Privacy Policy

 

Last updated and effective date :December 12, 2023

 

ORIENT BASIC SCIENCE AND TECHNOLOGY PTE. LTD., and its affiliates (“The Company”, “us”, “our” or “we”) are dedicated to protecting the privacy rights of our users (“users” or “you”). This Privacy Policy (the “Policy”) describes the ways we collect, store, use, and manage the information, including personal information, that you provide or that we collect in connection with our websites that link to the Policy or any The Company mobile application (available for example on iOS and Android) (collectively, the “Services”) and the privacy rights available to you.

 

Please note this Policy only applies to information collected or received by The Company through your use of the Services. It does not apply to, and The Company is not responsible for, the actions of third-party people or companies, the content of their sites, their use of information you provide to them, or any products or services they may offer. Any link to those sites does not constitute our sponsorship of, endorsement of, or affiliation with, those people or companies.

 

By using the Services, you confirm you have read and understand this Policy and the processing of your personal information, in the manner provided in this Policy.

 

If you have any questions about this Policy or do not see your concerns addressed here, please contact us by email at cs@lespark.us.

 

Information We Collect From or About You

The Company collects information about you as described below. As set out below in more detail, we use and in specific cases combine that information to operate, tailor content, personalize and adjust and improve our Services, and to send you messages or personalized information about our services, your scores, new features and more, including for marketing and promotional purposes in accordance with your preferences.

 

Information You Give Us: When you register for and/or use our Services (for example, when you create an account to access our Services, populate your in-app profile, communicate with other users of our Services (e.g. through in-App chat or forum posts), contact our customer service or participate in any activities), we collect and store any information that you give us. This information may also include information you provide through single-sign-on processes (such as through Facebook), including account name or account number (e.g. your user ID), email address or other identifiers needed to link your online account with our Services.

 

Creation of a The Company account. We will collect certain information from you during the registration/ sign-up process for the Services. This may include information like your name, locale, phone number, or email address.

 

Your content. Our Services may allow you to create, upload or share content such as text, images, audio, your profile information (such as your avatar name and appearance) or other content you create when you use our Services,

 

Facebook Connect, and Google+: You may be able to log in to our Services using sign-in services (“Social Login”) such as Facebook Connect, or an Open ID provider. These third party Social Login platforms will authenticate your identity and provide you the option to share certain personal information with us such as your name or email address to pre-populate our sign up form. Social Login platforms like Facebook Connect give you the option to post information about your activities on our Services to your profile page on such Social Login platform to share with others within your network.

 

We may collect and record information through the relevant Social Login platform in accordance with the policies and terms of that Social Login platform. The information we collect when you connect your user account to a Social Login platform may include: (1) your name, (2) your Social Login's user identification number and/or user name, (3) locale, city, state and country, (4) sex, (5) birth date, (6) email address, (7) profile picture or its URL, and (8) the Social Login's user identification numbers for your friends that are also connected to The Company.

 

Interaction with Customer Service: We may collect your email address and any other personal information you provide to us when you contact our customer service or otherwise communicate with us.

 

Information Collected Automatically: When you interact with or use our Services, we automatically collect certain information about your device and your use of our Services. This could include information such as your, browser type and language, IP address, device ID, hardware and software information, advertising ID, standard sever log information, your connections and interactions with other users, purchase histories with us and social media data (if you have linked your account and in accordance with your sharing permissions). We (or the third parties we work with) use standard tracking technologies (like log files, software development kits (SDKs) and web beacons) to do this. In addition, we or our partners may also use tracking technologies and advertising IDs to serve personalized ads to you in our Services. Please see the section below relating to Tracking Technologies [INSERT LINK TO COOKIES AND SIMILAR TECHNOLOGIES SECTION] for more details.

 

Mobile Platforms: When you use any of our applications, we or third party partners will collect and process certain information about you, including your unique device ID (persistent / non-persistent), hardware type, device maker, media access control (“MAC”) address, international mobile equipment identity (“IMEI”), the type and version of your operating system (“OS”), language of the OS, your unique device ID, your time zone, the screen size of your device, mobile device Advertising ID (known as “IDFA” for iOS devices, or “Android Advertising ID” for Android devices), your general geolocation information (city/country based on your Internet Protocol (“IP”) address) and your email address (if you have connected to Facebook or Google+). This information is useful to us for troubleshooting and helps us understand usage trends so that we can improve and personalize the Services for our users. Device identifier / information such as device type, hardware model, device maker, device operating system and its language or other technical data like screen size, or combination of this data, is also collected and used to determine device compatibility and optimal settings. We may also share this information with our advertising partners to enable the technical delivery of personalized ads to your device, as further described below [LINK TO INTEREST BASED ADVERTISING SECTION].

