1. CMW’s accountability
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:
to understand and meet your needs and preferences, and to provide you with the Services and/or Third Party Offerings, e.g.:
- for purposes related to the billing, activation, provision, maintenance, support, trouble shooting, resolving of disputes, deactivation, replacement, upgrade or update of the Services;
- to better understand, analyze and predict your preferences and interests, and combine such information with other information to customize your experience;
- to ensure the Services are technically functioning as intended and to help identify and troubleshoot issues;
- to facilitate your access and use of Services and/or Third Party Offerings;
- to send invitations-to-subscribe, messages and posts within the Services on behalf of Channel administrators;
- to combine such information with information obtained from other sources (including Third Party Offerings) in connection with the provision of the Services;
- to fulfill or enforce Notices applicable to the Services;
- to manage or respond to your inquiries;
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:
- upgrades or updates, or notices of upgrades or updates, of the Services or third party content or related products, services and software;
- notices of promotions, contests, offers and upcoming events;
- personalized information, surveys, marketing materials, advertisement or customized content;
- 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;
to manage and develop our business and operations, e.g.:
- 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;
- to allow for business continuity and disaster recovery operations;
- 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;
- for statistical purposes;
to meet legal and regulatory requirements and to respond to emergency situations, e.g.:
- to respond to court orders, warrants or other lawful requests or legal processes;
- to provide emergency assistance in situations that may threaten the life or physical safety of you or others; or
- 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
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.
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):
- in the case of an emergency that threatens the life, health or safety of an individual;
- when necessary for a purpose that is clearly in your interest, if consent cannot be obtained in a timely way;
- when necessary for any investigation;
- when disclosure is necessary to obtain legal services;
- to recover a debt;
- when necessary for proceedings including a subpoena, warrant or other court order, lawful request or legal process; or
- as may be otherwise required or permitted by law.
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.
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:
- 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.
- 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.
- 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.
- 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.
- 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.
- 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.
- 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).
- 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.
- 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.
5. Use, processing and disclosure of your personal information
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.
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.
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.
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.
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.
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
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
- by email: firstname.lastname@example.org, or
- write to the CMW office: CMW Data Protection Officer (attention Legal Department), 238B Thomson Road, #17-05/08, Novena Square, Singapore, 307685
Managing your preferences
Marketing or commercial communications: You may unsubscribe from receiving marketing or commercial communications about the Services by:
- clicking the unsubscribe link at the end of any marketing or commercial communication from CMW;
- 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.
- 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.