This Privacy Policy covers your personal information. Personal
information is information or an opinion, whether true or
false, and whether recorded in a material form or not, about
an identified individual, or an individual who is reasonably
identifiable. All personal information received in connection
with our business is subject to strict rules of
confidentiality.
More specifically, "Personal information" is
data that identifies, relates to, describes, can be used to
contact, or could reasonably be linked directly or indirectly
to you. For the purposes of this Privacy Policy, there is no
meaningful distinction between the terms "personal
information" and "personal data".
You may choose not to provide some of the
personal information described above. Please note, however,
that some of our services require some personal information to
operate, so if you choose not to provide the personal
information necessary to operate and provide you with a
particular service or feature of that service, you may not be
able to use that service or feature.
Common examples include your name, username,
password, IP address, unique device identifiers, gender,
signature, records of communication with TIA, address,
telephone number, email, date of birth, website usage
information, responses to market surveys and contests
conducted by TIA or on TIA’s behalf, bank account and digital
wallet details, billing and credit or debit card details,
photos and videos of you, other identification credentials and
biographical details, and commentary or opinions about you.
This policy:
- Sets out the principles TIA follows when
collecting, using, disclosing, retaining, and removing
personal data; and
- Describes other important topics relating to
an individual’s privacy.
By purchasing goods from TIA,
communicating with TIA through email, by telephone, in writing
or by using any of TIA’s other services, including the TIA
website, or by providing personal data to us, you agree to the
collection, use and disclosure of your personal data in the
manner described in this policy.
We may collect some or all the following types of personal
information:
- information that you give us through
your dealings with us.
- information that we may collect from you; and
- information that we may receive from you from
other third-party sources.
The type of personal data that TIA may
collect from individuals will depend upon the particular
transaction and the dealing. Under the paragraph “What does
this Policy Cover?”, you will see most of the personal
information that we will collect from you.
TIA only collects, uses, and discloses personal
data with an individual’s consent or deemed consent or as
otherwise permitted under the PDPA or other applicable laws
and regulations.
Personal Data will only be collected and used
for the primary purposes of, and TIA takes reasonable steps to
ensure the individual is aware of
- conducting, improving, maintaining, and
developing a business relationship.
- processing, servicing, or enforcing
transactions and sending related communications.
- identification and verification purposes in
connection with any of the services or products that may be
supplied to individuals.
- responding to individual’s queries.
- administering contests or market surveys
conducted by TIA or on TIAs behalf
- marketing (such as providing individuals with
information about our products and promotional notices and
offers); and
- improving TIA’s website.
- the use of the information.
- the means of requesting TIA on the provision
of personal data that is in the possession of TIA.
- the means of withdrawing any consent in
respect of the collection, use or disclosure of the personal
data that is in the possession of TIA.
- the identity and contact details of the
organization.
- any law requiring collection of the
information; and
- the main consequences of failure to provide
the information.
In addition, concerning our gaming
services, we use your personal information as follows:
- providing our services.
- investigating and/or preventing suspected
fraud or other criminal activities or misuse of our services.
- where we collect or disclose information that
is or relates to the Internet Protocol Address used to connect
your device to the internet, for the purpose of fraud
detection and management of the integrity of the TNT game
system and other services. This may include detecting when
users are cheating the TNT game system, and for handling
accounts we suspect are stolen or have otherwise been
compromised. This information helps us verify whether the
account or associated assets belong to a particular user.
- where information is or relates to system
version information of your device, or the make and model of
your device, for the purpose of our compatibility assessments
with our software versions and other aspects of our services.
- creating Leader boards of players, comprising
all players or players meeting criteria.
- investigating disputes between players.
- using your personal information to provide you
with information that you have requested from us, although we
do not create a link between your user ID and your user email.
- communicate with you, including to inform you
of updates to the App, TNT and TIA website, our Terms of Use
and/or this Privacy Policy.
- authenticating your financial account
information or processing the transfer of digital assets.
- authenticating your credit or debit card
information.
- using your personal information for marketing
purposes to provide or offer services to you. This includes,
but is not limited to, keeping you up to date with our latest
news, events, special offers and promotion of our brand or
other similar products that we think that you may be
interested in. This includes both our direct marketing to you
or another third party whom you have authorized us to disclose
your personal information to.