 

User ID: When you register to use the Services, we create a unique user ID to track your use of our Services. Specifically, this unique user ID is stored in connection with your profile information to track The Company applications you are using.

 

Mobile Analytics: Like most mobile applications, we use mobile analytics tools to collect certain information about your usage of our mobile applications, as well as on your device and the health of our Services to allow us to better understand the functionality of our Services on your device and for app optimization purposes. Such tools may record information such as how often you use the application, feature usage, usage statistics, events that occur within the application, aggregated usage and performance data, and where the application was downloaded from (i.e. which application store).

 

We do not link the information we store within the analytics software to any information that personally identifies you within the mobile application.

 

Our Use of Tracking Technologies to Collect Information Automatically

A. Tracking Technologies

 

We and our third-party partners, affiliates, or analytics service providers use standard tracking technologies (like web beacons, SDKs, APIs, scripts and tags) to identify your computer/device, to “remember” things about your visit or your use of the Services (such as your preferences or a user name) and to help us understand things like, what pages and features you use.

 

Such information may be linked to or combined with other personal information we process about you, such as your user ID, for purposes such as improving the quality of our Services, tailoring recommendations to your interests, providing, and personalizing our Services including making our Services easier to use, and for fraud prevention, security and authentication purposes.

 

Please refer to guidance provided by your device manufacturer, operating system developer, or individual web browser if you would like help in managing your preferences with respect to tracking technologies used on our Services.

 

B. Interest-Based Advertising

 

Some of our Services employ ad-serving technologies that use cookies, clear GIFs, web beacons, tracking pixels, and other similar technologies to deliver interest-based advertising to you about third-party products and services. We may via our third party advertising partners, also advertise our Services to you on third parties’ websites. You may also see our advertised in other services (like on Facebook). After clicking on one of these advertisements and installing our App, you will become a user of our Services.

 

When you use our apps, some third-party tools (SDKs) integrated within our Services may collect and use certain information collected from your device for the purpose of ad display and optimization. Such information includes GAID (Google Advertising ID on Android devices) or IDFA (Identifier for Advertising on iOS devices), region (i.e. the location where a given language is used), geo-location information (with your consent) and IP address. This Policy does not govern our third-party advertising partners, as they have their own privacy policies, which are accessible using the links provided below. We have no access to or control over such third parties. In addition to identifiers, these third parties may also collect information relating to:

 

Advertisements served and the location of the ad;

Length of time an advertisement was visible;

Domain type, IP address, size of the advertisement; and

Click-throughs (i.e. whether a click was made on the ad) and advertisement response.

They use this information (alone or in combination with information they have collected about you when you use third party websites or services) to: (i) enable the technical delivery of ads to your device and to verify click-throughs and/or installs; (ii) provide you with more relevant ads about our Services (for example, to present you with an offer for one of our services you might enjoy); (iii) enable offer walls, which allow you to choose from various rewarded ad or market research offers; (iv) track results and measure the effectiveness of ads; and (iv) improve the accuracy of their targeting and measurement systems.

You can learn more about ad serving companies and the options available to limit their collection and use of your information by visiting the websites for the Network Advertising Initiative and the Digital Advertising Alliance, and the webpages for Facebook's ad preferences tool and privacy policy. Similarly, you can learn about your options to opt-out of mobile app tracking by certain advertising networks through your device settings and by resetting the advertiser ID on your Apple or Android device. For more information about how to change these settings go to:

Apple: http://support.apple.com/kb/HT4228

Android: https://support.google.com/ads/answer/2662922

Windows: http://choice.microsoft.com/en-US/opt-out

Please note: adjusting your preferences as described in this section does not mean you will no longer receive advertisements, it only means the ads you do see will be less relevant to your interests. Our advertising partners will also still use your device’s advertising ID to serve you with ads that may be less relevant to you; for example, we may use this for frequency capping (in other words, to control the maximum number of times you see the same ad from us). You may also reset the Advertising ID associated with your device by following instructions provided by your device manufacturer or operating system developer.

