GORILLA’S PRIVACY POLICY

If you access the Gorilla Services in any way, or are a registered Account Holder of the Gorilla Services, you will be deemed to use and be a user of the Gorilla Services. Gorilla will collect the Personal Data of all users of the Gorilla Services, but will do so in compliance with the PDPA. This policy highlights the key information pertaining to what we collect when you use Gorilla Services. It also highlights the key information about how we store, use, share, transfer, and delete that information. It further includes information about how you may manage that information. For full details of how your Personal Data will be collected and processed by Gorilla from the Gorilla Services, please refer to the PDPA. In general, the Personal Data which is collected from you shall be processed in compliance with the PDPA. We share your data with our Data Intermediaries or other third-party service providers used by us to the extent necessary for them to provide their services. We use these Data Intermediaries or other third-party services solely to process or store your information for the purposes described in this policy.

Unless the context otherwise requires, the definitions and interpretative provisions in Schedule 1 apply throughout this Privacy Policy.

1 INFORMATION WE COLLECT

1.1 When you use the Gorilla Services or register an Account with Gorilla, and as you continue to use the Gorilla Services, we collect certain types of information from you, including but not limited to the following:

  • (a) full name;
  • (b) Passport, NRIC, or Identification Number or Information;
  • (c) mailing address;
  • (d) email;
  • (e) telephone number;
  • (f) credit history;
  • (g) geographical location;
  • (h) device identifiers;
  • (i) profile picture;
  • (j) your network usage data or other information gathered automatically by our systems, including computer IP address, links visited, and other activities conducted online;
  • (k) information about how you use the Gorilla Services; and
  • (l) other information which you may provide to Gorilla from time to time.

1.2 If you provide us with any Personal Data relating to a third party, by submitting such information to us, you represent to us that you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes set out in this Privacy Policy.

1.3 You should ensure that all Personal Data submitted to us is complete, accurate, true, and correct. Failure on your part to do so may result in our ability to provide you with the Gorilla Services you have requested.

2 COOKIES AND WEB BROWSER INFORMATIONT

2.1 When you visit the Gorilla Services, we send one or more cookies to your computer and other devices. The information obtained from such cookies may be used by us for storing user preferences and to enable Gorilla or thirdparty advertising partners to display targeted advertisements which may be of interest to you.

2.2 We also collect information which is sent to us by your web browser. When you browse the Gorilla Services, we automatically receive your computer’s IP address which provides us with information that helps us learn about your browser and operating system, such as the name of your operating system and the name and version of your browser.

2.3 Other information we may collect include the address of the web page you were visiting when you accessed the Gorilla Services and the date and time of your visit. The type of information we collect depends on the settings on your web browser.

3 PURPOSE OF PROCESSING

3.1 We use this information to:

  • (a) provide the Gorilla Services and its features to you, including:
    • (i) ensuring the contents of the Gorilla Services are presented in the best way for you and your computer (or mobile device);
    • (ii) providing you with information about products or services that you request for or which we consider may be of interest to you;
    • (iii) allowing you to use various features of the Gorilla Services;
    • (iv) measuring and improving the Gorilla Services and its features;
  • (b) provide you with customer support;
  • (c) provide you with service-related announcements;
  • (d) prevent potentially illegal activities;
  • (e) enforce our T&Cs;
  • (F) generate aggregate, non-identifying information about how people use the Gorilla Services; and
  • (g) for any other purpose for which Gorilla has specifically obtained your consent.
  • (h) provide, test, improve, promote and personalize the Gorilla Services;
  • (i) comply with any applicable rules, laws, regulations, code of practice guidelines, issued by any legal or regulatory bodies which are binding on Gorilla (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies, and conducting audit checks, due diligence, and investigations); and
  • (j) enforce our T&Cs;
  • (k) for any other purposes which are reasonably related to any of the above purposes, or for any other purpose which we may notify you at the time of obtaining your consent.

3.2 If you are an Account Holder, we collect, use, and disclose your Personal Data for the following purposes:

  • (a) Opening or continuation of Account and establishing or providing you with the Gorilla Services (including GO Token Bundles) you subscribe to (including but not limited to service activation, service operations, service delivery, and order processing);
  • (b) facilitating the continuation or termination of your subscription to the Gorilla Services (including but not limited to administering subscription arrangements, account maintenance, account closure, processing renewal of contracts and customer relationship management);
  • (c) facilitation the daily operation of the Gorilla Services (including but not limited to billing, customer service, customer verification, technical support, network maintenance and troubleshooting);
  • (d) facilitating third party services if purchased, obtained, administered, or processed through us;
  • (e) managing and executing our service-level agreements with you (if any);
  • (F) processing of payment instructions, GIRO, direct debit facilities and/or credit facilities requested by you;
  • (g) enforcement of repayment obligations (including but not limited to debt collection, filing of claims, retrieval of payments from losses made by our service partners);
  • (h) administering and processing any insurance claims and payments arising under the respective policies;
  • (i) credit and internal risk management (including but not limited to performing credit checks and disclosures to law enforcement agencies);
  • (j) generating internal reports (including but not limited to annual, operational and management reports);
  • (k) processing referral payments and commission fees to our external partners;
  • (i) administering fee adjustments, refunds and waivers;
  • (m) notifying you of your entitlements under any loyalty and reward programmes with us;
  • (n) analysing your use of the Products and Services so as to help us improve, review, develop and efficiently manage the Products and Services offered to you; and
  • (o) purposes which are reasonably related to any of the above purposes, or for any other purpose which we may notify you at the time of obtaining your consent.

