Information about Creative Skills

Privacy policy

Tutti Privacy Policy

Effective date: November 1st, 2018

Dear user,

We, DBMA Ltd, and our subsidiaries and affiliates worldwide (collectively, “Tutti” or “we” or “us” or “our”, as applicable) provide an online Platform (as defined below) that connects hosts (“Hosts” or “Host”) who have premises, rooms or space (collectively, “Music Space”) and/or musical instruments and equipment (“Music Instruments” or “Music Equipment,” as applicable), with users (“Guest Users” collectively with Hosts, “Users” or “User” or  “you” or “your”, as applicable) seeking to book such Music Space and/or Music Instruments and/or Music Equipment to use for music practice, music performance, music concerts or music events (collectively, the “Services“), which Services are accessible through our website(s) and/or webpage(s) and/or mobile application(s) and/or other social network platform(s) (collectively, the “Platform”). In this Privacy Policy (as defined below), Tutti and the Host are, where applicable, collectively referred to as, the “Parties” and each, as a “Party”.

We appreciate your business, visit to, and use of our Platform. As a visitor to our Platform and User of our Services, we consider the privacy of your data and information, whether corporate or personal, to be of fundamental importance and a top priority. Information we gather from you as a User, not only facilitates interactions and transactions between us and you and other Users, but also helps us continually improve your Platform experience.

Towards assuring you of the security and protection of the information you provide us when transacting on, or using our Platform Services, we outline below our policy that governs the use of this Platform, to protect your personal data as informed by the requirements of law (the “Privacy Policy”). By accessing and browsing the Platform and/or using our Services, you are agreeing to be bound by and affirm that you are conversant with our Privacy Policy, as amended and modified from time to time, and its limitations or qualification. Please read it carefully. Please also carefully read our Terms and Conditions which govern the use of our Platform in general, and which are incorporated herein by this reference. In the event of any conflict or inconsistency between the provisions of this Privacy Policy and the Terms and Conditions, the provisions of the Terms and Conditions shall control and govern.

All capitalised terms used herein but not otherwise defined in this Privacy Policy will have the meanings set forth in the Terms and Conditions.

Please note that we may, at our sole discretion, modify or revise this Privacy Policy at any time by updating the text of this page, without notice to you, and you are bound by any such modification or revision. You should therefore visit this page periodically to review our Privacy Policy. Your continued access, use and/or browsing on this Platform following the posting of changes to this Privacy Policy means you accept those modifications or revisions.

Tutti will not process your personal information outside your jurisdiction, territory or country. Each of the countries in which Tutti has a presence, has differing privacy laws offering different levels of protection for your personal information. Our Privacy Policy reflects these varying practices and we will act in accordance with this Privacy Policy in all jurisdictions we operate in by providing your personal information in any jurisdiction, in accordance with this Privacy Policy.

Please note that for Users in the European Union and the United Kingdom, a new legislation called the General Data Protection Regulation (GDPR) took effect on May 25, 2018. It was enacted as an act of reform and advancement of the 1995 Data Protection Directive and protects personal data and its free movement. We endeavour and are committed to complying with the GDPR in relation to all Users and personal data in the EU and the UK or that are subject to EU law. For such Users, our GDPR Compliance Policy shall apply as an extension of our Terms and Conditions and Privacy Policy and is incorporated in these Policies by this reference. In the event of any contradiction between our Terms and Conditions, Privacy Policy and our GDPR Compliance Policy our GDPR Compliance Policy shall prevail to the extent of such inconsistency.

Information We May Collect From You

By using the Platform and its related sites, Services and/or registering for a Tutti account, being either a Guest User account or a Host account, as applicable (collectively, the “Tutti Account”), you expressly consent to our collection, use, disclosure, and retention of your personal information as described in this Privacy Policy. You can browse our Platform without telling us who you are or revealing any personal information about yourself. If you register for a Tutti Account with us, you give us your personal information, and you are not anonymous to us. If you choose to provide us with personal information, you consent to the transfer and storage of that information on our servers located in any jurisdiction, territory or country of our choosing, and with respect to our affiliates, elsewhere in the world where we have a presence. When you visit our Platform or use our Services, our data processor, Google will collect information sent to us by your computer, mobile phone, or other access device.  This information is not associated with you personally unless you sign in as a registered User.

