Privacy Policy

This policy sets out the basis on which Shift Control Pte. Ltd. a company incorporated under the laws of Singapore (together with our subsidiaries, our holding company, subsidiaries of our holding company from time to time, collectively called "ShiftControl", “we”, “us”, or “our”) is committed to protecting your privacy, collects personal data from you and how we process such data.

By using our website shiftcontrol.io and any services made available via such website (our “Site”) or any subdomain of our website, or any services we provide or resell, you accept and consent to the practices and terms set out below.

1. COLLECTION OF INFORMATION
For the purposes outlined in Clause 3., we may collect and process the following information about you:
1.1. Information you give us - information that you provide us (which may include your name, address, email address, telephone number, credit card information and other personal description) by filling in forms on our Site, or by corresponding with us (by phone, email or otherwise), for example:
i. when you report any problem to us;
ii. when you use certain features on our Site;
iii. when you request any support from us; or
iv. when you complete any survey or questionnaire we send you.
1.2. Information we collect about you - information automatically collected when you visit our Site, for example:
i. technical information, including the Internet protocol (IP) address used to connect your computer to the Internet and your log-in information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
ii. information about your visit, including the full Uniform Resource Locators (URLs), clickstream to, through and from our Site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.
1.3. Information we receive from third parties - We work with third parties and we may receive information about you from them, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, or credit reference agencies. We are not responsible for the privacy or data security practices of our customers, which may differ from those provided by this policy. If not stated otherwise in this policy or in a separate disclosure, we process personal data in the role of a processor or service provider on behalf of a customer, who is the responsible controller of the applicable personal data.
1.4. Information we access from connected systems – Where you connect identity providers, productivity platforms, HR systems, device management platforms, or other third-party systems to our Platform, we may access and process information made available through those systems, including user names, email addresses, group memberships, organizational information, account metadata, application access information, OAuth authorization information, usage information, and similar data reasonably necessary to provide the Platform and related services.
We retain personal data for so long as reasonably necessary to provide our services, comply with legal and regulatory obligations, resolve disputes, enforce our agreements, maintain business records, and for other legitimate business purposes. When personal data is no longer required, we will take reasonable steps to delete or anonymize it unless retention is required or permitted by applicable law.

2. OUR ROLE AS CONTROLLER AND PROCESSOR
Depending on the circumstances, we may process personal data as a controller, joint controller, processor, or service provider.

We generally act as a controller in relation to personal data processed for our own business purposes, including account administration, billing, customer relationship management, compliance, marketing, and reseller activities.We may act as a processor or service provider where we process personal data on behalf of a customer in connection with the provision of our Platform or services, in accordance with the customer's instructions. Where we process personal data on behalf of customers as a processor, service provider, or data intermediary, we do so in accordance with the customer's instructions and any applicable contractual arrangements.

3. USES MADE OF THE INFORMATION
We use information held about you for the following purposes:
i. providing, improving and developing our services;
ii. researching, designing and launching new features or products;
iii. presenting content and information in our Site in the most effective manner for you and for the device you use;
iv. providing you with alerts, updates, materials or information about our services or other types of information that you requested or signed up to;
v. complying with laws and regulations applicable to us in any part of the world;
vi. responding or taking part in legal proceedings, including seeking professional advice;
vii. for direct marketing purposes (please see further details in Clause 3.2 below);
viii. communicating with you and responding to your questions or requests; and
ix. purposes directly related or incidental to the above.
3.2. We intend to use your personal data in direct marketing (i.e. offering or advertising products or services by sending the relevant information directly to you). We require your consent specifically for this purpose and you may opt out any time. For the purpose of this clause:
i. the personal data that may be used in direct marketing are those that you provide to us or we collect from you under Clause 1.1 above;
ii. the type of services or products that may be offered or advertised will be our products or services, seminars, conferences or events, and those of our affiliates or business partners;
iii. the relevant information may be sent to you by email;
iv. you may opt out any time by unsubscribing to the mailing list using the unsubscribe link in the email. We will cease to send you marketing information without charge.
3.3. Use and transfer of information relating to third-party APIs and services (where applicable):
i. To provide and improve our services, we may share your personal data with trusted third-party service providers (including Google Workspace, JumpCloud, Workato, and Sequence), through application programming interfaces (APIs), where such sharing is reasonably necessary for delivering our services or enabling specific features you request (for example, payment processing, cloud hosting, data analytics, communications, or integrations with third-party platforms).
ii. We require all such third parties and APIs to use your personal data only for the purposes for which it is disclosed, and to protect it in a manner consistent with the PDPA and our own data protection standards.
iii. Where we resell or administer third-party services, we may also disclose personal data to the relevant third-party provider where reasonably necessary to provision, activate, manage, support, renew, suspend, or terminate the relevant subscription or service.
3.4. Where we provide, facilitate, administer, or resell third-party products and services (including, for example, Google Workspace):
i. We may collect and process personal data such as contact details, account identifiers, billing information, subscription details, and communications data for purposes including account setup, provisioning, license administration, billing, support, compliance, fraud prevention and management of the customer relationship.
ii. The relevant third-party provider may also collect and process personal data independently in connection with its products or services, in accordance with its own privacy policy or notice. We do not control the privacy practices of such third-party providers in relation to their own services, and you should carefully review their applicable privacy documentation.