- notifying you about any changes to our
products, website, App and/or other software and/or mobile
applications, brand or services offered.
- seeking your opinion and feedback on any of
our services, including for the purposes of product
improvement and customization, website/software improvement
and personalization and other general services.
- for consumer engagement and/or customer
service purposes, including but not limited to identifying the
effectiveness of advertising, allowing you to participate on
website viral features such as sharing website content and
other community features (for example, blogs).
- analyzing the usage of and improve our
services.
- for other general services such as
website/software security, maintenance, identification of
fraud or errors, internal accounting, and administration, and
for any other purpose that we are required or permitted to do
by law; and
- managing our relationships with you and our
other customers.
In addition, we may utilize overseas IT
services (including software, platforms, and infrastructure),
such as data storage facilities or other IT infrastructure. In
such cases, we may own or control such overseas
infrastructure, or we may have entered contractual
arrangements with third party service providers to assist us
with providing our services to you.
As we utilize cross border IT services and
platforms which can be accessed from various countries via an
internet connection, it is not always practicable to know
where your information may be held.
We maintain commercially reasonable technical,
administrative, and physical security measures designed to
protect your information from loss, misuse, unauthorized
access, disclosure, alteration, and destruction.
When your credit or debit card account,
financial account or digital wallet information is being
transmitted to our services or through our services, it will
be protected by cryptographic protocols. To be clear, we do
not ourselves store your credit or debit card account
information, and we do not have direct control over or
responsibility for your credit or debit card account
information. We may use third party payment processors that
are the controllers of your information. Our contracts with
third parties that receive your information require them to
keep it secure and confidential.
However, we cannot guarantee that transmissions
of your information will always be secure or that unauthorized
third parties will never be able to defeat the security
measures taken by us or our third-party service providers.
Except to the extent that liability cannot be excluded or
limited due to applicable law, we assume no liability or
responsibility for disclosure of your information due to
errors in transmission, unauthorized third-party access, or
other causes beyond our control.
We will only keep your information for as long
as reasonably necessary to fulfill the purposes for which your
personal information was originally collected.
We will delete your information after a
reasonable time. You may be required to re-enter your personal
information if it has been deleted.
You agree and acknowledge that your personal
information may be stored at or transferred within Singapore
or a destination outside of Singapore. This will allow staff
operating outside of Singapore (whether employed by us or by a
third party engaged by us or otherwise authorized under this
Privacy Policy to access your personal information) to process
your information for the purposes of providing you with our
services.
We will take all reasonable steps and
precautions to ensure that any transmission of your personal
information via the internet is secure. However, we cannot
guarantee the security of any data transmitted to our website
and you agree and acknowledge that any such transmissions are
at your own risk.
Once we receive your information, we take
reasonable steps to protect your personal information. This
may include storing any information on a secure server and
employing strict procedures and security features to protect
your personal information from any unauthorized recipients and
to prevent unauthorized access to the same. We may also store
your personal information in physical form.
All our employees with access to your
information will be held to the confidentiality obligations as
set out in this Privacy Policy.
TIA discloses personal data:
- for the primary purpose for which it was
collected; or
- for purposes that a reasonable person will
consider appropriate in the circumstances; or
- where the individual has consented; or
- for direct marketing by TIA where consent has
been given but giving individuals the opportunity to opt out
of such direct marketing. TIA includes its contact details in
any direct marketing; or
- where permitted under the PDPA or other
applicable law or if required by law.
IA does not disclose your personal data
for any secondary purposes unless your consent has been given
or if so permitted or required under the PDPA or other
applicable laws and regulations.
TIA will not sell or license any personal data
that it collects from an individual.
There may be other situations where we may
collect and use personal data, which are outside a person’s
reasonable expectation. When this occurs, TIA is committed to
providing the individual with an explanation for the possible
use of the personal data when asking for the individual’s
consent.
TIA discloses personal data:
TIA takes steps to ensure information is
accurate and up to date by updating its records whenever
changes to information come to its attention. TIA disregards
information which seems, on a reasonable basis, be inaccurate
or out of date by reason of the time which has elapsed since
it was collected or by reason of any other information in its
possession.
