Website Privacy & Policy
Last Updated: 7th May 2020
The Internet is an amazing tool. It has the power to change the way we live. With only a few mouse-clicks, we can follow the news, look up facts, buy goods and services, and communicate with others from around the world. While we take advantage of all that the Internet has to offer, at TransCultural Group Pte Ltd (TCG), we also feel it is very important to ensure our customers retain their privacy. To do so, TCG is committed to meet the international privacy standards for its policy, including data protection for its customers.
This privacy policy will explain how TCG uses the personal data we collect from you when you use our website.
What data do we collect?
TCG collects personal information only when you provide to us. This can be when you place an order for Goods and/or our services, or in response to any inquiries or requests in which you have chosen to provide the information to us, either online or in person. The information collected may be unique and personally identifiable information, such as your full name, contact information such as but not limited to email, mailing and billing addresses. This is for us to process your orders to purchase and deliver the Goods or Services to you.
We will not collect sensitive information about you without your expressed consent, and you will be informed at each collection point as to what information is required and what information is optional. Other passive information may be collected (please refer to Passive Information Provision section below).
Passive Information Provision
Cookies: TCG may collect certain data from cookies, which are pieces of data stored directly on the computer or mobile device that you are using. Cookies allow us to collect data such as browser type, time spent on the Online Services, pages visited, referring URL, language preferences, and other aggregated traffic data. We use the data for security purposes, to facilitate navigation, to display data more effectively, to collect statistical data, to personalize your experience while using the Online Services and to recognize your computer to assist your use of the Online Services. We also gather statistical data about use of the Online Services to continually improve design and functionality, understand how they are used, and assist us with resolving questions.
We use cookies to keep you signed in and to understand how you use our website. Cookies allow us to select which advertisements or offers are most relevant to you and display them while you are using the Online Services or to send marketing emails. We also use cookies to track responses to online advertisements and marketing emails.
There are a number of different types of cookies, however, our site categorizes these cookies into two types:
Functionality – TCG uses these cookies so that we recognize you on our website and remember your previously selected preferences. These could include what language you prefer and location you are in. A mix of first-party and third-party cookies are used.
Advertising – TCG uses these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP address. We sometimes share some limited aspects of this data with third parties for advertising purposes. We may also share online data collected through cookies with our advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our website.
You can set your browser not to accept cookies. However, in a few cases, some of our website features may not function as a result. If you do not want data collected with cookies, you can learn more about controlling cookies here.
Analytics: TCG may collect data through Google Analytics and Adobe Analytics, which use cookies and technologies to collect and analyze data about the use of Services. These services collect data regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/ and opt out by downloading the Google Analytics opt out browser add-on, available at https://tools.google.com/dlpage/gaoptout. You can learn more about Adobe and opt-out by this link http://www.adobe.com/privacy/opt-out.html.
IP Address: TCG may collect your IP address, a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). An IP address is identified and logged automatically in our server log files when a user accesses the Online Services, along with theme of the visit and the pages that were visited. We use IP addresses to calculate usage levels, diagnose server problems and administer the Online Services. We also may derive your approximate location from your IP address.
Aggregated data
Through TCG’s site, TCG tracks general server statistics including but not limited to IP addresses, volume and patterns for visitor ship and peak traffic timings. The purpose for such tracking is to analyse general trends and server loads so as to prevent an interruption of the services. In order to provide you with better services, TCG may at its discretion, provide such analytical or aggregated information to third parties in relation to the general usage and/or performance of TCG. This aggregated data will not personally identify you or any other user.
How do we collect your data?
You directly provide TCG with most of the data we collect. We collect data and process data when you:
• create a Registration ID on our website
• place an order for our goods and/or services
• inquire or request something from us, whether online or in person
• download complementary material
• enter a contest
• order email newsletters
• join our live events
• use (such as comment) or view our website via your browser’s cookies
Online product and program registration
When you purchase a new product or service, we may ask you to register your purchase online. When you do, we merge your registration information with any information you’ve already left with us (we call that information your personal profile). If you haven’t previously registered with us, we create a personal profile for you from your product registration information.
