Creative Media Works PTE LTD (“CMW”, “we”, “us” or “our”) is committed to and has a long-standing policy of maintaining the privacy and security of your personal data or information (which is information about an identifiable individual as defined by applicable privacy or data protection laws). Any capitalized terms in this Privacy Policy that are not defined herein have the meaning set out in the BBM Terms of Service which can be viewed at www.bbm.com/en/legal/terms-of-service.html

This Privacy Policy generally explains CMW’s practices with respect to the processing of your personal information which includes the collection, use, processing, transfer, storage or disclosure of your personal information you may provide to us through the Services or any other communications with CMW. In addition, agreements or notices associated with certain Services may provide additional information about CMW’s and/or the other members of the CMW Group of Companies’ processing of your personal information (“Notice”). The application of this Privacy Policy remains subject to the Personal Data Protection Act 2012 of Singapore (“PDPA”) or other applicable laws including legislation, regulations and the orders of any courts or other lawful authorities, other lawful requests or legal processes.

1. CMW’s accountability

CMW is responsible for properly managing, protecting and processing your personal information in its control and will only collect, use and disclose your personal information in accordance with this Privacy Policy.


2. Purposes for using your personal information

CMW and other members of the CMW Group of Companies may collect, use, process and/or disclose your personal information provided by or on behalf of you in connection with your access to or use of the Services and/or Third Party Offerings, your correspondence with CMW or any other member of the CMW Group of Companies, your entering a contest sponsored by CMW or any other member of the CMW Group of Companies or your other interactions with CMW or any other member of the CMW Group of Companies, for the following purposes:

  1. to understand and meet your needs and preferences, and to provide you with the Services and/or Third Party Offerings, e.g.:
    1. for purposes related to the billing, activation, provision, maintenance, support, trouble shooting, resolving of disputes, deactivation, replacement, upgrade or update of the Services;
    2. to better understand, analyze and predict your preferences and interests, and combine such information with other information to customize your experience;
    3. to ensure the Services are technically functioning as intended and to help identify and troubleshoot issues;
    4. to facilitate your access and use of Services and/or Third Party Offerings;
    5. to send invitations-to-subscribe, messages and posts within the Services on behalf of Channel administrators;
    6. to combine such information with information obtained from other sources (including Third Party Offerings) in connection with the provision of the Services;
    7. to fulfill or enforce Notices applicable to the Services;
    8. to manage or respond to your inquiries;
  2. to develop new and enhance existing Services and to provide you with information on third party content or related products, services and software including to communicate with you about them using various means, e.g. to make available or send to you:
    1. upgrades or updates, or notices of upgrades or updates, of the Services or third party content or related products, services and software;
    2. notices of promotions, contests, offers and upcoming events;
    3. personalized information, surveys, marketing materials, advertisement or customized content;
  3. to collect, use and disclose advertising identifiers, including those provided by other software platforms, or similar identifiers, to facilitate the CMW Group of Companies in conducting analytics or the provision of promotional content or other information that may be relevant to you;
  4. to manage and develop our business and operations, e.g.:
    1. to detect, monitor, investigate, mitigate or attempt to prevent fraud and technical or security issues or to protect the property of the CMW Group of Companies;
    2. to allow for business continuity and disaster recovery operations;
    3. to obtain legal services, to seek legal advice and/or to enforce CMW’s legal rights or the legal rights of any other member of the CMW Group of Companies;
    4. for statistical purposes;
  5. to meet legal and regulatory requirements and to respond to emergency situations, e.g.:
    1. to respond to court orders, warrants or other lawful requests or legal processes;
    2. to provide emergency assistance in situations that may threaten the life or physical safety of you or others; or
  6. for any other purposes for which you have consented, such as those that may be set out in Notices, and other purposes as permitted or required by any applicable laws and regulations.

