videos, and we will identify you by displaying information such as your name, username, social media handle, or a link to your user profile along with the content you submit. However, we do not control how other users or third parties use any personal information that you make available to other users or the public.

Professional Advisors:

We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors, and insurers, where necessary in the course of the professional services that they render to us.

Compliance, Fraud Prevention, and Safety: We may share your personal information for compliance, fraud prevention, and safety purposes as described above.

Business Transfers:

We may sell, transfer, or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction, such as a corporate divestiture, merger, consolidation, acquisition, joint venture, reorganization or sale of assets, or in the event of bankruptcy or dissolution.

YOUR CHOICES

Access or Update Your Information. Depending on the type of account you have registered for, you may be able to access and update certain personal information in your account profile by logging into your account. Some accounts may allow you to control certain privacy settings on the Services through your user preferences.

Opt-out of marketing communications. You can opt-out of marketing-related emails by following the instructions provided at the bottom of the email, or by contacting us at [email protected]. However, you may continue to receive service-related and other non-marketing emails.

Cookies & Browser Web Storage. We may permit service providers and other third parties to use cookies and similar technologies to track your browsing activity across the Services and other third-party websites over time. Most browsers allow you to reject or remove cookies. However, if you disable cookies on some of our Services, certain features may not work properly. For example, disabling cookies may prevent us from tracking the points you have earned from our quizzes or trivia games. Similarly, your browser settings may allow you to clear your browser web storage.

Targeted online advertising. Some of the business partners that collect information about users’ activities on or through the Services may participate in organizations or programs that provide opt-out mechanisms for individuals regarding the use of their browsing behavior or mobile application usage for purposes of targeted advertising.

Users may opt-out of receiving targeted advertising on websites through members of the Network Advertising Initiative or the Digital Advertising Alliance. Users of our mobile applications may opt-out of receiving targeted advertising in mobile apps through participating members of the Digital Advertising Alliance by installing the AppChoices mobile app and selecting their preferences. However, please note that some companies that serve online behavioral advertising may not participate in the opt-out mechanisms provided by the above organizations or programs.

Do Not Track. Some Internet browsers may send “Do Not Track” signals to online services. However, we do not currently respond to “Do Not Track” signals. For more information about “Do Not Track,” please visit http://www.allaboutdnt.com.

Choosing not to share your personal information. If we are required by law to collect your personal information or we need your personal information to provide the Services to you, and you choose not to provide us with this information, we may not be able to provide you with our services. We will notify you of any information that you must provide in order to receive the Services at the time of collection or through other means.

Third-party platforms or social media networks. If you choose to connect to the Services through a third-party platform or social media network, you may be able to limit the information that we obtain from the third-party at the time you log in to the Services using the third-party’s authentication service. Additionally, you may be able to control your settings through the third-party’s platform or service. If you withdraw our ability to access certain information from a third-party platform or social media network, that choice will not apply to information that we have already received from that third-party.

OTHER SITES, MOBILE APPLICATIONS, AND SERVICES

The Services may contain links to third-party websites, mobile applications, products, or other services. Please note that these links do not represent our endorsement of, or affiliation with any third-party. Additionally, our content may be featured on web pages, mobile applications, or online services that are not associated with us. As we do not have control over third-party websites, mobile applications, or online services, we cannot take responsibility for their actions. It is important to note that other websites, mobile applications, and services may have different policies for collecting, using, and sharing your personal information. We encourage you to carefully review the privacy policies of any other websites, mobile applications, or services that you use.

SECURITY PRACTICES

We take the security of your personal information very seriously and have implemented a variety of organizational, technical, and physical measures to protect your data. Despite our efforts, it is important to note that all internet and information technologies carry some inherent risk, and we cannot guarantee the complete security of your personal information.

INTERNATIONAL DATA TRANSFERS

Our headquarters are based in the Singapore, and we work with service providers in other countries. As a result, your personal information may be transferred to Singapore or other locations outside of your state, province, or country. It is important to note that privacy laws in these locations may not be as protective as those in your state, province, or country.

CHILDREN

Our Services are not intended for individuals under the age of 16, and we do not knowingly collect personal information from anyone under the age of 16. If we become aware that we have inadvertently collected personal information from an individual under the age of 16, we will take reasonable steps to delete the information as soon as possible. If you are a parent or guardian and become aware that your child has provided us with personal information without your consent, please contact us using the information provided below, and we will take reasonable steps to delete the information as soon as possible.

CHANGES TO THIS PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time, so please review it frequently. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on our website or mobile application. We may also notify you of material changes in another way that we believe is reasonably likely to reach you, such as via email or other communication channels. Your continued use of our Services following the posting of any changes to this Privacy Policy constitutes your acceptance of those changes.

CONTACTING US

If you have any questions or concerns about this Privacy Policy, or if you would like to exercise any of your rights under this Privacy Policy or applicable law, please contact us at [email protected] or by postal mail at the following address:

6 RAFFLES QUAY #14-06 SINGAPORE(048580)

This section pertains exclusively to residents of California and outlines how we gather, employ, and distribute Personal Information of California residents in the course of operating our business, as well as the rights they have with respect to that Personal Information. In the context of this section, “Personal Information” has the meaning ascribed to it in the California Consumer Privacy Act of 2018 (“CCPA”), but does not cover data that is excluded from the scope of the CCPA.

