We, ECRUU COMMODITIES MEDIA MONITORING PTE. LTD. (“our Company”) thank you for visiting our website www.ecruu.com (“Website”) and/or downloading our associated mobile application (“App”) (Website and App being collectively referred to hereinafter as “our Site”). Your terms of use of our Site shall be governed by the terms and conditions as set out herein (“our Terms of Use”) and our Privacy Policy. Accordingly, your use of our Site constitutes your full agreement to our Terms of Use and our Privacy Policy, which shall form a legally binding and enforceable contract between you and our Company (“Agreement”). If you do not accept any provision in our Terms of Use or our Privacy Policy, please immediately cease all usage of our Site, and notify us to discontinue any Updates which you have signed up for, failing which you shall be deemed to be bound by all the provisions contained in our Privacy Policy and our Terms of Use as follows:-

1. Updates to our Terms of Use

1.1 You agree that it is your responsibility to regularly check our Terms of Use avail-able at Our Policy Page to keep yourself updated of any changes or modifica-tions.

1.2 You agree that our Terms of Use may be amended, modified, varied or revised from time to time without any prior notice to you, and your continued use of our Site following any such changes constitutes your agreement to be bound by our amended Terms of Use which is accessible at all times, and should be reviewed by you regularly, at Our Policy Page

2. Our Site Content

2.1 No information on our Site, our summaries or extracts or updates of news (“News”), or our newsletters, marketing materials, promotional updates, App messages, or other email updates (collectively including News, shall be referred to hereinafter as our “Updates”) which you may have viewed, subscribed to or downloaded via our Site, constitutes financial advice, legal advice or any other form of advice for which a license to provide such advice may be required under applicable law.

2.2 The content on our Site and Updates are meant to provide information regarding our Company, our products, our services, commodities trading, news that may have an impact on commodities trading and prices, and other associated matters, which includes News on topics which you have indicated your interest in to the Company whether via the Site or other channels. The aforesaid information constitutes general knowledge only not meant for specific reliance for any par-ticular or out-of-the-ordinary purpose by any entity or individual, and therefore in the event that you wish to obtain more information on any of our News, specific product or service, please email us at info@ecruu.com. Neither our Site, nor our Updates, is intended to be a substitute for any financial advice, legal advice, nor any representations by any law firms, trading houses, commodities brokerages, financial institutions, or any licensed financial planners. Should you should require advice on a specific matter, please approach an appropriately qualified entity licensed to practise in the industry in which you require advice, before relying on information, News, or subscribing to or purchasing from our Site.

2.3 For the avoidance of doubt, our Company is a publisher of summarized news de-rived from the news reported by new agencies. Our Company is not a registered commodities trading or investment advisor, and nothing in our Updates or Site is intended, and it should not be construed as, any trading or investment advice. Any written material found on our Site, our App and our Updates, is for in-formational use only, and any mention of a particular commodity, security, index, derivative, or other instrument is neither a recommendation by our Company to buy, sell, or hold that commodity, security, index, derivative, or other instrument, nor does it constitute an opinion of our Company (or of any of its employees, agents or representatives) as to the suitability of that commodity, security, index, derivative or other instrument for any particular purpose. Our Company is not in the business of giving trading or investment advice or advice regarding the per-formance or suitability for any purpose of any commodity, security, index, deriva-tive, other instrument or trading strategy, and nothing in our Updates or the con-tent on our Site should be so used or relied upon.

2.4 Our Site and Updates may contain information on third party products and ser-vices such as the news reports from news agencies upon which our Updates were derived. However, this does not imply any association with or endorsement by such news agencies or any other third parties. The content of such third party services and products as stated on our Site and in our Updates are based on in-formation made publicly available by such third parties, and we therefore make no representations or warranties on the accuracy or updatedness of such third-party service/product related information. You are encouraged to conduct your own checks on any such third party products or services that you see on our Site and/or our Updates prior to subscribing to, registering an account for, or purchas-ing any such third party products, whether from third party sites or via our Site.

2.5 Any general knowledge, trading information, commodities prices, stock market movements, opinions, articles, FAQs, questions and answers, expressed on our Site, and our Updates are derived from publicly available third party sources, and constitutes the sole discretionary opinion of our Company, and where applicable, third party writers, reviewers, individual contributors from the public, and consult-ants whose names shall be published along with such tips and/or opinions only, and does not represent the opinion of any regulatory bodies or regulated institu-tions (unless otherwise stated).