3. Your consent

By submitting or otherwise making available your personal information when you use the Services (including the installation and/or use of software, or associated Internet service or mobile data service, or the creation of a User ID or other user account), correspond with CMW or any other member of the CMW Group of Companies, enter a contest sponsored by CMW or any other member of the CMW Group of Companies or otherwise interact with CMW or any other member of the CMW Group of Companies, you consent to the CMW Group of Companies, their service providers, and other third parties collecting, using, disclosing and processing your personal information in accordance with this Privacy Policy.

By submitting or otherwise making available personal information relating to other individuals (such as your spouse, family members, employees or any other third parties, including minors) when you use the Services (including the installation and/or use of software, or associated Internet service or mobile data service, or the creation of a User ID or other user account), correspond with CMW or any other member of the CMW Group of Companies, enter a contest sponsored by CMW or any other member of the CMW Group of Companies or otherwise interact with CMW or any other member of the CMW Group of Companies, you represent and warrant that you are authorized to provide such information to us and that you have obtained all necessary consents to the collection, use, disclosure and/or processing of such information by the CMW Group of Companies, their service providers, and other third parties, in accordance with this Privacy Policy.

You represent and warrant that all information provided by you is accurate and complete, and that none of it is misleading or out of date. You will promptly update us in the event of any change to the personal information provided or otherwise made available by you to us or any other member of the CMW Group of Companies.

Before using the Services (or any portions thereof), you may be required to agree to an applicable Notice that may contain additional information regarding the collection, use, disclosure and/or processing of your personal information by the CMW Group of Companies, their service providers, and other third parties. Your use of the Services thereafter indicates your agreement to such Notice and your consent for your personal information to be collected, used, processed and/or disclosed by the CMW Group of Companies, their service providers and other third parties (as the case may be) to collect, use, process and disclose for the purposes identified in such Notice.

  1. When obtaining consent is not required
    In certain circumstances, your personal information may be collected, used or disclosed without your consent depending on the jurisdiction and any other applicable laws. For example, CMW and/or any other member of the CMW Group of Companies may not seek consent for the collection, use or disclosure of personal data (as may be applicable):
    1. in the case of an emergency that threatens the life, health or safety of an individual;
    2. when necessary for a purpose that is clearly in your interest, if consent cannot be obtained in a timely way;
    3. when necessary for any investigation;
    4. when disclosure is necessary to obtain legal services;
    5. to recover a debt;
    6. when necessary for proceedings including a subpoena, warrant or other court order, lawful request or legal process; or
    7. as may be otherwise required or permitted by law.
  2. Children
    CMW does not knowingly collect, use, process or disclose personal information from individuals under the age of 13 without the consent of their parent or legal guardian.
  3. Aggregated or anonymous information
    CMW and other members of the CMW Group of Companies may process, sell, trade or rent anonymous information that is not associated with or linked to an identifiable individual.

4. Types of information collected, used, disclosed and/or processed

The types of information that CMW and/or other members of the CMW Group of Companies may collect, use, disclose and/or process can vary depending on the portion of the Services used and the nature of your interaction with CMW and/or other members of the CMW Group of Companies. For example:

  1. Account and membership information: Information processed could include your name, postal address, email address, telephone number, User ID, device identifier information such as your BBM PIN, airtime service provider information, information contained in communications with CMW and any recorded complaints. CMW and other members of the CMW Group of Companies may also process your account credentials, passwords, profile information, language preference, country and time zone, and other information you provide to facilitate the Services you use.
  2. Profile management: The CMW Group of Companies may use your user account information (which may include your User ID) and information about products and services that are associated with your user account to better understand, analyze and predict your preferences and interests, and may combine it with other information to customize your experience, suggest other products and services to you, and provide you with more relevant promotional content based on your user profile. This does not mean that data that personally identifies you will be shared with third party advertisers. The CMW Group of Companies and their service providers may collect, use, disclose and process advertising identifiers, including those provided by other software platforms, or similar identifier, in order to facilitate the CMW Group of Companies in conducting analytics or providing promotional content or other information that may be relevant to you, and the CMW Group of Companies may connect such identifiers with your user profile. If you do not wish such identifiers to be connected to personally-identifiable information or associated with a persistent device identifier(s) by the CMW Group of Companies used in order to facilitate targeted promotional content, you should review the applicable settings for the software platform on which you access or use the Services for options that may be available to adjust interest-based advertising settings.
  3. Third Party Offerings: In some cases, the CMW Group of Companies may process information about applications used on your device including “Third Party Offerings” (i.e. applications, products, services, software, websites or content provided by a third party, including an airtime service provider or application developer, that may be used in conjunction with Services, but are not offered, operated or supported by CMW). If you choose to use Third Party Offerings with your user account with CMW, certain information may be collected and disclosed to the third party, or from the third party to CMW, in order to facilitate or improve the services and functionality provided.
  4. Social functionality: The Services include a "social functionality" element that allows you to make yourself discoverable and connect with other individuals, and to improve or enhance your experience with the Services or other services, software or content that are integrated with the Services. In order to provide such functionality, you agree that your availability to interact or connect with the others may be indicated to other users, and your profile, display names, display pictures, status messages, membership status, and other identifiers or information may be viewed and, in some cases, commented on by other users. For example, if you elect to use your user account credentials with ID Accessible Services, you agree that, where such functionality exists: (i) your BBM Contacts may see whether you are using such service; (ii) your BBM Contacts may see your profile for the service and the software and content (such as games, music or other media files, depending on the service or software) that you have downloaded, are consuming, or that is available for sharing as part of your use of the service, as well as comments you or others make about the service, software and content; (iii) when you submit comments about your BBM Contacts or the software or content such BBM Contacts have downloaded or are consuming as part of their use of the service, information about you (such as your comments, user profile name, and display picture) may be displayed to other contacts of that BBM Contact, and (iv) the service may include an automated functionality that performs analysis to develop recommendations based on your preferences and utilization of the service, content or software. Please check the applicable settings options for the relevant ID Accessible Services for available options to connect to or disconnect from your user account with CMW and adjust any other available privacy settings for such services or software.
  5. BBM Channels. By becoming a subscriber to a Channel, you acknowledge and agree that certain information about you, including your display name, display picture and other information contained in your public profile, will be accessible by the Channel administrator, and any personal information that is provided to the Channel administrator will be subject to the applicable privacy policy of the Channel administrator. The CMW Group of Companies may also use information collected in connection with your use of BBM Channels, including your Channel subscriptions and activities, information associated to your user profile and user account, and your location, to understand and predict your preferences and interests in order to develop, communicate, or provide you with Channels recommendations, content or services that may interest you. The CMW Group of Companies may also combine such data with information about your use of other products and services to customize your experience, suggest other products and services to you, and provide you with more relevant promotional content based on your user profile. This may include sending you invitations-to-subscribe, messages and posts on behalf of Channel administrators who request us to send messages to BBM Channels users or target audience segments that match your demographic profile and interests. However, we will not provide personally identifiable information to Channel administrators unless you give us permission to do so (for example, as set out in this Privacy Policy). The Channel administrators may send you content, offers, information about promotions, or other communications within the Services. Please review the applicable settings within the Portal for available controls regarding how to block future unsolicited invites or messages from a particular Channel, and how to unsubscribe from a Channel.
