1. Personal Data we collect and use

Generally, we do not collect any Personal Data when you are browsing this Website. We also do not employ any cookies or other technology to track your usage of this Website. Only in case that you send an inquiry to the contact e-mail provided on some of the pages or you sign up for our newsletter, we collect the information that you provide us. This will include your e-mail address, and any other information that you include in the inquiry, such as your name and the content of your messages. 

2. How we use your Personal Data and the basis on which we use it

We only use and store the information related to your inquiry in order to respond to your request. If you sign up to be informed about updates at respective form of the page, we will use your e-mail address to send you the requested newsletters.

3. Your rights over your Personal Data 

You have certain rights regarding your Personal Data, subject to local law. These include the following rights to:

• access your Personal Data
• rectify the information we hold about you
• erase your Personal Data
• restrict our use of your Personal Data 
• object to our use of your Personal Data
• receive your Personal Data in a usable electronic format and transmit it to an external party (right to data portability)
• learn more about the sources from which we collect information, the purposes for which we collect and share information, the information we hold, and the categories of parties with whom we share your information;
• for California residents, opt out of certain disclosures of Personal Data that California law defines as “sales” even if no money is exchanged (you may exercise that right here: Do Not Sell My Personal Data);
• exercise rights without fear of being denied goods or services;
• lodge a complaint with your local data protection authority.

If you would like to discuss or exercise such rights, please contact us via the e-mail address below. We will contact you if we need additional information from you in order to honour your requests. 

4. Information Sharing

We may disclose your Personal Data for business purposes to the following parties:

• Service providers and business partners. We may share your Personal Data with our service providers and business partners that perform business operations for us. For example, we may partner with other companies to support email and messaging services. 
• Rakuten Group companies. Rakuten Group, Inc. is the parent company.  We work closely with Rakuten Group, Inc. and other businesses and companies that fall under the Rakuten Group family. We may share certain information about you with Rakuten Group, Inc. and other Rakuten Group companies if your inquiry requires this.
• Law enforcement agencies, courts, regulators and government authorities. We may share your Personal Data with these parties where we believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party.
• Asset purchasers. We may share your Personal Data with any third party that purchases, or to which we transfer, all or substantially all of our assets and business. Should such a sale or transfer occur, we will use reasonable efforts to try to ensure that the entity to which we transfer your Personal Data uses it in a manner that is consistent with this privacy notice. 

5. Information Security and Storage

We implement technical and organisational measures to ensure a level of security appropriate to the risk to the Personal Data we process. These measures are aimed at ensuring the on-going integrity and confidentiality of Personal Data. We evaluate these measures on a regular basis to ensure the security of the processing. 

6. Retention

We will keep your Personal Data for as long as necessary to respond to your inquiry. We keep your e-mail address for newsletters until you unsubscribe. We will only retain your Personal Data after this time if we are required to do so to comply with the law, or if there are outstanding claims or complaints that will reasonably require your Personal Data to be retained.

7. International Data Transfers

Your Personal Data may be transferred to, stored, and processed in a country that is not regarded as ensuring an adequate level of protection for Personal Data in relation to the country you are located in. 

We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to ensure that your Personal Data is adequately protected. For more information on the appropriate safeguards in place, please contact us at the details below. 

As part of the Rakuten Group, we rely on the Rakuten Group Binding Corporate Rules to legitimize international data transfers within the Group. The Rakuten Group Binding Corporate Rules can be found at https://corp.rakuten.co.jp/privacy/en/bcr.html.

8. Contact Us

Rakuten Symphony Singapore, Pte. Ltd. is the controller responsible for the Personal Data we collect and process. 

If you have questions or concerns regarding the way in which your Personal Data has been used, please contact mobile-SymwarePrivacyPolicy@mail.rakuten.com

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to make a complaint to your data protection authority or to the data protection authority of Luxembourg, using their website https://cnpd.public.lu/en.html.

9. Changes to the Notice

We may modify or update this privacy notice from time to time. Please check back here for any updates.

Last modified: October 25, 2021