2.6 Any monetary figures cited in our Updates and on our Site may have been con-verted from local currency to United States Dollars, or from one currency to an-other, using internet currency conversion sites, and such values are therefore subject to change.

2.7 Where the published news from which our News are derived were originally in non-English languages, translations into English as reflected in our News are done using language conversion tools. As such, our Company assumes no legal liability for any inaccuracies or misunderstandings due to translations.

2.8 Free weblinks to the original news articles are provided when possible, and all news articles can be translated to other languages using resources readily avail-able on the internet. Although effort is made to ensure the aforesaid news links are active when the News is made available to you via Updates or on our Site, however, such links may expire or subsequently require payment for access. Our Company therefore hereby disclaims any responsibility to provide News or any news summaries for which the link to the source of the news has expired or requires paid access.

2.9 Reviews of our products, services, our Site, our Updates and other matters relat-ed to our Company posted by individuals or third party companies on our Site and our Updates are the personal views of such individuals or third party companies, and does not represent the view of the Company, nor any implied endorsement or recommendation by the Company. Such reviews are also not to be deemed as any warranty, express or implied, of the effectiveness or results of the reviewed products, services or other subject-matter.

2.10 We may make available limited trial services via our Site and/or our Updates. You agree that when you contact us for any such free trial services, it is not guaranteed that such free trial services or certain features thereto will definitely be made available to you, or the trial period may be different from what may have been published on our Site, our Updates or on other third party channels.

2.11 Promotions and discounts as featured on our Site and/or our Updates are for lim-ited time-periods only and subject to specific terms and conditions indicated as may be applicable in order to enjoy such promotions and/or discounts. Once a promotional period expires, you are no longer eligible to participate in such pro-motions and our Company is not howsoever obligated to provide any such previ-ously offered privileges or discounts to you even if you have contacted our Com-pany with queries during the promotional period.

3. Intellectual Property

3.1 All content, including any write-ups, summaries, extracts, derivations, articles, translations, quotations, diagrams, graphs, charts, layout, photographs and draw-ings, as displayed on our Site, and in our Updates, are protected by copyright, design rights, trade mark rights and/or other intellectual property rights (whether owned by our Company or licensed to our Company, or permitted under the law for use by our Company), and whether registered or otherwise. You agree there-fore that without our Company’s prior written consent, you are not permitted to reproduce, copy, download, extract, store, distribute, lease, time-share, publish, sell, translate, modify or create derivative works from, any part of the content found on our Site, or in our Updates. We reserve our rights to take legal action against you for any such unauthorised use of our content.

3.2 All company names (including our Company’s name and the company names of the any third parties featured on our Site), logos, trade marks, service marks, brands, whether registered or otherwise (collectively the “Branding”) represented on our Site, and in our Updates belong to our Company or to third parties who have agreed (or our Company is so permitted under applicable law) to display their Branding on our Site, and in our Updates. You are therefore not permitted to copy, replicate, modify, extract, download or howsoever use any such Branding for any purpose whatsoever without the prior written consent of our Company.

3.3 Certain third party Branding may be featured on our Sites and/or in our Updates to show that such third party products or services are available, and/or that our services/products can be used in conjunction with such third party ser-vices/products. However, this does not imply that our Company is a licensed of-ficial agent, distributor, or re-seller of the aforesaid third party services/products, as certain of such third party services/products may be authentic parallel imports or simply resold by our Company after purchasing from legitimate sources.

4. Third Party Sites and Browsing Experience

4.1 Please note that we do not control any links, services, content, products or re-sources provided by other third parties referenced or linked to our Site, or in our Updates, even if such third party’s website may be co-branded with ours by bear-ing our Company logo or name. We seek your further understanding that we are unable to control or influence any third parties’ actions even if their websites are hyperlinked on our Site, or in our Updates. Accordingly, should you decide to use or access such third parties’ websites, all use and access are at your sole risk and subject to the terms and conditions of use of such third parties’ websites. If you have any query on the terms and conditions of use of such third parties’ websites or their services or products, please contact the third parties directly.

4.2 You agree that our Company may employ cookies, action tags, dynamic device identifiers, or other legal technological means to record your anonymised access-ing of our Site for the purpose of providing better services and enhancing your browsing experience.

5. Minors

5.1 Our products and services are targeted for adults and business entities. Our Site, and our Updates are therefore not meant for persons who may be defined as minors under applicable law. However, it is not possible for our Company to determine whether any user of our Site is a minor. If you are a minor, please discontinue the use of our Site immediately. It is the responsibility of parents and legal guardians to monitor whether a minor is using our Site.

