PRIVACY POLICY

This Privacy Policy informs you of our policies regarding the collection, use and disclosure of information that we, Stack 22 Pte Ltd and/or our subsidiaries and/or affiliates ("Company") receives from users of the software application: Breadcrumbs (the "App") for mobile devices that was created by the Company. This Privacy Policy applies to the App, and Stack 22 Pte Ltd's website and related services (collectively referred to as the "Services"). Your use of the Services will constitute your acknowledgement of your consent to abide and be bound by the Privacy Policy.

We may periodically review and update this Privacy Policy by posting the latest version on www.breadcrumbsapp.com or within the App. Your continued use of the Services will be subject to the latest version of this Privacy Policy.

Contact Us

If you have questions about data protection, or if you have any requests concerning your personal data, please reach out to our Customer Service Representative via email at hello@breadcrumbsapp.com and we will get back to you as soon as possible.

About the App

The App is a location based mobile application that provides a platform for users to discover (or rediscover) places while learning through interactive quizzes and games, gamifying the experience and allowing them to level up and earn rewards.

Through specially curated Breadcrumb Trails, users will be taken on a journey with enhanced experiences through digital and augmented reality. Functionalities include location-based triggers (GPS & Bluetooth beacons), Augmented Reality & Always on cloud services.[ML1]

Our Commitment to Privacy

The Company is committed to complying fully with the requirements of the Personal Data Protection Act 2012 of Singapore (the "PDPA"). In doing so, the Company will ensure compliance to the strictest standards of security and confidentiality in respect of all personal information and data submitted by you via the App or any other website or media platform operated by the Company.

Please note that Third Party merchants whom we may partner with can seek additional information or data from you through the use of the App, the Services, or through a separate data collection method. We do not control, and are not responsible for, the policies and practices of the Third Party merchants with respect to their handling of your information or data. Please contact the Third Party merchants directly for their practices and privacy policies.

Why do we collect your data

In the course of using the Services, we may collect, process, use or disclose personal data received from you for a number of purposes, including but not limited to:-

(a) create accounts and allow you to use the App and/or Services and its functions;

(b) operate the Services;

(c) managing your relationship with the Company;

(d) obtaining feedback from you, responding to your comments and/or assisting with your enquiries;

(e) customise your experience in using the App and/or Services, including a gameplay experience tied to your real-world location;

(f) notify you or send you related information such as service upgrades and updates, security alerts and support messages;

(g) accounting, risk management and record keeping;

(h) to carry out research, planning and statistical analysis, including satisfaction surveys to improve and personalise the products and services offered to you;

(i) sending you marketing and promotional materials, advertisements or information on promotions by our partners or invitations to events;

(j) to enable you to participate in and receive information regarding the rewards and loyalty programs which you may qualify for;

(k) analyze and monitor use of the Services and its functions;

(l) to enable the Company to select and present information that matches the needs of the users or to create personalised contents;

(m) to detect, investigate, and/or prevent activities that may violate the Company's Terms of Use that could be fraudulent or illegal; and/or

(n) any other purpose which is reasonably related to the aforesaid.

By using the Services, you consent to the Company transferring your personal data to any location outside of Singapore for the purposes set out above.

Although you are not obliged to provide the information and/or data as requested when using the Services, you may not be able to enjoy certain functions or features within the App and/or Services if you do not do so.

If you are under the age of 16, you are encouraged to seek prior consent from a parent or guardian before using the Services. As part of the registration process, we require the user to confirm that they are the parent or guardian of any user under the age of 16, and that they have consented to the collection of personal information and/or data of users below the age of 16.

What kind of data is collected

The Company may collect personal information and/or data about you, such as your name and contact information, user login ID and password, profile information (such as profile photo), and other information that is not otherwise publicly available. Occasionally, the Company may also collect additional personal information and/or data from you in connection with contests, surveys, or special offers.

The Company also collects and uses your device location information as you use the App (if you elect to turn on background location tracking for the services), including how or where you move around and events that occur while using the App. The App includes location based triggers whose core feature is to provide a gameplay experience tied to a user's real world location, so the Company needs to know where the user is to operate the services for the user, and to plan the location of in-game resources (for example, to trigger a reward during in-game sponsored locations). The Company identifies the user's location using a variety of technologies, including GPS and WiFi points.

