Privacy Policy

Introduction 

Protection of personal privacy is important to Psylent, a product of 9 YARDS INNOVATION PTE. LTD. We aim to maintain the confidentiality of each individual user unless you consent to the release of your Personal Data or individual test results in the manners provided hereunder. In a similar manner, we protect the identity of individuals who access our websites. For the purposes of this Privacy Statement, the terms "Psylent”, “we”, “us”, and “our" refer to 9 YARDS INNOVATION PTE. LTD. (201415767M) and its subsidiaries and affiliates. Our data protection officer can be contacted at support@psylent.ai. 

This Privacy Statement describes the types of information, including Personal Data, collected and processed through our websites and through the services delivered via our websites, and how we treat and process such information. 

For questions about this Privacy Statement or your Personal Data, please contact support@psylent.ai.

Personal Data

By using the term "Personal Data" in our Privacy Statement, we refer to information that you individually provide to us, either directly or indirectly that on its own, or in combination with other information, can be used to identify you or make you identifiable. Personal Data includes for example your name, your mailing address, your telephone number, your e-mail address or other information that identifies you or makes you identifiable. Information that by itself cannot be used to identify you or make you identifiable does not qualify as Personal Data.

I. INFORMATION COLLECTED BY PSYLENT’S WEBSITES 

Our websites gather information in two ways: (1) indirectly, for example, through our website's technology, and (2) directly, for example, when you, the individual user, voluntarily provide information on various pages. The information will be transferred to our servers located in the Republic of Singapore. 

1. Information Collected Indirectly 

We indirectly collect a variety of information through your interaction with and use of our websites. This information may include, inter alia, browser and device information, data collected through automated electronic interactions, application usage data, content information based on your individual interests, demographic information, geographic or geo-location information, statistical and aggregated information ("Other Information"). 

Statistical or aggregated information does not directly identify a specific person, but it may be derived from Personal Data. For example, we may aggregate Personal Data to calculate the percentage of users in a particular postal code. If we combine Other Information with Personal Data, we will treat the combined information as Personal Data.

Psylent Cookies

Some types of indirectly collected information are stored in "cookies." Cookies are small files of electronic information that a website can transfer to a visitor's hard drive to help that visitor while on the site. There are different types of cookies:

• Strictly necessary cookies are required for the operation of our website.

• Functionality cookies are used to recognize you when you return to our website. These cookies simply store a user code so that the user does not have to re-enter their information when re-joining the site.

• Targeting cookies record your visit on our platform and the pages you have visited. We will use this information to make our website more relevant to your interest.

The use of cookies is standard on the Internet. Although most web browsers automatically accept cookies, the decision of whether to accept or not is yours. You have the choice to accept or decline cookies by way of consent. You may adjust your browser settings to prevent the reception of cookies, or to provide notification whenever a cookie is sent to you. You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this, you may not be able to access the full functionality of our websites. Cookies placed by us will expire when the user terminates the website session or after a reasonable period of inactivity.

a. Tracking Data and Third Party Analytics Providers

Website traffic volume and patterns, such as the number of visitors to a given website or page on a daily basis, are typically referred to as Tracking Data. This type of indirectly collected information is gathered through various means, such as an IP address, which is a number that is automatically assigned to your computer whenever you are surfing the web. Web servers, the computers that "serve up" web pages, automatically identify your computer by its IP address. When you visit any of our websites, our servers log your computer's IP address.

To obtain these Tracking Data, we use third-party analytics providers ("Third Party Analytics Providers"). The Third Party Analytics Providers use cookies to help us analyze how users use our websites. The information generated by the cookie about your use of our websites, including your IP address, will be transmitted to and stored by Third Party Analytics Providers' servers. On behalf of Psylent, the Third Party Analytics Providers will use this information for the purpose of evaluating your use of our websites, compiling reports on website activity, and providing other services relating to website activity. The Third Party Analytics Providers will not associate your IP address with any other data held by them. This processing is necessary for the purpose of our legitimate interests in accordance with Art. 6(1) 1 lit. f) GDPR, in particular, to ensure the proper functioning of our website.

For the above-mentioned purposes, we use the following Third Party Analytics Providers: Google Analytics and Hotjar. Further information can be found in their respective Terms of Service.

Only designated administrators of ours can access the information gathered by our Third Party Analytics Providers, and the information is used only for administrative and planning purposes to meet the needs of our users, such as to improve the content of our websites and to customize the content and/or layout of the site for individuals or groups of users.

b. Cookies for advertising

We may use third-party advertising companies to serve ads on our behalf. These companies may use cookies and action tags to measure advertising effectiveness. You can still decide whether you want to accept these cookies by way of consent. You may adjust your browser settings to prevent the reception of third-party cookies, or to provide notification whenever such third-party cookies are sent to you. If you do not accept these cookies, we will not be able to show you personalized content and ads.

2. Information Collected Directly 

We also collect Personal Data and other information that individual users voluntarily provide. It is entirely your decision to provide the requested information. 

