Last Updated: 12 November 2021
Effective Date: 12 November 2021
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact us via email at firstname.lastname@example.org .
1. INFORMATION COLLECTION
(a) Personal Information: In the course of using the Service (whether as a Requester or Pal), we may require or otherwise collect information that identifies you as a specific individual and can be used to contact or identify you (“Personal Information”). Examples of Personal Information include your name, email address, billing address, and phone number.
(b) Payment Information: If you use the Service to make or receive payments, we will also collect certain payment information, such as credit card or other financial account information, and billing address.
(c) Identity Verification: We may collect Personal Information, such as your date of birth or taxpayer identification number, to validate your identity or as may be required by law, such as to complete tax filings. We may request documents to verify this information, such as a copy of your government-issued identification or photo or a billing statement.
(d) Biometric Identifiers or Service Interaction Information: We may collect Personal Information such as a photograph of your face, a selfie, or data about your interactions with the Service to verify your identity and to detect fraud, identity theft, or other misuse of your account through the use of facial recognition and other technologies. We may request documents to verify this information, such as a copy of your government-issued identification. From time to time, MOBA Pal may require you to take and submit an additional or updated image of your face for comparison to your government-issued identification. The biometric identifiers or information collected are used only for identity verification and platform security and use integrity purposes.
(e) General Audience Service: The Service is general audience and intended for users 18 and older. We do not knowingly collect Personal Information from anyone younger than age 18. If we become aware that a child younger than 18 has provided us with Personal Information, we will use commercially reasonable efforts to delete such information from our files. If you are the parent or legal guardian of a child younger than age 18 and believe that MOBA Pal has collected Personal Information from your child, please contact us at: email@example.com .
(g) Combination of Personal and Non-Identifying Information: Certain Non-Identifying Information would be considered a part of your Personal Information if it were combined with other identifiers in a way that enables you to be identified (for example, combining information with your name). But the same pieces of information are considered Non-Identifying Information when they are taken alone or combined only with other non-identifying information (for example, your viewing preferences). We may combine your Personal Information with Non-Identifying Information, but MOBA Pal will treat the combined information as Personal Information.
(h) Collection of Third-Party Personal Information: We collect the following personal information from you about your contacts or friends: First name, last name, and email address when you provide it to us for the purpose of adding your contacts to a message room.
You do not have a statutory obligation to provide us with any information, but you may have a contractual obligation to do so, and if we do not receive certain information from you, then we will not be able to provide our Service to you. If you have any questions regarding whether provision of information is mandatory and the consequences for withholding such information, please contact us using the contact information below.
1.1 INFORMATION RECEIVED FROM THIRD PARTIES
1.2 INFORMATION COLLECTED AUTOMATICALLY
Like other online companies, we receive technical information when you use our Services. We use these technologies to analyze how people use the Service, to improve how our Site functions, to save your log-in information for future sessions, and to serve you with advertisements that may interest you.
We and our third-party service providers, including analytics and third-party content providers, may automatically collect certain information from you whenever you access or interact with the Service. This information may include, among other information, the browser and operating system you are using, the URL or advertisement that referred you to the Service, the search terms you entered into a search engine that led you to the Service, areas within the Service that you visited, which links you clicked on, which pages or content you viewed and for how long, other similar information and statistics about your interactions, such as content response times, download errors and length of visits to certain pages and other information commonly shared when browsers communicate with websites. We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you, and to improve marketing, analytics, and site functionality.
The information we collect also includes the Internet Protocol (“IP”) address or other unique device identifier (“Device Identifier”) for any device (computer, mobile phone, tablet, etc.) used to access the Service. A Device Identifier is a number that is automatically assigned or connected to the device you use to access the Service, and our servers identify your device by its Device Identifier. Some mobile service providers may also provide us or our third-party service providers with information regarding the physical location of the device used to access the Service.
(b) Web Beacons: We and our marketing partners, affiliates, analytics, and service providers may also employ software technology known as “web beacons” and/or “tracking tags” to help us keep track of what content on our Service is effective and to serve relevant advertising to you. Web beacons are small graphics with a unique identifier that may be invisible to you, and which are used to track the online activity of Internet users. Web beacons are embedded in the web pages you review or email messages you receive. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to our Service, to monitor how MOBA Pal Users navigate the Service, to count how many emails that were sent were actually opened, or to count how many particular articles or links were actually viewed.