 

C. Analytics Technologies

 

We use our own servers and third party analytic technologies to collect information about how you use our Services, your computer or device and the health of our Services.

 

For instance, we use Google Analytics, a web analytics service provided by Google, Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA), on our Services. Google Analytics uses cookies or other tracking technologies to help us analyze how users interact with and use the Services, compile reports on the Services’ activity , and provide other services related to our Services’ activity and usage. The technologies used by Google may collect information such as your IP address, time of visit and whether you are a return visitor. The Services do not use Google Analytics to gather information that personally identifies you. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies.

 

Your browser or device may include “Do Not Track” functionality. Because there is not yet a common understanding of how to interpret Do Not Track signals, we do not currently respond to "Do Not Track" signals. However, we provide you with the ability to opt-out of the use of tracking technologies to send you interest-based advertising as explained above.

 

How We Use Information

We use information collected through our Services, both individually and combined together, for purposes described in this Policy or disclosed to you in connection with our Services. For example, we may use your information to:

 

Create user accounts and allow users to use our mobile applications;

Identify and suggest connections with other users of our Services;

Facilitate sharing on social networks;

Operate, develop and improve our mobile applications,and other Services;

Understand you and your preferences to enhance and personalize your experiences and enjoyment using our Service;

Provide you with personalized recommendations for mobile applications and/or Services;

Respond to your comments and questions and provide customer service;

Provide and deliver products and services you request;

Measure the health of our Services;

Set up and maintain accounts you register for;

Identify, fix and troubleshoot bugs and Service or functionality errors;

Activate or authenticate your mobile applications and save in-App progress and stats (e.g. achievements);

Survey your opinions through surveys or questionnaires;

Serve and measure the effectiveness of advertising;

Send you service-related information, including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages;

Personalizing advertising for you;

Communicating with you via email about promotions, rewards, upcoming events, and other news about products and services offered by The Company and our selected partners, in accordance with your marketing preferences. If you no longer wish to receive marketing or promotional communications from us, you may opt-out at any time by emailing us at cs@lespark.us. or by using the unsubscribe options in the email;

Enable you to communicate with other users;

Personalize content and experiences on our Services, including providing you reports, recommendations and feedback based on your preferences;

Optimize or improve our products, services and operations;

Facilitate software updates and automatically update the software on your device;

Protect the integrity of the Services and enforce our Terms of Service and other applicable terms, including to detect and prevent fraud and unauthorized activities, to secure our systems and the Services, to prevent hacking, cheats and spamming and generally to keep our Services safe and fair and to detect, investigate, and prevent activities that may violate our policies or be illegal;

Detect security incidents, protect against malicious, deceptive, fraudulent or illegal activity, and prosecute those responsible for that activity;

Perform statistical, demographic, and marketing analyses of users of the Services.

We may use information we collect from or about you to create aggregated or de-identified data that does not specifically identify you.

 

Push Notifications: With your consent in accordance with your device settings, we may send you push notifications through our mobile applications to send you app updates, high scores and other service related notifications that may be of importance to you. You may at any time opt-out from receiving these types of communications by turning them off at the device level through your settings.

 

How We Protect Personal Information

A. We Take Reasonable and Feasible Measures to Protect Your Personal Information

We have a professional technical team responsible for handling data protection matters. In addition, we have established specific processes and security procedures for the collection and processing of user data to ensure that data storage and use comply with our expectations and legal requirements.

 

B. Other Security Measures We Take to Protect Information

We manage and standardize information storage and use through a data classification and grading system, data security management regulations, and data security development specifications.

We implement comprehensive security controls over data through confidentiality agreements with information access personnel and technical monitoring mechanisms.

 

C. Employee Access to Your Information

We only allow employees who need to know this information to access your information and require anyone who may have access to your information to fulfill the corresponding confidentiality obligations.

 

D. Security Suggestions

The internet is not a secure environment, and email, instant messaging, and other communication methods with other users are not encrypted. We strongly recommend that you do not send personal information through these methods. Please use complex passwords to assist us in ensuring the security of your account and be sure to properly safeguard sensitive information such as your identity, property information, and payment passwords.

 

E. Security Risk Reminder

Once you leave Our services and browse or use other products or services provided by third parties, we will have no ability or direct obligation to protect any personal information you submit to third parties, whether your login, browsing, or use of the abovementioned products or services is based on links or guidance from Our services. However, we will remind you to be aware that you are entering third-party products or services to better protect your personal information.