6. Feedback

6.1 In the event that you provide us with any feedback and comments, whether via email to our Company or any postings, we thank you for taking the time to write to us, and your feedback and comments are appreciated. Any such feedback, postings, and comments from you (“Feedback”) shall become and remain the property of our Company. Our Company shall be entitled in its sole discretion to howsoever use, publish or disseminate such Feedback, with or without attribution to you as the Feedback’s author, and without having to notify you or seek your consent in advance. Accordingly, you agree that you assign all ownership (in-cluding but not limited to copyright) in the Feedback to our Company once you submit your Feedback to our Company, and you further agree to waive all moral rights over your Feedback once submitted to the Company.

6.2 Kindly note that you are responsible for your Feedback, and you should ensure that such Feedback does not contain any libelous, scandalous, defamatory, of-fensive, seditious, misleading, misrepresentative, abusive or infringing contents, particularly if such Feedback will be published to the public whether via our Site, or our Updates, or other means (even if you were not aware that your Feedback would be published). You agree to fully hold harmless and indemnify our Com-pany for all losses and costs suffered or incurred by our Company due to your Feedback, including but not limited to third party claims, legal fees on a solicitor-client basis, settlement amounts, fines, penalties, and law enforcement actions.

7. Disclaimers and Limitation of Liability

7.1 While we have exercised due care in the preparation of all content displayed on our Site, and in our Updates, such content, information and materials are provided “AS IS”, “WITH ALL FAULTS” and “AS AVAILABLE”.




7.5 Our Company further disclaims any and all liability for any losses or damages that you may incur as a direct result of using or accessing our Site, or our Updates, including but not limited to any virus, trojan horse or worm attacks on your tablet, smart phone, or computer.

7.6 In the event that our Company’s liability to you in relation to our Site, Updates, products and/or services featured on our Site and/or Updates, cannot be fully disclaimed, you agree that our Company’s total liability to you shall not exceed S$50, which you agree is a reasonable compensation amount taking into consideration the limited nature of our Company’s services. Accordingly, you agree that upon receipt of S$50 from the Company, you will waive all rights against the Company and will make no further claims whatsoever against the Company.

8. Indemnification

8.1 You agree to indemnify and hold our Company and its shareholders, directors, officers, employees, representatives, agents, subcontractors, and licensors harmless from and against any and all claims (including third party claims for intellectual property infringement due to your breach of Section 3 herein), damages, costs and expenses, including but not limited legal fees and settlement payments on a full indemnity (solicitor-client) basis arising from or related to your breach of any of the provisions herein this Terms of Use, your use of our Site, the terms and conditions of our end-user licence agreement, our Privacy Policy, and/or our Updates.

9. Governing Law and Jurisdiction

9.1 Our Terms of Use and accordingly your agreement thereto shall be governed by and construed in accordance with the laws of the Republic of Singapore, without reference to any conflict-of-law principles.

9.2 In the event of any disputes arising from this Terms of Use, your agreement thereto, and/or your use of our Site, you must first contact our Company’s officer at info@ecruu.com regarding your dispute, and use your best endeavours to am-icably settle any dispute in good faith. We on our part will also use our best en-deavours to amicably settle your concerns in good faith. However, if no amicable resolution is reached within 30 days, both parties agree to submit to the exclusive jurisdiction of the Courts of Singapore.

10. Miscellaneous

10.1 If any provision or clause of our Terms of Use or part thereof is rendered void, illegal or unenforceable by any legislation or laws to which it is subject, it shall be modified so as to give effect to its intention, or where such modification is not possible, that provision or clause shall be rendered void, illegal or unenforceable to that extent only and it shall in no way affect or prejudice the enforceability of the remainder of such provision or clause or the other provisions of our Terms of Use.

10.2 The failure or delay of our Company at any time to enforce any of its rights here-under our Terms of Use shall not be constituted as a waiver thereof and shall in no manner affect our Company’s rights at a later time to enforce the same.

10.3 A person who is not a party to this Agreement shall have no right under the Con-tracts (Rights of Third Parties) Act (Cap. 53B) to enforce any of its terms.