  6. Cloud-based or back-up data: If you use a cloud-based (which include remote access or storage functionality) or back-up and restore service provided by or on behalf of CMW, information from your device or account including contacts, email addresses, calendar, reminder entries, photos, memo, tasks, display pictures, status, personal messages, address book information, media files and other on-device information may be sent to the CMW Group of Companies in order to facilitate or improve the use, remote access and restoration of that data on your device through the service provided.
  7. Cookies or similar technologies: A cookie is a small text file or piece of data that is downloaded to and stored on your computer or device when you visit a website. Cookies are then sent back to the originating website on each subsequent visit, or to another website that recognizes the cookie. As part of the Services, the CMW Group of Companies may use different types of cookies or similar technologies (“Cookies”) from time to time. Certain Cookies are necessary to facilitate your use of the Services (such as when you use a shopping basket) or to protect both you and the CMW Group of Companies when you sign-in to certain services (such as storing your credentials to make it easier whenever you want to use the Services or to confirm that you are logged in). Other Cookies are more performance-related such as for analytics or contextual purposes to help the CMW Group of Companies understand how users engage with the Services so the CMW Group of Companies can provide new and enhanced Services (such as which pages or features are most popular). Some Cookies are more function-related and help personalize your experience and make the Services easier to use (such as your language or jurisdiction preferences), or to help the CMW Group of Companies display personalized content to you. Other Cookies or similar technologies may be used for targeted advertising purposes (e.g. certain Services may be supported by advertising revenue and display advertisements and promotions which may be targeted against non-personally identifiable attributes or aggregate data collected by the CMW Group of Companies, and the CMW Group of Companies or their service providers may place such advertising on the Services). Anonymized information about usage of the Services may be provided in a form that does not personally identify you to the service providers of the CMW Group of Companies as part of analytics services and to help manage online advertising. You consent to the collection of your personal information using Cookies for the purposes set out in this paragraph. You may withdraw your consent to the collection of your personal information using Cookies by disabling Cookies on your browser. Most browsers are initially set to accept Cookies, but you can usually change your browser settings to refuse Cookies or to indicate when a Cookie is being sent. You can typically remove or block browser Cookies using the settings in your browser, but that may impact your ability to use certain Services as they may not work well or at all with Cookies disabled. Please visit the section below on “Managing your preferences” for more information on managing the use of Cookies by the CMW Group of Companies.
  8. Financial information: If you purchase a product, service, software or customer support directly from CMW or any other member of the CMW Group of Companies or our service providers, CMW or the relevant member of the CMW Group of Companies may process credit card or other payment information and use it to facilitate billing and credit services and conduct credit checks, as applicable. Similarly, CMW or a member of the CMW Group of Companies may process payment or other financial information when you use Near Field Communications functionality.
  9. General usage data: In some cases, information like technical properties and general usage information of software and hardware utilized in conjunction with the Services including device or computer information (for example, device PIN, IMEI, IMSI, UDID, MAC address or similar identifiers, and device model) might be processed when you use such products, services or software (e.g. type of web browser, referring or exit web pages, operating system version, hardware model of your device or personal computer platform, IP address and information about Internet service or mobile data service providers).
  10. Location information: The Services or a portion thereof may provide functionality that relies upon location information associated to your device (e.g. Global Positioning System (GPS) or similar satellite triangulation information, carrier or tower ID, the BSSID (Broadcast Service Set Identifier) and MAC address (Media Access Control address) of Wi-Fi access points, and signal strength of visible Wi-Fi hotspots or wireless towers) location information associated to your device (“Location-based Services”). By using such Location-based Services, you acknowledge and agree that: (i) the CMW Group of Companies or their service providers may collect, use, disclose and/or process such location information to provide you with or facilitate the provision of information and services (e.g. mapping services, measuring traffic congestion, location-sensitive promotions or coupons); and (ii) you assume responsibility for the risks involved in using such Location-based Services, and it is your responsibility to use them appropriately and according to applicable laws. If you are also a user of BBM