4. DISCLOSURE OF YOUR INFORMATION
We will keep your personal data we hold confidential but you agree we may provide information to:
i. any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in Section 5 of the Companies Act 1967;
ii. personnel, agents, advisers, auditors, contractors, financial institutions, and service providers in connection with our operations or services (for example staff engaged in the fulfillment of your order, the processing of your payment and the provision of support services);
iii. our overseas offices, affiliates, business partners and counterparts (on a need- to-know basis only);
iv. persons under a duty of confidentiality to us;
v. persons to whom we are required to make disclosure under applicable laws and regulations in any part of the world; or
vi. actual or proposed transferees of our operations (or a substantial part thereof) in any part of the world.
vii. where personal data is transferred internationally, we ensure appropriate safeguards are in place (such as Standard Contractual Clauses or other approved mechanisms) to protect your information in accordance with the PDPA and other applicable law.

5. COOKIES
5.1. Our Site uses cookies to distinguish you from other users of the Site. This helps us to provide you with a good experience when you browse our Site and also allows us to improve our Site.
5.2. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree to the use of cookies. Cookies contain information that is transferred to your computer's hard drive.
5.3. We use persistent cookies and session cookies. A persistent cookie stays in your browser and will be read by us when you return to our Site or a partner site that uses our services. Session cookies only last for as long as the session (usually the current visit to a website or a browser session).
5.4. We use the following cookies:
i. Strictly necessary cookies - These are cookies that are required for the operation of our Site. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
ii. Analytical/performance cookies - They allow us to recognise and count the number of visitors and to see how visitors move around our Site when they are using it. This helps us to improve the way our Site works, for example, by ensuring that users are finding what they are looking for easily.
iii. Functionality cookies - These are used to recognize you when you return to our Site. This enables us to personalize our content for you, greet you by your name and remember your preferences (for example, your choice of language or region).
5.5. You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you do so, you may not be able to access all or parts of our Site.
5.6. We may use third-party web services on our Site. The service providers that administer these services use technologies such as cookies (which are likely to be analytical/performance cookies or targeting cookies), web server logs and web beacons to help us analyze how visitors use our Site and make the information displayed on it more relevant to your interests. The information collected through these means (including IP addresses) is disclosed to these service providers. These analytics services may use the data collected to contextualize and personalize the marketing materials of their own advertising network.

6. THIRD-PARTY SITES 
Our Site or our communication with you may from time to time contain links to third- party websites over which we have no control. If you follow a link to any of these websites, please note that they have their own practices and policies. We encourage you to read the privacy policies or statements of these websites to understand your rights. We accept no responsibility or liability for any practices of third-party websites. Personal data processed by the relevant third-party provider in connection with its own service is governed by that provider’s own privacy policy, notice, and terms. We provide free of charge access to IR-1 by Blackpanda (the "BP Service") see our Terms of Service for more details. We do not control the BP Service and your use thereof is subject to Blackpanda's own privacy policy and other terms found here.

7. SECURITY
7.1. All information you provide to us is stored on our secure servers.
7.2. Any payment transactions will be encrypted using TLS/SSL technology.
7.3. Where we have given you (or where you have chosen) a password that enables you to access certain parts of the Site, you are responsible for keeping this password confidential. You are responsible for protecting your password(s) and other authentication factors, as well as maintaining the security of your devices.
7.4. We restrict access to personal information to our employees, service providers and contractors on a strictly need-to-know basis and ensure that those persons are subject to contractual confidentiality obligations.
7.5. We review our information collection, storage and processing practices from time to time to guard against unauthorised access, processing or use.
7.6. Please note, however, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk.
7.7. In the event of a personal data breach affecting personal data under our control, we will investigate and respond appropriately and will notify affected customers and relevant authorities where required by applicable law.

8. YOUR RIGHTS
You have the right to:
i. check whether we hold personal data about you;
ii. access any personal data we hold about you; and
iii. require us to correct any inaccuracy or error in any personal data we hold about you.
Any request under Clause 8. may be subject to a small administrative fee to meet our cost in processing your request.

9. CHANGES TO OUR PRIVACY POLICY
We may amend this policy from time to time by posting the updated policy on our Site. By continuing to use our Site after the changes come into effect means that you agree to be bound by the revised policy.

10. CONTACT US
If you have any questions, comments or requests regarding personal data, please address them to [email protected].

ShiftControl has designated a Data Protection Officer who can be contacted at [email protected] regarding any questions relating to this Privacy Policy or our handling of personal data.