(c) Embedded Scripts: We and our marketing partners, affiliates, analytics, and service providers may also employ software technology known as an Embedded Script. An Embedded Script is programming code that is designed to collect information about your interactions with the Service, such as the links you click on. The code is temporarily downloaded onto your computer or other device and is deactivated or deleted when you disconnect from the Service.
In addition, we and our marketing partners, affiliates, analytics, and service providers may use a variety of other technologies (such as tags) that collect similar information for security and fraud detection purposes and we may use third parties to perform these services on our behalf.
1.3 HOW WE RESPOND TO DO NOT TRACK SIGNALS
1.3.1 MOBA PAL DOES NOT RESPOND TO DO-NOT-TRACK SIGNALS.
Please note that your browser setting may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, MOBA Pal does not alter its practices when it receives a “Do Not Track” signal from a visitor’s browser.
1.3.2 USER PROFILES
Pals and Requesters may create a profile, with certain or all information publicly available. You may have the opportunity to create a profile, which consists of information about you, and may include Personal Information, photographs, examples of your work, information on work previously performed via the Service and outside the Service, skills, games played, games record, hourly pay rates and earnings information, feedback/rating information and other information, including your username (“Profile”). The information in your Profile may be visible to all MOBA Pal Users and the general public subject to the privacy choices you make within your MOBA Pal Profile. You may edit certain information in your Profile via your account and may choose to limit who is able to view certain content you post to your Profile. If, in any case, you believe that an unauthorized profile has been created about you, you can request for it to be removed by contacting us at firstname.lastname@example.org .
1.3.3 IDENTITY VERIFICATION
Pals, and Requesters may communicate with each other through the Service. For example, Pals, and Requesters may wish to discuss Requester needs and Pal work proposals. If you communicate with a Requester, that Requester will also be a “data controller” with respect to such communications.
1.3.5 COMMUNITY FORUMS & BLOG
We may offer public forums or blogs. If you participate, your comments and questions will be publicly displayed.
To request removal of your personal information from our blog or community forum, contact us at email@example.com . In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so and why.
We display personal testimonials of satisfied customers on our Service, in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at firstname.lastname@example.org .
1.3.7 POSTINGS THROUGH THE SERVICE
If you choose to post a Request via the Service as a Requester, the contents of such listing will be viewable publicly, unless you designate the listing as only viewable through the Service or as private using the settings available on the applicable website. Requests posted include information such as budget, location, history of request listing(s) by the Requester, the names of other Pals performing work for the Requester, Requester feedback and rating information and timing of project performance.
We also collect feedback from Users about our Service. We use this information to respond to your inquiries, improve the Service and how our Site functions, and develop new products and features.
1.3.9 REFERRAL VIA VARIOUS METHODS
MOBA Pal lets you send request postings to friends via Facebook, Twitter, Pinterst, QR Code and other methods. You should only provide MOBA Pal contact information from individuals who are familiar to you and with their consent. If you choose to use this feature, your friend’s account details which might include email address will be used to send the requested posting and your email address will be used to copy you on the message to your friend or to send the message on your behalf. MOBA Pal stores this information for the sole purpose of sending this one-time email and tracking the success of our referral program. Your friend may contact us at email@example.com to request that we remove this information from our database.
1.3.10 SOCIAL NETWORKING SERVICES
You may register for an account directly with our Site, or through a social networking service. If you register with a social networking service (or later link your account to one), we will collect certain information about you from that social networking service, and what we collect depends on your privacy settings with that social networking service. The Service may also allow you to “like” or share content with social networking services.
You may register to join the Service directly via the Service or by logging into your account with a third-party social networking service (“SNS”) via our Service (e.g., Facebook, and other third-party services that let you sign in using your existing credentials with those services). If you choose to register via an SNS, or to later link your account with the Service to your account with an SNS, we will use the Personal Information you have provided to the SNS (such as your name, email address, gender and other information you make publicly available via the SNS) to create your account. Note that the information we collect from and through an SNS may depend on the privacy settings you have set with the SNS and the permissions you grant to us in connection with linking your account with the Service to your account with an SNS. Other than what we may share with the SNS as described below, the Personal Information an SNS has about you is obtained by the SNS independent of our Service, and MOBA Pal is not responsible for it.
The MOBA Pal Service also may permit additional interactions between it and a third-party website, service, or other content provider, such as enabling you to “like” or share content to a third-party SNS. If you choose to “like” or share content, or to otherwise share information from or via our Service with a third-party site or service, that information may be publicly displayed, and the third-party may have access to information about you and your use of our Service (and we may have access to information about you from that third-party). These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. Your interactions with third parties through an SNS or similar features are governed by the respective privacy policies of those third parties.