Channels, you acknowledge and agree that the Location-based Services involve your device's current or saved location being sampled periodically (as frequently as every fifteen minutes, including in some cases even if the Portal is not open / active on your device) and stored on your device, using GPS (where available), wireless tower, and Wi-Fi/WLAN hotspot information, and in some cases, as your device moves locations, your device’s location information will be sent to our servers so that we may associate such information to your user profile in order to customize your experience, and provide you with more relevant promotional or BBM Channels content, including localized or time-sensitive offers that utilize geo-fencing functionality based on your device's current location. If you use Third Party Offerings which provide location-based services, please review the third party’s terms and conditions and privacy policy regarding how your location and personal information will be processed, and how to opt-out of any location-based services and advertising provided by the third party. You may manage through the settings on your device either the overall settings for your device’s GPS or location functionality or individual settings for the Services.
  11. Quality assurance and customer service: If you contact us for support, or send diagnostics or other technical information to us through email or logging tools provided by us for such purposes, you agree that the CMW Group of Companies may collect technical information like device identifiers, hardware ID and model number, memory status, operating system and environment information, Wi-Fi/WLAN information, radio or wireless strength and connections, list of installed applications, application usage information, data regarding processes running and device configuration, and other information regarding the condition of your device and the software on your device that may be helpful for diagnostic purposes. Such information will be used for the purposes of troubleshooting, customer support, software updates, and improvement of our products and services in accordance with this Privacy Policy. You acknowledge and agree that your customer service telephone calls with CMW and CMW’s service providers may be recorded or monitored for quality assurance and customer service purposes such as to assist the CMW Group of Companies in addressing your inquiries, troubleshooting, training and analytics to identify trends and make improvements to the Services.
  12. Third party information: Portions of the Services may require or utilize Third Party Offerings to function. If you choose to integrate or link the Services with Third Party Offerings (for example, services that facilitate your use of the Services in association with social networking or other services offered by third parties), you authorize and consent to our use of your user account credentials and our collection, use, processing and disclosure of your personal information relating to such Third Party Offerings in order to facilitate your access to such Third Party Offerings for your personal and/or domestic purposes. Such information may include: (i) your account ID, password(s), authentication tokens, or other credentials for each such Third Party Offerings or other account(s) you integrate with the Services; (ii) your user account information (for example, account ID, display picture, display name, personal message, availability status, country, time zone, unique device identifiers, etc.); (iii) on-device contacts information; (iv) an indication of which third party applications or services you have connected to your user account; and (v) session data resulting from your use of the third party applications or services you have connected to your user account (for example, high scores you have achieved in a connected third party game or application for display in your account profile box, instant messaging data resulting from instant messaging chats you have undertaken within a connected third party application or service and which have been facilitated by the Services' instant messaging functionality, etc.). You also authorize and consent to us obtaining personal information from and disclosing personal information to the applicable third party service providers (including your Internet service or mobile data service providers) for activation, billing, provision, service, maintenance, and deactivation purposes. Any Third Party Offerings accessed or used by you are not under our control. If necessary to fulfil the CMW Group of Companies’ identified purposes, you consent that the CMW Group of Companies may collect your personal information from third parties including your Internet service or mobile data service providers and combine such information with information you have submitted or otherwise made available to the CMW Group of Companies.
  13. Storing of Messages. The contents of messages that have been delivered via the Services are not maintained or archived by us in the normal course of business. Your messages are sent via data services to servers operated by or on behalf of us, and routed to the recipient(s), if the recipient(s) are online. Once a message has been delivered, it no longer resides on our servers. If the recipient(s) are not online, the undelivered message is held in servers operated by or on behalf of us until it can be delivered for up to thirty (30) days, after which the undelivered message will be deleted from our servers. The contents of any delivered messages reside directly on the sender's and recipient's devices unless deleted by those users, or by auto-delete features of the software used by such users. Notwithstanding the above, we may retain transactional details associated with the messages and devices (for example, date and time stamp information associated with successfully delivered messages and the devices involved in the messages), as well as any other information that we are legally compelled to collect.