ECRUU COMMODITIES MEDIA MONITORING PTE. LTD. (“our Company”, ‘we’, ‘our’, or ‘us’) respects your privacy when you communicate (whether online or offline) with us through our website at www.ecruu.com (“our Website”), our ECRUU news update mobile application and other applications made available by our Company (collectively “App”), email, telephone, text messaging and/or offline programmes and events (collectively “Communication Channels”)

In order to provide you with appropriate customer service, we require infor-mation from you and/or your organization, some of which may be considered as personal data pertaining to individuals or confidential information of your or-ganisation respectively. We have therefore set out in detail below how we col-lect, use and protect your information and data. Kindly review the terms and conditions of our Privacy Policy as follows so that you may be reassured that we take data protection seriously:-
A. Please note that your access and use of our Website, App, and other rele-vant Communication Channels is subject to our Website’s Terms of Use (“Terms of Use”), as well as the terms and conditions as set out herein this Privacy Policy. Accordingly, by accessing our Website, App, other Commu-nication Channels, or otherwise howsoever providing us with your personal data, you are agreeing to our collection of your information pursuant to this Privacy Policy. Should you disagree with any clause in our Terms of Use and/or this Privacy Policy, please immediately cease your access of our Website, App and/or other Communication Channels.

B. In order for you to maximise the utility of our Website and App, access our services, products, news summaries, request information from us, take-part in our promotions, text messaging programmes, telephone promotions, of-fline and online programmes and other events, receive our marketing mate-rials, newsletters or updates for information and/or promotion regarding our services, our products, our subscription plans, and other related matters (our newsletters, news summaries, news extracts, blog, updates and/or promotions shall be collectively referred to as our “Updates”), your Personal Data (as defined in clause 1.2 below) and/or your Confidential Information (as defined in clause 1.4 below) has to be provided to us, and we will need to keep and use your Personal Data and/or Confidential Information in order to fulfil the purpose for which you have contacted us, subscribed to our App, our Website, Updates and/or services.
For expediency and for compliance with any changes in the law, we reserve the right to amend this Privacy Policy in our sole discretion at any time without pri-or notice to you, and you agree that your continued access to and/or use of our App, our Website, blog, social media channels and/or other Communication Channels, your continued desire to receive our Updates and email us, take part in text messaging programs, liaising with us via the telephone, offline and online programs, events and/or utilise any of our Communication Channels constitutes your unconditional acceptance of our amended Privacy Policy. You agree that it is your sole responsibility to keep yourself updated of any amendments by reviewing this Privacy Policy at our Website regularly.

1. Types of Data Collected

1. When you visit or access our Website, App, social media channels, other Communication Channels, sign-up for any of our Updates, email us, call us, take part in our text messaging programmes and/or in offline or online programmes and events, we collect Personal Data and Anony-mised Data.

1.2 “Personal Data” refers to information, whether true or otherwise, with personal identifiers that can be used separately or collectively to identify an individual, such as name, address, NRIC or other identification num-ber, mobile number, phone IMEI, email address, birthdate, gender, in-come range, trading preferences, trading accounts, residency status, bank account details, and credit card details, but excludes information that is publicly available (including but not limited to Social Media Data).

1.3 “Anonymised Data” refers to information that is not associated with or linked to your Personal Data and cannot be used to identify individual persons.

1.4 “Confidential Information” refers to sensitive or proprietary information of an organization (incorporation, partnership, or other similar forms of legal entity) that is not available in the public domain, such as the annual turnover of an exempt private company, or information of an individual that is private but does not constitute Personal Data.

1.5 “Social Media Data” refers to information that would have been deemed as your Personal Data but is generally not protected as such due to your voluntary disclosure of such information to the public domain via a social media platform (example, Facebook, Twitter and LinkedIn), including but not limited to your social media accounts’ information such as name, birthdate, email address, list of friends, and any other additional infor-mation or activities that you permit the third party social media platform to share with us.

2. Collection of Anonymised Data

2.1 When you access our App, our Website, and/or email us, we collect Anonymised Data about you via the application of generally acceptable web technologies including but not limited to “web beacons”, “cookies”, “clear GIFs”, “widgets”, “online evaluations”, “surveys”, “HTML5”, “dy-namic device identifiers”, and third-party web analytics such as “Google analytics” (collectively, “Acceptable Technologies”). This automatic col-lection of non-personal information includes (without limitation) collec-tion of your IP Address, the web browser software that you used, the type of smart phone or tablet that you may be using, the operating soft-ware/platform of your device, your sign-up(s) for any Updates or infor-mation via our Website and/or App, the specific pages of our Website viewed by you, the specific categories or features in our App accessed by you, any third party application used in conjunction with our App, your downloading of related applications, and third party websites that you may have visited prior to our Website. Our purpose for the aforesaid collection of information is for us to understand the preference of our visitors and users so as to enhance and facilitate the ease with which you are able to access or use our Website and our App.

