Privacy Policy
Only available if you are located in the US, EU and Singapore.
Thank you for using our products and services! We respect your concerns about privacy and appreciate your trust and confidence in us.
Please note that this privacy policy (“Privacy Policy”) only applies to ABetterChoice platform located at https://abetterchoice.ai/ (“Service”). If you use any other products or services, please refer to the privacy policy for that particular product or service.
If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, our contact information can be found here.
For the purpose of data protection laws, the data controller of your personal information in relation to the Service is Proxima Beta Pte. Limited.
SUMMARY
Here is a summary of the information contained in this Privacy Policy. You can find more detail by clicking ‘More Information’.
| What information do we need to be able to provide the Service? | · If you register an account to use the Service then we will need some information from you to set this up. This may include your username, email address, password. If you submit a customer support query, we may also need some information from you to address your concerns. | More Information. |
| How will we use your information? | · We use your information to set up your account, enable you to use the Service and to comply with our legal obligations and enforce our legal rights. | More Information. |
| Who do we share your information with? | · We work with our affiliates and/or use third parties to help us deliver the best possible experience. · All third party service providers providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose except where strictly necessary for the Service (i.e., to fulfil the purpose(s) described above) · In some cases we may be required by a court or be under a legal obligation (such as a valid search warrant or subpoena) to disclose certain information. | More Information. |
| Where do we process your information? | · We may transfer data outside of the location in which you are based for the purposes described in this Privacy Policy. · We have servers for the Service in Singapore. Your information can be accessed from outside of where you live by our support, engineering and other teams around the world including Singapore and the People’s Republic of China. · For EEA users, transfers between our affiliates and to third parties use applicable safeguards, such as incorporating standard contractual clauses or taking into account adequacy assessments. | More Information. |
| How long do we keep your information? | · Unless otherwise required or permissible by applicable laws, we retain your information for the period during which you maintain an account for the Service, or for so long as the information is needed to fulfil the purpose for which it was collected (as further described in this Privacy Policy). We then delete or anonymise such data, in accordance with applicable laws. | More Information. |
| How can I exercise my rights over my information? | · Certain jurisdictions offer users specific rights with respect to their information, so you may have a right to access or receive a copy of your data, or to delete your data or restrict or object to our processing of your data. | More Information. |
| How will we notify you of changes? | · Changes to this Privacy Policy will be posted here. We will also notify you of changes in accordance with relevant legal requirements. | More Information. |
Welcome to A Better Choice Website!
This Privacy Policy explains the when, how and why when it comes to the processing of your personal information with A Better Choice’s website (the “Service”), and sets out your choices and rights in relation to that information. Please read it carefully – it will allow you to understand how we collect and use your information, and how you can control it.
Please note that this Privacy Policy only applies to the Service. If you use any other products or services please refer to the privacy policy for that particular product or service.
If you do not agree to the processing of your personal information in the way this Privacy Policy describes, please do not provide your information when requested and stop using the Service. By using the Service you are acknowledging how we process your personal information as described in this Privacy Policy.
For the purpose of data protection laws, the data controller of your personal information in relation to the Service is Proxima Beta Pte. Limited (“we”, “us”, “our”).
If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, our contact information can be found here. You can also reach out to our data protection officer at dpo_abetterchoice@proximabeta.com. We have representatives for data protection purposes listed here.
1. Cookies
We use cookies and other similar technologies (“Cookies”) to enhance your experience using the Service. Cookies are small files which, when placed on your device, enable us to provide certain features and functionalities. For more information about our Cookies policy, click here.
2. Children
Children must not use the Service for any purpose.
By children, we mean users under the age of 18 years old; or in the case of a region where the minimum age for processing personal information differs, such different age. We will not knowingly allow children to register for our Service and/or provide any personal identification information. If you are child, please do not sign up to use our Service or provide any information about yourself through the Service.
3. How We Process Your Personal Information
This section provides more detail on the types of personal information we collect from you, and why.
It also identifies the legal basis under which we process your data pursuant to applicable data protection laws.
| Personal Information | Use | Legal Basis (where applicable) |
|---|---|---|
| Account registration information: username, email address, password | We use this information to: · create your Service account in accordance with your request and facilitate your login; · allow for password resets; · provide you with user support; · enforce our terms, conditions and policies | Necessary to perform our contract with you to provide the Service. |
| Log data: User browser activity and its log information | We use this information to display your browsing activity when using the Platform to you. | Necessary to perform our contract with you to provide the Service |
| User’s preferred language(only stored via cookies) | We use this information to provide the appropriate version of the Service to you. | Necessary to perform our contract with you to provide the Service. |
| Support enquiry data: data provided by you when you submit a support enquiry via Slack community | We use this information to provide customer support services. | Necessary to perform our contract with you to provide the Service. |
4. How We Store and Share Your Personal Information
We may transfer data outside of the location in which you are based for the purposes described in this Privacy Policy.
