- Culkey Foundation is the publisher and operator of the website(s) listed at the beginning of this Policy. Hereinafter, shall be referred to as Culkey Foundation “Company”. When first-person pronouns are used in this Policy, (Us, We, Our, Ours, etc.) these provisions are referring to Company. Additionally, when the terms “the Website” or “Website” are used, these terms refer to the website(s) listed at the beginning of this Policy.
- You, the User – As the User of this Website, this Policy will refer to the User as “You” or through any applicable second-person pronouns, such as “Yours,” etc. Hereinafter, the User of the Website shall be referred to in applicable second-person pronouns.
- If you wish to contact us regarding this Policy or any privacy-related matters, please contact our Data Protection Officer via email at firstname.lastname@example.org.
II. Revisions to this Policy
We reserve the right to revise, amend, or modify this Policy and Our other policies and agreements at any time and in any manner. You should periodically check for any modifications to this Policy by re-visiting this web page and using the “refresh” button on Your browser prior to Your use of the Website and the Services. You should note the date of the last revision to this Policy, which appears at the top of this Policy. If the “last modified” date remains unchanged after You have clicked the “refresh” button on Your browser, You may presume that no changes have been made since the last reading of the Policy. A changed “last modified” date indicates that this Policy has been updated or edited, and the updated or edited version supersedes any prior versions immediately upon posting. In a merger or acquisition of the Company, customer personal data will likely form part of the assets to be transferred. Any and all changes to this Policy arising from such merger or acquisition will be posted on the Website and You will be notified of the changes via a news update within Your account settings page. By continuing to use our Website and Services after any changes to this Policy, you are deemed to agree to the revised Policy.
III. Personal Data that We Collect
The data that’s collected is in different stages:-
- Pre-Registration – We collect and verify mobile and email for on-boarding purpose
- Registration – We use Aadhaar API to verify the identity and record data of Full Name, Gender, Date of Birth and Address and Aadhar profile picture. Any change in this data will be a re-verification of Aadhaar.
- We then allow the user to create his/her virtual visiting card that will contain the above information along with the link of social media accounts.
IV. How We Collect Personal Data from You
- Active Collection – We may also actively collect and process your personal data in the course of your usage of the Website and/or Services, including but not limited to:
(i) Personal data that You may provide when filling in forms on, or otherwise submitting or making available information to, this Website. This includes but is not limited to any information provided when You create a user account and/or register as a user of the Website or for any Services, such as Your name, email address, and contact details;
(ii) Any correspondence You may have with Us;
(iii) Personal data that may be captured via any error logging and reporting tool that captures error report data and sends this data to us in order for Us to be informed of any software errors or problems that may occur during your use of the Website and/or Services; and
(iv) Details of your visits to our Website, the activities you engage in when using the Services, and the resources that you access on or via the Website.
Online queries from users timeline
First response time – 2 working days
Final resolution time – 4 working days
Final resolution time – 4 working days
If Culkey Foundation needs additional time for any case, same will be informed to customer along with reason of delay and expected resolution timelines
V. How We Use and Disclose Your Personal Data
The primary uses for Your personal data are to provide You with services You have requested and/or paid for, to conduct consented data sharing of your personal data with third parties who have requested access to your personal data, customer identification and anti-money laundering reviews and compliance and to comply with applicable law. We may also use Your personal data to administer Your account with Us and to deliver customized services and content to You. Member personal information, login information, and e-mail addresses may be disclosed to third parties for the purpose of providing certain features or third-party services associated with the Services. The Website may contain links to other third-party websites, which are regulated by their own privacy policies. We are not responsible for the privacy policies of these other third-party websites even if You accessed them using links from the Website or were linked to the Website from a third-party website. We are not responsible for how third parties use your personal data, and You should become familiar with such third parties’ privacy policies prior to requesting their services. Non-personal and aggregate data, such as that collected passively, is used in order to customize Our marketing efforts or to customize the efficient use of Our Website for an aggregate group of customers. We generally will use Your personal data for the purposes for which You specifically provide it, for example, sharing personal data with merchants, to ensure payment for subscription services, if applicable. We may also use Your data for market research purposes in the form of aggregate data – in order to increase Your (and other Users’) experience according to tracked interests, to analyze and target potential new markets, and for other marketing purposes. Such general information may be shared with third parties to show general service usage but is however not linked to personally identifiable information.