4 USE OF INFORMATION FOR MARKETING PURPOSES

4.1 Gorilla will send you marketing communications by email if they relate to goods and services similar to those you have expressed an interest in and if you have consented to us contacting you in this manner.

4.2 You have the right to unsubscribe to the marketing communications by clicking the corresponding link featured in each marketing communication email sent to you.

4.3 You have the right to request that Gorilla does not use the Personal Data collected for marketing purposes or refrain from transferring the data to third parties for marketing purposes, by notifying Gorilla of the same via https://gorillago.io/ and/or [email protected]

5 POTENTIAL CONSEQUENCES OF PROCESSING

5.1 By registering an Account with Gorilla, you may make available to the public certain Personal Data from your Account, and through interactions on the Gorilla Platforms.

5.2 Where such Personal Data may reveal special category protected data, it is processed on the basis that you have manifestly made it public.

5.3 If you do not agree with and accept the risk of such use of your Personal Data, you will not be permitted to use the Gorilla Services as an Account Holder.

6 POTENTIAL CONSEQUENCES OF PROCESSING

You may at any time object to the use of your Personal Data by notifying Gorilla of the same via https://gorillago.io/, and/or [email protected] Your Account will be suspended in the meantime whilst investigations are underway for any alleged misuse of your Personal Data.

7 TRANSFER OF PERSONAL DATA ACROSS BORDERS

Any personal data provided to us may be transferred to, stored by or disclosed to an overseas recipient. For example, we may use a server hosted overseas to store data, which may include your personal data. Your personal data may also be processed by our employees, third parties and their suppliers operating outside of Singapore who are subjected to personal data protection obligations similar to that PDPA.

8 MODIFICATION OF PERSONAL DATA

You may at any time access and modify your Account Information through your Account. It is your responsibility to ensure that the information therein is accurate and kept up-to-date at all times.

9 EXPORTING OF PERSONAL DATA

You may at any time request to export your Account Information through your Account / by requesting the same through [https://gorillago.io/] and/or [email protected]

10 DELETION OF PERSONAL DATA

You may at any time delete your Personal Data by deleting your Account by requesting to terminate your Account through [portal link], or filling in the request [form – hyperlink] and sending a copy of the duly completed form to [email]. Gorilla will notify you of the acceptance/confirmation of termination of your Account. Your Account will be considered terminated once your Account becomes unrecoverable. Your Account will become unrecoverable after a period of [●] Business Days from the date of notice of confirmation of termination. All your Account Details will be deleted from our systems, saved as aggregated data and to the extent required to facilitate compliance with global industry standards of data retention.

11 RETENTION OF PERSONAL DATA

Gorilla retains Personal Data associated with your Account for the entire duration which your Account remains active, and your consent is not withdrawn. In the event that your Account is deleted, or consent is withdrawn, Gorilla will only retain your Personal Data to the extent required by law and to the extent permitted by the PDPA.

12 DISCLOSURE

12.1 We may disclose your Personal Data if we are required by law to do so or if it is necessary to facilitate any investigation for breach of our T&Cs or to enforce our rights under the T&Cs.

12.2 By using the Gorilla Services, subject to the provisions of the PDPA. Gorilla may share your Personal Data:

  • (a) with parties whom you have consented for Gorilla to share such information;
  • (b) with Gorilla’s partners, affiliates or subsidiaries;
  • (c) in the event of a sale, transfer of ownership of the shares or assets of Gorilla, merger or other similar transaction;
  • (d) where we provide services jointly with other companies or Data Intermediaries;
  • (e) to give search engines access to publicly available information; and
  • (f) as otherwise set forth in this Privacy Policy.

12.3 Information about you may also be shared where you have made that information public by uploading it on or to the public areas of Gorilla Platforms.

13 DATA INTERMEDIARIES AND THIRD PARTY SERVICE PROVIDERS

13.1 In general, the Data Intermediaries or other third-party service providers used by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us. Gorilla shall ensure that they do so within the boundaries of the PDPA.

13.2 This Includes the following categories of recipients:

  • (a) hosting, storage, and other infrastructure;
  • (b) security;
  • (c) analytics;
  • (d) network providers and partners; and
  • (e) communication and support.