We collect the following types of personal information in order to provide you with the use and access to our Platform and our Services:

  • personal information you provide to us such as your name, title, home and/or business address (billing (if applicable) and/or mailing address), email address, home and/or business phone number, mobile telephone number, wireless and/or fax number, physical contact information

  • other information, personal or otherwise, such as Music Space and/or Music Instrument and/or Music Equipment characteristics, availability or preference, as applicable, Platform use history and marketing preferences, that you provide to us through questionnaire, correspondence, chats, dispute resolution, or shared by you from other social applications, services, or websites;

  • additional personal information we ask you to submit to authenticate yourself or if we believe you are violating our Platform policies (for example, we may ask you to send us an ID or bill to verify your address, or to answer additional questions online to help verify your identity);

  • other supplemental information obtained from third parties such as demographic and navigation data; your program level in their User incentive program and your Tutti Account information; and, especially with respect to Hosts, your credit check information, and additional information about you from a credit bureau, as permitted by law;

  • information from your interaction with our Platform, Services, content and advertising, including, but not limited to, web logs, device ID, device type, geo-location information, computer and connection information, statistics on User behaviour, page views, traffic to and from the Platform, ad data, IP address and standard web log information; and

  • details of interactions, communications and transactions you carry out through our Platform.

Guest Users may be required to provide information to Hosts in the course of Hosts offerings Music Space and other related services. Such information may range between personal and public information and may include, without limitation (i) personal identification, (ii) reasonable professional background information, and (iii) dates of Music Space usage.

Hosts are required to keep information provided by Guest Users confidential, and may be liable to Tutti and the applicable Guest User for any breach of confidentiality.

Sharing Information With Our Third Party Payment Processor

When you sign up on the Platform, you are obligated to provide your credit card data as part of your personal information. Your credit card information is held and processed by our third party payment provider, STRIPE : (the “Payment Processor”). In this regard, the processing of payments or credits, as applicable, in connection with your use of the Platform will be subject to the terms, conditions and privacy policies of the Payment Processor and your credit card issuer in addition to this Privacy Policy and our Terms and Conditions. We are not responsible for any errors by the Payment Processor.

Sharing of Information and Registration with Social Media Platforms

We offer and will be offering sign-on Services that allow you to use third party login credentials to access our Platform. We also offer Services that allow you to share information with third party social media websites such as Facebook, Google Plus, Twitter, YouTube and others.

You may choose to provide us with access to certain personal information stored by such third-party websites. The personal information we have access to varies by website and is controlled by your privacy settings on that website and your consent. By associating an account managed by a third party with your Tutti Account and authorising Tutti to have access to this information, you agree that Tutti may collect, use and store information from these websites in accordance with this Privacy Policy.


Our primary purpose in collecting personal information is to provide you with access to our Platform and our Services, and provide you with a safe, smooth, efficient, and customised experience. You agree that we may use your personal information to:

  • where applicable, process transactions between you and us;

  • process data internally, for instance compile statistical information about your interests and that of other Users in relation to the Services on our Platform;

  • provide you with information, Services that you request from us or which we believe would interest you in a way that is targeted and relevant;

  • provide access to our Platform and the Services and User support you request;

  • carry out contractual obligations based on agreements entered between you and us;

  • resolve disputes and troubleshoot problems;

  • prevent, detect, and investigate potentially prohibited or illegal activities, and enforce our Terms and Conditions;

  • customise, measure, and improve our Services, content, and advertising to ensure you have a better User experience on our Platform;

  • tell you about our Services and those of our corporate family, as well as changes to them;

  • advise you of forthcoming new Services, Music Spaces and/or Music Instruments and/or Music Equipment, and promotional offers;