If an individual has submitted personal data to
TIA electronically or otherwise, and would like it corrected,
then a written request should be sent by email to the Privacy
Officer at marian@nsmg21.com or to one of the addresses below:
- 31A Upper Cross Street #04-98 Hong Lim,
Singapore
TIA will comply with an individual’s
request to correct their personal data as soon as practicable.
If TIA disagrees with any request to correct an
individual’s personal data on reasonable grounds, TIA shall
annotate the personal data with the correction that was
requested but not made.
An individual may withdraw his consent for the collection, use or disclosure of personal data by giving TIA reasonable notice by sending a written request (a) by email to the Privacy Officer at marian@nsmg21.com or (b) to the address below. TIA shall inform the individual of the consequences of the withdrawal of the consent. TIA will cease to collect, use, or disclose the personal data upon such withdrawal unless otherwise permitted or required by the PDPA or other applicable laws and regulations.
As with most websites, when you visit the TIA website or use
an application on the TIA website, TIA may record anonymous
information such as IP address (where not used to identify a
specific individual), time, date, referring URL, pages
accessed and documents downloaded, type of browser and
operating system.
The TIA websites may contain links to or from
other websites. TIA is not responsible for the privacy
practices of other websites. This privacy policy applies only
to the information we collect on the TIA website. We encourage
you to read the privacy policies of other websites you link to
from TIA’s website.
Our TIA and TNT website and/or App and/or other mobile
applications use "cookies". Cookies are small pieces of data
sent from a website and stored in your web browser. Cookies
may collect and store your personal data. You may adjust your
internet browser to disable cookies but if you opt for this,
you may be limited to using certain features of our services.
These pieces of data will allow our website and/or App and/or
other mobile applications to remember who you are and to
obtain information from you which allows us to deliver you a
better and more customized service.
As a result of our website and/or App and/or
other mobile applications' use of cookies, we may collect
information such as your IP address, online activity and your
web browser details. Information that we will not collect, or
store includes your passwords or other sensitive information.
We will use both persistent cookies, which could
remain on your device until their expiration (which can be, in
some cases, up to 10 years), and session cookies, which are
temporary files removed from your device once your browser is
closed.
The types of cookies we may use include
analytical and tracking cookies, which allow us to recognize
and count the number of visitors and analyze use of the
services, as well as to verify transactions, and advertising
and re-targeting cookies, which allow us to generate
appropriate advertising directed to you on our website as well
as on the App.
If you enabled cookies when accessing our
website and/or App and/or other mobile applications, we will
take this as consent to our use of cookies and other
technologies mentioned in our Privacy Policy.
Please note that you should also refer to our
website's Terms of Use for further information on this issue.
TIA will take reasonable steps to ensure that personal data is securely stored. TIA protects personal data from misuse or loss by restricting access to the information in electronic format and by appropriate physical and communications security. Any data destroyed is disposed of in a manner that protects the privacy of personal data in an appropriate manner.
TIA takes all reasonable steps to ensure that all unsolicited information is destroyed immediately.
If an individual wishes to be provided with information regarding their Personal Data that is in the possession or under the control of TIA or the ways in which such Personal Data has been used or disclosed by TIA in the year preceding such request, then that person needs to send a written request by email to the Privacy Officer at marian@nsmg21.com or to the address as detailed below. TIA will handle such requests as soon as reasonably possible in accordance with the PDPA.
TIA allows individuals the option not to identify themselves when dealing with it, where practicable.
Any personal data provided to TIA may be transferred to, stored by, or disclosed to an overseas recipient. For example, TIA may use a server hosted overseas to store data, which may include your personal data. Your personal data may also be processed by employees or by other third parties operating outside of Singapore, who work for TIA, or by the representatives and employees of TIA’s parent company. TIA will take reasonable steps, in the circumstances, before your personal data is disclosed to an overseas recipient, to ensure that the overseas recipient provide a standard of protection to personal data so transferred that is comparable to the protection under the PDPA.
TIA does not collect sensitive information without the individual’s consent and unless it is specifically relevant and necessary for TIA’s primary purposes of conducting, improving, maintaining, and developing a business relationship. All sensitive information is collected and used in accordance with this privacy policy. TIA does not use government identifiers (e.g., tax file numbers) to identify individuals.