We have servers for the Service in Singapore. Your information can be accessed from outside of where you live by our support, engineering and other teams around the world including Singapore and the People’s Republic of China.
For EEA users, transfers between our affiliates and to third parties use applicable safeguards, such as incorporating standard contractual clauses or taking into account adequacy assessments.
Only where necessary will we share your personal information with third parties. Situations where this occur may include:
Third parties that provide services in support of the Service, including providers of services that process information identified in this policy for the purpose of providing the Service. All third party service providers providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose except where strictly necessary for the Service (i.e., for the purpose(s) described above).
Regulators, judicial authorities and law enforcement agencies. There are circumstances in which we may be legally required to disclose information about you, such as to comply with legal obligations or processes. In complying with the terms of valid legal processes, such as a subpoena, or search warrant, unfortunately we may not be able to seek your consent to or notify you in advance of such disclosure.
Third parties to ensure safety, security, or compliance with laws. We may disclose your information to:
1.enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;
2.detect, prevent or otherwise address security, fraud or technical issues;
3.protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law (such as exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction).
- A third party that acquires all or substantially all of us or our business. We may also disclose your information to third parties if we either: (a) sell, transfer, merge, consolidate or re-organise any part(s) of our business, or merge with, acquire or form a joint venture with, any other business, in which case we may disclose your data to any prospective buyer, new owner, or other third party involved in such change to our business; or (b) sell or transfer any of our assets, in which case the information we hold about you may be sold as part of those assets and may be transferred to any prospective buyer, new owner, or other third party involved in such sale or transfer.
5. The Security of Your Personal Information
We have information security and access policies that limit access to our systems and technology, and we protect data through the use of technological protection measures such as encryption.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will implement and maintain reasonable measures to protect your personal information, we cannot guarantee the security of the information transmitted through the Service or otherwise via the Internet; any transmission is at your own risk.
6. Data Retention
We do not keep your data for longer than is necessary to fulfil the relevant purpose described above unless we are required or permitted to do so under law.If we retain your information beyond the retention periods set out below, for example to comply with applicable laws, we will store it separately from other types of personal information.
For further details on how long we keep your data, please refer to the time periods set out below.
| Personal Information | Retention Policy |
|---|---|
| Account registration information Log data User’s preferred language Support enquiry data | Stored for the lifetime of your use of the Service (i.e. until account deletion in accordance with your request) and then deleted within 30 days. |
7. Your Rights
Some jurisdictions’ laws grant specific rights to users of the Service.** Please refer to the Supplemental Jurisdiction-Specific Terms, or the applicable laws in your jurisdiction, for an overview of specific rights that apply to persons subject to data protection laws in the listed jurisdictions and how these can be exercised.
You may have certain rights in relation to the personal information we hold about you. Some of these only apply in certain circumstances (as set out in more detail below). You can exercise some of these rights directly by accessing and updating the information in your account. If you believe we hold any other personal information about you, please contact us.
Access
You may have the right to access personal information we hold about you, how we use it, and who we share it with. You can access the personal information you have made available as part of your account by logging into your account.
Portability
You may have the right to receive a copy of certain personal information we process about you. For example, in certain jurisdictions this can comprise personal information we process on the basis of your consent (e.g., survey information) or pursuant to our contract with you (e.g., account name), as described above in the section “How We Use Your Personal Information”. We will provide further information to you about transferring this data if you make such a request.
Correction
You may have the right to correct personal information we hold that is inaccurate. You can access the personal information we hold about you by logging into your Service account.
Erasure
You may be able to delete your account, or remove certain personal information, by logging into your Service account. We may need to retain personal information if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or freedom of expression) but we will let you know if that is the case. Where you have requested that we erase personal information that has been made available publicly on the Service and there are grounds for erasure, we will use reasonable steps to try to tell others that are displaying the personal information or providing links to the personal information to erase it too.
Restriction of Processing to Storage Only
You may have a right to require that we stop processing the personal information we hold about you (other than for storage purposes in certain circumstances). Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or for another’s protection). Where we agree to stop processing the personal information, we will take steps to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.
Objection
You may have the right to object to our processing of your personal information. If you wish to do so, please contact us at dpo_abetterchoice@proximabeta.com or using the contact details set out below, and we will consider your request.
Consent Withdrawal
To the extent provided by applicable laws and regulations, you may withdraw consent you previously provided to us for certain processing activities by contacting us at dpo_abetterchoice@proximabeta.com.Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent we may not be able to deliver the expected service.Please note that the right to withdraw consent is only available if the legal basis for processing information is consent.
Announcements
We may from time to time send you announcements when we consider it necessary to do so (for example, when we temporarily suspend access to the Service for maintenance, or security, privacy or administrative-related communications). These are essential system and service-related announcements and you are not able to opt-out of these notifications, which are not promotional in nature.
8. Contact
You can reach us using our online form for submitting data privacy related requests and questions here. For any questions not covered by the form, please email us at .
