We know that you care how information about you is used and shared, and we appreciate your trust that we will do so carefully and sensibly. This Privacy Policy describes how Topreels Pte. Ltd. and its affiliates (collectively "Topreels", "we", "us", or "our") collect and process your Personal Data through Topreels websites services, and applications that reference this Privacy Policy (together, the "Platform"). In this Privacy Policy, “Personal Data” means data, whether true or not, about you who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.
By using Topreels you confirm you have read and understand this Privacy Policy and agree to the processing of your Personal Data in accordance with this Privacy Policy. IF YOU DO NOT AGREE TO THE PROCESSING OF YOUR PERSONAL DATA IN THE WAY THIS PRIVACY POLICY DESCRIBES, PLEASE DO NOT PROVIDE YOUR PERSONAL DATA WHEN REQUESTED AND STOP USING TOPREELS.
The Platform is provided and controlled by Topreels Pte. Ltd., a company registered and operating in accordance with the laws of Singapore.If you have any questions or concerns regarding this Privacy Policy or the use of your Personal Data, You may contact us via email at support@topreels.com Please note that this Privacy Policy only applies to data collected or received by us through your use of Topreels. It does not apply to, and we are not responsible for, the actions of third party people or companies, the content of their sites, their use of data you provide to them, or any products or services they may offer. Any link to those sites does not constitute our sponsorship of, endorsement of, or affiliation with, those people or companies.
For the purposes of this Privacy Policy, unless the context otherwise requires, “you” and “your” means you, the user of the Platform, and “information” means information which we collect about you or which is provided to us by you, including your personal data. THIS PRIVACY POLICY IS IMPORTANT. WE HOPE YOU WILL TAKE THE TIME TO READ IT CAREFULLY.
The Platform is not designed for users under the age of 13. We do not knowingly collect or solicit Personal Data from children under 13, nor do we knowingly permit them to use our Platform. If you are under 13, please do not send any Personal Data to us, including your name, address, phone number, or email address.
If a parent, guardian, or anyone else becomes aware that a child under 13 has provided us with Personal Data without consent, or suspects that we have information from or about a child, they should contact us at support@topreels.com. If we discover that a user under 13 has created an account or posted content on the Platform, we will promptly terminate the account and remove the information or content as soon as possible.
For users between the ages of 13 and the age of majority for entering into contracts in their jurisdiction (each a “Teen”), it is essential to review the Privacy Policy with a parent or legal guardian. Both you and your parent or legal guardian must understand and agree to the Privacy Policy. Teens may only access or use the Services if (a) both the Teen and their parent or legal guardian have agreed to the Privacy Policy, and (b) the Teen uses an account established by their parent or legal guardian, under their supervision and with their permission. By permitting a Teen to use the Platform, the parent or legal guardian agrees to the Privacy Policy on behalf of both themselves and the Teen, and accepts sole responsibility for all use of the Platform by the Teen, whether authorized by them or not.
We want you to understand the types of information we collect as you use Topreels. This information helps us operate, develop, and enhance our services. It includes basic details like your preferred language, as well as more complex insights such as the advertisements you might find most useful or the mini-series you might enjoy.
The information we collect varies based on your use of Topreels and your choices. When you interact with Topreels, we may gather Personal Data and data that is stored in a way that cannot be traced back to you ("Non-Personal Data").
Your Profile Information. You give us information when you register on the Platform, including your username, password, date of birth (where applicable), email address and/or information you disclose in your user profile.
User Content and Behavioural Information. We process the content you generate and view on the Platform, including preferences you set (such as language choice), your data related to viewing, liking, and saving content, among others.
We collect information through surveys, challenges, and competitions in which you participate. Before you complete any survey, challenge, or competition, we will inform you of its purpose and the identity of the service provider (if we have engaged one). The processing of your information in these instances will be based on your consent, which will be obtained separately for each survey, challenge, or competition. Contact information
If you provide feedback or contact us, or otherwise provide information voluntarily to us, our employees, or our contractors, you contact information, any information you voluntarily provide and any associated data will be collected by us as well.
