🛡️ Privacy Policy

Effective April 11, 2024

1. INTRODUCTION

1.1 Welcome to the REN platform run by REN Consulting Group Compnay Limited and its affiliates (individually and collectively, "REN", "we", "us" or "our"). REN takes its responsibilities under applicable privacy laws and regulations ("Privacy Laws") seriously and is committed to respecting the privacy rights and concerns of all Users of our REN website and mobile application (the "Platform") (we refer to the Platform and the services we provide as described on our Platform collectively as the "Services"). Users refers to a user who registers for an account with us for use of the Services, including both buyers and sellers (individually and collectively, “Users”, “you” or “your”). We recognize the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data. This Privacy Policy (“Privacy Policy” or “Policy”) is designed to assist you in understanding how we collect, use, disclose and/or process the personal data you have provided to us and/or we possess about you, whether now or in the future, as well as to assist you in making an informed decision before providing us with any of your personal data.

1.2 1.2 "Personal Data" or "personal data" means data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access. Common examples of personal data could include name, identification number and contact information.

1.3 By using the Services, registering for an account with us, visiting our Platform, or accessing the Services, you acknowledge and agree that you accept the practices, requirements, and/or policies outlined in this Privacy Policy, and you hereby consent to us collecting, using, disclosing and/or processing your personal data as described herein. IF YOU DO NOT CONSENT TO THE PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED IN THIS PRIVACY POLICY, PLEASE DO NOT USE OUR SERVICES OR ACCESS OUR PLATFORM. If we change our Privacy Policy, we will notify you including by posting those changes or the amended Privacy Policy on our Platform. We reserve the right to amend this Privacy Policy at any time. To the fullest extent permissible under applicable law, your continued use of the Services or Platform, including placing of any orders, shall constitute your acknowledgment and acceptance of the changes made to this Privacy Policy.

2. WHEN WILL REN COLLECT PERSONAL DATA?

2.1 We will/may collect personal data about you: 1. when you register and/or use our Services or Platform, or open an account with us; 2. when you submit any form, including, but not limited to, application forms or other forms relating to any of our products and services, whether online or by way of a physical form; 3. when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our products and services; 4. when you interact with us, such as via telephone calls (which may be recorded), letters, fax, face-to-face meetings, social media platforms and emails, including when you interact with our customer service agents; 5. when you use our electronic services, or interact with us via our application or use services on our Platform. This includes, without limitation, through cookies which we may deploy when you interact with our application or website; 6. when you grant permissions on your device to share information with our application or Platform; 7. when you link your REN account with your social media or other external account or use other social media features, in accordance with the provider’s policies; 8. when you carry out transactions through our Services; 9. when you provide us with feedback or complaints; 10. when you register for a contest; and/or 11. when you submit your personal data to us for any reason. The above does not purport to be exhaustive and sets out some common instances of when personal data about you may be collected.

2.2 We may collect personal data about you from you, our affiliates, third parties, and from other sources, including without limitation business partners (such as logistics or payment service providers), credit bureaus or scoring agencies, marketing service providers or partners, referral or loyalty programs, other users of our Services or publicly available or governmental sources of data.

2.3 In some situations, you may provide personal data of other individuals to us (such as your family members or friends or persons in your contact list). If you provide us with their personal data, you represent and warrant that you have obtained their consent for their personal data to be processed in accordance with this Poliy.

2.4 This Policy applies in conjunction with other notices, contractual clauses, consent clauses that apply in relation to the collection, storage, use, disclosure and/or processing of your personal data by us and is not intended to override those notices or clauses unless we state expressly otherwise.

3. COLLECTION OF PERSONAL DATA

3.1 The personal data that REN may collect includes but is not limited to: 1. name; 2. email address; 3. date of birth; 4. billing and/or delivery address; 5. bank account and payment information; 6. telephone number; 7. gender; 8. information sent by or associated with the device(s) used to access our Services or Platform; 9. information about your network, including your contact list when you share permissions on your device, and the people and accounts you interact with; 10. photographs or audio or video recordings; 11. government issued identification or other information required for our due diligence, know your customer, identity verification, and/or fraud prevention purposes; 12. marketing and communications data, such as your preferences in receiving marketing from us and third parties, your communication preferences and history of communications with us, our service providers, and other third parties; 13. usage and transaction data, including details about your searches, orders, the advertising and content you interact with on the Platform, and other products and services related to you; 14. location data; 15. any other information about the User when the User signs up to use our Services or Platform, and when the User uses the Services or Platform, as well as information related to how the User uses our Services or Platform; and 16. aggregate data on content the User engages with.