We will endeavour to deal with your request as soon as possible. This is without prejudice to any right you may have to launch a claim with a data protection authority in the region in which you live or work where you think we have infringed data protection laws.
9. Changes
If we make any changes to this Privacy Policy we will post the updated Privacy Policy here and notify you in accordance with relevant legal requirements.
10. Language
Except as otherwise prescribed by law, in the event of any discrepancy or inconsistency between the English version and local language version of this Privacy Policy, the English version shall prevail.
Our Representatives in Certain Jurisdictions
| Jurisdiction | Representative | Address | Contact details |
|---|---|---|---|
| EU | Proxima Beta Europe B.V. | Buitenveldertselaan 1-5, 1082 VA, Amsterdam, the Netherlands | dpo_abetterchoice@proximabeta.com |
SUPPLEMENTAL TERMS – JURISDICTION-SPECIFIC
Some jurisdictions’ laws contain additional terms for users of the Service, which are set out in this section. If you are a user located in one of the jurisdictions below, the terms set out below under the name of your jurisdiction apply to you in addition to the terms set out in our Privacy Policy above.
United States
For purposes of this section, “personal information” and “sensitive personal information” have the meanings given in the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) (“CCPA”), and respectively include the terms “personal data” and “sensitive data” as defined in the Colorado Privacy Act (“CPA”), the Connecticut Act Concerning Personal Data Privacy and Online Monitoring (“CTDPA”), the Utah Consumer Privacy Act (“UCPA”) and the Virginia Consumer Data Protection Act (“VCDPA”), (collectively, “US State Laws”). The terms do not include information excluded from the scope of US State Laws.
Collection and Disclosure of Personal Information
Over the past 12 months, we have collected and disclosed the following categories of personal information from or about you or your device:
Identifiers, such as your name, email address and username.This information is collected directly from you.
Internet or other electronic network activity information, such as your information regarding your use of the Service, including user browser activity and log information as described in the main Privacy Policy. This information is collected directly from you and your device.
We collect and disclose your personal information for the following purposes:
To provide you with the Service, maintain your account
To provide customer service
For additional information about what each type of personal information is used for, see Section 3 (How We Process Your Personal Information).
We disclose each of the categories of personal information that we collect as described in Section 4 (How We Store and Share Your Personal Information).
In the past 12 months, we have not sold Personal Information of California residents within the meaning of “sold” and “share” in the CCPA. And we have no knowledge of any sale or sharing of personal information of users under 16 years of age.
In addition, we do not use or disclose sensitive personal information for purposes other than to perform the services reasonably expected by an average consumer who requests those services or as otherwise permitted by US State Laws.
Retention of Your Personal Information
The retention period varies among the different categories of data collected. For detailed information about the retention period for any specific category of data, see this chart in the main portion of the Privacy Policy.
Rights under US State Laws:
Depending on where you live, you may have some or all of the rights listed below in relation to information that we have collected about you. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law.
- Right to Access/Know. Request we confirm whether we process information about you and give you access to that information. You may also request to receive that information in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the information to another business without impediment. If you are a California resident, you may request the following information about our collection, use and disclosure of your information:
the categories of personal information about you that we collected;
the categories of sources from which the personal information was collected;
the business or commercial purposes for collecting personal information about you;
the categories of third parties to whom we disclosed personal information about you and the categories of personal information that was disclosed (if applicable) and the purpose for disclosing the personal information about you;
the specific pieces of personal information we collected about you;
Request to Delete. Request we delete personal information we collected about you;
Request to Correct. Request we correct inaccurate personal information that we maintain about you;
Right to Opt out of Targeted Advertising or Profiling. Request to opt-out of the processing of your information for the purposes of targeted advertising or the profiling of your information in furtherance of decisions that produce legal or similarly significant effects;
Right to Non-Discrimination. Be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or denying goods or services to you when you exercise your rights under the US State Laws.
How to Exercise Your Rights
First, you may wish to log into your account and manage your data from there. If you are a California resident to whom the CCPA applies, you may also exercise your rights, if any, regarding other data by contacting us as specified in Section 8 (Contact). We may take steps to verify your identity before complying with your request to protect your privacy and security, and may decline your request if we are unable to verify your identity. To verify your identity, we may need the following information from you: your first name, last name, address, phone number, date of birth and email address.
Depending on where you live, you may exercise these rights yourself or you may also designate an authorized agent to make these requests on your behalf. In order for us to process the request, you must provide the authorized agent with signed written permission. We reserve the request to require the agent to verify their own identity and to confirm directly with you that you have provided the authorized agent permission to submit the request.
Singapore
By clicking “accept”, you consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, the locations specified in Section 4 (How We Store and Share Your Personal Information).
You have the right to access your personal information, how we use it, and who we share it with. You have the right to correct any of your personal information that is inaccurate.
Our designated data protection officer for the purposes of compliance with the Personal Data Protection Act 2012 can be contacted as set out in Section 8 (Contact)