2.2 As part of the Anonymised Data that we collect, when you access our Website via your mobile device or tablet, we will also collect information regarding the type of mobile device or tablet that you are utilising so that our Website and/or App can provide you with the version of our Website and/or App best suited for access via your mobile device or tablet.

2.3 If you do not consent to our collection of Anonymised Data, please adjust the settings on your computer, tablet and mobile device to block or disable our use of the Acceptable Technologies. In the event that you choose to access our Site without blocking or disabling or opting out of the Acceptable Technologies, such access by you will constitute your consent to our use of the Acceptable Technologies and our collection of information thereto.
2.4 To better assist you in understanding the generally accepted technology used in our collection of Anonymised Data:-
2.4.1 “IP Address” refers to a number that is automatically assigned to your computer when you access the Internet. Under certain cir-cumstances, your IP Address remains the same from browser session to browser session. However, in the event that a con-sumer Internet access provider is utilised, your IP Address will likely vary from session to session. We track IP Addresses solely in conjunction with session cookies to analyse the flow of webpages on our Website.
2.4.2 “Cookies” refer to small pieces of data that a website sends to your computer’s hard drive or mobile device’s internal storage while you are viewing the said website. Our Website utilises both session cookies (they expire the moment your Internet browser is closed) and persistent cookies (they will remain in your computer and your mobile device until you actively take steps to delete them) so as to provide you with a more personalised and interac-tive experience on our Website. By changing the options on your Internet browser and adjusting the settings in your mobile device (subject to your version of operation system and your device’s features), you can control whether to accept or decline cookies.

2.4.3 “Clear GIFs” refer to clear electronic images that are used to track your opening of webpages on our Site and your pattern of brows-ing our webpages, for the purpose of allowing us to assess the at-tractiveness of the content on our Site, and the flow of webpages and layouts that appeal to you. Clear GIFs are also commonly known as “web beacons” and may be included on our Site, and generally works in conjunction with cookies to identify users and user behaviour. Some of our HTML based emails also utilise Clear GIFs in order for us to assess what are the emails we sent that have been opened and acted upon. Clear GIFs collect only limited data, such as a cookie number, the time and date of when a particular webpage on our Site is accessed, and a description of the webpage on Our Site in which the clear GIF resides. Such col-lected Anonymised Data helps us to determine the effectiveness of the way our webpages are arranged on Our Site, our modes of communications and promotional campaigns.

2.4.4 “Third-party web analytics” refer to services provided by third party service providers for the assessment, analysis, measurement and reporting of the behaviour of visitors to a website in order to assess and improve the effectiveness of the website. One of the most well-known third-party analytics service is “Google Analytics”.

2.4.5 “HTML5 local storage” refer to caching services utilizing primarily a cache manifest file, which allows for storage of your preferences offline which will then be updated and synchronized when you go online.

2.4.6 “Dynamic device identifiers” refer to “identifier for advertisers” or “IFA”, which is a random, anonymous number assigned to a user of the iPh-one or iPad and is temporary, allowing it to be blocked like a cookie. When a user views an application or browses the internet, the user’s presence generates a call for an advertisement as the publisher’s site that the user is viewing will pass the IFA to the ad server and the adver-tiser is then able to serve the user with an advertisement relevant to the topic being viewed. IFA can also be used to identify whether the adver-tisements resulted in users downloading applications or purchasing products that were advertised. The IFA does not identify the user per-sonally, it provides an aggregated audience data that advertisers can target with advertisements. IFA can be opted out of via the settings in the user’s device (by default, the IFA is enabled), subject to the availa-bility of such options in the version of your operating system and the features of your device.

3. Your Consent to our Collection, Retention and Use of Personal Data and Confidential Information

3.1 In order for our Company to provide you with our services and products, you agree and consent to our Company collecting, using and retaining your Personal Data and/or Confidential Information as follows:-
(i) When you sign up for our Updates, or you email or call us with any queries, you will be required to provide us with your Personal Data and/or Confidential Information in order for us to add you to our mailing list, or to revert to your queries.

