Last Updated Date: [May 24, 2018]

AbeApps Pte Ltd.(“Secure Web Payments” or “we”) has developed various software and e-commerce solutions, including payment processing services, for the marketing and sale of digital products and services provided by third parties (each a “Vendor”) to end-users (“End-Users”). We provide this Privacy Policy to inform you of our policies and procedures regarding the collection, use and disclosure of information through our service (collectively, “Service”) on our website at www.securewebpayments.com (the “Site”). This Privacy Policy may be updated from time to time. We will notify you of any material changes by posting the new Privacy Policy on the Site.
As used in this policy, the terms “using” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization or among our partners within the United States or internationally.

AbeApps Pte Ltd. has been awarded TRUSTe’s Privacy Seal signifying that this privacy policy and practices have been reviewed by TRUSTe for compliance with TRUSTe’s program requirements including transparency, accountability and choice regarding the collection and use of your personal information. The TRUSTe program does not cover information that may be collected through downloadable software. The TRUSTe program covers only information that is collected through this Website, www.securewebpayments.com. TRUSTe’s mission, as an independent third party, is to accelerate online trust among consumers and organizations globally through its leading privacy trustmark and innovative trust solutions. If you have questions or complaints regarding our privacy policy or practices, please contact us at privacy@securewebpayments.com. If you are not satisfied with our response you can contact TRUSTe here.

Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
“Account”
means an account required to access and/or use certain areas and features of Our Site;
“Cookie”
means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 12, below;]
“Our Site”
means this website,abeapps.com;
“USA and EU Cookie Law”
means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015; and 2018]
“We/Us/Our”
means AbeApps Pte Ltd.( Formerly 383 Media Inc.)

Scope – What Does This Policy Cover?
This Privacy Policy applies only to your use of Our Site. It does not extend to any websites that are linked to from Our Site (whether We provide those links or whether they are shared by other users). We have no control over how your data is collected, stored or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

Information Collection and Use

Our primary goals in collecting information from End-Users are to provide and improve the Service and the Site, and to administer the Service and the Site.

    • All personal data is stored securely in accordance with the EU General Data Protection Regulation (Regulation (EU) 2016/679) (GDPR). For more details on security see the section “How Do We Store Your Data”, below.
    • If you are an End-User purchasing a Vendor’s product or service on our Site, we may collect at the check-out page certain Personal Information about you, including name, company’s name, email address, telephone number, physical address, credit card details, and order ID. “Personal Information” means information that can be used to identify or contact a living individual. Upon payment, you may be required to provide additional information to the applicable Vendor. Some data will be collected automatically by Our Site (for further details, please see section “What Cookies We Use and For What” on Our use of Cookies)
    • We use your Personal Information to provide the Service and administer your inquiries, including in the following ways:
      • To process, validate and verify payments for purchases made through the Service.
      • To make payments to Vendors.
      • To verify the accuracy of your information.
      • To contact you about the Service.
      • To enable you to receive personalized content, advertising and promotions based on your preferences.
      • To enforce our Terms of Use.
      • Providing and managing your Account;
      • Providing and managing your access to Our Site;
      • Personalising and tailoring your experience on Our Site;
      • Supplying Our [products and] services to you;
      • Personalising and tailoring Our [products and] services for you;
      • Responding to communications from you;
      • Supplying you with email newsletters (you may unsubscribe or opt-out at any time by Insert Description of Unsubscription Method;
      • [Market research;]
      • Analysing your use of Our Site [and gathering feedback] to enable Us to continually improve Our Site and your user experience;
    • We may also use your Personal Information to contact you with our newsletters, marketing or promotional materials and other information that may be of interest. If you decide at any time that you no longer wish to receive such communications from us, please follow the unsubscribe instructions provided in any of the communications. (See “Changing or Deleting Information” below)
    • We may also collect Personal Information from Vendors, including business contact details and any information that Vendors decide to provide to use, whether through the Site or otherwise. We use such information only in connection with our relationship with the applicable Vendor.
    • In some cases, the collection of data may be a statutory or contractual requirement, and We will be limited in the [products and] services We can provide you without your consent for Us to be able to use such data.
    • With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email AND/OR telephone AND/OR services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Com
    • [Advertisers whose content appears on Our Site may engage in what is known as “behavioural advertising” – advertising which is tailored to your preferences, based on your activity. Your activity is monitored using Cookies, as detailed below in section 12. You can control and limit your data used in this way by adjusting your web browser’s privacy settings. Please note that We do not control the activities of such advertisers, nor the information they collect and use. Limiting the use of your data in this way will not remove the advertising, but it will make it less relevant to your interests and activities on Our Site.]
    • Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following basis applies:
        • you have given consent to the processing of your personal data for one or more specific purposes;
        • processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;
        • processing is necessary for compliance with a legal obligation to which we are subject;
        • processing is necessary to protect the vital interests of you or of another natural person;
        • processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or
        • processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child. [List specific legitimate interests if available]