Customer profiles
As mentioned above, every registered customer has a unique personal profile. Each profile is assigned a unique personal identification number, which helps us ensure that only you can access your profile. When you register, we create your profile, assign a personal identification number, and send this personal identification number back to your hard drive in the form of a cookie, which is a very small bit of code. This code is uniquely yours. It is your passport to seamless travel across www.transculturalgroup.com restricted pages, allowing you to download software or updates, order newsletters, and visit premium sites without having to fill out registration forms with information you’ve already provided. Even if you switch computers, you won’t have to re-register – just use your Registration ID to identify yourself.
Comments section
When visitors leave comments on our site, we collect the data shown in the comments form, and also the visitor’s IP address and browser user agent string to help spam detection.
An anonymized string created from your email address (also called a hash) may be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approval of your comment, your profile picture is visible to the public in the context of your comment.
Media
If you upload images to our membership website, you should avoid uploading images with embedded location data (EXIF GPS) included. Visitors to the website can download and extract any location data from images on the website.
Contact forms
We also collect the data you provide in the contact form. However, we do not use it for marketing purposes unless you subscribe to our notifications or newsletter. We only use the information you provide in your contact form to answer your query.
Embedded content from other websites
Posts on this site may include embedded content (e.g. videos, images, articles, etc.). Embedded content from other websites behaves in the exact same way as if the visitor has visited the other website.
These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.
How will we use your data?
We will ask you when we need information that personally identifies you (personal information) or allows us to contact you. Generally, this information is requested when you create a Registration ID on the site or when you download complimentary material, enter a contest, order email newsletters or join our live events. We use your Personal Information for the following purposes:
• To make the site easier for you to use by not having to enter information more than once.
• To improve the speed of response to our users (e.g. to help you quickly retrieve your information or find your services).
• To help us create content and services most relevant to you.
• To alert you to product upgrades, special offers, announcements, updated information and other new services from TCG, which you can always choose to opt out later.
• To process your requests and orders.
• To send you updates about your order.
• To send you questionnaire that measures your satisfaction with our service.
• To bill you for the products/s or services you order at that time (credit card details and billing address). For your convenience, we do save billing information in case you want to order from us again, but we don’t use this information again without your permission.
TCG also occasionally hires other companies to provide limited services on our behalf, including, mailing and delivering purchases, answering customer questions about products or services, sending postal mail and processing event registration. We will only provide those companies the information they need to deliver the service and they are prohibited from using that information for any other purpose.
We may also ask advertisers outside of www.transculturalgroup.com to display ads promoting our Services. We may ask them to deliver those ads based on the presence of a cookie, but in doing so will not share any other information with the advertiser.
TCG will disclose your personal information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on TCG or the site; (b) protect and defend the rights or property of TCG and its family of Websites, and, (c) act in urgent circumstances to protect the personal safety of users of TCG, its Websites, or the public.
How do we store your data?
TCG securely stores your data in a Singapore server. We will keep your data/information for an indefinite period of time.
How do we protect your personal information?
Your privacy is important to you and to us. Personal data you shared with us are securely stored, classified confidential and can only be accessible by authorized personnel. It is protected against unauthorized or unlawful processing with care. We will not rent or sell any of the personally-identifiable information that we collect from you to third parties, nor will we share your personally identifiable information with third parties, unless we believe the sharing is permitted by you, reasonably necessary to offer our Services, or when legally required to do so. For example: When you make a payment or enter into transactions using services of third party service providers. When you enter into transactions with others or make payments over our Website (e.g. using online payment gateway service providers), we will share transaction information with only those third parties necessary to complete the transaction. However, we will identify the partner and present such third party’s service provider’s privacy policy to you before you use that service. We’ll use state-of-the-art security measures to protect your information from unauthorized users.
TCG takes strong measures to protect the security of your personal information and to ensure that your choices for its intended use are honored. We carefully protect your data from loss, misuse, unauthorized access or disclosure, alteration, or destruction. Your personal information is never shared outside the company without your permission, except under conditions explained above. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please immediately contact us at contact@transculturalgroup.com.
You also have a significant role in protecting your information. No one can see or edit your personal information without knowing your user name and password, so please do not share these with others.
What data breach procedures we have in place?