We automatically record your activities on Topreels, including data related to various app events such as app activations, clicks, purchases, downloads, playbacks, episode views, ratings, usage duration, likes, favorites, shares, and searches (including video or keyword searches), the ads you view, the content you read and issues you encounter, your preferences, purchase history, top-up records, reward information, episode feedback analysis and improvement settings, as well as other detailed information about your usage and operations on Topreels. When you log in on multiple devices, we will use your profile information to identify cross-device activities. Where appropriate, we will also use this information to provide personalized advertisements and inform you about new services and opportunities.
Information from Third Parties. You may choose to share certain data with us from third parties or through your use of the Platform, we may collect such third party data automatically. We have set out further detail on the information we receive from third parties below:
If you choose to register to use the Platform with social networking credentials, such as a third-party account (e.g., Facebook, Google, Apple), we will request permission to access basic information from that account, including your username, email address, public profile, and other possible related information. Similarly, we will share certain information with the relevant social network, such as your app ID, access token, and the referring URL. You can stop sharing that information with us at any time by revoking our access to your third-party account.
We use the information collected from you, along with your interactions on the Platform and other third-party sites and apps, to infer your likely interests and provide you with more relevant advertising. This information includes details about websites you've visited, apps you've downloaded, and purchases you've made, allowing us to predict what else might interest you in the future and evaluate the effectiveness of advertising on our Platform. We gather this information through cookies and similar technologies on our Platform, as well as from similar data received from third parties who advertise on our Platform and whose sites or apps you visit.
Technical Information we collect about you. We collect certain information about the device you use to access the Platform, including your IP address, user agent, mobile carrier, time zone settings, advertising identifiers, device model, operating system, network type, device IDs, screen resolution, app and file names and types, keystroke patterns or rhythms, battery status, audio settings, and connected audio devices. If you log in from multiple devices, we can use your profile information to identify your activity across those devices.
We may collect your payment information if you are a paying customer. This information is required to complete commercial transactions on our Platform and is used to enable and fulfill your orders. If you choose to use a third-party service to finalize and pay for your order, you will provide your credit card number directly to the third party. Please review the relevant app store's terms and notices regarding the handling of such data. To credit your account with the correct value, we keep a record of your purchases, including the time and amount of each transaction.
Non-Personal Data refers to data that cannot be used to identify an individual. Examples include statistics on website visits, application downloads, and product sales volume. We collect this statistical information to understand how users interact with our Platform, which helps us improve our services to better meet your needs. In some instances, we may collect, use, disclose, and transfer Non-Personal Data for other purposes at our discretion. For example, we might share this data with advertisers or publicly display trends about the general use of our Platform.
We and our vendors and service providers use cookies and other similar technologies (e.g., web beacons, flash cookies, etc.) (“Cookies”) to automatically collect information, measure and analyze which web pages you click on and how you use the Platform, enhance your experience using the Platform, improve our services, and provide you with targeted advertising on the Platform and elsewhere across your devices. Cookies enable the Platform to provide certain features and functionality. Web beacons are very small images or small pieces of data embedded in images, also known as “pixel tags” or “clear GIFs,” that can recognize Cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, and similar information from your computer or device.
There are generally different types of cookies:
- Temporary cookies (session cookies): Temporary cookies are stored only during your visit to a website and are deleted when you close your browser.
- Persistent cookies (permanent cookies): Persistent cookies are stored for a longer, but limited, period of time. You can delete persistent cookies yourself from your browser.
- First-party cookies: First-party cookies are set by the operator of the website a user is browsing and are not accessible by browsers across websites.
- Third-party cookies: Third-party cookies are set by another party other than the operator of the website a user is browsing and can be accessed from other websites as well.
- Strictly necessary cookies: These cookies are necessary for the operation of a website. For example, they include cookies that allow you to access the internal areas of a website. These cookies do not collect information about you that can be used for marketing purposes or to track previously visited websites. This category of cookies cannot be disabled.
