Privacy & Cookie Policy - ACROSS Global Alliance

1. Collecting Your Data

When you submit a query on the website we will collect details of your name, email address, and geographical (IP) address.

2. Use of your personal data

We may use your personal data (a) in accordance with the terms of policy of the website; (b) to customise, measure and improve our services, content and advertising; (c) better to understand our users, diagnose and fix problems with the website; and (d) on an anonymous basis, for research purposes and for our general business purposes.

We do not share personal data with third parties, except (a) to respond to legal requirements (including the Personal Data Protection Act (Singapore) 2012, and the General Data Protection Regulation (EU) 2016/679) as replaced or amended from time to time) or protect a third party’s rights, property, or safety; (b) with any service providers, sub-contractors and agents that we may appoint to perform functions on our behalf and in accordance with our instructions and in accordance with all applicable laws; and (c) in connection with, or during negotiations of, any merger, sale of assets, consolidation or restructuring, financing, or acquisition of all or a portion of our business by or into another company.

3. Marketing

When you submit a query, upon email response you will be offered the opportunity to agree to receive marketing email messages from us. You can choose to no longer receive marketing emails from us by contacting us at [email protected] or clicking unsubscribe from a marketing email.

We shall therefore retain your personal data in our records for marketing purposes until you notify us that you no longer wish to receive marketing emails from us.

4. Information about your device

When you use the website we automatically collect and store information about your device and your activities. This information could include (a) your device’s unique ID number; (b) your device’s geographic location; (c) your IP address: (d) technical information about your device such as type of device, web browser or operating system; (e) your preferences and settings such as time zone and language; (f) how long you used the website and which services and features you used.

We will use information about your device to customise, measure and improve our services to you, to improve our content, offer appropriate advertising and to understand our users better.

5. Where we hold and process your personal data

Some or all of your personal data may be stored or transferred outside of Singapore and outside of the European Economic Area (the EEA) for any reason, including for example, if our email server is located in a country outside of Singapore or the EEA or if any of our service providers are based outside of Singapore or the EEA. You are deemed to accept and agree to this by using the system and submitting information to us.

If we do store or transfer your personal data outside of Singapore or the EEA, we will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within Singapore or the EEA and under the Personal Data Protection Act (Singapore) 2012 and the General Data Protection Regulation (EU) 2016 / 679 as replaced or amended from time to time.

6. Security

We take appropriate technical and organizational measures against unauthorized or unlawful processing of your personal data and against accidental loss or destruction of, or damage to, personal data.

Notwithstanding the above, you agree that no system can be completely secure. Therefore, although we take steps to secure your information, we do not promise that your personal data will always remain secure.

7. Your rights

You have the right to obtain from us a copy of the personal data that we hold. You also have the right at any time to require that we delete your personal data. To exercise these rights, or any other rights you may have under applicable laws, in the first instance please contact the ACROSS Global Data Protection Officer (DPO) at [email protected]

Please note, we reserve the right to charge an administrative fee of Euro 10 if you wish to obtain a copy of the personal data that we hold for you.

If you are not satisfied with the ACROSS Global DPO’s response to your complaint(s) in relation to this policy or otherwise in relation to our processing of your personal data, you are free to contact the Singapore – Personal Data Protection Commission see www.pdpc.gov.sg.

8. Cookies

A cookie is a small file that asks permission to be placed on your browser’s memory or alternatively your hard drive.

Cookies help us to provide you with a better experience by enabling us to monitor which pages you find useful and which you do not. You can delete cookies at any time or you can set your browser to reject or disable cookies although this may disable some of the functionality of the website.

We use the following cookies:

Analytical/performance cookies: They allow us to recognise and count the number of visitors and to see how visitors move around our site when they are using it. This helps us to improve the way our site works, for example, by ensuring that users are finding what they are looking for easily.

Functionality cookies: These are used to recognise you when you return to our site. This enables us to personalise our content for you and remember your preferences (for example, your choice of language or region).

Targeting cookies: These cookies record your visit to our site, the pages you have visited and the links you have followed. We will use this information to make our site and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.

You can find more information about the individual cookies we use and the purposes for which we use them in the table below:

Name	Description	Expiry
__utma, __utmb, __utmc, __utmc, ga, gat, gid	These cookies are used to collect information about how visitors use our website and WordPress blog. We use the information to compile reports and to help us improve the website. The cookies collect information in an anonymous form, including the number of visitors to the website and blog, where visitors have come to the website from and the pages they visited. Read Google’s overview of privacy and safeguarding data	Various
CookieControl	CookieControlThis cookie is used to remember a user’s choice about cookies on across.global. Where users have previously indicated a preference, that user’s preference will be stored in this cookie..	180 days
wordfence_verifiedHuman	Wordfence – manages site security preventing hacking and blocking access from suspicious IP addresses.	24 hours
wfvt_3558583528	Wordfence – manages site security preventing hacking and blocking access from suspicious IP addresses.	30 mins

Third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

Google Analytics operates on our site. Google Analytics sets the following cookies:

Name	Description	Expiry
_utma	Like _ga, this lets us know if you’ve visited before, in order we can count which users are new to our site or to a certain page	2 years
_utmb	This works with _utmc to calculate the average length of time you spend on our site	30 minutes
_utmc	This works with _utmb to calculate when you close your browser	When you close your browser
_utmz	This tells us how you reached our site (e.g. from another website or a search engine)	6 months

9. General

If any provision of this policy is held by a court of competent jurisdiction to be invalid or unenforceable, then such provision shall be construed, as nearly as possible, to reflect the intentions of the parties and all other provisions shall remain in full force and effect.

This policy shall be governed by and construed in accordance with the laws of Singapore and you agree to submit to the exclusive jurisdiction of the Singaporean Courts.

Last updated: June 2020

10. How to contact us

Please contact us if you have any questions about our privacy policy or information we hold about you: by email [email protected]