1. What are we collecting and why?

1. 1.1 User consent
   

   We collect some data to enhance your experience on our website or for any further marketing purposes.
   • We collect cookies to enhance user experience and improve our website performance, but this collection is restricted to only strictly necessary cookies listed below:
     
     • analytics cookies to recognise the user’s browser/device so that the patterns of returning website visitors can be collected and analysed,
     • performance cookies to enhance performances of user’s browsers and sessions,
     • functional cookies to remember user choices, browsing and personalise the content.
   • Social sharing through end user’s Facebook, LinkedIn, Twitter, Youtube, Wechat, Instagram. These widgets/links may be placed on the website. Please refer to clause 3.2 of our Terms of Use.
   • When you access why-innovation.com website, your Internet address is collected if you provide consent and is also stored in our Internet access logs (i.e. log files on server). We also record the URLs of the websites and pages you visit, the times and dates of such visit, information about the computer hardware and software you use. Internet access logs may include Internet protocol (IP) addresses, browser type and version, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data, number of visits, websites from which you accessed our site (Referrer), and websites that are accessed by your system via our site.

2. 1.2 User Registration & accuracy of data
   

   The accuracy and completeness of user profile information lies with the end user and why innovation! will not be held responsible for incorrect/incomplete user data provided or if the user enters personal data of another person. The company holds the right to deny registration or even terminate any user already registered if any malicious or fraudulent intentions are suspected or evidenced that can damage the company’s brand and reputation.

3. 1.3 Personal Identifier (PII) / Sensitive information
   

   Personal data we collect:
   • End user personal information (Name & Surname, Phone number, Email address, Country, Company name, Role In the company, Areas of Interest) are collected when you register to why innovation! website, and also during events, meetups, conferences, surveys, trainings, newsletters, whitepapers and job position applications.
   • Photos and videos taken at our office premises during events/trainings/ workshops may be used for social sharing/company posts/websites. Remark: approval will be obtained from the concerned authorities for those obtained at client locations or other permissible event locations.
     Any of the above user data is agreed by you to be shared with other why innovation! office locations if the need arises (sharing via official email).
     Remark: we do not collect any “sensitive data” such as ethnicity, political /religious opinions, sexual life or orientation, physical or mental health or criminal convictions, unless situation/guidelines by a Governing body warrants the same.

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2. Details on Personal Data Protection

1. 2.1 User data security

   • why innovation! put security measures in place to preserve user’s personal data: why-innovation.com website utilises only secure https protocol and there is no transmission of user information over the Internet to any third-party.
   • Cross border data transfers are handled securely through our established branded platform. The access to personal data is also secured with only authenticated personnel having privileged rights to read/view/edit based on the organisational roles and responsibilities.
   • If any payment services for training or consulting are incorporated in the website, then the third-party payment gateway/vendor involved will be fully compliant to PCI-DSS (Payment Card Industry Data Security Standard) security in order to handle financial transactions.
   • User's personal data will be solely used for the purpose intended unless there is a special request for any dispute resolution or for legality purposes.
     

2. 2.2 User rights to view/update/delete personal data

   • As the owner of your personal data, you are entitled to request access to view or receive a copy of the personal data collected. You can also request rectification to correct/complete the data already provided, request for deletion or for any special restriction of your personal data.
   • You can also withdraw your consent or seek clarifications (if any) related to your personal data by contacting us (contact@why-innovation.com).
   • Our Data Protection officer (DPO) will handle any personal data related queries /requests from the individuals or organisations (DPO contact: itadmin@why-innovation.com).
     

3. 2.3 Specific regulations/laws/guidelines linked to user’s location

   1. 2.3.1 Singapore

1. 1. • NRIC number
        NRIC number is treated as sensitive data and therefore collected in person during the trainings from participants (where CITREP funding claims are relevant). NRIC numbers are categorised as highly sensitive personal information in the inventory and stored in physical files placed in locked file cabinets. The keys to these cabinets are held by authorised personnel only. This collection is required by CITREP guidelines and why innovation! does not have the right to alter this guideline.
        

