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| A. Overview |
In order to operate the comGateway service and to reduce the risk of fraud, comGateway must ask you to provide us information about yourself and your credit card. This Privacy Policy describes the information we collect and how we use that information. comGateway takes the privacy of your personal information very seriously and will use your information only in accordance with the terms of this Privacy Policy. We will not sell or rent your personally identifiable information or a list of our customers to third parties. However, as described in more detail in Part C below, there are limited circumstances in which some of your information will be shared with third parties, under strict restrictions, so it is important for you to review this Privacy Policy. This Privacy Policy applies to all services that are hosted on the comGateway.com Web site, whether the services are offered by comGateway. By accepting the Privacy Policy and User Agreement in registration, you expressly consent to our use and disclosure of your personal information in the manner described in this Privacy Policy. This Privacy Policy is incorporated into and subject to the terms of the comGateway User Agreement. This Privacy Policy will take effect on November 1, 2004. Please note that your personal information will be stored and processed on our computers. The laws on holding personal data in the Singapore may be less stringent than the laws of your country but comGateway will hold and transmit your personal information in a safe, confidential and secure environment. If you object to your personal information being transferred or used as described in this Privacy Policy, please do not register for the comGateway service.
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| Notification of Changes |
This policy may be revised over time as new features are added to the comGateway service or as we incorporate suggestions from our customers. If we are going to use or disclose your personally identifiable information in a manner materially different from that stated at the time we collected the information, you will have a choice as to whether or not we use or disclose your information in this new manner. Any material changes will be effective only after we provide you by e-mail with at least 30 days' notice of the amended Privacy Policy (if you have closed your comGateway account, you will not be contacted to notify you of the amended Policy and your personal information will not be used or disclosed in this new manner). We will post the amended Privacy Policy prominently on our Web site so that you can always review what information we gather, how we might use that information, and whether we will disclose it to anyone. Please check the comGateway Web site at www.comGateway.com at any time for the most current version of our Privacy Policy.
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| A Special Note About Children |
Children are not eligible to use our service and we ask that minors (under the age of 18) do not submit any personal information to us or use the service.
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| B. Information We Collect |
| Required Information |
To open a comGateway account, you must provide your name, address, mobile phone number, e-mail address and your credit card number and expiration date. We also ask you to choose a security question to answer (such as your city of birth or your pet's name) This required information is necessary for us to process transactions, issue a new password if you forget or lose your password, protect you against credit card fraud and checking account fraud, and to contact you should the need arise in administering your account.
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| Transaction Information |
When you use comGateway to purchase merchandise or services from someone else, we ask you to provide information related to each transaction, including the amount of the transaction, a brief description of the purchase. We retain this information for each of your transactions through comGateway. We also collect the Internet address (IP address) of the computer or device you use to access your comGateway account, in order to help detect possible instances of unauthorized transactions. To facilitate customs declarations when we courier your purchases to you, we will disclose information of your purchase to the relevant authorities on your behalf.
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| Additional Verification |
Your comGateway password and mobile phone PIN are to be used when operating your comGateway service only. We will never disclose these data to any third parties including your bank and/or Credit Card Company. You should also not disclose your comGateway password or mobile phone PIN except when operating your account with comGateway.
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| Customer Service Correspondence |
If you send us correspondence, including e-mails and faxes, we retain such information in the records of your account. We will also retain customer service correspondence and other correspondence from comGateway to you. We retain these records in order to measure and improve our customer service, and to investigate potential fraud and violations of our User Agreement. We may, over time, delete these records if permitted by law.
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| Questionnaires, Surveys and Profile Data |
From time to time, we offer optional questionnaires and surveys to our users for such purposes as collecting demographic information or assessing users' interests and needs. The use of the information collected will be explained in detail in the survey itself. If we collect personally identifiable information from our users in these questionnaires and surveys, the users will be given notice of how the information will be used prior to their participation in the survey or questionnaire.
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| C. Our Use and Disclosure of Information |
| Internal Uses |
We collect, store and process your personal information on servers located in Singapore. We use the information we collect about you in order 1) to provide our services and process your transactions, 2) to provide customer service, 3) to determine your eligibility to receive offers for special features or products.