TIA complies with all provisions regarding the DNC Registry under the PDPA.
TIA reserves the right to modify this privacy policy at any time. A current version of this policy will be published on TIA’s website or may be obtained free of charge upon request.
If you have any queries or concerns about TIA’s privacy
policy, please contact:
TIA Co. Ltd. Singapore Privacy Officer
Address and email:
marian@nsmg21.com
31A Upper Cross Street #04-98 Hong Lim,
Singapore
Singapore law defines personal data as data, whether true or
not, about an individual who can be identified from that data;
or from that data and other information to which the
organization has or is likely to have access.
The personal data collected by TIA may include,
but not limited to, the following:
- name, title, address.
- personal identification and/or passport
number.
- telephone number.
- email address and online passwords.
- records of communications with TIA.
- responses to market surveys and contests
conducted by TIA or on its behalf.
- credit card or debit card information.
- username, password and other identifiers when
you register at TIA’s website.
In processing personal data, we will
consider the nature of its sensitivity and will only process
sensitive data upon the express consent of the data subject
and only for purposes it was provided, or in accordance with
law.
In processing sensitive data, TIA will inform
data subjects of the sensitive data that is necessary to
fulfill the core functionality of the product or service, and
the consequences of refusal to the processing, for the purpose
of allowing the data subjects to decide whether to give
consent.
Personal data will only be collected and used for the primary
purposes of:
- communicating with employees, customers,
contractors, suppliers, agents, or any other individuals.
- conducting, improving, maintaining, and
developing a business relationship and/or for employment
purposes.
- general HR administration and information
required for the management of the employment relationship.
- processing, servicing, or enforcing
transactions and sending related communications.
- identifying and verifying individuals that
have been supplied with any TIA services or products.
- administering customer orders or managing
projects.
- responding to an individual’s queries.
- administering contests or market surveys
conducted by TIA or on TIA’s behalf.
- marketing with consent (such as providing
individuals with information about TIA products and
promotional notices and offers).
- processing your purchase, application,
inquiry, or request.
- ensuring IT security and resource management.
- ensuring site security.
- compliance with applicable laws and
regulations of regulatory authorities and enforcement
agencies.
- administrative purposes such as billing,
payment, and debt collection.
- responding to any claim and/or legal process;
and
- improving TIA’s website.
TIA discloses personal data:
- for the primary purpose for which it was
collected; or - for purposes that a reasonable person will
consider appropriate in the circumstances; or
- where the individual has consented; or
- for direct marketing by TIA where consent has
been given, but individuals will be given the opportunity to
opt out of such direct marketing. TIA includes its contact
details in any direct marketing; or
- where permitted by law.
- to TIA’s parent, related, affiliate and/or
associate company.
- in any court of law or any relevant party in
connection with any claim or legal
proceedings, legal firms and/or advisors, debt
collection agencies, credit reporting agencies and/or credit
providers.
- to any payment agencies including, but not
limited to, financial institutions for purposes of maintaining
financial records, assessing, or verifying credit, and
facilitating payment.
- regulatory authorities and enforcement
agencies.
- third party service providers, consultants,
insurers, underwriters, auditors, and advisors as well as
their respective agents and/or contractors on a need-to-know
basis; and
- any actual or potential assignee, transferee,
or acquirer of any of TIA’s business in connection with any
corporate exercise.
TIA does not disclose your personal data
for any secondary purposes unless your consent has been
previously obtained in accordance with law.
TIA will not sell or license any personal data
that it collects from an individual.
In situations where TIA processes personal data
outside reasonable expectations, TIA will require your consent
prior to processing.
Any personal data provided to TIA may be transferred to,
stored by, or disclosed to an overseas recipient. For example,
TIA may use a server hosted overseas to store data, which may
include your personal data.
Your personal data may also be processed by
employees or by other third parties operating outside of
Singapore in countries like the United States of America or in
the European Union, who work for TIA, or by the
representatives and employees of TIA’s parent company and
affiliates.
TIA will take reasonable steps, in the
circumstances, before your personal data is disclosed to an
overseas recipient, to ensure that the overseas recipient does
not breach privacy laws in relation to your personal data. In
this regard, TIA has a Transborder Data Flow Agreement in
place that requires foreign recipients of your personal data
to provide a standard of protection comparable to the
protection under the Personal Data Protection Act of 2012
(PDPA).