  • deliver targeted marketing, Service updates, and promotional offers based on your communication preferences;

  • compare information for accuracy, and verify it with third parties;

  • contact you, for the purposes provided in this Privacy Policy, any other of our policies or for whatever reason, at telephone numbers we have collected, by placing a voice call or through text (SMS) or email messaging, as authorised by this Privacy Policy;

Please note that if the email address you provide to us is a wireless email address, and you have elected to receive promotional messages from us, you agree to receive messages at such address from us, unless and until you have elected not to receive such messages by following the instructions in the marketing section below. You understand that your wireless carrier's standard rates apply to these messages, and that you may change your mind at any time by following the instructions in the marketing section below. You represent that you are the owner or authorised user of the wireless device on which messages will be received, and that you are authorised to approve the applicable charges.


We do not sell, trade or lease your personal information to third parties for their marketing purposes without your explicit consent. We may combine your personal information with information we collect from other companies and use it to improve and personalise our Services, content and advertising.

If you do not wish to receive marketing communications from us, you can indicate your communications preference in your Tutti Account, or within direct communication channels with us including through means we may seek to contact you such as email, text, SMS or any other messaging service, telephone, fax and by post.

Our Disclosure of Your Information

We disclose personal information to respond to legal requirements, enforce our policies, respond to claims that a listing or other content violates the rights of others, or protect anyone's rights, property, or safety. Such information will be disclosed in accordance with applicable laws and regulations.

We also share your personal information with:

  • our affiliates to provide joint content and Services (like registration, transactions, and User support), to help detect and prevent potentially illegal acts and violations of our policies, and to guide decisions about their products, sites, applications, tools, services and communications. We shall use this information to send you marketing communications only if you have requested our Services and will use your personal information in compliance with our Privacy Policies and our global privacy standards;

  • service providers and other third parties that provide products or services for or through our Platform or for our business (such as website or database hosting companies, address list hosting companies, email service providers, analytics companies, distribution companies, fulfilment companies, and other similar service providers that use such information on our behalf) under contract who help with our business operations (such as, but not limited to, fraud investigations, bill collection, insurance service providers, affiliate and rewards programs, site operations, and co-branded credit cards);

  • other third parties to whom you explicitly ask us to send your information (or about whom you are otherwise explicitly notified and consent to when using a specific Service) including third party incentive or reward programs in which you may enrol, and we may participate, which information shared would be limited;

  • law enforcement, governmental agencies, authorised third parties, judicial proceedings, including a valid court order in relation to litigation or in response to a verified request relating to criminal investigations or alleged illegal activity or any other activity that may expose us, you, or any other User to legal liability. In such events, we will disclose information relevant and necessary to the investigation, inquiry or court proceedings, such as name, city, state, ZIP code, telephone number, email address, User ID history, IP address, fraud complaints, Platform use history, and anything else we may deem relevant in that regard;

  • other business entities which provide offers to select Users through us. When we do this, we do not provide those businesses with your name and address, and you have every right to notify us that you are not interested in receiving such offers; and

  • other business entities, should we plan to merge with or be acquired by a given business entity. (Should such a combination occur, we will require that the new combined entity follow this Privacy Policy with respect to your personal information. If your personal information will be used contrary to this Privacy Policy, you will receive prior notice).

Without limiting the above, in an effort to respect your privacy and our ability to keep the community free from bad actors, we will not otherwise disclose your personal information to law enforcement, other government officials, or other third parties without a subpoena, court order or substantially similar legal procedure, except when we believe in good faith that the disclosure of information is necessary to prevent imminent physical harm or financial loss or to report suspected illegal activity.

Further, other than as set forth above, you will receive notice when information about you might go to third parties, and you will have an opportunity to choose not to share the information.