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| Disclosure to Third Parties |
comGateway will not sell or rent any of your personally identifiable information to third parties. comGateway will not share any of your personally identifiable information with third parties except in the limited circumstances described below, or with your express permission. These third parties are limited by law or by contract from using the information for secondary purposes beyond the purposes for which the information is shared.
| 1. |
We share information with companies that help us process the transactions you request and protect our customers' transactions from fraud, such as sharing your Credit card number with a service that screens for lost and stolen card numbers. We disclose information that we in good faith believe is appropriate to cooperate in investigations of fraud or other illegal activity, or to conduct investigations of violations of our User Agreement.
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| 2. |
We disclose information in response to a subpoena, warrant, court order, levy, attachment, order of a court-appointed receiver or other comparable legal process, including subpoenas from private parties in a civil action.
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| 3. |
We share aggregated statistical data with our business partners or for public relations. For example, we may disclose that a specific percentage of our users live in Singapore. However, this aggregated information is not tied to personally identifiable information.
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| 4. |
We share your information with our parent, subsidiaries and joint ventures to help coordinate the services we provide to you, enforce our terms and conditions, and promote trust and safety.
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| Our Contacts with comGateway Customers |
We communicate with users on a regular basis via e-mail to provide requested services, and we also communicate by phone to resolve customer complaints or investigate suspicious transactions. We use your e-mail address to confirm your opening of a comGateway account, to send you notice of payments that you send or receive through comGateway (including referral payments described below), to send information about important changes to our products and services, including the comGateway Periodical newsletter and to send notices and other disclosures required by law. Generally, users cannot opt out of these communications, but they will be primarily informational in nature rather than promotional.
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| Internet Address Information |
We use IP addresses, browser types and access times to analyze trends, administer the site, improve site performance and gather broad demographic information for aggregate use.
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| D. Information Security |
| Information Security |
comGateway is committed to handling your customer information with high standards of information security. Your credit card and account information are stored only in encrypted form on computers that are not connected to the Internet. We restrict access to your personally identifiable information to employees who need to know that information in order to provide products or services to you. We maintain physical, electronic and procedural safeguards to protect your nonpublic personal information. We test our security systems regularly and also contract with outside companies to audit our security systems and processes.
The security of your comGateway account also relies on your protection of your comGateway password and mobile phone PIN. You may not share your comGateway password with anyone. comGateway will never ask you to send your password or other sensitive information to us in an e-mail, though we may ask you to enter this type of information on the comGateway website, which will always have a URL beginning with https://www.comGateway.com/. The padlock icon found in most browsers will appear locked and the first characters of the website address will change from "http" to "https" if you are accessing a secure server.
Any e-mail or other communication requesting your password, asking you to provide sensitive account information via email, or linking to a website with a URL that does not begin with https://www.comGateway.com/ should be treated as unauthorized and suspicious and should be reported to comGateway immediately. If you do share your comGateway password and/or mobile PIN with a third party for any reason, including because the third party has promised to provide you additional services such as account aggregation, the third party will have access to your account and your personal information, and you may be responsible for actions taken using your password. If you believe someone else has obtained access to your password, please change it immediately by logging in to your account at www.comGateway.com and changing your Profile settings.
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| E. Accessing and Changing Your Information |
You can review the personal information you provided us and make any desired changes to such information, or to the settings for your comGateway account, at any time by logging in to your account on the comGateway Web site and changing your profile including your password and/or mobile phone PIN. You can also close your account through the comGateway Web site. If you close your comGateway account, we will mark your account in our database as "Closed," but will keep your account information in our database. This is necessary in order to deter fraud, by ensuring that persons who try to commit fraud will not be able to avoid detection simply by closing their account and opening a new account. However, if you close your account, your personally identifiable information will not be used by us for any further purposes, nor sold or shared with third parties.
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| F. Contacting Us |
If you have any questions about this privacy statement, comGateway's information practices, or your dealings with comGateway, you can contact us by writing to us at Customer Service comGateway (S) Pte Ltd, 5 Shenton Way, UIC Building #05-01 Singapore 068808 or send us an email at customerservice@comGateway.com.
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