Some of this information would not by itself identify you to the CMW Group of Companies or be personally identifiable and is therefore considered non-personal information. If the CMW Group of Companies combines any such non-personal information with other personal information available to the CMW Group of Companies, the combined information will be treated as personal information in accordance with this Privacy Policy.


5. Use, processing and disclosure of your personal information

  1. Retention
    The CMW Group of Companies retains personal information as long as necessary for the fulfilment of the CMW Group of Companies’ identified purposes or as otherwise necessary to comply with applicable laws. When personal information is no longer necessary or relevant for such purposes, or required by applicable laws, CMW will take steps to have it deleted, destroyed, erased, aggregated or made anonymous. Consistent with good business practice, CMW continues to evolve our controls, schedules and practices for information and records retention and destruction which apply to your personal information.

  2. International operations and onward transfers
    You agree that, to be able to better serve you and facilitate the use or functioning of Services, your personal information may be collected, used, processed, transferred or stored by or on behalf of CMW in multiple jurisdictions including Canada, the United States, the European Economic Area, Singapore and any other country where the CMW Group of Companies or their service providers have offices or facilities, including countries which may be outside the region in which you are situated and may have different privacy or data protection legislation, and may therefore be subject to the laws of these countries. If you are a resident of the European Economic Area or a country which restricts data transfers outside of that jurisdiction or region without your consent, you consent to your personal information being transferred outside of the European Economic Area or your country for processing or storage by or on behalf of the CMW Group of Companies.

    Given the international nature of our business, the CMW Group of Companies may also be required to disclose or otherwise provide access to your communications data, including the contents of your communications, and other information under the laws of countries where the CMW Group of Companies, their service providers and data are located. By using the Services, you consent to the CMW Group of Companies’ compliance with applicable laws including any legal process that the CMW Group of Companies believes requires them to produce or provide access to your communications data and other information.

  3. Marketing communications
    The CMW Group of Companies may communicate with you by a variety of means, such as using the email address(es) associated to your user account or your unique device identifier (e.g. PIN). The CMW Group of Companies may communicate information, surveys, marketing materials, advertisements or customized content which has been personalized to try to make it more relevant to you as part of your relationship with the CMW Group of Companies. For example, we may do so where you have not unsubscribed from receiving such communications and it is permitted by law, where you have explicitly agreed to receive such communications, where you use free services which rely upon advertising (including targeted advertising based on profile information), or through utilizing aggregated data or data that has been made anonymous. The CMW Group of Companies may ask you from time to time if you would like to receive from the CMW Group of Companies or authorized third parties selected by the CMW Group of Companies, additional announcements, news, offers or event invitations regarding the CMW Group of Companies and the Services. You may also choose to provide the CMW Group of Companies with information in response to various promotional activities of the CMW Group of Companies. If you agree to participate in contests, surveys, giveaways, reviews, or other promotions that the CMW Group of Companies sponsors or co-sponsors, please ensure that you read the Notice that may be associated with these initiatives in order to obtain further details about how your personal information will be managed. Typically, an unsubscribe mechanism is included with every CMW marketing or commercial communication. Please visit the section below on “Managing your preferences” for more information on managing marketing or commercial communications from CMW.

  4. Service-related communications from CMW
    CMW may also send you certain service-related communications. For example, CMW may send a welcome email or message when you first register for your user account to inform you about the service and its terms, to notify you of important changes, to tell you how to manage your credentials or account, to provide service infrastructure notifications or information about upgrades or updates, safety or security information, or for surveys of current or former users. Because such service-related communications are important to your use of the Services, you may not opt-out of receiving these communications.

  5. Information sharing
    In accordance with this Privacy Policy, the CMW Group of Companies may share your personal information within the CMW Group of Companies or with their service providers. The CMW Group of Companies may also share information with our financial, insurance, legal, accounting or other advisors that provide professional services to the CMW Group of Companies. The CMW Group of Companies may also share information in a manner consistent with this Privacy Policy with third parties involved in providing the Services to you including merchants of record or payment processors or subcontractors for the purposes set out in this Privacy Policy.