You represent that you are entitled to use your SNS account for the purposes described herein without breach by you of any of the terms and conditions that govern the SNS, and without obligating MOBA Pal to pay any fees or making MOBA Pal subject to any usage limitations imposed by such SNS. You can disable the link between your MOBA Pal account and your SNS account at any time through the “Settings” section of our Service. Please note that your relationship with any SNS is governed solely by your agreement(s) with such SNS. If your SNS account terminates, then functions enabled through the link between your MOBA Pal account and your SNS account will terminate as well.
2. USE OF INFORMATION
We use information collected through the Service to provide and improve the Service, process your requests, prevent fraud, provide you with information and advertising that may interest you, comply with the law, and as otherwise permitted with your consent.
2.1 THE INFORMATION WE COLLECT IS USE TO:
(a) Provide and improve the Service, complete your transactions, address your inquiries, process your registration, verify the information you provide is valid, and for compliance and internal business purposes.
(b) Contact you with administrative communications and MOBA Pal newsletters, marketing or promotional materials (on behalf of MOBA Pal or third parties) and other information that may be of interest to you. If you decide at any time that you no longer wish to receive such communications from us, please follow the instructions in our respective channels or email to firstname.lastname@example.org .
(c) Tailor content we display to you and offers we may present to you, both on the Service and elsewhere online.
(d) Administer and develop our business relationship with you and, if applicable, the corporation or other legal entity you represent.
(e) Assess your proposal to perform a Request for MOBA Pal and prepare related governmental and internal statistics reports.
(f) Enforce and comply with the law, including to conduct an investigation, to protect the property and rights of MOBA Pal or a third-party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, fraudulent, unethical or legally actionable activity. We may also use Device Identifiers to identify MOBA Pal Users.
2.2 WE USE YOUR PERSONAL INFORMATION FOR THE PURPOSES DESCRIBED ABOVE:
(a) To Honor Our Contractual Commitments to You. Much of our processing of Personal Information is to meet our contractual obligations to our investors, or to take steps at Users’ request in anticipation of entering into a contract with them.
(b) For Our Legitimate Interests. In many cases, we handle Personal Information on the grounds that it furthers our legitimate interests in commercial activities, such as the following, in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals:
(i) Providing our Site and Service.
(ii) Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity.
(iii) Measuring interest and engagement in our Services.
(iv) Short-term, transient use, such as contextual customization of ads.
(v) Improving, upgrading or enhancing our Services.
(vi) Developing new products and services.
(vii) Ensuring internal quality control and safety.
(viii) Authenticating and verifying individual identities.
(ix) Debugging to identify and repair errors with our Services.
(x) Auditing relating to interactions, transactions and other compliance activities.
(xi) Enforcing our agreements and policies.
(xii) Analyzing and improving our business.
(xiii) Communications, including marketing and responding to your inquiries about our services.
(xiv) Addressing information security needs and protecting our Users, MOBA Pal, and others.
(xv) Managing legal issues.
(c) To Comply with Legal Obligations. We need to use and disclose Personal Information in certain ways to comply with our legal obligations.
3. DATA RETENTION
Unless you request that we delete certain information, we retain government-issued identification documents you submit to verify your identity for 30 days, selfies you submit to verify your identity for 180 days, a copy of the headshot image from your identity document for 3 years, and other information we collect for at least 5 years. Your information may persist in copies made for backup and business continuity purposes for additional time. If you choose to provide us with Personal Information, we encourage you to routinely update the data to ensure that we have accurate and up-to-date information about you.
4. INFORMATION SHARING & DISCLOSURE
We may share information about you to provide the Services, for legal and investigative purposes, in connection with sweepstakes and promotions, or if we are part of a merger or acquisition. We may also share non-identifying information with third parties. You have choices as to whether we share your personal information with third parties for their own marketing purposes.
(a) Information about Pals Shared with Requesters, and Partners of MOBA Pal: We share information regarding Pals who have entered into a contract with a Requester, with Requesters, and MOBA Pal Payment vendors. Note that if a Pal is suspended from the MOBA Pal Service, we may share that information with Requesters for whom that Pal has worked or submitted proposals for work. If you choose to view a Request post or submit a proposal for Request as a Pal via the Service, we may share relevant information with the applicable Requester(s), including, but not limited to, the information contained in your Pal Profile.