- Functional cookies: Functional cookies enable the website operator to offer enhanced functionality and personalization. For example, they are used to save information about past choices made by a visitor on a website and to recognize the visitor. If these cookies are not accepted, certain features on a website will not work as intended.
- Analytics/performance cookies: These cookies allow the operator of the website to record and count the number of visitors and to see how visitors move around the website during their visit. This helps website operators improve the way the website works, for example, by ensuring that users can easily find what they are looking for. If these cookies are not accepted, your visit will not be included in the statistics.
- Advertising cookies (marketing): These cookies are used to show you advertising that is tailored to your interests and therefore more relevant to you. If you do not accept these cookies, you will receive a more general and less personalized user experience.
With the exception of strictly necessary cookies, we will use cookies only with your voluntary consent. You can give your consent to our use of cookies other than the strictly necessary cookies by accepting them in the cookie banner displayed when you arrive at the website. You can withdraw your consent at any time via www.topreels.com. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. If you do not consent to our use of cookies, certain services of our Platform might not work as intended.
We reserve the right to change this cookie policy from time to time at our sole discretion. When we do, we will also revise the “last updated” date at the top of this cookie policy. If material changes are made to this cookie policy, we will notify you of such changes by placing a notice on our website. We encourage you to periodically review this cookie policy to stay up to date on how we are using cookies.
How we use your Personal Data
We use your Personal Data to operate, provide, develop, and improve the products and services we offer our customers. These purposes include:
- User Management: We use your Personal Data to manage users, confirm your intention to subscribe, verify age, obtain consent from legal representatives, verify the identity of users and their legal representatives, identify users, and confirm their intention to unsubscribe.
- Service Provision and Improvement: We use your Personal Data to provide functionality, analyze performance, fix errors, and enhance the usability and effectiveness of the Platform. This includes processing transactions, conducting research, developing new features, and improving algorithms.
- Recommendations and Personalization: We use your Personal Data to recommend features, products, and services that might interest you, identify your preferences, and personalize your experience with us. This also includes providing personalized user features and access.
- Communication: We use your Personal Data to communicate with you about your use of our Services, product announcements, software updates, and to respond to your requests for assistance, including account verification support. We may send you notifications, emails, SMS messages, instant messages, and inbox messages to inform you about updates to our Services, Terms of Service, Privacy Policy, operating rules, policies, procedures, new videos, campaigns, promotions, special offers, and other direct marketing information about our products and Services, based on your prior consent. You may withdraw your consent at any time by contacting us at support@topreels.com.
- Content Display and Advertising: We use your Personal Data to display User Content associated with your account and ensure it is available to you when you use our Services. We may also use User Content as part of our advertising and marketing campaigns to promote Topreels and deliver targeted advertising that is tailored to your interests.
- Security and Fraud Prevention: We use Personal Data to prevent and detect fraud, abuse, and illegal activity, protecting the security of our customers, our company, and others. This includes detecting and preventing misuse of our Services, calculating aggregate statistics on the number of unique devices using our Services, and verifying parental and guardian consent for underage minors through a payment procedure.
- Payment Processing: We may collect your payment information if you are a paying customer. This information is required to complete a commercial transaction on our Platform. We use this information to enable and fulfill your transaction. We keep a record of the purchases you make, the time at which you make those purchases and the amount spent.
- Legal Compliance: We collect and use your Personal Data to comply with legal requirements, such as tax or reporting obligations, or to fulfill lawful governmental requests. We also enforce our terms, conditions, and policies.
- Other Purposes: We may combine all the information we collect or receive about you for any of the foregoing purposes and for any other purposes disclosed to you at the time we collect your information or pursuant to your consent.
By integrating these purposes, we aim to provide you with a seamless and personalized experience on Topreels, ensuring that our services meet your needs and preferences.
Information about users is an important part of our business, and we do not sell our users' Personal Data to others. We share your Personal Data only as described below:
- With Your Consent: After obtaining your consent, we will share the information you have authorized with specified third parties or categories of third parties.
