Privacy Policy
Privacy Policy
Effective from 5th FEB, 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:
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Contact information, such as your first and last name, email address, mailing address, and phone number.
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Content you upload to the Services, such as text, images, audio, and video, along with associated metadata.
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Profile information, such as your username, password, photograph, interests, and preferences.
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Registration information, such as information related to services, accounts, or events you register for.
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Feedback or correspondence, such as information you provide when you contact us with questions, feedback, or other correspondence.
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Responses, answers, and other input, such as quiz responses and other information you provide when using the Services.
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Contest or giveaway information, such as contact information you submit when entering a prize drawing or sweepstakes we host or participate in.
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Demographic information, such as your city, state, country, postal code, and age.
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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.
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Marketing information, such as communication preferences and engagement details.
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Job applicant information, such as professional credentials, educational and work history, and other resume or curriculum vitae details.
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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 providers 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 referrals 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:
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Protect our, your or others rights, privacy, safety or property (including by making and defending legal claims)
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Enforce the terms and conditions that govern the Services
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Protect, investigate, and deter fraudulent, harmful, unauthorized, unethical, or illegal activity
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Maintain the safety, security, and integrity of our Services, products and services, business, databases, and other technology assets
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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-partys services), we may disclose the
personal information that you authorized us to share. However, we do not control the third partys 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-partys authentication service. Additionally, you may be able to control your settings through the
third-partys 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:
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The categories of Personal Information that we have collected.
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The categories of sources from which we collected Personal Information.
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The business or commercial purpose for collecting and/or selling Personal Information.
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The categories of third parties with whom we share Personal Information.
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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.
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Whether weve sold your Personal Information, and if so, the categories of Personal Information received by each category of third party recipient.
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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 Californias 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 parents or guardians
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:
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Identifiers
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Commercial information
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Online identifiers
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Internet or network information
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Inferences
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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.