(ii) When you sign up for any Updates, register for any accounts, sub-scribe to our services, enroll for any membership or loyalty pro-gramme, utilise any of our Communication Channels, participate in text messaging programmes, enter into a subscription plan, or other promotional campaigns, offline and online programmes and events that we provide, we will require your Personal Data and/or Confidential Information in order to keep a record of and provide you with the benefits that accompany your subscription plan, mem-bership programme, text messaging programmes, and/or promo-tional campaigns (whether online or offline). Unless you terminate your subscription plan, withdraw from our membership programme or promotional campaigns, or our relevant promotional campaign ends, we will keep your Personal Data for as long as you are still part of a subscription plan, our membership programme and/or promotional campaigns (whichever is the later) so that we can pro-vide you with the relevant benefits. In relation to your Confidential Information, we will retain them for as long as we are of the reason-able opinion that you may still be interested in our Company’s products services so that our Company can be expeditious in the provision of our services whenever you should seek a delivery of any of our products or our assistance.

(iii) In the event where we should use Google ads and wWhen you click on any of our Company’s Google ads or other internet based adver-tisements for more information regarding our services or our Web-site or our mobile application, we collect the Personal Data and/or Confidential Information that you provide in order to follow up with you pertaining to your interest in our products, services and/or our Website.

2. In addition, we will retain your Personal Data and/or Confidential Infor-mation where necessary and for such duration as may be required in or-der for our Company to comply with applicable laws and regulations, assist in any legal investigations, meet the demands from any regulatory or law enforcement bodies, for utilization in legal proceedings, minimiz-ing fraud, collection of debts, repayment of loans, resolving disputes, identifying issues, enforcing contractual breaches and/or claiming for damages.

4. Disclosure of Personal Data and Confidential Information

4.1 We may need to disclose your Personal Data and/or Confidential Infor-mation to:-

(i) third party service providers in order for us to facilitate your access to and use of our Website, utilise our App, access our text messag-ing programme, for us to contact you as you may have requested via our Website or telephone, for us to maintain and update your records to ensure that you receive our replies to your queries, for us to follow up on any delivery of news summaries, products or services that you may have requested for, and to provide you with any other updates and perks accompanying your participation in our subscription plan, membership programme and/or promotional campaigns. The aforesaid third party service providers have a con-tract with us to perform the services necessary for you to use our Website, our App, receive Updates and/or our services or products that you might have ordered, and such third party service providers therefore include but is not limited to webhost companies, website maintenance companies, database storage companies, membership programme service providers, app stores, app maintenance providers, companies that assist to perform mass mailing on our behalf, courier and logistics companies, etc.;

(ii) our book-keepers, accounting firms, audit firms, law firms and/or other professional advisory firms who are maintaining our records in accordance with legal requirements;

(iii) governmental, regulatory or law enforcement bodies who have a legal right to demand for your Personal Data and/or Confidential In-formation;

(iv) credit bureaus, credit rating agencies and fraud preventing compa-nies for the purpose of minimizing fraudulent activities via your Personal Data and/or Confidential Information; and

(v) our affiliated or related companies and/or third parties to whom we may sell, divest, transfer, assign, share or otherwise engage in a transaction that involves, some or all of our Company’s assets (which may include your Personal Data), in the course of a corpo-rate divestiture, corporate restructuring, merger, acquisition, joint venture, bankruptcy, dissolution, reorganisation, or any other simi-lar transaction or proceeding.

Except as provided above, we do not sell, rent, licence or otherwise disclose your Personal Data and/or Confidential Information to third parties or our affiliated companies. We are careful in our selection of third party service providers, and all such third party service providers as well as our abovementionedabove-mentioned affiliated companies are bound by obligations of data protection (pursuant to contracts and/or applicable laws) similar to the obligations herein this Privacy Policy. In general, the third party service providers engaged by us will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us.

5. Transferring Personal Data out of Singapore

5.1 Pursuant to the purposes and activities as set out in sections 3 and 4 above, it may be necessary for us to transfer your Personal Data out of Singapore. You hereby agree and consent to the aforesaid transfer, on the understanding that the recipients of such Personal Data are also sub-ject to applicable laws or contractual obligations similar to the obliga-tions as set out in the Personal Data Protection Act 2012.

6. Accurate and Complete Personal Data and Confidential Information

6.1 In order for us to provide you with access to our Website, our App, our text messaging programme, our other Communication Channels and all their respective associated functions, our services and our products, and to perform the activities as set out in sections 3, 4 and 5 above, you warrant that the Personal Data (and/or Confidential Information) that you provide to us is accurate, and that all Personal Data (and/or Confidential Information) as may be relevant for that particular purpose/circumstance has been provided.