13.3 However, when you click on links available on the Gorilla Services, they may redirect you away from the Gorilla Services. Once you exit the Gorilla Services or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy or our website’s T&Cs.

13.4 We are not responsible for the privacy practices of these Data Intermediaries/service providers and encourage you to read their privacy policies in order to understand the manner in which your personal information will be handled by these providers.

13.5 In particular, please note that certain providers may be located in or have facilities that are located in a different jurisdiction. Thus, if you elect to proceed with a transaction that involves the services of a third-party service provider, your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.

14 CONSENT

14.1 Gorilla collects and stores your Personal Data only on the legal basis set out in the PDPA. Consent is obtained when you provide us with Personal Data to register your Account and consciously tick the box to agree to this Privacy Policy.

14.2 If we wish to use your Personal Data for a purpose other than as set out in this Privacy Policy, we will ask you for your express consent.

15 AGE OF CONSENT

15.1 Gorilla does not knowingly provide access to the Gorilla Services to anyone under the Age of Majority or collect any Personal Data in relation to any such person.

15.2 By using the Gorilla Services, you represent that you are at least the Age of Majority in your country/state/province of residence, where applicable.

16 WITHDRAWAL OF CONSENT

You may withdraw consent by deleting your Account at any time by requesting to terminate your Account through [https://gorillago.io/], or filling in the request [form – hyperlink] and sending a copy of the duly completed form to [email protected] Gorilla will notify you of the acceptance/confirmation of termination of your Account. Your Account will be considered terminated once your Account becomes unrecoverable. Your Account will become unrecoverable after a period of 1 (one) Business Days from the date of notice of confirmation of termination. Doing so will erase your Personal Data, save as to where it is aggregated and anonymised, within reasonable time from such a request for withdrawal of consent being made, and will thereafter not collect, use and/or disclose your personal data in the manner stated in your request (except to the extent that Gorilla is prevented from doing so by law).

17 SECURITY

17.1 To protect your Personal Data, we take reasonable precautions and follow industry practices to ensure that such information is not lost, misused, accessed by unauthorised persons, disclosed, altered or destroyed.

17.2 Nonetheless, you should be aware that transmission of information via the internet is not entirely secure and Gorilla cannot guarantee the security of any data transmitted to our Gorilla Services via the internet.

17.3 You should take steps to keep your data secure by protecting your password and other account credentials for your Account and any other account which is accessed through the Gorilla Services.

17.4 In the event that there is a data breach, Gorilla shall notify you within 72 hours with a relevant breach notification.

18 CHANGES TO POLICY

Gorilla reserves the right to modify this Policy at any time to ensure that it is consistent with its business development or changes in applicable legal or regulatory requirements. Changes and clarifications will take effect immediately upon their publication on the Gorilla Services. We will notify you about significant changes to our Privacy Policy. Should you no longer agree to this Privacy Policy, you can opt out of any such changes to our Privacy Policy by deleting your account.

19 GOVERNING LAW

This privacy policy forms part of the T&Cs of the Gorilla Services and shall be governed and construed in accordance with laws of the Republic of Singapore. Any dispute arising out of or in connection with this privacy policy including any question regarding its existence, validity or termination, shall be referred to and finally resolved exclusively by the courts of Singapore.

20 CONTACT INFORMATION

20.1 If you would like to access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information, please contact our Customer Service Support at [email protected]

20.2 For further information on how your data is stored and/or processed through third-party services utilised by Gorilla, the third-party services’ relevant contact information are as follows:

21 FURTHER INFORMATION

We reserve the right to modify this privacy policy at any time. A current version of this policy will be published on our website. If you have any queries or feedback about the privacy policy, please contact [email protected] For more information about PDPA in general, please visit the Personal Data Protection’s website at http://www.pdpc.gov.sg

DEFINITIONS AND INTERPRETATION

Definitions

In this Privacy Policy, unless the context otherwise requires, the following words and expressions shall have the following meanings:

  • Account” means a Gorilla User account provided to an individual who has subscribed to Gorilla Services and completed the required registration process.
  • Age of Majority” means 21 years old, as stipulated in the PDPA, or such age as stipulated by the requisite law in order for Gorilla to lawfully collect Personal Data from the individual without parental consent.
  • Data Intermediaries” means third party service providers engaged by Gorilla to manage or process its data, including Personal Data.
  • IP address” means internet protocol address.
  • PDPA” means the Personal Data Protection Act 2012 (No. 26 of 2012) of Singapore, as may be amended from time to time.
  • Personal Data” means any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person;
  • Gorilla Services” means the Gorilla website (https://gorillago.io/ ) and the mobile application (GorillaApp) (collectively, the “Gorilla Platforms”), including any content, functionality, services, and products, offered on and through the Gorilla Platforms.
  • Unless otherwise defined in this Privacy Policy, all capitalized terms shall have the meanings ascribed to them in the T&Cs and relevant Service Specific T&Cs at.