3.2 You agree not to submit any information to us which is inaccurate or misleading, and you agree to inform us of any inaccuracies or changes to such information. We reserve the right at our sole discretion to require further documentation to verify any information provided by you.

3.3 If you sign up to be a user of our Platform using your social media account (“Social Media Account”), link your REN account to your Social Media Account or use any REN social media features, we may access information about you which you have voluntarily provided to your Social Media Account provider in accordance with such provider's policies, and we will manage and use any such personal data in accordance with this Policy at all times.

3.4 If you do not want us to collect the aforementioned information/personal data, you may opt out at any time by notifying our Data Protection Officer in writing. Further information on opting out can be found in the section below entitled "How can you withdraw consent, remove, request access to or modify information you have provided to us?". Note, however, that opting out or withdrawing your consent for us to collect, use or process your personal data may affect your use of the Services and the Platform. For example, opting out of the collection of location information will cause its location-based features to be disabled.

4.COLLECTION OF OTHER DATA

4.1 As with most websites and mobile applications, your device sends information which may include data about you that gets logged by a web server when you browse our Platform. This typically includes without limitation your device’s Internet Protocol (IP) address, computer/mobile device operating system and browser type, type of mobile device, the characteristics of the mobile device, the unique device identifier (UDID) or mobile equipment identifier (MEID) for your mobile device, the address of a referring web site (if any), the pages you visit on our website and mobile applications and the times of visit, and sometimes a "cookie" (which can be disabled using your browser preferences) to help the site remember your last visit. If you are logged in, this information is associated with your personal account. The information is also included in anonymous statistics to allow us to understand how visitors use our site.

4.2 Our mobile applications may collect precise information about the location of your mobile device using technologies such as GPS, Wi-Fi, etc. We collect, use, disclose and/or process this information for one or more Purposes including, without limitation, location-based services that you request or to deliver relevant content to you based on your location or to allow you to share your location to other Users as part of the services under our mobile applications. For most mobile devices, you are able to withdraw your permission for us to acquire this information on your location through your device settings. If you have questions about how to disable your mobile device's location services, please contact your mobile device service provider or the device manufacturer.

4.3 4.3 As and when you view pages on our website or mobile application, when you watch content and advertising and access other software on our Platform or through the Services, such information may be sent to us (including, without limitation, IP Address, operating system, etc.); but, instead of page views, your device sends us information on the content, advertisement viewed and/or software installed by the Services and the Platform and time.