If you establish social contacts with others through third-party social software, we will have no ability or obligation to protect any activities that occur outside of Our services, nor will we be responsible for any harm that occurs outside of Our services. Please be cautious of fraud, avoid transferring money to strangers, avoid meeting strangers offline, and avoid providing sensitive personal information to strangers to protect your personal and property safety.

How We Disclose Your Information

The Company does not share your personal information except as approved by you or as otherwise described in this Policy. We may disclose your information in the following circumstances.

 

With your consent: We may share your personal information with certain third parties with your approval and consent.

 

Service Providers: We engage other companies and individuals to perform services on our behalf for the purposes described in this Policy. Examples of these services include analyzing data, IT and related services, payment processing, sending emails and providing customer support, and security fraud-detection services. These agents and service providers may have access to your personal information in connection with the performance of services for The Company and are contractually obligated to maintain the confidentiality and security of your personal information. We also require that they only use the data on our behalf and for purposes consistent with this Policy.

 

Third Party Plug-ins: With third party applications and platforms, such as Facebook Connect, that give you the option to post information about your activities on our websites and services to your profile page to share with others within your network. This Policy does not apply to your use of any such third party applications and services, and we are not responsible for how those third parties collect, use and disclose your information. We encourage you to review the privacy policies of those third parties before connecting to or using their applications or services to learn more about their information and privacy practices.

 

Disclosures to protect us or others: We may release your information as required by law, such as to comply with a subpoena, or when we believe that release is appropriate to comply with the law; investigate fraud, respond to a government request, enforce or apply our rights; or protect the rights, property, and safety of us or our users, or others. This includes exchanging information with other companies and organizations for fraud protection.

 

Disclosures in the event of merger, sale or asset transfer: We may share your information in connection with any merger, sale of our assets, or a financing or acquisition of all or a portion of our business to another company. You will be notified via email and/or a notice on our Services of any change in ownership or use of your personal information.

 

Affiliates: We may share personal information with our affiliated companies.

Advertising Partners: Through our Services, we may allow third-party advertising partners to set technologies and other tracking tools to collect information regarding your use of the Services and your devices as further described in the Interest Based Advertising section above.

Other Important Information

 

Changes to the Policy

We may update this Policy from time to time to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the email address specified in your account) or by means of a notice on the Services prior to the change becoming effective. If we are required by applicable data protection laws to give you enhanced notice or seek your consent to any such changes, we will do so. You can see when this policy was last updated by checking the "last updated" date displayed at the top of this Policy. We encourage you to periodically review this page for the latest information on our privacy practices.

 

Security

The Company takes reasonable and appropriate measures to protect your information from unauthorized access or against loss, misuse or alteration by third parties.

 

Although we make good faith efforts to store the information collected on the Service in a secure operating environment that is not available to the public, we cannot guarantee the absolute security of that information during its transmission or its storage on our systems. Further, while we attempt to ensure the integrity and security of our network and systems, we cannot guarantee that our security measures will prevent third parties from illegally obtaining access to this information. We do not warrant or represent that your information will be protected against, loss, misuse, or alteration by third parties. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.

 

Data Retention and Transfers

Storage Location: Your data will be stored on overseas cloud servers. That means that we will transmit your data to its servers or data centers outside of Singapore. We will carefully evaluate the qualifications of service providers and enter data protection contracts with them.

 

Storage Duration We retain your personal information for the shortest period necessary to fulfill the purposes of providing you with our products and services. For example, when you use our registration function, we need to collect your mobile phone number, and we will continue to store your mobile phone number during the period of your use of this function to provide you with this function and ensure the security of your account and the system. In addition, we may retain your relevant information for the necessary period as stipulated by relevant laws.

 

Information Deletion and Backup Reminder: Based on the protection of personal information, saving network storage space, unpredictable system failures, and other reasons, we may delete or anonymize information that has been retained for more than one year. After processing, the information may not be recoverable or viewable. Please make backups or take local download measures for information that you consider important.

 

Our Policy Regarding Children

We do not knowingly collect or solicit personal information from a child under the age of 18 (or the age of majority in your jurisdiction of residence), nor do we knowingly allow children to use our Service. If you are a child under 18 (or the age of majority in your jurisdiction of residence), please do not send any information about yourself to us, including your name, address, telephone number, or email address. No one under the age of 18 may provide any personal information. If you believe that we have collected personal information from a child, please contact us using the contact details as set forth below. In the event that we learn that we have collected personal information from a child, we will delete that information as soon as commercially practicable.