7. Do-Not-Call (“DNC”) Provisions and Registries

7.1 We respect your selections in relation to the channels via which you wish to receive our Updates. Therefore, if you have registered your telephone and/or fax number with the Do-Not-Call Registries in relation to telephone calls, text or fax messages, we will not send you any Updates via the channels that you have opted out of by registering with the Do-Not-Call Registries. However, if you have previously consented to our sending you Updates via your telephone number (calls or text messages) and/or facsimile number, we will continue doing so until you withdraw your consent by contacting our Data Protection Officer at in-fo@ecruu.com[insert email address, eg. privacy@ecruu.com]

8. Withdrawal of Consent

8.1 You may at any time withdraw your consent to our use, retention, disclo-sure or transfer of your Personal Data and/or Confidential Information pursuant to this Privacy Policy by emailing our Data Protection Officer at [insert email address, eg. privacy@ecruu.com]info@ecruu.com. Howev-er, please note that any such withdrawal of consent may result in us be-ing unable to continue providing our services or fulfilling our contractual obligations with you, including but not limited to termination of your ac-cess to our Website and App, cancellation of any subscription plan and thereby all deliverables that would have been provided thereunder, ter-mination of membership programme benefits that would otherwise have been available to you, cessation of your access to our text messaging programme, termination of delivery of news summaries to you, inability to provide you with the opportunity to participate in promotions, inability to fulfil any request for information that you may have submitted to our Company, inability to fulfill any purchaser orders, and potentially inability of third parties to provide you with their services or products as you might have contracted with them through our Website or App. Accord-ingly, your withdrawal of consent may also lead to the termination of any contract(s) that you may have with our Company, as well as termination of any contracts with any third parties engaged through our Website or App, for which our Company expressly reserves its rights and remedies thereto. Our Data Protection Officer will further advise you on the legal consequences that may ensue should you contact her to withdraw your consent.

8.2 Should you wish to unsubscribe to our email updates, please click the “unsubscribe” option made available in our emails to you. Please note however that this may result in our being unable to make available to you updates on our products and services, your benefits under our member-ship programme and any ongoing promotions.

8.3 Should you wish to unsubscribe to any of our mobile applications or text messaging programmes, please utilise the “unsubscribe” or “termina-tion” option that may be available on the application itself. If such option is not available, kindly email us at [insert email address, eg. termi-nate@ecruu.com]info@ecruu.com

9. Access and Correction of Personal Data and Confidential Information

9.1 Should you wish to access, update or make corrections to your Personal Data and/or Confidential Information held with us, or if you wish to re-ceive further clarifications on your Personal Data and/or Confidential In-formation held with us, please email our Data Protection Officer at [insert email address, eg. privacy@ecruu.com]info@ecruu.com.

9.2 There will be no administrative fees or other charges levied for any re-quest to correct or update your Personal Data and/or Confidential Infor-mation. However, for all other requests such as accessing your Personal Data and/or Confidential Information held with us, obtaining a record of when you accessed our Website or App, the date of your requests for in-formation, etc., a reasonable administrative fee may be levied depending on your request as time and resources will be spent in accommodating your requests.

9.3 Should you have any queries or complaints pertaining to this Privacy Policy, our Terms of Use, your Personal Data and/or Confidential Infor-mation as registered with us, or in relation to our Company’s use, reten-tion, disclosure or transfer of your Personal Data and/or Confidential In-formation, or should you desire to learn more about our data protection policies and security measures, please email our Data Protection Officer at [insert email address, eg. privacy@ecruu.com]info@ecruu.com.

10. Minors

10.1 Our Website, our App, our Updates and our services are not meant for persons who may be defined as minors under applicable law. We do not knowingly collect Personal Data from minors, however, through the in-ternet, we are not able to ascertain on our end whether such individuals are minors. It is thus the responsibility of parents or guardians to ensure that their minors do not access our Website, download or access our App, email us, or provide us with Personal Data without their paren-tal/guardian’s consent. If a parent or guardian becomes aware that his or her minor has accessed our Site or provided us with Personal Data with-out his/her consent, he or she should contact our Data Protection Officer at [insert email address, eg. privacy@ecruu.com]info@ecruu.com promptly. If we become aware that a minor under 18 has provided us with Personal Data without their parent or guardian’s consent, we will delete such information from our records.

11. Security Measures for Protection of Personal Data and Confidential In-formation

11.1 We ensure that our Website and App are protected by reasonable securi-ty measures afforded by current technology, and that all our data hosts and servers are similarly protected by such security measures, including but not limited to firewalls.