Information You Share on our Platform

Your User ID is not displayed throughout the Platform (and so is not available to the public), although for our internal purposes and out of the public eye, it is connected to all of your Tutti activity. For Guest Users, people you allow to use your Tutti Account on the Platform, can see your Host and Music Space and/or Music Instrument and/or Music Equipment selections and usage as well as other related information. Once you select a Music Space and start interacting with a potential Host, the Host can see some of your identifying information. For Hosts, people you allow to follow you on the Platform, can see your Music Space(s) and/or Music Instrument(s) and/or Music Equipment, the price for their use, and some of your identifying information. Notices sent about suspicious activity and policy violations on our Platform refers to User IDs and specific items. So, if you associate your name with your User ID, the people to whom you have revealed your name will be able to personally identify your Tutti activities.

If you access our Platform from a shared computer, a computer in an Internet café or another person’s mobile phone, certain information about you, such as your User ID, activity, or reminders from Tutti, may also be visible to other individuals who use the computer or mobile phone after you.

Our Texting Service

Our Platform will have or currently has a robust texting service as part of its Services (the “Texting Service”). Through the Texting Service, Guest Users and Hosts can connect and communicate freely. We do not monitor the text messages of Guest Users and Hosts. However, in the unlikely event that we become privy to any leaked messages of Guest Users and/or Hosts, we shall not be responsible or liable for any loss or damage arising from such leaked messages, whether it was caused by a failure of Tutti’s systems, an act of Tutti’s employees or an act of cyber hacking.

Using Information from Us

We enable you to share personal information using the Platform and our Services. We encourage you to disclose your privacy practices and respect the privacy of other Users. To help protect your privacy, we allow only limited access to other Users' contact and usage information to facilitate connection, interaction and flow of relevant or common information. When Users are involved in connecting with each other, they may have access to each other's name, User ID, email address and other contact information. In all cases, you must give other Users a chance to remove themselves from your database and a chance to review what information you have collected about them.

You agree to use User information only for:

  • User connection-related purposes that are not unsolicited commercial messages;

  • using Services offered through Tutti; or

  • other purposes that a User expressly chooses.



We use “cookies” (small data files placed within your computing device) on certain of our pages to help analyse our Platform page flow; customise our Services, content and advertising; measure promotional effectiveness, and promote trust and safety. Cookies track your movement on our Platform, including what you view, your transactions and what you purchase. They essentially serve to improve and personalise your experience on our Platform.

A few important things you should know about our use of these technologies are:

  • we offer certain features that are available only through the use of cookies and are therefore one of the primary ways in which we announce a new feature that was added since the last time you visited our Platform;

  • we use cookies to help identify you, track information about you and maintain your signed-in status;

  • most cookies are "session cookies," meaning that they are automatically deleted from your hard drive at the end of a session;

  • you are always free to decline our cookies if your browser permits, although doing so may interfere with your use of our Platform or Services;

  • you may encounter cookies from third parties, known as service providers, that we have allowed on our Platform that assist us with various aspects of our Platform operations and services; and

  • you also may encounter cookies from third parties on certain pages of our Platform that we do not control and have not authorised. (For example, if you view a Platform page created by another User, there may be a cookie placed by that page).

Most web and mobile phone browsers or Flash players have functionalities that can be set to block or refuse the use of cookies. However, refusing a cookie may, in some instances, hinder or curtail your User experience on our Platform or certain areas of it.

Clear GIFs

We may use "clear GIFs" (also known as "web beacons" or "pixel tags") or similar technologies, in the Platform and/or in our communications with you, to enable us to evaluate Platform usage information about visitors to our Platform, target campaigns, upgrade visitor information, and know whether you have visited a Platform page or received a message. A clear GIF is typically a one-pixel transparent image (although it can be a visible image as well), located on a Platform page or in an email or other type of message, which is retrieved from a remote site on the Internet thus enabling the verification of an individual's viewing or receipt of a Platform page or message. A clear GIF may enable us to relate your viewing or receipt of a Platform page or message to other information about you, including your personal information.