Your privacy rights as a California resident. As a California resident, you possess the rights specified below concerning your Personal Information. However, these rights are not absolute, and in certain circumstances, we may decline your request as permitted by law.

Access. As a California resident, you have the right to request information about the Personal Information that we have collected and used in the past 12 months. This includes:

• The categories of Personal Information that we have collected.
• The categories of sources from which we collected Personal Information.
• The business or commercial purpose for collecting and/or selling Personal Information.
• The categories of third parties with whom we share Personal Information.
• Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of third party recipient.
• Whether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of third party recipient.
• A copy of the Personal Information that we have collected about you during the past 12 months.

Deletion. You can request that we delete the Personal Information that we have collected from you.

Opt-out of sales. If we sell your Personal Information, you can opt-out of such sales. Furthermore, if you direct us not to sell your Personal Information, we will consider it a request pursuant to California’s “Shine the Light” law to stop sharing your personal information covered by that law with third parties for their direct marketing purposes.

Opt-in. If we know that you are younger than 16 years old, we will ask for your permission (or if you are younger than 13 years old, your parent’s or guardian’s permission) to sell your Personal Information before we do so.

Nondiscrimination. You have the right to exercise the above-mentioned rights without experiencing discrimination. This means that we cannot legally increase the price of our Service or decrease its quality if you choose to exercise your rights.

To exercise your privacy rights, you may follow the steps outlined below:

Access and Deletion: You may request access to and deletion of your Personal Information by sending the email to [email protected]. Please include “CCPA Consumer Request” in the subject line of your email.

Opt-Out of Sale: If you do not want your Personal Information to be sold, you may opt-out by clicking on the “Do Not Sell My Personal Information” link. You can exercise this opt-out by toggling the button next to “Sale of Personal Data” and clicking the “Confirm My Choices” button at the bottom of the opt-out screen.

Please note that we may need to verify your identity before processing your request, which may require you to provide additional information. We will respond to your request within the timeframe required by law.

We reserve the right to verify your California residency to process your requests and will need to confirm your identity in order to process your requests to exercise your access or deletion rights. This is a necessary security measure to ensure that we do not disclose information to an unauthorized individual. In accordance with California law, you may designate an authorized agent to make a request on your behalf. If you choose to do so, we may require identification from both the requester and the authorized agent, as well as any other necessary information to verify your request, including valid permission for the authorized agent to act on your behalf. If we do not receive sufficient information to understand and respond to your request, we may be unable to process it.

We will not charge a fee to access your Personal Information or to exercise any of your other rights. However, if your request is clearly unfounded, repetitive, or excessive, we may charge a reasonable fee or refuse to comply with your request.

We aim to respond to all legitimate requests within 45 days of receiving them. In some cases, if your request is particularly complex or if you have submitted multiple requests, it may take longer than 45 days to respond. If this is the case, we will notify you and keep you informed about the status of your request.

The following chart provides a summary of our collection, use, and sharing practices with respect to Personal Information, categorized according to the CCPA. This information pertains to the 12 months preceding the date this Privacy Policy became effective. The categories in the chart correspond to the categories defined in the general section of this Privacy Policy.

The following chart provides a summary of the personal information (PI) that we collect, as defined under the CCPA, and describes our practices during the 12 months preceding the effective date of this Privacy Policy:

Category of Personal Information (PI)	PI We Collect
Identifiers	Contact information, your content, profile information, registration information, feedback or correspondence, contest or giveaway information, usage information, marketing information, social media platform data, referral information
Commercial Information	Registration information, contest or giveaway information, usage information, marketing information
Online Identifiers	Usage information, marketing information, social media platform data, device data, online activity data and other information collected by automated means
Internet or Network Information	Device data, online activity data and other information collected by automated means
Inferences	May be derived from: your responses, contest or giveaway information, demographic information, usage information, marketing information, device data, online activity data and other information collected by automated means
Professional or Employment Information	Your responses
Protected Classification Characteristics	Your responses, demographic information, may also be revealed in other information we collect, such as profile information or your content
Education Information	Your responses
Sensory Information	Content you choose to upload to the Services

If you are looking for information regarding the sources, purposes, and third parties with whom we share your Personal Information, please refer to the sections titled “Personal Information We Collect,” “How We Use Your Personal Information,” and “How We Share Your Personal Information,” respectively. We may share certain categories of Personal Information, which are outlined in the table above, with companies that assist us in marketing or advertising to you, such as our Advertising Partners, Sweepstakes and Joint Marketing Partners, Third-Party Platforms, and Social Media Networks. For more details on our data sharing practices, please see the relevant sections of this Privacy Policy. Note that some of the Personal Information we share with these entities may be considered a “sale” under California law.

The following categories of personal information may be collected by us:

• Identifiers
• Commercial information
• Online identifiers
• Internet or network information
• Inferences
• Other information that you provide to us, including information included in your responses or demographic information.

For more information about these categories of personal information, please refer to the table above and the “Personal Information We Collect” section in our Privacy Policy.