(b) Information about Requesters Shared with Pals: If you have entered into a service contract with another user, we may provide him/her with your name, company address, billing address, or tax ID or GST number in order to complete the transaction or to facilitate the resolution of a claim or dispute. The user receiving your information is not allowed to use it for purposes unrelated to the transaction, such as to contact you for marketing purposes, unless you have expressly consented to it.
(c) Service Providers: We may employ third-party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform Service-related services (e.g., without limitation, maintenance services, database management, web analytics and online advertising, payment processing, fraud detection and improvement of MOBA Pal’s features) or to assist us in analyzing how our Service is used. These third-parties may have access to your Personal Information in order to perform these tasks on our behalf.
(e) Legal and Investigative Purposes: MOBA Pal will share information with government agencies as required by law in response to lawful requests by public authorities, including to meet national security or law enforcement requirements and, including without limitation, in connection with reporting earnings. We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), or, at the request of governmental authorities or other third parties conducting an investigation where we determine in our sole discretion the disclosure is necessary to
(i) protect the property and rights of MOBA Pal or a third-party,
(ii) protect the safety of the public or any person, or
(iii) prevent or stop activity we may consider to be, or pose a risk of being, illegal, fraudulent, unethical or legally actionable activity.
(f) Internal and Business Transfers: MOBA Pal may share information, including Personal Information, and any current or future subsidiaries or affiliates, primarily for business and operational purposes, including activities such as IT management, for them to provide services to you, or support and supplement the Services we provide. We may sell, transfer, or otherwise share some or all of our assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets (including, in each case, as part of the due-diligence process with any potential acquiring entity) or in the event of bankruptcy.
(g) Sweepstakes, Contests, and Promotions: We may offer sweepstakes, contests, and other promotions (any, a “Promotion”) that may require registration. By participating in a Promotion, you are agreeing to the official rules that govern that Promotion, which may contain specific requirements of you, including, except where prohibited by law, allowing the sponsor(s) of the Promotion to use your name, voice, likeness, or other indicia of persona in advertising or marketing associated with the Promotion. If you choose to enter a Promotion, your Personal Information may be disclosed to third-parties or the public in connection with the administration of such Promotion, including, without limitation, in connection with winner selection, prize fulfilment, and as required by law or permitted by the Promotion’s official rules, such as on a winner’s list.
5. THIRD-PARTY ANALYTICS PROVIDERS, AD SERVERS AND SIMILAR THIRD PARTIES
We may work with advertising agencies and vendors who use technology to help us understand how people use our Site. These vendors may use technologies to serve you advertisements that may interest you. You can choose to opt out of receiving interest-based advertising.
MOBA Pal works with (or may in the future work with) network advertisers, ad agencies, analytics service providers and other vendors to provide us with information regarding traffic on the Service, including pages viewed and the actions taken when visiting the Service; to serve our advertisements on other websites, within mobile apps and elsewhere online; and to provide us with information regarding the use of the Service and the effectiveness of our advertisements. Our service providers may collect certain information about your visits to and activity on the Service as well as other websites or services, they may set and access their own tracking technologies on your device (including cookies and web beacons), and may use that information to show you targeted advertisements. Some of these parties may collect Personal Information when you visit the Service or other online websites and services. We may also share certain Non-Identifying Information with these parties, including Hashed Information, in connection with the services they provide to us.
6. YOUR CHOICES & RIGHTS
According to applicable law, you may have certain choices and rights associated with your personal information.
(a) Registered MOBA Pal Users may update their choices regarding the types of communications you receive from us through your online account.
(b) You may opt-out of receiving marketing emails from us by following the opt-out instructions provided in those emails. Please note that we reserve the right to send you certain communications relating to your account or use of the Service (for example, administrative and service announcements) via email and other means and these transactional account messages may be unaffected if you opt-out from receiving marketing communications.
(c) Registered MOBA Pal Users who access the Service by using an MOBA Pal mobile application may, with permission, receive push notifications. Similarly, registered MOBA Pal Users who access the Service by using certain desktop browsers may, with permission, receive push notifications. Notification preferences can be modified in the settings menu for the mobile application or the applicable browser.
6.1 DATA SUBJECT RIGHTS.
In accordance with applicable law, you may have the right to:
(a) Access Personal Information about you, including:
(i) confirming whether we are processing your personal information;
(ii) obtaining access to or a copy of your personal information.
(b) Request Correction of your personal information where it is inaccurate, incomplete or outdated. In some cases, you can update your personal information within your MOBA Pal account by logging in and visiting settings/user settings.