1. We protect your personal data by employing techniques such as access restrictions, encryption, pseudonymization, backups, data minimization, and we perform regular testing on all these techniques.
2 . We will notify the appropriate supervisory authority no more than 72 hours after of becoming aware of a breach of users’ personal data, including the number of users whose data was exposed, the nature of the breach, and what actions are being taken to mitigate its effects.
3. We will communicate this information to the impacted users, especially if the data breach exposed any of their unencrypted personal data.
4. We will consider the needs of any law enforcement investigations before publicly announcing the breach, and we will take the necessary actions accordingly.
Consent
If you choose not to register or provide personal information, though you may still be able to go through most of TCG’s site (www.transculturalgroup.com), but you will not be able to access areas that are restricted to registered users. If you decide to register, you will have the option to select the types of information you wish to receive from us. TCG may occasionally allow our strategic partners to offer our registered customers useful information about their products and services. If you do not want to receive these offers, you may inform us that you do not wish to receive marketing materials from third parties.
Privacy policies of other websites
Our website may contain links to other sites, products or services. You need to understand that we do not manage such third party websites, products and services, and thus, they are not governed by this Privacy Policy nor are we responsible for the privacy practices or the content of such websites, products or services. Please visit the privacy policies of these third-party sites in order to understand their privacy policies and data collection practices.
EWWW Image Optimizer
By default, the EWWW Image Optimizer does not store any personal data nor share it with anyone. User-submitted images that are displayed on this site will be transmitted and stored on a global network of third-party servers (a CDN).
Your data protection rights
TCG would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:
The right to access – You have the right to request TCG for copies of your personal data, though we may charge you a small fee for this service. We will provide you with the means to ensure that your personal information is correct and current. You may review and update this information at any time using the User Profile section in our Members portal on www.transculturalgroup.com.
The right to rectification – You have the right to request correction for any information you believe is inaccurate. You also have the right to request us to complete the information you believe is incomplete.
The right to erasure – You have the right to request that we erase your personal data, under certain conditions. At any time, should you wish to have your name and profile removed, you may email us at contact@transculturalgroup.com or send us your request using our online contact form.
The right to restrict processing – You have the right to request that TCG restrict the processing of your personal data, under certain conditions.
The right to object to processing – You have the right to object to TCG’s processing of your personal data, under certain conditions.
The right to data portability – You have the right to request that TCG transfer the data that we have collected to another organization, or directly to you, under certain conditions.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, you may email us at contact@transculturalgroup.com or send us your request using our online contact form.
Notice to Parents or Guardians
Parents or guardians: we want to help you guard your children’s privacy. We encourage you to talk to your children about safe and responsible use of their Personal Information while using the Internet.
The TCG website does publish content that is targeted to children. However, if you are concerned about your children providing TCG any personal information without your consent, TCG offers a Child account. It allows parents to give parental consent for the collection, use and sharing of children’s (ages 16 and under) personal information online.
Enforcement
If for some reason you believe TCG has not adhered to these principles, please notify us by email at contact@transculturalgroup.com. Be certain the words Privacy Policy are in the Subject line. We will act as promptly as we can to rectify any failure to comply with this Privacy Policy. We do not in any case warrant error-free performance of this Privacy Policy.
Updates to This Policy
The “Last Updated” legend at the top of this page indicates when this Policy Statement was last revised. Any changes will become effective when we post the revised Policy Statement on the Online Services. Your use of the Services following these changes means that you accept the revised Policy Statement. If you would like to review the version of the Privacy Statement that was effective immediately prior to this revision, you can contact us at contact@transculturalgroup.com.
Applicable Law/International Issues
Information that is submitted to TCG’s site will be collected, processed, stored and disposed of in accordance with applicable Singapore law. If you are a non Singaporean user, you acknowledge and agree that TCG may collect and use your information, as discussed above, outside your resident jurisdiction. In addition, such information may be stored on servers located outside your resident jurisdiction. Singapore law may not provide the degree of protection for information that is available in other countries. By providing us with your information, you acknowledge that you have read this Policy, understand it, agree to its terms and consent to the transfer of such information outside your resident jurisdiction.
Contact Us
Should you have any questions or comments about the above Policy, you can contact us at contact@transculturalgroup.com.
