This Data Privacy Notice (“Notice”) sets out the basis which Titan Digital Media Pte. Ltd., UEN: 201801023G,, its affiliates and their respective officers & employees (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of data subjects in accordance with applicable personal data protection laws (“Data Privacy Laws”). This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.

When a data subject accesses our websites, uses our services and/or submits personal data to us, the data subject is agreeing to our data privacy policies and consenting to our collection, processing, use and storage of the data subject personal data, as described herein.

If the data subject does not agree with the terms and conditions under this Notice, the data subject must not access our websites, use our services and/or submit personal data to us.


Depending on the nature of interaction with us, we may collect the following types of personal data from data subjects for the purpose(s) on the following legal bases:

Personal Data Type Purpose(s) Legal Basis

Name (full name, nickname, alias, online identifier), Address, Contact phone number(s), Email Address

Torespondtothedata subject’s request(s) for our service(s)

Communicatewiththedata subject relating to business or employment opportunities

Communicatewiththedata subject relating to our business operations






business relationships




service updates (product

Consent: the data subject has given clear consent for us to process the personal data for the specific purpose(s)

Contract: the personal data is necessary for a contract to be entered into or entered into between us and the data subject

Legal Obligation: the personal data of the data subject is needed for us to comply with our legal obligations

Legitimate interests: the processing of the data subject personal data is necessary due to our legitimate interests,

news, special offers, etc) to the Data Subject

except where such interests are overridden by interests, rights and freedoms of the data subject

Legal Claims: for us to exercise or defend against legal claims

Photo ID, Birth date, nationality, citizenship, gender, health, insurance and medical, ethnic origin, fingerprint, religion, and belief.

1. Conductduediligence 2. Verifyidentityofdata subject (eg: contracts)


3. Accidentresponse

4. Manageemployment

matters (eg: medical certificate for leave applications, etc)

5. Managebusiness operations (eg: fingerprint for site access)

6. Governmenttax,auditsand to meet reporting requirements

Credit card, bank account number, user account number or other financial information

Managedatasubject’s payment and invoices relating to our goods and services

Manageourpaymentto and invoices from the data subject or any third parties

CCTV images, work site access records, Work site photography, audio and video recordings

Forourbusinessandwork as a digital media company

Torespondtofeedbackor complaints regarding work site safety



and/or improvement

Data subject log data, metadata, IP Address(es), device information (geolocation, etc)

To administer and manage our websites

Data subject social networking site data

To interact with the data subject through our social networking site

Data Subject preference(s) and service usage data (eg: cookies)

To ensure the content which we provide to the data subject via the device is relevant and presented in an effective manner



1. We collect and use personal data of data subjects when:

(a) it is provided to us voluntarily by the data subject directly or via a third party who

has been duly authorised by the data subject to disclose such personal data to us (“authorised representative”) after (i) the data subject (or the authorised

representative) have been notified of the purposes for which the data is collected, and (ii) the data subject (or the authorised representative) have provided written consent to the collection and usage of such personal data for those purposes, or

(b) collection and use of personal data without consent is permitted or required by Data Privacy Laws or other laws. We will seek consent from data subjects before collecting any additional personal data and before using the personal data for a purpose which has not been notified to the data subject (except where permitted or authorised by law).

We collect, use and disclose personal data to the extent reasonably and legitimately required for our work and business purposes and/or as authorised by the data subject (or the authorised representative).

We do not knowingly solicit, collect or maintain personal data from children, minors and legally incapacitated persons without parental or legal guardian consent. Should we be informed that a child, minor or legally incapacitated person has provided us with any personal data, we will take reasonable steps to delete such personal data within the time period as required under law.

We may transfer or disclose personal data of data subjects:

(a)  where such transfer or disclosure is required for performing obligations in the course of or in connection with our provision of the goods and services requested by the data subject;

(b)  to third party service providers, agents and other organisations we have engaged to perform any of the functions with reference to the above-mentioned purposes;

(c)  to our affiliates, business partners or professional advisors for the above- mentioned purposes;

(d)  due to our business merger(s), acquisition(s) or reorganization(s); and/or

(e)  for any of the purposes based on any of the legal basis as provided above.

The purposes listed above may continue to apply even in situations where the data subject’s relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter but only to the extent permitted under applicable laws (including, where applicable, a period to enable us to enforce our rights under any contract with the data subject).

At websites that we operate and/or control, we may collect payment information, such as credit card numbers, to process payment of purchases made by data subjects and to provide refunds. Such information may be collected directly by us or indirectly through the following third parties (please refer to Section J (Third Party Websites) for more information):



Green World FinTech Service Co., Ltd. (a.k.a ECPay)

Stripe Payments Singapore Pte Ltd


Shopify Commerce Singapore Pte. Ltd. Apple South Asia Pte Ltd


PayPal Pte. Ltd.