(c) Request Deletion, Anonymization or Blocking of your personal information when processing is based on your consent or when processing is unnecessary, excessive or noncompliant. Note that if your information is deleted, then your account may become deactivated. If your account is deactivated or you ask to close your account, you will no longer be able to use the Service. If you would like to close your account in our system, you can do so through the MOBA Pal Service (once you have logged in, visit settings / user settings, and then click on the close my account link).
(d) Request Restriction of or Object to our processing of your personal information when processing is noncompliant.
(e) Withdraw your Consent to our processing of your personal information. If you refrain from providing personal information or withdraw your consent to processing, some features of our Service may not be available.
(f) Request data portability and receive an electronic copy of personal information that you have provided to us.
(g) Be informed about third parties with which your personal information has been shared.
(h) Request the review of decisions taken exclusively based on automated processing if that could affect data subject rights.
While we strongly encourage you to first raise any questions or concerns about your Personal Information directly with us, you have a right to lodge a complaint with the relevant supervisory authority and to seek judicial remedy.
We will use commercially reasonable efforts to honour your requests for deletion; however, certain information will actively persist on the Service even if you close your account, including messages you posted to the Service. In addition, the rights described above may be limited, for example, if fulfilling your request would reveal personal information about another person, or if you ask us to delete information, we are required by law to keep or have compelling legitimate interests in keeping (such as for fraud prevention purposes). Your Personal Information may remain in our archives and information you update or delete, or information within a closed account, may persist internally for our administrative purposes, to the extent permitted by law. In addition, we typically will not remove information you posted publicly through or on the Service. Bear in mind that neither you nor MOBA Pal can delete all copies of information that has been previously shared with others on the Service.
We take a number of steps to protect your data, but no security is guaranteed. MOBA Pal takes commercially reasonable steps to help protect and secure the information it collects and stores about MOBA Pal Users. All access to the Site is encrypted using industry-standard transport layer security technology (“TLS”). When you enter sensitive information (such as tax identification number), we encrypt the transmission of that information using secure socket layer technology (“SSL”). We also use HTTP strict transport security to add an additional layer of protection for our MOBA Pal Users. But remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. Thus, while we strive to protect your Personal Information, MOBA Pal cannot ensure and does not warrant the security of any information you transmit to us.
8. TRANSFER OF PERSONAL INFORMATION GLOBALLY
Because we are a Republic of Singapore company, we process and store your information in the Republic of Singapore and our service providers may process and store it elsewhere.
When we transfer Personal Information from territories in the EEA or with similar laws to our affiliates or service providers in the Republic of Singapore and elsewhere outside the EEA, we rely on approved data transfer mechanisms, which may include standard contractual clauses approved by the European Commission and the Privacy Shield, as described below. You may request a copy of the standard contractual clauses relevant to your Personal Information, if any, using the contact information below.
9. PDPA NOTICE
MOBA Pal Republic of Singapore operations adhere to the Personal Data Protection Act Policies (“PDPA”) with respect to the Personal Information that they receive. To learn more about PDPA, please visit https://www.pdpc.gov.sg/Overview-of-PDPA/The-Legislation/Personal-Data-Protection-Act .
MOBA Pal does not rely on the PDPA as a legal basis for the transfer of personal data, however, when MOBA Pal or one of its affiliates receives Personal Information under the PDPA and then transfers it to a third-party service provider acting as an agent on their behalf, MOBA Pal or its affiliate may have certain responsibility under PDPA if both
(i) the agent processes the information in a manner inconsistent with PDPA and
(ii) MOBA Pal or its affiliate is responsible for the event giving rise to the damage.
For other Personal Information MOBA Pal or its affiliates receive under PDPA, MOBA Pal and its affiliates have committed to refer unresolved privacy complaints. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit https://www.pdpc.gov.sg/Complaints-and-Reviews for more information and to file a complaint.
10. LINKS TO OTHER SITES
Our Service contains links to other websites. If you choose to click on a third-party link, you will be directed to that third-party’s website. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third-party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third-party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit Personal Information from you. We encourage you to read the privacy policies or statements of the other websites you visit.
11. PUBLIC PROFILE
The profile you create on our Site will be publicly accessible unless otherwise indicated. You may change the privacy settings of your profile through your account portal.
Phishing websites imitate legitimate websites in order to obtain personal or financial information. Identity theft and the practice currently known as “phishing” are of great concern to MOBA Pal. Additionally, if you believe you have received an email or had a similar interaction with a third-party pretending to be MOBA Pal, please report it at email@example.com .
14. CONTACT MOBA PAL