- Service Providers: We engage other companies and individuals to provide services for any of the purposes described in this Privacy Policy, such as cloud storage providers, and payment card processing and verification. We require these service providers to offer the same level of protection for user information as stated in this Privacy Policy and prohibit them from retaining, using, or disclosing your information except as necessary to provide services to us.
- Business Partners: We share information with third-party applications and platforms, such as Facebook and Google, that allow you to post information about your activities on our Platform to share with others within your network. This Privacy Policy does not apply to your use of any such third-party applications and services, and we are not responsible for how those third parties collect, use, and disclose your information. We encourage you to review the privacy policies of those third parties before connecting to or using their applications or services to learn more about their information and privacy practices.
- Other Users: Any information that you include in your publicly visible profile, which may include your profile ID, nickname, photo, and personal introduction, will be shared on our Platform with all other users. If you participate in social features, such as chat, any pictures or other electronic information you disclose may become publicly available and may be read, copied, collected, or used by other users.
- Government, Public, Regulatory, Judicial, and Law Enforcement Bodies or Authorities: We may release your information as required by law, such as to comply with a court order, or when we believe in good faith that release is appropriate to comply with the law and reasonably necessary to (a) comply with a legal obligation, process, or request (including tax and related reporting requirements); (b) enforce our Terms and Conditions, Privacy Policy, and other agreements, policies, and standards, including the investigation of any potential violations thereof; (c) detect, prevent, or otherwise address security, fraud, or technical issues; or (d) protect the rights, property, or safety of us, our users, a third party, or the public as required or permitted by law. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
- Disclosures in the Event of Merger, Sale, or Asset Transfer: We may share your information in connection with any merger, sale of our assets, financing, or acquisition of all or a portion of our business by another company. Under these circumstances, we will require third parties or related companies to comply with this Privacy Policy.
- Affiliates: We may share your information with any members, subsidiaries, or affiliates of our company to provide our services, including improving and optimizing our services, preventing illegal use, and supporting users.
- Advertisers and Advertising Networks: We share information with advertisers and third-party measurement companies to show how many and which users of the Platform have viewed or clicked on an advertisement. We may allow third-party advertisers and advertising networks to set technologies and other tracking tools to collect your information, as described in the section “Advertisement; Third Party Content and Services” below, to enable the technical delivery of personalized advertisements to your device.
If you decide to use our Platform or share your information with us, your data may be transferred to, processed, and stored on servers or databases located outside your current country or jurisdiction. It may also be handled by staff operating outside your country who work for us, our suppliers, or our business partners. By submitting your information, you consent to this transfer, storage, and processing. We will take all reasonably necessary steps to ensure that your information is treated securely and in compliance with this Privacy Policy and applicable laws.
We implement appropriate security measures, such as encryption, to ensure the confidentiality of your Personal Data during transmission and storage. These measures protect against unauthorized access, alteration, disclosure, or destruction of data. Access to your Personal Data is restricted to our staff who need it to operate, develop, or improve our services.
While we make good faith efforts to store the information collected on our Services in a secure environment, we cannot guarantee the absolute security of that information during its transmission or storage on our systems. We do not warrant or represent that your information will be protected against loss, misuse, or alteration by third parties, as no method of transmission over the internet or electronic storage is completely secure.
Reliance On Legitimate Interests Exception
In compliance with the Singapore Personal Data Protection Act (“PDPA”), we may collect, use or disclose your personal data without your consent for the legitimate interests of us or another person. In relying on the legitimate interests exception of the PDPA, we will assess the likely adverse effects on the individual and determine that the legitimate interests outweigh any adverse effect.
In line with the legitimate interests’ exception, we will collect, use or disclose your personal data for the following purposes:
a.Fraud detection and prevention.
b.Detection and prevention of misuse of services.
c.Network analysis to prevent fraud and financial crime, and perform credit analysis.
d.Collection and use of personal data on company-issued devices to prevent data loss.
The purposes listed in the above clause may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter.