4.2 Additional data we may collect: ● Financial Information: Our payment processor Stripe, Inc. (“Stripe”) collects the financial information necessary to process payments through the Service. Accordingly, in addition to this Privacy Policy and our Terms of Service, your financial data is also processed pursuant to Stripe’s services agreement and privacy policy. ● Communication Information: We may collect information when you contact us with questions or concerns and when you voluntarily respond to questionnaires, surveys or requests for market research seeking your opinion and feedback. Providing communication data is optional to you. ● Commercial Information: We may retain a history of the Creator Content you browse, make available, and/or purchase using the Service. ● Demographic Information: We collect your age and gender. ● Social Media Information: We have pages on social media sites like Instagram, Facebook, Instagram, YouTube, and TikTok (“Social Media Pages”). When you interact with our Social Media Pages, we will collect personal information that you elect to provide or make available to us through your settings with the relevant Social Media Pages, such as your contact details, profile photos, and friend lists. In addition, the companies that host our Social Media Pages may provide us with aggregate information and analytics regarding the use of our Social Media Pages. ● Internet Activity Information: When you visit, use, and interact with the Service, we may receive certain information about your visit, use, or interactions. For example, we may monitor the number of people that visit the Service, peak hours of visits, which page(s) are visited, the domains our visitors come from (e.g., google.com, yahoo.com, etc.), and which browsers people use to access the Service (e.g., Chrome, Firefox, Microsoft Internet Explorer, etc.), broad geographical information, and navigation pattern. In particular, the following information is created and automatically logged in our systems: ● Log Information: Information that your browser automatically sends whenever you visit the Site. Log Information includes your Internet Protocol address, browser type and settings, the date and time of your request, and how you interacted with the Site. ● Cookies Information: Please see the “Cookies” section below to learn more about how we use cookies. ● Device Information: Includes name of the device, operating system, and browser you are using. Information collected may depend on the type of device you use and its settings. ● Usage Information: We collect information about how you use our Service, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency, and duration of your activities. ● Location Information: We derive a rough estimate of your location from your IP address. ● Email Open/Click Information: We use pixels in our email campaigns that allow us to collect your email and IP address as well as the date and time you open an email or click on any links in the email. ● Google Information: In order to provide the Service, we will synch with your gmail account so we can help you monetize your business. Through this integration, we will have access to your gmail inbox and any information available there (“Google Information”). Notwithstanding anything else in this Privacy Policy, we (1) only use the Google Information to provide the Service; (2) do not transfer Google Information to third parties except as necessary to provide or improve the Service, as required by law, or in connection with a merger, acquisition, or sale of assets where we provide notice to users; (3) do not use the Google Information for serving advertisements; and (4) do not permit humans to read Google Information, except (a) if we obtain your affirmative consent, (b) as necessary for security purposes or to comply with applicable law, or (c) our use is limited to internal operations and the Google Information (including derivations) have been aggregated and anonymized

5. COOKIES

5.1 We use cookies to operate and administer our Site, gather usage data on our Site, and improve your experience on it. A “cookie” is a piece of information sent to your browser by a website you visit. Cookies can be stored on your computer for different periods of time. Some cookies expire after a certain amount of time, or upon logging out (session cookies), others survive after your browser is closed until a defined expiration date set in the cookie (as determined by the third party placing it), and help recognize your computer when you open your browser and browse the Internet again (persistent cookies). For more details on cookies please visit All About Cookies.

5.2 We or our authorized service providers and advertising partners may from time to time use "cookies" or other features to allow us or third parties to collect or share information in connection with your use of our Services or Platform. These features help us improve our Platform and the Services we offer, help us offer new services and features, and/or enable us and our advertising partners serve more relevant content to you, including through remarketing. “Cookies” are identifiers that are stored on your computer or mobile device that record data about computer or device, how and when the Services or Platform are used or visited, by how many people and other activity within our Platform. We may link cookie information to personal data.

5.3 You may refuse the use of cookies by selecting the appropriate settings on your browser or device. However, please note that if you do this you may not be able to use the full functionality of our Platform or the Services.

6. HOW DO WE USE THE INFORMATION YOU PROVIDE US?

6.1 We may collect, use, disclose, and/or process your personal data for one or more of the following purposes:

To consider and/or process your application/transaction with us or your transactions or communications with third parties via the Services.

To manage, operate, provide, and/or administer your use of and/or access to our Services and Platform (including remembering your preferences), as well as your relationship and user account with us.

To respond to, process, deal with, or complete a transaction and/or fulfill your requests for certain products and services and notify you of service issues and unusual account actions.

To enforce our Terms of Service or any applicable end-user license agreements.

To protect personal safety and the rights, property, or safety of others.

For identification, verification, due diligence, or know-your-customer purposes.

To maintain and administer any software updates and/or other updates and support that may be required from time to time to ensure the smooth running of our Services.

To deal with or facilitate customer service, carry out your instructions, deal with or respond to any inquiries given by (or purported to be given by) you or on your behalf.