   2. 2.3.2 Hong Kong

      • Cross border data transfers
        According to Hong Kong Personal Data (Privacy) Ordinance (the "PDPO"), why innovation! will proceed to cross border data transfers only via e-mails and by authorised office staff. All user data storage from the website is done as per the cloud provider’s data privacy policy.
        

   3. 2.3.3 China

      • Geographical location
        Geographical location is treated as Sensitive data and Data security incidents will go through required due diligence. Currently, why innovation! does not process (nor expects to process) personal data of more than 500,000 people in 12 months. If it becomes the case in the future, why innovation! will set up a specific department and dedicate specialised staff for the security of personal data that would include conducting regular personal data security risk assessments, adopting necessary security measures for personal data and sensitive data based on the risk assessment report, conducting data security audits on data security strategies, procedures and security measures.
        The site does not target or involve collection of personal data of children under 14 years of age.
        Reminder: by agreeing our “Privacy Policy and Terms of use”, you acknowledge to be above the age of majority in your country.
      • Data security incident
        On the event of Data security incident, it will be recorded and assessed by why innovation! team, and appropriate remedial measures will be taken for data subjects including notifying them in a timely manner and disclosing the public relevant information concerning the incident will be executed.
        

   4. 2.3.4 Rest of the world:
      

      why innovation! complies with the EU General Data Protection Regulations (GDPR) in line with the chosen Cloud platform including notification of Data breaches, which will be notified to registered users within 72 hours of incident occurrence.
      

2. 2.4 Personal Data storage, backup and retention

   • Personal data will be stored as long as necessary and will be accessible only by authorised personnel of why innovation!
   • Cross border data transfer of user data collected via the website will be handled by the chosen Cloud provider and why innovation! will not be responsible for any breach occurring at the Cloud provider’s end.
   • Retention of user data collected via the website depends on the active status of the user account or on specific legal requirements. Backup and retention strategies are in line with the chosen Cloud provider used.

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3. Terms of Use

1. 3.1 Intellectual property rights
   

   • why-innovation.com website and all contents including but not limited to texts, images, downloadable files/whitepapers, photos, videos, business/delivery processes and interactive features on this website are duly owned by why innovation! Group Pte. Ltd.
   • All trademarks, copyrights services/contents, company logos and trade names related to why innovation! that may appear on why innovation! website are solely owned by why innovation! Group Pte. Ltd.

2. 3.2 Website Contents /3rd party links

   • why-innovation! is not responsible for contents or data privacy in links to Facebook, LinkedIn, Twitter.
   • why-innovation.com website may contain links to third-party websites: why-innovation! can cannot be considered as liable for opinions and judgements communicated by these third-party websites.
   • why innovation! do not endorse, warrant third-party websites contents and are not responsible/liable for undertaking the terms of use and privacy policies mentioned in those third-party sites.
   • why-innovation! website contents are results of several years of past rich experience in consulting and training. The responsibility to evaluate the accuracy, completeness, relevance, or usefulness of this website contents lies with the end user. Under no circumstances will why innovation! be liable for any loss or damage caused by your reliance on any content provided by why-innovation.com website.

3. 3.3 Access and use of website

   • Do not tamper/reuse our site contents after downloading!
   • You shall not use, alter/reproduce, distribute, create derivative works, publicly display, publicly perform, publish, transmit, or otherwise exploit any why-innovation.com website content for any purpose whatsoever without prior explicit written consent from why innovation!

4. 3.4 Disclaimer related to trainings provided by why innovation!
   

   In case the minimum number of registered trainees is not reached, then why! reserves the right to postpone the session.
   

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4. Policy revision

• Change management
  Privacy policy and Terms of Use may be updated to reflect any changes in latest applicable laws/regulations or internal data management processes changes. why innovation! reserves the right to change these policies at any given time.