The Company collects and uses the user's in-game progress, actions and achievements, as well as certain information about your mobile device (including device identifiers, device OS, model, configuration, settings and information about third party applications or software installed on your device), to operate the services for you and to personalise your gameplay and user experience.

How do we use your data

When you provide us with your personal information and/or data, we may share such personal information to third parties when required to do so by law. We will not share your personal information except where:

(a) the information is disclosed and/or transferred to any third party who has been duly authorised by the Company to use such information and who will facilitate the provision of the Services, including but not limited to IT services, hosting and maintenance services, data analytics services, organising of the Company's events etc.;

(b) the Company needs to protect and defend its rights and property;

(c) where you have specifically consented to such disclosure; or

(d) the Company deems necessary in order to maintain and improve the Services.

Subscription to Advertising, Promotional or Marketing Materials

The App includes features, such as social media interaction tools and in-game advertising, provided by our partners who operate under their own privacy policies as data controllers. These partners can use advertising identifiers, cookies, web beacons, and other tracking technologies (including location tracking in location-based games) to collect or receive data about you. Our statements under this Privacy Policy do not apply to the features, technologies or practices of such third parties, as we may not control those features and are not responsible for them. We encourage you to check their privacy policies to learn more about their data processing practices.

The Company may from time to time send you promotional or marketing materials based on the personal information and/or data that you have provided to the Company. Such materials may include offers or promotions related to Breadcrumbs events or special offers from our partners, donations and contributions for charitable and/or non-profit making purposes, or products/services offered by our partners that you may be interested in. You acknowledge that the Company may receive monetary or non-monetary benefits in return for providing the personal information and/or data to third parties, and your consent will be sought.

You may choose to opt-out of receiving promotional or marketing materials by logging into the registration or user account maintenance webpage, or by clicking on the automatic link appearing in each newsletter/message, or by contacting the Customer Service Representative of the Company via email at hello@breadcrumbsapp.com.

Your rights

You have the right to correct your data, have your data deleted, object to how we use or share your data, and restrict how we use or share your data. You can always withdraw your consent, for example by turning off GPS location sharing in your mobile device settings.

If you wish to access or amend your data, the Company may request you to provide personal details in order to verify and confirm your identity. Please contact us via email at hello@breadcrumbsapp.com if you need more information on or access to data which you have previously provided.

Cookies and similar technologies

Like most online services, the Company and our partners use cookies and similar technologies to collect information to enable us to interact with you more efficiently, and to operate and improve the Services. For example, cookies help us with things like remembering your user name for your next visit, understanding how you are using our Services, tracking frequency of use, and improving our Services based on that information (essential purposes). We also use cookies for non-essential purposes like analytics and marketing that some of our partners may use to contact you about events that they may offer.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may however prevent you from taking full advantage of the Services.

Third Party Links

The Services may contain links to other websites (including social media websites like Facebook) or applications whose data protection and privacy practices differ from ours. These linked websites have separate and independent privacy policies. We do not control and, therefore, have no responsibility or liability for the content and practices of these linked websites.

Security

The security of your personal information and/or data is important to the Company. We have put in place appropriate administrative and technical security measures and procedures in order to safeguard, protect, and secure your personal information and/or data from unauthorised access or against loss, misuse or alteration. However, you understand that no method of transmission over the Internet, or method of electronic storage, is completely secure. Therefore, while the we strive to protect our users' personal information and data against unauthorised access, loss, misuse or alteration, we cannot guarantee its absolute security.

Retention of Personal Data

We will only retain your personal information and/or data for as long as is necessary for the purposes described in this Privacy Policy. Subject to applicable laws and any legal requirements, your personal information and/or data will be retained until deactivation of the Services or until you request the Company in writing to delete your personal information and/or data.

Governing Law and Jurisdiction

Nothing in this Privacy Policy shall limit or restrict your rights under the PDPA. This Privacy Policy shall be governed by the laws of the Republic of Singapore. You agree to submit to the exclusive jurisdiction of the Singapore courts.