PRIVACY POLICY

This Privacy Policy (“Policy”) describes how Asia Growth Solutions Pte. Ltd. (“LIKED”, “we”, “us”, or “our”) collects, uses, discloses, retains, and protects Personal Data on our website, applications, and services (collectively, “Platform”). This Policy applies to users in Singapore and the Philippines and is designed to comply with Singapore’s Personal Data Protection Act 2012 (“PDPA”) and the Philippine Data Privacy Act of 2012 (“Philippine DPA”), as well as any other applicable data protection laws.

  1. INTRODUCTION & SCOPE
    1.1. Purpose. We respect your privacy and are committed to protecting your Personal Data in accordance with PDPA, Philippine DPA, and relevant regulations in both jurisdictions. This Policy explains: what data we collect; how and why we process it; with whom we share it; and your rights.
    1.2. Applicability. This Policy covers all LIKED-controlled entities in Singapore and the Philippines and applies to Personal Data collected via our Platform, marketing activities, events, or third-party integrations.
    1.3. Language & Jurisdiction. In case of any conflict with local language versions, the English version prevails. Where local laws impose stricter requirements, such requirements shall apply.
  2. KEY DEFINITIONS
    • Personal Data: Any information about an identified or identifiable individual (PDPA §2; Philippine DPA §3) including sensitive personal data as defined by Philippine DPA.
    • Processing: Collection, recording, organization, storage, adaptation, alteration, retrieval, consultation, use, disclosure, erasure, or destruction of Personal Data.
    • Data Subject: The individual to whom Personal Data relates.
    • Data Controller: LIKED, which determines the purposes and means of processing Personal Data.
    • Data Processor: Any third party processing Personal Data on behalf of LIKED.
  3. PERSONAL DATA WE COLLECT
    3.1. Categories of Data: We collect both User-Provided and Automatically-Collected Data:
    – Identity & Contact: Full name; date of birth; gender; nationality; postal address; email; phone number; social media handles; images (photos, video recordings).
    – Government IDs & Sensitive Data: Identity card number; passport number; tax identification number; sensitive personal data (e.g., health information) only if necessary and with explicit consent.
    – Demographics & Profile: Marital status; income; education level; preferred language.
    – Account & Credentials: Username, password, login history.
    – Financial & Payment Details: Bank account information; payment card details (number, expiry, security code, billing address); transaction history.
    – Device & Usage: IP address; browser type; operating system; device identifiers (UDID, MEID); cookie identifiers; clickstream and log data; geolocation (real-time via GPS or inferred from IP).
    – Behavioral & Preference Data: Browsing behavior; purchase history; campaign performance; surveys; feedback; testimonials; event participation data.
    – Third-Party Data: Data from partners, affiliates, public sources, or social media platforms.
  4. SOURCES OF PERSONAL DATA
    4.1. Direct Collection: Information you provide when registering, using our Platform, contacting support, participating in events, or completing surveys.
    4.2. Automated Tools: Cookies, web beacons, analytics tools (e.g., Google Analytics), server logs.
    4.3. Third Parties: Advertisers, affiliates, business partners, analytics providers, social media networks, public databases.
  5. PURPOSES OF DATA PROCESSING We process Personal Data for the following purposes (including but not limited to):
    • Service Delivery & Account Management: Registration; KYC/identity verification; invoicing; payments; account maintenance.
    • Platform Improvement & Analytics: Performance analysis; A/B testing; product enhancement; fraud detection; internal audits and training.
    • Marketing & Communication: Promotional emails; newsletters; targeted advertising; webinar invitations; third-party campaign outreach (with consent).
    • Legal & Compliance: Regulatory reporting; anti-money laundering; combating fraud; responding to lawful requests by authorities.
    • Events & Promotions: Sweepstakes; contests; user testimonials; feedback collection; customer support.
  6. LEGAL BASES FOR PROCESSING
    6.1. Consent: Where required, you have provided freely given, specific, informed, and unambiguous consent.
    6.2. Contractual Necessity: Processing is necessary to perform our contract with you.
    6.3. Legal Obligation: Processing is required by law (PDPA §18; Philippine DPA §8).
    6.4. Legitimate Interests: Processing is necessary for our legitimate business interests, where it does not override your rights and freedoms.
  7. DISCLOSURE & SHARING OF DATA We may share Personal Data with:
    7.1. Affiliates & Subsidiaries: For group-wide administration and integration.
    7.2. Service Providers: Cloud hosting; payment gateways; CRM; marketing platforms; analytics; legal and auditing firms.
    7.3. Advertisers & Business Partners: For campaign execution, verification, and reporting.
    7.4. Regulators & Authorities: Courts; government agencies; law enforcement, when compelled by law.
    7.5. Mergers & Acquisitions: In the event of business sale, transfer, merger, or reorganization.
    7.6. User Consent: Third parties you authorize us to share data with.
  8. CROSS-BORDER TRANSFERS
    8.1. Transfers outside Singapore & Philippines occur only with appropriate safeguards, such as Standard Contractual Clauses or PDPA-approved arrangements.
    8.2. We ensure recipients in other jurisdictions maintain PDPA-equivalent or higher data protection standards.
  9. DATA RETENTION & DELETION
    9.1. Retention periods are based on legal requirements, contractual needs, and legitimate business interests, after which data is securely deleted or anonymized.
    9.2. You may request deletion or archival of your data, subject to legal or compliance obligations.
  10. COOKIES & SIMILAR TECHNOLOGIES
    10.1. Types of Cookies: Strictly necessary; performance; functionality; targeting and advertising.
    10.2. Usage: To enable core Platform functions, analyse traffic, and serve personalized content.
    10.3. User Controls: You may manage or reject cookies via browser settings; rejection may impact Platform functionality.
  11. DATA SUBJECT RIGHTS Under PDPA and Philippine DPA, you may:
    • Access, correct, update, or erase your Personal Data.
    • Withdraw consent at any time (without affecting lawfulness of prior processing).
    • Object to processing or request restriction.
    • Download your data in a portable format.
    • Lodge complaints with PDPC (Singapore) or NPC (Philippines).
  12. SECURITY MEASURES & USER RESPONSIBILITIES
    12.1. Security Controls: Encryption in transit and at rest; access controls; network firewalls; intrusion detection.
    12.2. Physical Safeguards: Secure server facilities; restricted access; regular security audits.
    12.3. User Obligations: Keep credentials confidential; notify us of unauthorized access; update passwords regularly.
    12.4. Breach Notification: We will notify PDPC, NPC, and affected individuals within the timeframes required by law.
  13. UPDATES TO THIS POLICY
    We may revise this Policy to reflect changes in laws or business practices. We will post the updated Policy with a revision date. Continued use indicates acceptance.