VI. Special Cases
We take the protection of Your personal data very seriously and recognize the need to keep Your personal data registered with the Website secure. Save as expressly provided herein, Your personal data will not be passed on by Us or by Our agents for use by third parties in any form whatsoever unless We have obtained Your consent or are legally required to do so except for the following purposes. It is Our policy not to use or share the personal data about our Users in ways unrelated to those described in this Policy without also providing You an opportunity to opt-out or otherwise prohibit such unrelated uses. However, We may disclose personal data about Users (including all information and documentation provided to us concerning a User), or information regarding Your use of the services or Website(s) accessible through Our services, for any reason if, in Our sole discretion, We believe that it is reasonable to do so, including but not limited to:
- To satisfy or comply with any laws, such as the Personal Data Protection Act, regulations, or governmental, or legal requests for such personal data;
- To our third-party service providers, including the service providers who conduct our customer identification and anti-money laundering reviews and compliance (e.g., by providing personal data about Users to third-party identity verification services) and who store our data.
- To make reports concerning suspicious activity, potential money laundering, terrorism financing, or other potentially unlawful activity to law enforcement agencies, regulatory agencies, and other governmental agencies in any jurisdiction where we deem it appropriate in our sole discretion;
- To disclose information that is necessary to identify, contact, or bring legal action against someone who may be violating our Terms & Conditions or other User policies;
- To operate Our Website and Services properly;
- To protect the rights, property, and safety of Ourselves, Our Users, and the general public, We specifically reserve the right to disclose any and all information to law enforcement in the event that a crime is committed, is suspected, or if We are compelled to do so by lawful criminal, civil, or administrative process, discovery requests, subpoenas, court orders, writs, or reasonable request of authorities or persons with the reasonable power to obtain such process.
- It is further within Our sole discretion to cooperate with and disclose information to law enforcement, private party litigants, and governmental agencies, about Our Users to the extent required by applicable law. Examples of such cooperation include lawful criminal, civil, or administrative processes, discovery requests, subpoenas, court orders, writs, or reasonable requests of authorities or persons with reasonable power to obtain such process.
- If We have reason to believe that a User is not the owner of a credit card or other account, even if the credit card or account use is authorized, We may provide information about You to the credit card and/or account holder and/or appropriate authorities.
- Anyone who violates Our Anti-Spam Policy, if applicable, may have their personal data made public. If there is any investigation on any unlawful spamming, any use of bulk e-mail in order to promote Your User profile, or any use of bulk e-mail in any manner that leads back to Our Website, or any one of Our Websites, We may take such steps as we deem appropriate in our discretion to ensure that Your bulk e-mail activities stop.
- To store, host, and/or back up (whether for disaster recovery or otherwise) your personal data, whether within or outside Singapore
VII. Transmittals from Us
We may send You periodic announcements including the details of Our existing and new programs We may also use Your personal data for other marketing purposes, such as to inform new opportunities that we, in our sole and absolute discretion, think may be of interest to you. You may opt out of these announcements by contacting email@example.com or by clicking the opt-out link at the bottom of these emails. If You opt out of these marketing emails, You may still receive system notices and other information that is specifically related to Your account.
VIII. Our Commitment to Data Security
We will retain control of and responsibility for the use of any personal data You disclose to Us. We take measures to protect the transmission of all sensitive User data. We make all reasonable efforts to ensure the integrity and security of Our network and systems by utilizing encrypted software and protective firewalls. All User personal data is retained in-house for the life of the account and is secured via administrative password protection. Nevertheless, We cannot guarantee that Our security measures will prevent third-party ‘hackers’ from illegally obtaining this information. We take all reasonable measures to prevent such breaches of security, but You however acknowledge and agree that communications through the internet are not entirely secure and hence, We are unable to guarantee that Our security is one hundred percent (100%) breach-proof. You assume the risk of such breaches to the extent that they occur despite Our reasonable security measures. Our security procedures shall nevertheless continuously be revised based on new technological developments. Whilst We have security measures in place to protect Your personal data, please do not send any other confidential or proprietary information through the Website. You should exercise extreme caution when disclosing such confidential or proprietary information in this way. We will not be responsible for any loss or damage arising from the disclosure of such confidential or proprietary information that is sent through the Website.
IX. How to Access or Modify Your Personal Data
You may withdraw your consent for us to collect, use, disclose and/or process your personal data for some or all of the purposes listed in this Policy. However, please note that you may be unable to use the Website or all or parts of the Services if we do not obtain and maintain your personal data or are not able to share it with certain third parties. You may request to access and/or correct the personal data currently in our possession by writing to the Data Protection Officer using the contact details provided below. Please note that we may charge you a reasonable fee for the handling and processing of your requests to access your personal data. To access or modify your personal data, contact our Customer Service via info