      .

Anonymous Information
We may also collect various information regarding the interaction(s) between End-Users and the Site, including IP addresses and usage information, such as ad content/banner delivery, counting click-throughs on an ad/banner, tracking web page views following a click-through, and sales tracking] (collectively, “Anonymous Information”). We use Anonymous Information mainly to evaluate and improve the Service, and to provide Vendors with insights into their End-Users’ behaviors and preferences, all on an anonymous basis.

How and Where Do We Store Your Data?
We only keep your data for as long as We need to in order to use it as described above in “How we use your information”, and/or for as long as We have your permission to keep it. In any event, We will conduct an annual review to ascertain whether we need to keep your data. Your data will be deleted if we no longer need it in accordance with the terms of our Data Retention Policy. Our Data Retention Policies are:

[Your data will only be stored within the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein).]

OR

[Some or all of your data may be stored or transferred outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland and Liechtenstein). You are deemed to accept and agree to this by using Our Site and submitting information to Us. If We do store or transfer data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the EEA and under the GDPR. Such steps may include, but not be limited to, the use of legally binding contractual terms between Us and any third parties We engage and the use of the EU-approved Model Contractual Arrangements. [If We intend at any time to transfer any of your data outside the EEA, We will always obtain your consent beforehand.

Data security is of great importance to Us, and to protect your data We have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through Our Site.

Notwithstanding the security measures that We take, it is important to remember that the transmission of data via the internet may not be completely secure and that you are advised to take suitable precautions when transmitting to Us data via the internet.

Do We Share Your Data?

[We may share your data with other companies in Our group. This includes [Our subsidiaries] AND/OR [Our holding company and its subsidiaries].]
We may contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law. We currently contract with Google, Bing, Facebook,

We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales and other information. All such data will be anonymised and will not include any personally identifying information. We may from time to time share such data with third parties such as prospective investors, affiliates, partners and advertisers. Data will only be shared and used within the bounds of the law.

In certain circumstances We may be legally required to share certain data held by Us, which may include your personal information, for example, where We are involved in legal proceedings, where We are complying with the requirements of legislation, a court order, or a governmental authority. We do not require any further consent from you in order to share your data in such circumstances and will comply as required with any legally binding request that is made of Us.

What Happens If Our Business Changes Hands?
We may, from time to time, expand or reduce Our business and this may involve the sale and/or the transfer of control of all or part of Our business. Data provided by users will, where it is relevant to any part of Our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the data for the purposes for which it was originally collected by Us.
In the event that any of your data is to be transferred in such a manner, you will not be contacted in advance and informed of the changes.

How Can You Control Your Data?
When you submit information via Our Site, you may be given options to restrict Our use of your data. We aim to give you strong controls on Our use of your data (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details.

You may email Us at any time at privacy@securewebpayments.com for further information on your data.

Your Right to Withhold Information and Your Right to Withdraw Information After You Have Given it
You may access Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data. You may restrict your internet browser’s use of Cookies. For more information, see section below “What Cookies Do We Use and What For?”

You may withdraw your consent for Us to use your personal data as set out above at any time by contacting Us using the details set out in section “What Cookies Do We Use and What For?”, and We will delete Your data from Our systems. However, you acknowledge this may limit Our ability to provide the best possible products and services to you.