Psylent keeps all information directly collected confidential, and will only use the information for the particular purpose(s) stated at the point of collection. Psylent will seek your specific permission for any additional use(s). You may choose to have this information removed at any time. We will never barter, trade, or sell access to your information without your specific consent.

2.1. User Account Data 

When setting up an account on one of our websites (a "User Account"), you may be asked to provide Personal Data including, but not limited to, your name, e-mail address, and your phone number. 

When you sign up for a User Account, you give us Personal Data voluntarily by providing it to us. We collect and use that information in order to authenticate you when you register an account and use our services, to make sure you are eligible and able to receive the services, and so that you receive the correct version of the services. That information includes the user name you choose to use on our services, and internal account IDs that we assign to your account. 

You may have an account with a supported third-party single sign-on service to use our services. As such, the Personal Data we collect also depends on which third-party accounts you choose to use, their privacy policy, and what your privacy settings with those services allow us to see when you use their services to access our services. If you choose to link your LinkedIn account to our services, we will collect a unique user ID, your email address and an authentication token. 

If you choose to purchase any products, services, access codes or other items for sale by us, you will also be asked to provide payment details and your full address for billing purposes. As a customer/user of Psylent, we may obtain Personal Data about you when you register to use one of our websites or services/products or when you provide feedback about our products or services. The processing is necessary to perform the contract with you according to Art. 6 (1) 1 lit. b) GDPR. 

As a customer/user, we will use your Personal Data, unless otherwise prohibited by law, for the following purposes: 

• To provide you with the products and services you request; 

• To communicate with you about your account or transactions with us and send you changes to our policies; 

• To provide support including, but not limited to, product updates, and fixes and other similar communications; 

• Furthermore, we will use your Personal Data for our legitimate interests according to Art. 6 (1) 1 lit. f) GDPR to notify you about information about features on our site; new product releases; service developments; and to advertise our products and services in accordance with this Privacy Statement. 

Any User Account data will only be stored until you decide to terminate your User Account (see clause III.1. below). In case we are obliged to further store your Personal Data due to statutory retention requirements, your Personal Data will be barred for further use by Psylent and only be stored until such retention periods expire. 

2.2. Other Personal Data Provided Directly 

Personal Data provided by you on Psylent Websites, e.g. via contact forms, or via telephone will be stored in our service database and retained for the period necessary to fulfill our contractual obligations to you in accordance with Art. 6 (1) 1 lit. b) GDPR unless a longer retention period is required by law.

II. DATA COLLECTION 

Our websites offer users the opportunity to participate in surveys or assessments via the internet. We will provide information about the purpose and process for each survey or assessment as part of the applicable survey or assessment. 

1. Sharing your Survey Results with other people 

After completion of the survey or assessment, you may have the opportunity to share your survey or assessment results via email, or social networks. Please note that only your name and results will be displayed. By sharing your information from your User Account with any social media service, you are authorizing us to share information we collect from and about you with the social media service provider, other users, and your network of contacts on the social media service, and you understand that the social media service's use of the shared information will be governed by the social media service's privacy policy. If you do not want your Personal Data shared in this way, please do not connect your Psylent information to a social media service provider.

III. GENERAL INFORMATION ON COLLECTION AND PROCESSING OF INFORMATION 

1. Correcting and Changing User Information and Preferences; Deletion of User Accounts 

If you have given your consent in accordance with Art. 6 (1)1lit. a) GDPR to receive e-mail communications from us but wish to withdraw your consent and discontinue this service, you may do so at any time by contacting our Data Protection Officer at the email provided herein (see also below clause III.8. "Your rights"). You also have the option, at all times, to have your User Account deleted for any of our websites or to request a revision of your user information at any time. To do so, please contact us. 

2. Information Security 

Psylent employees understand the need for user privacy, and we maintain reasonable and appropriate security procedures to protect your information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into due account the risks involved in the processing and the nature of the Personal Data. Psylent has appointed a Data Protection Officer to monitor privacy practices. Access to user data is strictly limited to specific individuals who are trained to respect user privacy. The access given to these employees is restricted to their need for such information for business purposes. A log of those who accessed the data is maintained and monitored to prevent security breaches.

3. Third-Party Information Storage 

We provide Personal Data to our affiliates; data intermediaries; and other trusted businesses or persons to process it for us, based on our instructions and in compliance with our Privacy Statement and any other appropriate confidentiality and security measures. For example, we use service providers such as Amazon Web Services for data storage. Any vendor or agent that we retain are not allowed to use Personal Data they receive from us for any other purpose than to perform the contracted services we have contracted them to perform. Psylent remains responsible and liable under this Privacy Statement if third-party agents that we engage to process the Personal Data on our behalf do so in a manner inconsistent with the Principles, unless we prove that we are not responsible for the event giving rise to the damage. 

4. Children and Privacy 

Psylent sites do not contain content that is generally considered unsuitable for children. 

5. Links to Other Sites 

Our websites may contain links to sites owned and/or operated by other organizations, and the privacy policies of those sites may differ from that of ours. These sites may collect Personal Data and make use of it in ways that we do not. We encourage you to review the privacy policies posted on all third-party sites. 