IP Address and Clickstream Data

Our server automatically collects data about your server's Internet address when you visit us. This information, known as an Internet Protocol address, or IP Address, is a number that's automatically assigned to your computer by your Internet service provider whenever you're on the Internet. When you request pages from our Platform, our servers may log your IP Address and sometimes your domain name. Your IP Address is used to help identify you and to gather demographic information about our Users as a whole. Our server may also record the referring page that linked you to us (e.g., another website or a search engine); the pages you visit on our Platform; the website or mobile application you visit after our Platform; the ads you see and/or click on; other information about the type of web browser, computer, platform, related software and settings you are using; any search terms you have entered on this Platform or a referral site; and other web usage activity and data logged by our web servers. We use this information for internal system administration, to help diagnose problems with our server, to administer our Platform, and to customise your User experience. Such information may also be used to gather demographic information, such as country of origin and Internet Service Provider. We may link this information with your personal information.

Any or all of these activities with regard to Platform usage information may be performed on our behalf by our services providers, including, for example, our analytics vendor(s) and our email management partner(s).

No Spam, Spyware or Spoofing

We and our Users do not tolerate spam. Make sure to set your Tutti communication preferences so we communicate to you as you prefer. You are not licensed to add other Users to your mailing list (email or physical mail) without their express consent. To report Tutti-related spam or spoof emails to Tutti, please forward the email to

You may not use our communication tools to send spam or otherwise send content that would violate our Terms and Conditions. We automatically scan and may manually filter messages to check for spam, viruses, phishing attacks, and other malicious activity or illegal or prohibited content, but we do not permanently store messages sent through these tools. If you send an email to an email address that is not registered in our community (via Refer-a-Friend or other tools), we do not permanently store that email or use that email address for any marketing purpose. We do not rent or sell these email addresses.


With identity theft a continuing problem, it has become increasingly common for unauthorised individuals to send email messages to consumers, purporting to represent a legitimate company such as a bank or on-line merchant, requesting that the consumer provide personal, often sensitive information. Sometimes, the domain name of the email address from which the email appears to have been sent, and the domain name of the website requesting such information, appears to be the domain name of a legitimate, trusted company. In reality, such sensitive information is received by an unauthorised individual to be used for purposes of identity theft. This illegal activity has come to be known as “phishing.”

We will never request your password or social security number via email. If you receive an email or other correspondence requesting that you provide any sensitive information (including your Platform password or credit card information) via email or to a website that does not seem to be affiliated with our Platform, or that otherwise seems suspicious to you, please do not provide such information, and report such request to us using the email

Accessing, Reviewing and Changing Your Personal Information

Your password is the key to your Tutti Account. Use unique numbers, letters, and special characters, and do not disclose your Tutti password to anyone. If you do share your password or your personal information with others, remember that you are responsible for all actions taken in the name of your Tutti Account. If you lose control of your password, you may lose substantial control over your personal information and may be subject to legally binding actions taken on your behalf. Therefore, if your password has been compromised for any reason, you should immediately notify Tutti and change your password.

You can see, review, and change most of your personal information by signing on to Tutti. Generally, we will not manually modify your personal information because it is very difficult to verify your identity remotely. You must promptly update your personal information if it changes or is inaccurate. Once you make a public posting, you may not be able to change or remove it. Upon your request, we will close your Tutti Account and remove your personal information from view as soon as reasonably possible, based on your Tutti Account activity and in accordance with applicable law. We do retain personal information from closed accounts to comply with law, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations, enforce our Terms and Conditions, and take other actions otherwise permitted by law.

How we Protect and Store Personal Information

Throughout this Privacy Policy, we use the term "personal information" to describe information that can be associated with a specific person and can be used to identify that person. We do not consider personal information to include information that has been made anonymous so that it does not identify a specific User. We store and process your personal information on our computers in the United Kingdom and elsewhere in the world where we have a presence. We protect your information using technical and administrative security measures to reduce the risks of loss, misuse, unauthorised access, disclosure and alteration. Some of the safeguards we use are firewalls and data encryption, physical access controls to our data centres, and information access authorisation controls.