How Can You Access Your Data?
You have the legal right to ask for a copy of any of your personal data held by Us (where such data is held). Please contact Us for more details at support@abeapps.com, or using the contact details below under “Contact Us”.

What Cookies Do We Use and What For?
Our Site may place and access certain first party Cookies on your computer or device. First party Cookies are those placed directly by Us and are used only by Us. We use Cookies to facilitate and improve your experience of Our Site and to provide and improve Our [products and] services. For more details, please refer to section 5, above, and to section 12.6 below. We have carefully chosen these Cookies and have taken steps to ensure that your privacy is protected and respected at all times.

By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. For more details, please refer to section on “Cookies” below. These Cookies are not integral to the functioning of Our Site.

All Cookies used by and on Our Site are used in accordance with current English and EU Cookie Law.

Before [any] Cookies are placed on your computer or device, you will be shown a [Insert description of prompt e.g. pop-up, message bar etc.] requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended. [You will be given the opportunity to allow only first party Cookies and block third party Cookies.]

[Certain features of Our Site depend on Cookies to function. [Your Country] and EU Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below in Table 1.1 Your consent will not be sought to place these Cookies. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that Our Site may not work as intended if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.]

The following first party Cookies may be placed on your computer or device (Table 1.1):

Name of Cookie Purpose Strictly Necessary
8812c36aa5ae336c2a77bf63211d899a Maintains user country, currency and cart identified data. It also includes key marked for A/B yes
PHPSESSID Maintaining User’s session Yes
SERVERID Identifies which server is serving user’s request. This is used for load balancing Yes
affiliateCode From which affiliate user lands on website No
clickid Clickid of of landing page. No
subSource From which sub source user lands on website No
ckIds list of all Clickids of user No

and the following third party Cookies may be placed on your computer or device(Table 1.2):

Name of Cookie Provider Purpose
__cfduid Maxmind Fraud Detection

 

Our Site uses analytics services provided by [Google Analytics, Leads 383media. Website analytics refers to a set of tools used to collect and analyse usage statistics, enabling Us to better understand how people use Our Site. This, in turn, enables Us to improve Our Site and the [products and] services offered through it. You do not have to allow Us to use these Cookies, as detailed below, however whilst Our use of them does not pose any risk to your privacy or your safe use of Our Site, it does enable Us to continually improve Our Site, making it a better and more useful experience for you.
The analytics service(s) used by Our Site use(s) Cookies to gather the required information. [Certain of these Cookies may be placed immediately when you first visit Our Site and it may not be possible for Us to obtain your prior consent. You may remove these Cookies and prevent future use of them by following the steps set out below in section 12.10.]
The analytics service(s) used by Our Site use(s) the following Cookies:

Name of Cookie First / Third Party Provider Purpose
NID
__utma
__utmb
__utmc
__utmz
__utmt
Third Party Google analytic Names of cookies that start with __utm and _ga originate from Google Analytics and are used to collect information about usage statistics.
JSESSIONID Third Party Leads 383media User session identifier
LDSERVERID Third Party Leads 383media Identifies which server is serving user’s request. This is used for load balancing
ckIds Third Party Leads 383media List of all Clickids of user
clkid Third Party Leads 383media Clickid of of landing page
clickid Third Party Leads 383media Clickid of of landing page.

 

Name of Cookie Provider Purpose
APISID, NID, SID, 1P_JAR Google API Google uses these cookies, based on recent searches and interactions, to customise ads on Google websites

 

You can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all cookies or only third party cookies. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

You can choose to delete Cookies at any time however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.

It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.]

Summary of Your Rights under GDPR
Under the GDPR, you have:

  • the right to request access to, deletion of or correction of, your personal data held by Us;
  • the right to complain to a supervisory authority;
  • be informed of what data processing is taking place;
  • the right to restrict processing;
  • the right to data portability;
  • object to processing of your personal data;
  • rights with respect to automated decision-making and profiling (see section 14 below).

To enforce any of the foregoing rights or if you have any other questions about Our Site or this Privacy Policy, please contact Us using the details set out in section “Contact Us”.