    In certain situations where you purchase or use a Third Party Offering (e.g. paid content subscription service, downloaded application), CMW may share certain information with the third party for purposes of allowing us to provide you with great new third party products, services or software and your information may also be subject to the third party’s privacy policy. We encourage all our users to learn about the privacy practices of such third parties before agreeing to purchase or obtain their products, services or software.

    CMW uses contractual or other means to provide a comparable level of protection while the information is being processed by our service providers. It is CMW’s policy to enter into confidentiality obligations with any third party that obtains confidential information including personal information from CMW. For example, except where CMW is required or permitted by law to disclose personal information, our service providers to whom we provide your personal information typically agree to hold the information in confidence and only use the information for the purposes for which it was provided or to comply with applicable laws.

    In the event of the sale of all or a portion of CMW’s assets, CMW may provide your personal information to the third party purchaser. You hereby consent to the collection, use, disclosure and/or processing of your personal information by CMW for the purposes of any purchase, sale, lease, merger or amalgamation or any other acquisition, disposal or financing of CMW or a portion of CMW or of any of the business or assets of CMW.

    The CMW Group of Companies may utilize third parties (e.g. advertising networks) to target advertisements at non-personally identifiable attributes or anonymized data that is derived from profile data processed by the CMW Group of Companies, and provide such third parties with general statistics relating to the advertisements delivered. Please visit the section below on “Managing your preferences” for more information on managing marketing or commercial communications from the CMW Group of Companies.

  6. Third Party Offerings
    When you download or utilize Third Party Offerings, personal information from your device or the Services may be accessed by such third party providers. You should review the privacy policies and any agreements with such third parties to understand how your personal information will be treated by those entities, as the CMW Group of Companies is not responsible for your dealings with third parties or their applications, products, services or software. The CMW Group of Companies does not directly control how such third parties process any personal information they collect in connection with the Third Party Offerings you use.

    In some cases, you may adjust the permissions granted to Third Party Offerings. You should periodically review these permissions including default permissions, as well as the Options or Settings menu on your device, in order to learn more about its security and available controls.


6. Accuracy of your personal information

CMW takes reasonable steps to ensure that personal information is sufficiently accurate, complete and up-to-date. CMW also depends on you to update or correct your personal information whenever necessary.


7. Safeguarding your personal information

CMW continues to evolve our physical, organizational and technological measures used to protect your personal information against loss or theft, unauthorized access, alteration or disclosure appropriate to its level of sensitivity.

  1. Your obligations to safeguard your personal information
    You also have an obligation to safeguard your personal information. You can reduce risk of unauthorized access to your personal information by using common sense security practices. For example, you are responsible for utilizing appropriate security measures to control access to your device and computer system, such as creating a strong password that cannot be easily guessed by others (e.g. by including punctuation marks, numbers, capital and lowercase letters, and choosing a password of an appropriate length and which does not include your name or account name), using different passwords for different services and using up-to-date antivirus software.

    As noted above, in some cases, you may adjust the permissions granted to Third Party Offerings. You should periodically review these permissions including default permissions, as well as the Options or Settings menu on your device, in order to learn more about its security and available controls.

    If you return, sell, discard, or transfer your device to another person or entity (such as providing your device to another entity for repair, refurbishment or replacement), you should ensure that the device and any associated accessories and peripherals are removed or securely wiped of any personal information or other sensitive data they might contain (e.g. SIM cards, microSD cards). You should also disassociate your device from all email accounts and other data services so that messages and data are no longer directed to the device (e.g. push services, remote backup). Otherwise, your personal information may be available to a subsequent user of the device, and you may incur subscription and network data charges. You may learn more about how to take steps to protect yourself through the Options or Settings menu on your device, or by contacting your airtime service provider.


8. CMW’s ongoing efforts to be transparent

CMW continues to make available information to help our users better understand CMW’s processing of personal information and how to exercise choices regarding the use of your personal information through various channels including this Privacy Policy, applicable Notices and additional information that may be made available from time to time on various CMW websites.