Where a suspected data breach has occurred, TIA will act in accordance with its data breach response plan. If TIA has determined that a data breach has occurred, we will notify the local data privacy regulator and affected data subject (s) in accordance with law.
TIA gives individuals the option not to identify themselves when dealing with it, where practicable. However, if you do not provide us with the personal data that we request, our ability to handle your inquiry, request, complaint, or application may be diminished.
You may choose whether to provide your personal data, and, if
already provided, you may choose to exercise your right to
object, block, or remove such personal data as provided by
law. If you would like to exercise your right to object,
block, or remove your consent, please contact TIA using the
contact details below.
In this case, however, we may not be able to
provide you the assistance or services you requested. When you
object, block or remove your consent, TIA shall no longer
process your personal data, except in cases allowed or
required by law.
If you would like to update, correct, or access
your personal data, please contact us using the contact
details below.
Through our website, social media, App and/or other software
and/or mobile applications, we provide services to users
throughout the world. We are primarily bound by the Singapore
Data Protection Act, and we will manage your personal
information pursuant to these laws. In addition, as we process
personal information of data subjects inside the European
Economic Area (“EEA”) we are also bound by Regulation (EU)
2016/679, the General Data Protection Regulation (“GDPR”).
The purpose of the following data protection
information is to provide you with an understandable,
transparent, and concise explanation of how we intend to
process your personal data in accordance with Articles 13 and
14 of the GDPR. However, should you require further
explanations relating to our data protection or wish to
exercise any of your rights, please do not hesitate to contact
our Privacy Officer at marian@nsmg21.com.
We recognize the below rights which you enjoy
under the applicable data protection law with respect to your
personal data:
Right to be informed: You have the right to be
informed about the collection and use of your personal data.
This information is set out in the terms of our Privacy
Policy.
Right of access: You may request information
from us at any time as to whether we have stored your personal
data and which personal data it has stored. We are required to
provide this information to you free of charge.
Right to rectification: If your personal data
stored by us is inaccurate or incomplete, you have the right
to demand at any time that we correct the information.
Right to erasure: You have the right to demand
that we erase your personal data if and to the extent that the
data is no longer needed for the purposes for which it was
collected or if the data is processed on the basis of your
consent and you have opted to revoke your consent. In such
cases, we must cease processing your personal data and remove
that data from our IT systems and databases.
You do not have a right to erasure if:
The data may not be deleted due to a statutory
obligation or must be processed due to a statutory obligation.
The processing of data is necessary for the
establishment, exercise, or defense of legal claims.
Right to restriction of processing: You have the
right to demand that we restrict the processing of your
personal data.
Right to object to processing: If your data is
processed by us on the basis of Article 6(1)(f) GDPR, you may
object at any time to processing by us. You may assert all the
rights of data subjects described above against us by
addressing your specific requests by contacting our Privacy
Officer via marian@nsmg21.com.
Right to lodge a complaint with a data
protection supervisory authority: Pursuant to Article 77 GDPR,
you have the right to lodge a complaint with a data protection
supervisory authority if you believe that the processing of
your personal data infringes data protection law.
If you have any queries or concerns about TIA’s privacy
policy, this addendum or about our use of your personal data,
you may write to us using the following contact details:
In addition, you have the right to request
access to the personal information we hold about you by
contacting us or our Privacy Officer by emailing
marian@nsmg21.com or in writing at the following address:
TIA Co. Ltd.
Attn: Data protection officer TIA Co. Ltd.
31A Upper Cross Street #04-98 Hong Lim,
Singapore
If we cannot provide you with access, we will
write to you and provide you with the reasons why we are
unable to provide you with access.
If any personal information that we hold about
you is inaccurate, incomplete or not up to date, you may write
to us or our Privacy Officer and request that we correct the
information at the above address.
You have the right to request that we do not
disclose your personal information (for example, for marketing
purposes). You can exercise your rights by unchecking the
relevant check boxes on our website and/or App and/or other
mobile applications when you provide us with your personal
information, or by writing to us at the above address.
You may choose to opt out of receiving any
further correspondence from us by writing to us at the above
address or emailing us at the above email address.