 

International Transfers

We may transfer information that we collect about you to affiliated entities, or other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world. Please note that these countries and jurisdictions may not have the same data protection laws as your own jurisdiction, and we take steps to ensure adequate safeguards are in place to enable transfer of information to the U.S. and elsewhere and the use and disclosure of information about you, including personal information, as described in this Policy.

 

Your Choices and Rights

User Behavior Policy

Our services may allow you to create, upload or share content such as text, images, and audio. There is no tolerance for objectionable content or abusive users. If the content you create contains objectionable content or abusive users behavior, we have the right to delete or remove it.

 

Your Privacy Choices

Your Choices About Information Provided by You

If you do not want to provide The Company with personal information, then you can choose not to provide it. If you choose not to provide us with personal information, we may not always be able to provide you with the Services you want. For example, without providing an email address, you cannot create an account with us to access our applications.

 

Your Choices About Information Provided by Third Parties

You may be able to control how third parties collect and share your Information by changing your preferences or opting out of collection directly with those third parties. Before disclosing Information to third parties, we recommend you check their respective privacy policies for further details.

 

Your Marketing and Advertising Choices

You can exercise choices over how we use your personal information and update your preferences at any time:

To remove yourself from individual services or promotions, or to opt-out from receiving marketing communications from us, simply click the unsubscribe link in the email or emailing us.

 

Other Rights

You may submit a request to know, access, correct or delete the information we have collected about you by contacting customer services. You may appeal any decision we have made about your request by following the instructions in the communication you receive from us notifying you of our decision. You may also exercise your rights to know, access, correct, delete, or appeal by sending your request to the physical address provided in the Contact Function. You can also update your account information directly through your in-app settings, as well as request a copy of your data or request to deactivate or delete your account. Your right to know includes what personal information we have collected about you, including the categories of sources from which the personal information is collected, the business or commercial purpose for collecting or sharing personal information, the categories of third parties to whom we share the personal information, and the specific pieces of personal information we have collected about you. We do not discriminate based on the exercise of any privacy rights that you might have.

You may be entitled, in accordance with applicable law, to submit a request through an authorized agent. To designate an authorized agent to exercise choices on your behalf, please provide evidence that you have given such agent power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. We will respond to your request consistent with applicable law and subject to proper verification. We will verify your request by asking you to send it from the email address associated with your account or to provide information necessary to verify your account.

While some of the information that we collect and use may constitute sensitive personal information, we only process such information to provide the Platform and within other exemptions under applicable law. For example, we may process your financial information to provide you the goods or services you request from us or your driver’s license number to verify your identity.

 

How to Contact Us

Developer Name: ORIENT BASIC SCIENCE AND TECHNOLOGY PTE. LTD.,

Email: cs@lespark.us

If you have any questions, comments, or suggestions regarding this privacy policy or your personal information, please contact cs@lespark.us.

In general, we will respond within 3 working days. If you are not satisfied with our response, especially if our handling of personal information has harmed your legitimate rights and interests, you can also complain or report to regulatory authorities such as the internet, telecommunications, public security, and industry and commerce.

 

Governing Law and Dispute Resolution

The establishment, effectiveness, performance, interpretation, termination, and dispute resolution of this agreement shall be governed by the laws of Singapore.

Any dispute arising out of or in connection with this contract, including any question regarding its existence, validity or termination, shall be referred to and finally resolved by arbitration administered by the Singapore International Arbitration Centre (“SIAC”) in accordance with the Arbitration Rules of the Singapore International Arbitration Centre (“SIAC Rules”) for the time being in force, which rules are deemed to be incorporated by reference in this clause.

The seat of the arbitration shall be Singapore.

The Tribunal shall consist of 1 arbitrator.

The language of the arbitration shall be English.

 

Miscellaneous

This privacy policy applies to all products and software operated by ORIENT BASIC SCIENCE AND TECHNOLOGY PTE. LTD.,

The headings of this privacy policy are for convenience and reading purposes only and do not affect the meaning or interpretation of any provision in the text.

In the event of any inconsistency or conflict between different language versions of this privacy policy, the English text shall prevail.

ORIENT BASIC SCIENCE AND TECHNOLOGY PTE. LTD., reserves the right to interpret the terms of this privacy policy.

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