Privacy Policy

Information we collect and receive

We may collect and receive information from you in the following situations:

• When you register for an account with us (“Account”).
• When you choose to connect your Account with an external third-party service or application, such as Facebook or Google.
• When you use the features and functions available on our Services, for example, by interacting with through our chat or instant messaging feature, placing or booking a swimming lesson or transacting with other users.
• If you contact us, for example, with a query or to report a problem.
• When you register for a survey, campaign, contest and/or lucky draw with us.
• When you interact with us offline or through an external third party.

You are under no obligation to provide the information to us. However, if you choose to withhold the information or to revoke permission for us to receive the information, we may be unable to provide certain aspects of our Services to you.

By providing us with any information relating to a third party (e.g. information of your spouse, children, parents, and/or employees), you represent to us that you have validly obtained the consent of the third party to provide us with their information for the respective purposes.

We may collect and receive the following information. Please note that not all of our Services collect all of the information listed below:

• Account credentials such as username.
• Profile information such as, age, name, gender, identification number, email address, profile photo, mobile number, date of birth and current health information.
• Location information such as last known location, meet-up location and public swimming pool.
• Any other information disclosed by you in any of the above-mentioned methods and/or through the use our Services.
• Aggregate data collected through the use of our Services.
• Any communications between you and another user of our Services.

Your interactions with others

Our Services offer features which allow users to connect and communicate and to share information with each other to complete a transaction. Please use common sense and exercise good judgement when sharing information in these groups or with others. We generally do not monitor or remove the information which you share, and such information may remain available on our Services after your Account has been deactivated, terminated, or is otherwise closed. You are responsible for the information you choose to share with other users.

Why we collect the information and how we use it

We may use the information collected and received from you for the following purposes:

• To verify your identity, update our records and generally maintain your Account with us.
• Provide our Services and customise the content shown to you.
• Develop, operate, improve, deliver and maintain our Services.
• To process transactions.
• To process or arrange payment.
• To process or resolve any dispute arising from or in connection with any transactions, in accordance with our Terms of Service.
• Responding to your queries and resolving complaints.
• To facilitate, confirm and/or provide updates or notifications in relation to any transactions.
• Carry out polls, surveys, analysis and research on how our Services are being used and how we can improve them.
• To facilitate your participation in any contest and/or event.
• To update you on the listings and our Services (e.g. new offers, new chats, new feedback, new comments). These updates will be sent by email and/or through push notifications and you can choose to unsubscribe from these updates at any time through the “Settings” page of your Account.
• To send you marketing and/or promotional materials on the latest products or carefully selected third parties. These updates will be sent by email and/or through push notifications and you can choose to unsubscribe from these marketing communications via the link in the email you have received. These marketing communications may also be communicated to you through text messages and/or voice calls if you have indicated that you wish to receive such updates through these methods.

Who we share your information with:

We may share information about you in the following ways:

• When you register for an Account, the information which you make available on your profile may be viewed by other users of our Services.
• We may share the information with third party service providers which may include but not limited to banks and insurance providers who assist us in performing certain aspects of our Services on our behalf, such as processing transactions, fulfilling requests for information, receiving and sending communications, updating marketing lists, analysing data, providing support services or in other tasks. Such service providers will only have access to your personal information to the extent necessary to perform their functions.
• We may share the information with our potential partners, investors and other parties with a view to a potential business partnership, collaboration, joint venture or otherwise in furtherance of our business.
• We may share any information collected in accordance with this Privacy Policy with: (i) governmental and other regulatory authorities or the courts in any jurisdiction; (ii) any third party claimants or potential third party claimants; or (iii) your card issuing bank, financial institution and/or payment service provider, to process or resolve dispute arising from or in connection with a transaction using our Services in accordance with our Terms of Service.
• In addition to other information described in this Privacy Policy, we may collect and share with third party data management platforms or advertising and analytics partners precise location information. This location information may be used by itself, aggregated, or combined with mobile identifiers (such as IDFAs and Android IDs), and shared with third parties for purposes related to advertising, analytics, attribution (e.g., measuring ad performance), analytics and market research. We have included the links to their privacy policies below.
• We may disclose your personal information if required to do so by law or if we believe that such action is necessary to prevent fraud or crime or to protect our Services or the rights, property, or personal safety of any person.

We respect your privacy, and we will not sell your personal information to any third party. We may disclose data and aggregate statistics about users of our Services and sales to prospective partners, advertisers, sponsors and other reputable third parties in order to describe our Services, deliver targeted advertisements or for other lawful purposes, but these data and statistics will not include information which can be used to identify you.

Transfer of information

By using our Services, you authorise us to use your information for the purposes mentioned above. We will ensure that your information is transferred in accordance with this Privacy Policy and protected in accordance with applicable laws on personal data protection (including, but not limited to, the Personal Data Protection Act 2012).

Protecting your information

The security of your information is important to us. We have security measures in place to protect against the loss, misuse and alteration of information under our control. We also follow generally accepted industry standards to protect the information transmitted to us over the Internet, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security.

It is important that you protect against unauthorised access of your Account and information by choosing your password carefully, and keeping your password and Account secure (e.g. by signing out after using our Services).

Accessing and updating your information

You may access and update your information within our Services through the “Settings” page of your Account.