Automated Decision-Making and Profiling
In the event that We use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on You, You have the right to challenge to such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from Us.

The right described in section 14.1 does not apply in the following circumstances:

a) The decision is necessary for the entry into, or performance of, a contract between the You and Us;
b) The decision is authorised by law; or
c) You have given you explicit consent.

Where We use your personal data for profiling purposes, the following shall apply:

a) Clear information explaining the profiling will be provided, including its significance and the likely consequences;
b) Appropriate mathematical or statistical procedures will be used;
c) Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
d) All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.

Log Data
When you visit the Site, our servers automatically record information that your browser sends whenever you visit a website (“Log Data”). This Log Data may include information such as pages that you visit, the time spent on those pages, access times and dates, and other statistics. We use this information to monitor and analyze use of the Service and for the Service’s technical administration, to increase our Service’s functionality and user-friendliness, and to better tailor our Service to our visitors’ needs. We also use this information to verify that visitors to the Service meet the criteria required to process their requests. We do not use Log Data in association with other Personal Information, though we may aggregate, analyze and evaluate such information for the same purposes as stated above regarding other Anonymous Information.

Cookies
Like many websites, we use “cookies” to collect information on the Site. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. We use cookies for two purposes. First, we utilize persistent cookies to save your login information for future logins. Second, we utilize session ID cookies to enable certain features of the Site, to better understand how you interact with such sites and to monitor aggregate usage by users and web traffic routing on such sites. Unlike persistent cookies, session cookies are deleted from your computer when you log off from the applicable site and then close your browser. You can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all functionality of the Site.

Phishing
Identity theft and the practice currently known as “phishing” are of great concern to us. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information, your login information, or national identification numbers in a non-secure or unsolicited e-mail or telephone communication. For more information about phishing, visit the Federal Trade Commission’s website.

Information Sharing and Disclosure
Vendors. We may share information collected from End-Users, whether Personal or Anonymous Information (collectively, “End-User Information”) with the applicable Vendor, i.e., the Vendor that provides the products or services purchased by the End-User through the Site.

Service Providers. We may employ third party companies and individuals to facilitate our Service, to provide the Service on our behalf, to perform services related to the Site (e.g., without limitation, maintenance services, database management, web analytics, payment processing) or to assist us in analyzing how our Service is used. These third parties have access to End-User Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Compliance with Laws and Law Enforcement. We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose End-User Information to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to, subpoenas), to protect the property and rights of Securewebpayments or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable activity.

Business Transfers. We may sell, transfer or otherwise share some or all of its assets, including End-User Information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.

Changing or Deleting Your Information
If you are an End-User with an account with us, you may review, update, correct or delete the Personal Information provided during registration by contacting us at: privacy@securewebpayments.com.
If you completely delete all such information, then your account may become deactivated. If you would like us to delete your account in our system, please contact us as described above with a request that we delete your Personal Information from our database. We will use commercially reasonable efforts to honor your request. We may retain an archived copy of your records as required by law or for legitimate business purposes.

Security
Secure Web Payments is very concerned with safeguarding your information. We process payments in connection with the Service in compliance with the PCI Security Standards and employ reasonable physical, technological, and administrative security measures and attempt to ensure they are applicable under the circumstances. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored “personal data” (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting via the Service in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

International Transfer
Your information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to provide information to us, Secure Web Payments may transfer your information, including Personal Information, to the United States and processes it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Links to Other Websites
Our Service contains links to other websites. If you choose to click on a third party link, you will be directed to that third party’s website. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other websites follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.

Our Policy Toward Children
This Service is not directed to persons under 18. We do not knowingly collect personally identifiable information from children under 13. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at privacy@securewebpayments.com. If we become aware that a child under 13 has provided us with Personal Information, we will delete such information from our files.

Contact Us
If you have any questions about this Privacy Policy, please contact us at privacy@securewebpayments.com or support@abeapps.com

BY MAIL:
AbeApps Pte. Ltd.
Street: 17 PHILLIP STREET
#05-01 GRAND BUILDING
SINGAPORE (SG) 048695