To contact you or communicate with you via voice call, text message, fax message, email, and/or postal mail for the purposes of administering and/or managing your relationship with us or your use of our Services, including sending administrative information related to our Services.

to conduct research, analysis and development activities (including, but not limited to, data analytics, surveys, product and service development and/or profiling),

to analyse how you use our Services, to recommend products and/or services relevant to your interests,

to improve our Services or products and/or to enhance your customer experience;

to allow for audits and surveys to, among other things, validate the size and composition of our target audience, and understand their experience with REN’s Services;

for marketing and advertising, and in this regard, to send you by various mediums and modes of communication marketing and promotional information and materials relating to products and/or services (including, without limitation, products and/or services of third parties whom REN may collaborate or tie up with) that REN (and/or its affiliates or related corporations) may be selling, marketing or promoting, whether such products or services exist now or are created in the future. You can unsubscribe from receiving marketing information at any time by using the unsubscribe function within the electronic marketing material and/or adjusting your settings in the Platform, as applicable. We may use your contact information to send newsletters or marketing materials from us and from our related companies;

to offer loyalty, partner and bonus programs and offers and other co-branded marketing efforts, e.g., merchant loyalty programs, seller offers or co-branded credit cards in collaboration with third parties

to respond to legal processes or to comply with or as required by any applicable law, governmental or regulatory requirements of any relevant jurisdiction or where we have a good faith belief that such disclosure is necessary, including, without limitation, meeting the requirements to make disclosure under the requirements of any law binding on REN or on its related corporations or affiliates (including, where applicable, the display of your name, contact details and company details)

to produce statistics and research for internal and statutory reporting and/or record-keeping requirements;

to carry out due diligence or other screening activities (including, without limitation, background checks) in accordance with legal or regulatory obligations or our risk management procedures that may be required by law or that may have been put in place by us;

to audit our Services or REN's business;

to prevent or investigate any actual or suspected violations of our Terms of Service, fraud, unlawful activity, omission or misconduct, whether relating to your use of our Services or any other matter arising from your relationship with us;

to respond to any threatened or actual claims asserted against REN or other claim that any Content violates the rights of third parties; to store, host, back up (whether for disaster recovery or otherwise) of your personal data, whether within or outside of your jurisdiction;

6.2 You acknowledge, consent and agree that REN may access, preserve and disclose your Account information and Content if required to do so by law or pursuant to an order of a court or by any governmental or regulatory authority having jurisdiction over REN or in a good faith belief that such access preservation or disclosure is reasonably necessary to: (a) comply with legal process; (b) comply with a request from any governmental or regulatory authority having jurisdiction over REN; (c) enforce the REN Terms of Service or this Privacy Policy; (d) respond to any threatened or actual claims asserted against REN or other claim that any Content violates the rights of third parties; (e) respond to your requests for customer service; or (f) protect the rights, property or personal safety of REN, its users and/or the public.

6.3 As the purposes for which we will/may collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of the applicable data without your consent is permitted by the Privacy Laws.

7. HOW DOES REN PROTECT AND RETAIN CUSTOMER INFORMATION?

7.1We implement a variety of security measures and strive to ensure the security of your personal data on our systems. User personal data is contained behind secured networks and is only accessible by a limited number of employees who have special access rights to such systems. However, there can inevitably be no guarantee of absolute security.

7.2We will retain personal data in accordance with the Privacy Laws and/or other applicable laws. That is, we will destroy or anonymize your personal data when we have reasonably determined that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; (ii) retention is no longer necessary for any legal or business purposes; and (iii) no other legitimate interests warrant further retention of such personal data. If you cease using the Platform, or your permission to use the Platform and/or the Services is terminated or withdrawn, we may continue storing, using and/or disclosing your personal data in accordance with this Privacy Policy and our obligations under the Privacy Laws. Subject to applicable law, we may securely dispose of your personal data without prior notice to you.

8. DOES REN DISCLOSE THE INFORMATION IT COLLECTS FROM ITS VISITORS TO OUTSIDE PARTIES?

8.1 In conducting our business, we will/may need to use, process, disclose and/or transfer your personal data to our third party service providers, agents and/or our affiliates or related corporations, and/or other third parties, which may be located in Singapore or outside of Singapore, for one or more of the above-stated Purposes. Such third party service providers, agents and/or affiliates or related corporations and/or other third parties would be processing your personal data either on our behalf or otherwise, for one or more of the above-stated Purposes. We endeavour to ensure that the third parties and our affiliates keep your personal data secure from unauthorised access, collection, use, disclosure, processing or similar risks and retain your personal data only for as long as your personal data is needed for the above-mentioned Purposes

8.2 For the avoidance of doubt, in the event that Privacy Laws or other applicable laws permit an organisation such as us to collect, use or disclose your personal data without your consent, such permission granted by the laws shall continue to apply. Consistent with the foregoing and subject to applicable law, we may use your personal data for recognized legal grounds including to comply with our legal obligations, to perform our contract with you, to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights, or where necessary in connection with a legal claim.