We take steps to ensure that the personal information we collect is accurate and up to date, and we provide you with the opportunity to update your information through your Tutti Account profile settings. We retain information as long as it is necessary and relevant for our operations or for as long as is expressly agreed between you and us. In addition, we may retain personal information from closed accounts to comply with the law, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Terms and Conditions and take other actions permitted by law.

Although we try our best to protect the security and integrity of your personal information against both unauthorised physical and electronic access, we cannot guarantee that information during transmission through the Internet or any computer network is entirely safe from unauthorised intrusion, access or manipulation. We will make your sensitive information available to our employees and agents on a need-to-know basis. Nonetheless, we will have no liability for disclosure of information to anyone due to errors or unauthorised acts of third parties during or after transmission. In any event, where we believe personal data has been compromised, we will notify you of this.

Please note that it is important for you to protect against unauthorised access to your password and your computer. You agree to (a) immediately notify us of any unauthorised use of your password or Tutti Account or any other breach of security, and (b) ensure that you exit from your Tutti Account at the end of each session, especially where you are accessing our Platform on a public computer. It is your sole responsibility to control the dissemination and use of your password, control access to and use of your Tutti Account, and notify us when you desire to cancel your Tutti Account on our Platform. We will not be responsible or liable for any loss or damage arising from your failure to comply with this provision.

Third Parties

Except as otherwise expressly included in this Privacy Policy, this document addresses only the use and disclosure of information we collect from you. If you disclose your information to others, whether they are Users on our Platform or other sites throughout the Internet, different rules may apply to their use or disclosure of the information you provide to them. When you click links and banners on our Platform that take you to third party websites, you will be subject to the third parties’ privacy policies. Tutti does not control the privacy policies of third parties, and you are subject to the privacy policies of those third parties where applicable. We encourage you to ask questions before you disclose your personal information to others.

Right to a Copy

You have a legal right to request and obtain a copy of the information we hold about you. This includes information on how this will be used and to ensure this information is accurate. You may review and edit the personal information that is stored in your Tutti Account on our Platform. You may send us new or updated information at any time. Considering the foregoing, we will endeavour to respond to your request to access, update or delete your information as soon as practicable. Before we are able to provide you with any information, correct any inaccuracies or delete any information, however, we may ask you to verify your identity and to provide other details to help us to respond to your request. In addition, you have the right to request access to the personal information that we hold about you at any time.

Contact Us

If your privacy questions are not answered online, you may write to us by using the Contact form here, or by emailing us at

Effective date: November 1st 2018

GDPR Compliance Policy

Effective date: November 7th, 2018

This Policy on the General Data Protection Regulation (GDPR), applies to only those Users based in the European Union (EU) member states and the United Kingdom, or who are subject to EU law in relation to personal data we collect from them.

For the avoidance of doubt, for Users based in the EU member states and the United Kingdom, or who are subject to EU law in relation to personal data we collect from them, this GDPR Compliance Policy is an extension of the Terms and Conditions and the Privacy Policy, however, in the event of any contradiction between this GDPR Compliance Policy and either or both the Terms and Conditions and the Privacy Policy, the GDPR Compliance Policy shall prevail to the extent of such inconsistency. All capitalised terms not otherwise defined in this GDPR Compliance Policy shall have the same definitions ascribed to them in the Privacy Policy.

The GDPR is the new comprehensive EU legislation on the protection of personal data and its free movement, which came into effect on May 25, 2018.  The law intends to create uniform data privacy and protection laws throughout the EU member states and clarify, strengthen and elevate the rights of EU citizens and residents in relation to protecting their personal information. The GDPR applies to us in relation to any offers of products and services we make to you and any personal data we collect from you.

The information that is protected by the GDPR is “personal” and “sensitive personal” data. Personal data includes information such as your name, mailing address, e-mail address, financial information, photos and videos and online identifiers such as IP address and cookies.

GDPR requires that we follow privacy principles outlined in Article 5 of the GDPR and comply with at least one of the personal data processing conditions (see Privacy Principles and Personal Data Processing Conditions, below).