11.2 Your Personal Data and Confidential Information is kept securely and protected against unauthorized access and disclosure. We utilise securi-ty means such as (without limitation) password protection, encryption, locked and restricted access. We have strict policies in place restricting access to Personal Data and Confidential Information to only our author-ized personnel on a need-to-know basis.

11.3 We will take practical steps to ensure that your Personal Data will not be kept longer than as set out herein this Privacy Policy, or for as long as is necessary for fulfilling the purposes for which you have entrusted us with your Personal Data, or as may be required for legitimate business or legal purposes, whichever is the latest.

12. Third Party Sites, and Social Network Sites

12.1. Our Website, App, text messaging programme and other Communica-tion Channels may contain hyperlinks to websites operated by third parties. However, such third party websites are not governed by our Privacy Policy or Terms of Use. We are not responsible for the priva-cy policies or data security of such third party websites, even if they are co-branded with our Company name or logo, or our Website or App displays products or services that originate from such third par-ties. As such, we urge you to learn about the privacy policies of these third party websites before accessing or using them, and to be careful about providing any Personal Data and/or Confidential Information to such third party websites. We seek your understanding that we are not liable for any acts or omissions or any loss or damage that you may suffer due to your use or access of such third party websites.

11.2 Our Company may utilise reputable social media/network sites such as, but not limited to Facebook, Twitter, Instagram, Pinterest and LinkedIn (collectively the “Social Media Sites”) so as to connect to your social networks. In order to generate interest in our Website and App, our products and services amongst the contacts in your social networks and to allow you to share your interest in our Website, App and/or our prod-ucts and services, we provide access to our Website and App to the third party Social Media Sites, and there are links on our Website and App to such Social Media Sites. The aforesaid association with the Social Media Sites does not constitute any endorsement or recommendation of any of the Social Media Sites by our Company nor vice versa. As per clause 12.1 above, kindly review the terms of use and privacy policies of the Social Media Sites before you use or access such Social Media Sites in con-junction with our Website or App or any of our promotions and our prod-ucts or services made available via any Social Media Sites.

11.3 The association of our Website and App with the Social Media Sites makes available certain features which when used by you, may result in information being made available from your accounts with the Social Media Sites to our Company. Such information which we collect about you shall constitute public information that is available in the general domain because such information was made publicly available by the Social Media Sites. Should you prefer that we do not collect your infor-mation from the Social Media Sites, please (i) do not use the features or links that associates our Website and/or App with the Social Media Sites; and (ii) adjust the settings in your accounts with the Social Media Sites to prevent the sharing of your information with our Site and mobile ap-plication. Please note that our Company cannot control nor is our Com-pany howsoever responsible for the sharing of your information by the Social Media Sites with third parties.

11.4 One of the features which you may see available on our Website and App in association with the Social Media Sites, is the “like” feature by Face-book, and other similar functions provided by other Social Media Sites. When you “like” our Website or App or our products or services, infor-mation about our Website or App, our products and services will be made known to your network within your Social Media Sites’ accounts via a variety of methods employed by the relevant Social Media Site. Your information may also be made known alongside with our products or services that you have liked pursuant to the methods/channels made available by Social Media Sites in relation to such features. If you are not agreeable to the aforegoing, please instruct the relevant Social Media Site or adjust your account settings with the Social Media Site. Please note however that we are not obliged to display on our Website or any re-lated webpages (whether on Social Media Sites or otherwise) any of your information, including but not limited to your photo or name, even if you “like” our Website, our App, our products or services. In the event that any of your information, product or service endorsements (including your liking of our Website, our App, any of our Company’s products or services, or third party products or services featured on our Website or App) appear on our Website or any related webpages (whether on Social Media Sites or otherwise), we shall have the right in our sole discretion to remove such information or product/service endorsements from our Website or any related webpages.

12. Governing Law and Jurisdiction

12.1 The terms and conditions of this Privacy Policy are governed by the laws of Singapore. In the event of any disputes arising from this Privacy Policy and your use of our Website and/or our App, you must first contact our Data Protection Officer at [insert email address, eg. priva-cy@ecruu.com]info@ecruu.com regarding your concern and use your best endeavours to amicably settle any dispute in good faith. We on our part will also use our best endeavours to amicably settle your concerns in good faith. However, if no amicable resolution is reached within 30 days, you agree to submit to the exclusive jurisdiction of the Courts of Singapore.

If you have any questions regarding this Privacy Policy or your Personal Data, please contact our Data Protection Officer at
Version: 1 September 2016