Where you provide personal information about yourself to us, you are responsible for providing accurate, not misleading, complete and up-to-date information about yourself and any other person whose personal information you provide us, and to update this personal information as and when it becomes inaccurate, misleading, incomplete or out-of-date.

In certain circumstances, you may need to provide to us personal information about someone other than yourself. If so, we rely on you to inform these individuals that you are providing their personal information to make sure they consent to you giving us their information and to advise them about where they can find a copy of this Privacy Policy. If you wish to:

    (a) apply for a copy of the information we hold about you; or

    (b) withdraw consent you previously provided to us to use, collect or disclose the information we hold about you,

please contact us. Please allow us a reasonable period of time to respond to any request and effect any change. We may ask to verify your identity and for more information about your request. Where we are legally permitted to do so, we may refuse your request and may give you reasons for doing so.

Where you have requested for a copy of the information we hold about you, we may charge a reasonable administrative fee to cover the costs of responding to your request. If we decide to do so, we will provide you with a written estimate of such fee beforehand.

Tracking technologies

We use tracking technologies on our Services. This enables us to understand how you use our Services which, in turn, helps us to provide and improve our Services. However, the tracking technologies do not access, receive, or collect information which can be used to identify you. We have listed below some examples of the tracking technologies used on our Services:

• Cookies. A cookie is a small data file sent from a website to your browser that is stored on your device. Cookies are used for a number of purposes, including to display the most appropriate content based on your interests and activity on our Services, estimate and report our Service's total audience size and traffic, and conduct research to improve our Services. We may also partner with selected third-party vendors such as Google Analytics to allow tracking technologies and remarketing services on our Platforms through the use of first party cookies and third-party cookies for such purposes. You can configure your device's settings to reflect your preference to accept or reject cookies. If you reject all cookies, you will not be able to take full advantage of our Services.
• Pixels. We may from time to time use certain Facebook Business Tools such as the Facebook Pixel. This tool allows us to keep track of what users do after they see or click on a Facebook advertisement and enables us to monitor the effectiveness of Facebook ads for purposes of statistics and market research. We will be able to better understand and deliver ads and make them more relevant to you. The collected data remains anonymous and we cannot see the personal data of any individual user.

However, the collected data is saved and processed by Facebook. Facebook may be able to connect the data with your Facebook account and use the data for their own advertising purposes and in accordance with Facebook’s Data Use Policy. Facebook has ultimate control of the information gathered through the Facebook Business Tools and communications.

Data collected in this way is anonymous to us, which means we cannot see the personal data of individual users. However, this data is saved and processed by Facebook. Facebook can connect this data with your Facebook account and use it for its own advertising purposes, in accordance with Facebook’s Data Policy which can be found at https://www.facebook.com/about/privacy/. You can allow Facebook and its partners to place ads on and outside of Facebook. A cookie can also be saved on your device for these purposes.

• Flash cookies. We use Flash cookies (a.k.a local shared objects or LSOs) to store some of your viewing preferences on our Services. These are used to collect and store information, but differ from browser cookies in the amount, type and manner in which data is stored.

Poolva Opt-Out

We may deliver personalised and/or targeted advertisements (each, a “Targeted Ad”) to you in the course of your use of our Services and/or through a variety of advertising networks and exchanges.

From the “Settings” page of your Account, you may opt out of behavioural tracking and/or interest-based advertising through our Platforms. Your changes to such opt-out setting may take 24 hours to become effective.

Please note that if you choose to “opt out”, we will not use information we have collected about you to deliver Targeted Ads, but it does not opt you out of seeing advertisements. You will still see generic, non-targeted advertisements which are served without the use of any information we have collected about you. You may still be served advertisements for other reasons, such as:

• General advertisements served to all users of our Platforms.
• Personalised and/or targeted advertisements from other third parties and not delivered by Poolva through your mobile and/or web activities.

Please also note that even though Poolva does not share your personal data (other than hashed or device identifiers, to the extent they are personal data in some countries) with any advertising networks and exchanges without your consent or unless as specified in this Privacy Policy, when you view or interact with an advertisement via any of your devices, an advertiser or advertising network or exchanges can infer that you are within their target audience; or when you click on an advertisement, the publisher and/or advertiser will know you visited the page that you clicked on and may still be able to associate personal data collected by such third parties directly from you through their cookies and similar tracking technologies.

Changes to this Privacy Policy

We reserve the right to make changes to this Privacy Policy at any time and all changes will be posted here. If we believe that the changes are material, we will notify you of the changes by posting a notice on our Services or by email. You are responsible for reviewing the changes which we make this Privacy Policy. Your continued use of our Services constitutes your acceptance of the updated Privacy Policy.

Third party sites and resources

Our Services may, from time to time, contain links to external sites or resources which are operated by third parties. We have no control over the content and privacy practices of such sites or resources. You are advised to review the privacy policies of these sites and resources operated by third parties and understand how your information may be used by those third parties.

Conflict

Please kindly note that where this Privacy Policy has been translated to any other non-English language, in the event of any inconsistencies in the meaning of any provision of the English language text of this Privacy Policy, the English language text shall prevail.

Contact us

If you have any questions, complaints, concerns, or comments on our Privacy Policy, we welcome you to contact us by sending an email to our DPO as stated above. Your indication at the subject header would assist us in attending to your email speedily by passing it on to the relevant staff in our organisation. For example, you could insert the subject header as "Personal Data".