8.3 Third parties may unlawfully intercept or access personal data transmitted to or contained on the site, technologies may malfunction or not work as anticipated, or someone might access, abuse or misuse information through no fault of ours. We will nevertheless deploy reasonable security arrangements to protect your personal data as required by the Privacy Laws; however there can inevitably be no guarantee of absolute security such as but not limited to when unauthorised disclosure arises from malicious and sophisticated hacking by malcontents through no fault of ours.

8.4 As set forth in REN’s Terms of Service, Users (including any employees, agents, representatives, or any other person acting for such User or on such User's behalf) in possession of another User’s personal data through the use of the Services (the “Receiving Party”) hereby agree that, they will (i) comply with all applicable Privacy Laws with respect to any such data, including any collection, processing, storage or transfer of such data; (ii) allow REN or the User whose personal data the Receiving Party has collected (the “Disclosing Party”) to remove his or her data so collected from the Receiving Party’s database; and (iii) allow REN or the Disclosing Party to review what information has been collected about them by the Receiving Party, in each case of (ii) and (iii) above, in compliance with and where required by applicable laws.

9. INFORMATION OF CHILDREN

9.1 The Services are not intended for children under the age of 13. We do not knowingly collect or maintain any personal data or non-personally-identifiable information from anyone under the age of 13 nor is any part of our Platform or other Services directed to children under the age of 13. As a parent or legal guardian, please do not allow such children under your care to submit personal data to REN. In the event that personal data of a child under the age of 13 in your care is disclosed to REN, you hereby consent to the processing of the child’s personal data and accept and agree to be bound by this Policy on behalf of such child. We will close any accounts used exclusively by such children and will remove and/or delete any personal data we believe was submitted without parental consent by any child under the age of 13.

10. INFORMATION COLLECTED BY THIRD PARTIES

10.1 Our Platform uses Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses cookies, which are text files placed on your device, to help the Platform analyse how Users use the Platform. The information generated by the cookie about your use of the Platform (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the Platform, compiling reports on website activity for website operators and providing other services relating to website activity and Internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google.

10.2 We, and third parties, may from time to time make software applications downloads available for your use via the Platform or through the Services. These applications may separately access, and allow a third party to view, your identifiable information, such as your name, your user ID, your device’s IP Address or other information such as any cookies that you may previously have installed or that were installed for you by a third party software application or website. Additionally, these applications may ask you to provide additional information directly to third parties. Third party products or services provided through these applications are not owned or controlled by REN. You are encouraged to read the terms and other policies published by such third parties on their websites or otherwise.

11. DISCLAIMER REGARDING SECURITY AND THIRD PARTY SITES

11.1 WE DO NOT GUARANTEE THE SECURITY OF PERSONAL DATA AND/OR OTHER INFORMATION THAT YOU PROVIDE ON THIRD PARTY SITES. We do implement a variety of security measures to maintain the safety of your personal data that is in our possession or under our control. Your personal data is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the personal data confidential. When you place orders or access your personal data, we offer the use of a secure server. All personal data or sensitive information you supply is encrypted into our databases to be only accessed as stated above.

11.2 In an attempt to provide you with increased value, we may choose various third party websites to link to, and frame within, the Platform. We may also participate in co-branding and other relationships to offer e-commerce and other services and features to our visitors. These linked sites have separate and independent privacy policies as well as security arrangements. Even if the third party is affiliated with us, we have no control over these linked sites, each of which has separate privacy and data collection practices independent of us. Data collected by our co-brand partners or third party web sites (even if offered on or through our Platform) may not be received by us.

11.3 We therefore have no responsibility or liability for the content, security arrangements (or lack thereof) and activities of these linked sites. These linked sites are only for your convenience and you therefore access them at your own risk. Nonetheless, we seek to protect the integrity of our Platform and the links placed upon each of them and therefore welcome any feedback about these linked sites (including, without limitation, if a specific link does not work)