We generally rely on Personal Data provided by you (or your authorised representative). In order to ensure that your Personal Data is current, we provide mechanisms for updating and correcting your Personal Data across many areas of our Platform. You have the right to rectify and correct your Personal Data by logging into your account at any time. If we agree that your correction request is valid and that the Personal Data is inaccurate or incomplete, we will make efforts to inform any third parties who have received the relevant Personal Data so they can also make corrections. You have the right to access the Personal Data we hold about you, understand how we use it, and know who we share it with. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
You also have the right to request the restriction of processing and the portability of your Personal Data. However, we may continue to process your Personal Data if there are other valid legal grounds for doing so (e.g., for the defense of legal claims or other protections). You have the right to withdraw your consent at any time, but this will not affect the legality of any processing carried out based on your consent prior to its withdrawal. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose Personal Data where such collection, use and disclose without consent is permitted or required under applicable laws.
We will retain your information for as long as your account is active or as necessary to provide you with our services. You can delete your account, and we will evaluate such requests on a case-by-case basis. You can request to delete your account, including your Personal Data, at any time. To do so, please contact us at support@topreels.com or select the [Disable Account] option in the App setting. Please note that deleting your account will result in the loss of access to all or part of our Platform. However, we may retain some of your information for as long as reasonably necessary for our legitimate business interests, including fraud detection and prevention, and to comply with our legal obligations, including tax, legal reporting, and auditing requirements.
You can exercise these rights with us by sending a request to our Data Protection Officer at the following email address: pe@topreels.com. We reserve the right to refuse requests that are not meaningful, manifestly unfounded, or excessive, that infringe on others' privacy rights, that are extremely unrealistic, that require disproportionate technical work, or that are not required under local law. Additionally, requests concerning information that has been made public or given under confidential conditions may be denied. If we believe that certain aspects of a deletion or access request may hinder our ability to legally use the information for anti-fraud and security purposes, we may also reject those requests.
We allow third-party advertisers and advertising networks to serve interest-based advertisements about third-party products and services within our Platform. These advertisers and networks use technologies to send ads and links directly to you. When you use our Platform, third-party tools (SDKs) integrated into our Platform may collect certain information from your device for advertisement display and optimization. This information includes device manufacturer, model, operating system, screen size, orientation, audio settings, battery status, device memory usage, carrier name, IDFV, IDFA or Android Advertising ID, time zone setting, locale settings (country and preferred language), and IP address. They may also use technologies such as cookies, JavaScript, or Web Beacons to measure advertisement effectiveness and personalize the advertising content you see.
Please consult the privacy policies of third-party advertisers and advertising networks for more information on their practices and instructions on opting out of certain practices. Our Privacy Policy does not apply to these third parties, and we cannot control their activities. Any data obtained by these third parties and subsequently shared with us will be managed in accordance with this Privacy Policy.
If you follow a link to any third-party websites, please note that these websites have their own privacy policies. We do not accept responsibility or liability for these policies. Please review these policies before submitting any information to these websites.
We may update this Privacy Policy from time to time to reflect changes in our information practices ("Updated Policy"). We will not reduce your rights under any updates to the Policy without your explicit consent. The date of the last changes will always be indicated.
For changes required to meet security, legal, or regulatory needs, we may not be able to notify you in advance. If you would like to learn about theupdates to the content or features within the Services, please feel free to check through the app or the agreement section on our website at any time. Unless specified otherwise, any changes to this Policy will become effective immediately upon posting.
We encourage you to periodically review the Policy to stay informed about how Topreels is protecting your information.
As you are not permitted to use the services if you do not agree to the Policy, your continued access or use of the services after the Updated Policy is posted will signify your acceptance and agreement to be bound by the Updated Policy. If you do not agree to the Updated Policy, you must stop accessing or using the services and close your account (if applicable).
This Privacy Policy may be prepared in multiple languages. In the event of any inconsistency or different interpretation among any language version, the English language shall always prevail. All other language versions shall be deemed to be automatically amended to conform with and to make the relevant text consistent with the English text.