9. You can access your personal information

Upon written request, CMW will inform you whether or not it holds personal information about you and provide you with access to your information within a reasonable timeframe and at minimal or no cost in accordance with applicable laws. If you identify an inaccuracy or incompleteness in your personal information, CMW will amend your information and notify any third parties as required by applicable laws.

In certain situations and depending on applicable laws, CMW may not be able to or be required to provide access to all of the personal information that it holds about you. For example, CMW may not provide access to information if doing so:

  • would likely reveal personal information about a third party;
  • could reasonably be expected to threaten the life or safety of another individual;
  • would reveal CMW’s confidential commercial information that could harm the competitive position of CMW; or
  • includes information that is protected by legal privilege; or
  • includes information that was collected for the purposes of an investigation of a breach of an agreement or a contravention of a law.

In order to safeguard your personal information from unauthorized access, CMW may ask that you provide sufficient information to identify yourself prior to providing access to your personal information.

Depending on the circumstances and applicable laws, CMW may refuse to process certain access requests (e.g. access requests that are unreasonably repetitive or systematic, would be extremely impractical or require disproportionate technical effort).


10. Questions or concerns? How to contact us

If you have any questions, regarding this Privacy Policy please contact CMW (and our Data Protection Officer) either by email or in writing and we will use commercially reasonable efforts to respond:

  1. by email: dpo@bbmtek.com, or
  2. write to the CMW office: CMW Data Protection Officer (attention Legal Department), 238B Thomson Road, #17-05/08, Novena Square, Singapore, 307685
  1. Managing your preferences
    Generally, you may withdraw at any time your consent for CMW to collect, use, process and/or disclose your personal information or request us to limit the processing or use of your personal data in accordance with this Privacy Policy, subject to the PDPA or other applicable laws and regulations. However, please note that such requests may affect our ability to provide the Services to you. For example, although you can use the Services for some purposes without providing us with any personal information, CMW may need to process personal information for some services, including those that require payment or involve an ongoing relationship such as registration or subscription services. As such, if you refuse to provide CMW with the information it requires or later contact us in writing at one of the addresses above to withdraw your consent to use and disclose this information, CMW may no longer be able to provide you with your requested Services. In such event, we shall be entitled to treat such withdrawal as your termination of any agreement which you may have with us, without prejudice to any rights and remedies which we may have in law.

    Marketing or commercial communications: You may unsubscribe from receiving marketing or commercial communications about the Services by:

    1. clicking the unsubscribe link at the end of any marketing or commercial communication from CMW;
    2. by writing to CMW Data Protection Officer (attention Legal Department), 238B Thomson Road, #17-05/08, Novena Square, Singapore, 307685 and advising what particular types of marketing or commercial communications you no longer wish to receive.

    Cookies: As noted above, you may also opt-out of CMW’s use of Cookies through one of the following methods:

    1. Change your browser settings to refuse Cookies or to indicate when a Cookie is being sent.
    2. Remove or block browser Cookies using the settings in your browser, but that may impact your ability to use certain Services as they may not work well or at all with Cookies disabled.
  2. Changes to this Privacy Policy
    CMW will occasionally update this Privacy Policy so that it remains relevant and current with changing technologies, applicable laws, our evolving business practices and the needs of our users. CMW encourages you to periodically review this Privacy Policy to stay informed of how CMW manages your personal information. If any changes are made to this Privacy Policy, CMW will revise the “Last Updated” date that is indicated on the Privacy Policy.

    If material changes are made that impact you, we will notify users by placing a prominent notice at www.bbm.com/legal. Depending on the circumstances, we may also decide to send users a notice electronically. If you continue to use the Services after notice of the change has been given, you will be deemed to have accepted and agreed to such changes. If you do not agree to any of the changes to this Privacy Policy, you must stop accessing and/or using the Services.