We generally do not collect sensitive personal data which includes, without limitation, information such as racial or ethnic origin, political opinions, religious, or philosophical beliefs, trade union membership, genetic, biometric and health data. GDPR requires that if we did or if we do, we should follow privacy principles outlined in Article 9 of the GDPR and comply with at least one of the personal data processing conditions relevant to sensitive personal data.

Privacy Principles

The six (6) privacy principles we must comply with in relation to your personal data are: (i) the collection must be processed lawfully, fairly and in a transparent manner; (ii) collection of personal data must be for specific, explicit and legitimate purposes, and not further processed in a manner that is incompatible with those purposes; (iii) collected personal data must be minimised to that which is adequate and relevant for the purpose for which it is processed; (iv) collected personal data must be accurate, and where necessary, kept up to date; (v) the personal data collected must be kept only for as long as is necessary for the purpose for which the data collected are processed, and removed thereafter; and (vi) the personal data collected must be processed in a manner that ensures appropriate security of the personal data.

Personal Data Processing Conditions

Personal data processing under the GDPR must satisfy at least one of the following conditions: (i) your consent must be obtained; (ii) the personal data must be necessary for the performance of a contract to which you are a party or as a preparatory step prior to entering into the contract; (iii) the personal data processing is necessary for compliance with a legal obligation; (iv) the personal data processing is necessary to protect your vital interests or of another person; (v) the processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in us; and (vi) processing is necessary for the purpose of legitimate interest pursued by us or a third party, except when such interests are overridden by your rights and freedoms.

Data Controller

As your personal data controller, we are required to conduct data privacy impact assessments, obtain appropriate consent from you (which consent you may withdraw at any time) before collecting your personal data, implement privacy by design (as explained below), and to respect the eight (8) rights of users.

Data Privacy Impact Assessments

In order to continually safeguard the protection of your data, when necessary, as determined at our discretion, we will conduct data processing impact assessments to evaluate our data protection processes and systems with an outlook toward perpetual improvement.

Appropriate Consent

Going forward, in such situations where we shall be requesting (i) your personal data such as your name, e-mail address or date of birth, afresh or for the first time, we shall request your clear, unambiguous affirmative consent beforehand, and (ii) your sensitive personal data afresh or for the first time, we shall request your explicit consent.

Privacy By Design

We undertake to continuously make the effort to implement and satisfy the requirements of privacy by design, by (i) being proactive about preventing data breaches, (ii) placing the highest premium on maintaining the privacy of your personal data, (iii) integrating privacy as a key component of future designs and updates, (iv) placing the highest premium on the privacy of your personal data, (v) implementing full lifecycle protection for your collected data, (vi) being open and transparent with you about our Privacy Policy and legal agreements, and (vii) placing you first in respect of your personal data.

Your Data Rights

The eight (8) rights that you as the user have under the GDPR with regards to when your personal information is collected, include, the right (i) to receive transparent information about data processes; (ii) of access to one’s own personal data; (iii) of correction and amendment of personal data; (iv) to expunge personal data; (v) to curtail and restrict personal data processing; (vi) to use personal data for other purposes; (vii) to objection of the processing of personal data; and (viii) in relation to protection of personal data from automation processes.

Data Processor Requirements Under the GDPR

We utilise the services of certain data processors such as Google Analytics. In some respects, we may be considered as acting as a data processor. The GDPR recognises the responsibility of data processors to maintain, secure and process collected personal data. Going forward, our data processors will be required to (i) keep and maintain written records for such data processing they carry out for us, (ii) put in place appropriate security measures in relation to the protection of your personal data, and (iii) notify us as soon as possible of any data breaches that occur, which information we are in turn required to pass on to you. To the extent that, at any time or from time to time, we may be considered to be acting as data processors, we shall endeavour to comply with this requirement.

In case you have any questions regarding your personal data and the application of the GDPR, please contact us and we shall be happy to assist you.

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