Taiwan Singapore International International International

The consent provided by the data subject or the authorised representative for the collection, use and disclosure of personal data will remain valid until such time it is being withdrawn in writing. The data subject may withdraw consent and request us to stop collecting, using and/or disclosing the personal data of the data subject for any or all of the purposes listed above by submitting a request to us at the contact details provided below.

Upon receipt of the written request to withdraw consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with the data subject) for such request to be processed and for us to notify the data subject of the consequences of us acceding to the same, including any legal consequences which may affect the rights of the data subject and liabilities to us. In general, we shall seek to process the data subject request within the time period as required under Data Privacy Laws.

Whilst we respect the data subject’s decision to withdraw consent, the provision of our goods or services to the data subject and/or the data subject’s access to our websites may be affected or impacted by the withdrawal of consent, depending on the nature and scope of the request. The withdrawal of consent will not affect the lawfulness of any processing we have conducted prior to the withdrawal of consent. The withdrawal of consent will also not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.


1. If a data subject wishes to make requests for (a) access to a copy of the personal data which we hold about the data subject or information about the ways in which we use or disclose the personal data of the data subject, or (b) correction or update of any of the personal data of the data subject which we have in our records, the data subject may submit the request to us at the contact details provided below.

To the extent permitted under Data Privacy Laws and within the legal limits, if applicable, a reasonable fee may be charged for an access request. If so, we will inform the data subject of the fee before processing the request.

We will respond to the request as soon as reasonably possible. In general, our response will be within the time period as required under Data Privacy Laws. If we need an extension of time to attend to the data subject request(s), or if we are unable to accede to the request(s) of the data subject, we will inform the data subject accordingly (except where we are not required to do so under Data Privacy Laws).


A data subject may, by reaching us at the contact details provided below, make request(s) for:

(a)  (Erasure or deletion) personal data which we hold about the data subject to be removed, deleted or erased;

(b)  (Portability) personal data of the data subject that we have collected to be transferred to another organization or directly to the data subject;

(c)  (Restrict processing) restrictions to apply to how we collect, use, disclose or process personal data of the data subject;

(d)  (Opt-out of email marketing) us to stop communicating with the data subject for marketing purposes;

(e)  (Profiling and automated decision-making) us to stop processing the personal data for automated processing or profiling; and/or

(f)  (Opt-out of sale of personal data to third parties) personal data not to be sold to third parties as contemplated by the California Consumer Privacy Act of 2018.

We will respond to the above requests within the time period as required under Data Privacy Laws. We may refuse any such requests if Data Privacy Laws allow or require us to do so. We will inform the date subject of the reasons for our refusal if required under Data Privacy Laws. In order for us to process such request(s), we may retain some basic information about the data subject, and we may keep a record of the request and our response.


1. To safeguard the personal data of data subjects from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced certain administrative, physical and technical measures such as up-to-date antivirus protection, encryption, and disclosing personal data both internally and to our affiliates, business partners, professional advisors, authorised third party service providers and agents only on a need-to-know basis.

2. However, no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of the information and are constantly reviewing and enhancing our information security measures.


We generally rely on personal data provided by the data subject (or the authorised representative). In order to ensure that the personal data of the data subject is current, complete and accurate, data subjects may update us if there are changes to the personal data by informing us at the contact details provided below.


We may retain the personal data of data subjects for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.

We will cease to retain the personal data of data subjects, or remove the means by which the data can be associated with the data subjects, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.


Our websites may contain links to other third-party websites. Data subjects’ access and use of such third-party websites and services are subject to other terms, conditions and privacy policies which we have no control over. To the maximum extent permissible under law, we do not accept any responsibility or liability for such terms, conditions and policies or the processing of personal data by such third parties. We strongly encourage you to read and understand such terms, conditions and policies before you accept them.


We may operate within and/or outside the data subject country of residence and/or office. The personal data of data subjects may thus be transferred, accessed and stored globally as necessary for the uses stated above in accordance with the terms of this Notice, and in compliance with Data Protection Laws.

Personal data may be transferred to or processed at locations outside of the European Economic Area (EEA), some of which have not been determined by the European Commission to have an adequate level of data protection.

For cross border transfers, we will take measures, such as the standard contractual clauses adopted by the European Commission, or other adequate transfer mechanism.


We may supplement this Notice with Addendums that address additional provisions which are applicable to certain jurisdictions. Such Addendums will apply to data subjects residing in or working at such jurisdictions.

In the event of any discrepancy or inconsistency between the English version of this Notice and a version of this Notice under a different language, if available, the English version shall prevail.


Data subjects can send us feedback, complaints or enquiries via post at:


Titan Digital Media Pte. Ltd.

29 Tai Seng Ave #01-01, Natural Cool Lifestyle Hub, Singapore, 534119

Or reach us via our online Contact Form at


This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of personal data by us.

We may revise this Notice from time to time without any prior notice. The data subject may determine if any such revision has taken place by referring to the date on which this Notice was last updated. The data subject’s continued use of our services shall constitute acknowledgement and acceptance of such changes.





Last updated : 6 April 2021