6. Location of Data Collection and Processing and Storage 

In personally accessing our websites, you may be submitting Personal Data and survey or assessment results that we will use for business purposes that are consistent with this Privacy Statement. Your information may be processed in Singapore or any other country in which Psylent now maintains facilities, or at any other time may maintain facilities, including any Psylent subsidiary. Psylent keeps Personal Data gathered and processed for the purposes described in this Privacy Statement for as long as there is a business purpose. 

7. Compliance and Cooperation with Regulatory Authorities 

Psylent complies with the Personal Data Protection Act of Singapore.

8. Your rights 

You have the right to access the Personal Data that we hold about you and to correct, update, amend, suppress, delete or otherwise modify any Personal Data where it is inaccurate, or has been processed in violation of this Privacy Statement. When updating your Personal Data, we may ask you to verify your identity before we can act upon your request. 

For users from the EU 

You may also, if governed by the GDPR, object to the use or processing of your Personal Data or withdraw consent to use your Personal Data at any time. Under the GDPR, regarding the processing of your Personal Data, you have the following rights: 

• The right to require free of charge (i) information whether your Personal Data is retained and (ii) access to and/or (iii) duplicates of the Personal Data retained. However, if the request affects the rights and freedoms of others or is manifestly unfounded or excessive, we reserve the right to charge a reasonable fee (taking into account the administrative costs of providing the information or communication or taking the action requested) or refuse to act on the request; 

• The right to request proper rectification, removal or restriction of your Personal Data; 

• Where processing of your Personal Data is either based on your consent or necessary for the performance of a contract with you and processing is carried out by automated means, the right to receive the Personal Data concerning you in a structured, commonly used and machine-readable format or to have your Personal Data transmitted directly to another company, where technically feasible (data portability); 

• Where the processing of your Personal Data is based on your consent, the right to withdraw your consent at any time without impact to data processing activities that have taken place before such withdrawal or to any other existing legal justification of the processing activity in question; the right not to be subject to any automatic individual decisions which produces legal effects on you or similarly significantly affects you; and 

• The right to take legal actions in relation to any breach of your rights regarding the processing of the Personal Data, as well as to lodge complaints before the competent data protection regulators. 

To exercise the rights referred to above, please contact us at support@psylent.ai.

As far as we process your Personal Data on the basis of our legitimate interests pursuant to Art. 6 1) lit. f) GDPR, you may object to processing at any time. You may find the detailed description of our processing activities and the legal basis in the sections before. If you object, we will no longer process your Personal Data unless there are compelling and prevailing legitimate grounds for the processing; or the data is necessary for the establishment, exercise or defense of legal claims. If you object to such processing, we ask you to state the grounds of your objections in order for us to examine the processing of your Personal Data and decide whether to adjust the processing accordingly. 

Please note that the processing of your Personal Data may involve advertising activities as described above. If you do not want us to process your Personal Data for direct marketing activities, you can object free of charge at any time via e-mail to support@psylent.ai.

We will obtain your consent before sharing your Personal Data with any third party that is not acting as an agent or vendor to perform tasks on our behalf or to use the information for a purpose materially different from the purpose for which it was initially collected or subsequently authorized by you. An exception to this will be (among others) where our processing of Personal Data is necessary for compliance with a legal obligation under the applicable law.

9. Sensitive Information 

For processing of your sensitive information (e.g. medical information, Personal Data revealing ethnic or racial origin, political opinions, religious or philosophical beliefs, trade union membership, the processing of genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or a natural's person sex life or sexual orientation), we will obtain your explicit consent. 

We are not required to obtain explicit consent with respect to sensitive information where the processing is, inter alia, (a) necessary to protect the vital interests of the data subject or another natural person where the data subject is physically or legally incapable of giving consent; (b) necessary for the establishment, exercise or defense of legal claims or whenever courts are acting in their judicial capacity; (c) necessary to carry out our obligations in the field of employment law insofar as it is authorized by the European Union or Member State Law or a collective agreement pursuant to Member State Law providing for appropriate safeguards for the fundamental rights and the interests of the data subject; or (d) related to information that is manifestly made public by the individual.

10. Dispute Resolution 

If you have any complaints regarding our compliance with this Policy or a Privacy Shield-related or general privacy-related complaint, you should first contact us. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of Personal Data in accordance with this Policy. 

11. Policy Updates 

This Privacy Statement is our promise to our website users and Users with a registered User Account. Additional information that is particular to specific sites may exist, and updates to this policy may be posted. For these reasons, we suggest that users who may have specific concerns about the information being gathered and use of that information regularly view the Privacy Statement on each site. We reserve the right to change the policy on use of information collected at any time. 

12. Additional Questions or Comments 

If you have any inquiries, complaints, access requests and any other questions arising under Privacy Shield or comments regarding Psylent’s Privacy Statement, please contact our data protection officer via the email address provided earlier herein. We will respond to you within 30 days of receiving a complaint.