Privacy Policy

1. Introduction


1.1 World Taekwondo AR textbook (the “App”) is the first and only virtual textbook for Taekwondo (“TKD”) practitioners recognised by the World Taekwondo Federation (“WTF”). It features 3D virtual avatars that execute WTF approved TKD poomsaes, for training references and educations. The App is owned and managed by Refract Technologies Pte. Ltd. References in this privacy policy (“Privacy Policy” or “Policy”) to "we", "our", and "us" or any other grammatical variations thereof shall unless otherwise stated, mean Refract Technologies Pte. Ltd (“Refract”).

1.2 We take our responsibilities under the applicable privacy laws and regulations ("Privacy Laws") seriously and are committed to respecting the privacy rights and concerns of all Users of our App (we refer to the services we provide as described in our App collectively as the "Services" and users who download and use our App and our Services as “Users”). This Privacy Policy is designed to assist you in understanding how we collect, use, disclose and/or process the personal data you have provided to us and/or we possess about you, whether now or in the future, as well as to assist you in making an informed decision before providing us with any of your personal data. Please read this Privacy Policy carefully. If you have any questions regarding this Privacy Policy, please see the section entitled "Contact Us" at the end of this Privacy Policy.

1.3 "Personal Data" or "personal data" means data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access. Common examples of such personal data could include an individual’s name, identification number and contact information.

1.4 By using or accessing the Services and registering your account with Refract, you unconditionally and unequivocally acknowledge and agree that you fully accept the practices, requirements, and/or policies outlined in this Privacy Policy, and you hereby consent to us collecting, using, disclosing and/or processing your personal data as described herein. IF YOU DO NOT CONSENT TO THE PROCESSING OF YOUR PERSONAL DATA AS DESCRIBED IN THIS PRIVACY POLICY, PLEASE DO NOT USE OUR SERVICES OR REGISTER FOR AN ACCOUNT. If we change our Privacy Policy, we will make the amended Privacy Policy available on the App. We reserve the right to amend this Privacy Policy at any time without notice.

2. When Will Refract Collect Personal Data?


2.1 We will/may collect personal data about you:
(a) when you register and/or use our Services or App, or open an account with us;
(b) when you submit any form, including, but not limited to, application forms or other forms relating to any of our products and services, whether online or by way of a physical form;
(c) when you enter into any agreement, or provide other documentation or information in respect of your interactions with us, or when you use our products and services;
(d) when you interact with us, via mediums such as but not limited to telephone calls (which may be recorded), letters, fax, face-to-face meetings, social media platforms and emails;
(e) when you use our electronic services, or interact with us via our App or our Services. This includes, without limitation, through cookies which we may deploy when you interact with our App;
(f) when you carry out transactions through or in relation to our Services;
(g) when you provide us with feedback or complaints; and
(h) when you submit your personal data to us for any reason.

Paragraph 2.1 above does not purport to be exhaustive and merely sets out some common instances of when personal data about you may be collected.

2.2 When you visit, use or interact with our App in any fashion, you acknowledge that we may collect certain information by automated or passive means using a variety of technologies which may be downloaded onto your device, and may set or modify settings on your device. The information we collect may include, but is not limited to, your Internet Protocol (“IP”) address, computer/mobile device operating system and browser type, type of mobile device, the characteristics of the mobile device, the unique device identifier (“UDID”) or mobile equipment identifier (“MEID”) for your mobile device, the address of a referring website (if any), and the pages you visit on our App, and the specific timings of such visits. We may collect, use, disclose and/or process this information only for the Purposes (defined below).

3. What Personal Data will Refract Collect?


3.1 The personal data that Refract may collect includes but is not limited to your:
• name;
• email address;
• date of birth;
• billing address;
• telephone number;
• country;
• dojang; and
• any other information about the user when the user signs up to use our Services or App, and when the user uses the Services or App, as well as information related to how the user uses our Services or App.

3.2 If you object to us collecting the aforementioned information/personal data in any way, you may opt out at any time by notifying our Data Protection Officer in writing about it. Further information on opting out can be found in the section below entitled "How can you opt-out, remove, request access to or correct information you have provided to us?". You must note that opting out of us collecting your personal data or withdrawing your consent for us to collect, use or process your personal data may affect your use of the Services.

4. Setting Up An Account


In order to use certain functionalities of the Services, you will have to create a user account which requires you to submit certain personal data. When you register and create an account, we require you to provide us with your name and email address, as well as a user name and password of your own selection. Your user name and password will be used so you can securely access and maintain your account.

The Personal Data we collect also depends on which external accounts you choose to use, their respective privacy policies, and what your privacy settings with those services allow us to see when you use their services to access our Services.
• If you choose to link your Google account to the Services, we will collect your Google email address and an authentication token provided by Google.
• If you choose to link your Facebook account to the Services, we will collect a unique user ID provided by Facebook and, if permitted by you, your Facebook registered email address.
• If you choose to link your Apple account to the Services, we will collect your email address on file with your Apple ID account or a private relayed email address if you use the Hide My Email option provided by Apple.

5. Cookies


5.1 We may from time to time implement "cookies" or other features to allow us or third parties to collect or share information that will help us improve our App and the Services we offer, or help us offer new services and features. “Cookies” are identifiers we transfer to your mobile device that allow us to recognize your device and tell us how and when the Services or App are used or visited, by how many people and to track movements within the App. We may link cookie information to your personal data. Cookies also link to information in relation to items you have selected for purchase and pages that you have viewed.

5.2 You may refuse the use of cookies by selecting the appropriate settings on our App. However, please note that if you do this you may not be able to use the full functionality of our App or the Services. We will not be responsible for the same in any way.

6. How Do We Use The Information You Provide Us?


6.1 We may collect, use, disclose and/or process your personal data for one or more of the following purposes:
(a) to provide Augmented Reality (“AR”) experiences. We need to locally derive AR geospatial data from your device camera;
(b) to manage, operate, provide and/or administer your use of and/or access to our Services and our App as well as your relationship and user account with us; (c) to manage, operate, administer and provide you with as well as to facilitate the provision of our Services, including, without limitation, remembering your preferences;
(d) to respond to, process, deal with or complete a transaction and/or to fulfil your requests for certain products and services and notify you of service issues and unusual account actions;
(e) to enforce our terms of Service or any applicable end user license agreements;
(f) to protect personal safety and the rights, property or safety of others;
(g) for identification and/or verification;
(h) to maintain and administer any software updates and/or other updates and support that may be required from time to time to ensure the smooth running of our Services;
(i) to deal with or facilitate customer service, carry out your instructions, deal with or respond to any enquiries given by (or purported to be given by) you or on your behalf;
(j) to contact you or communicate with you via voice call, text message and/or fax message, email and/or postal mail or otherwise for the purposes of administering and/or managing your relationship with us or your use of our Services, such as but not limited to communicating administrative information to you relating to our Services;
(k) to conduct research, analysis and development activities (including, but not limited to, data analytics, surveys, product and service development and/or profiling), to analyse how you use our Services, to improve our Services or products and/or to enhance your customer experience;
(l) to allow for audits and surveys to, among other things, validate the size and composition of our target audience, and understand their experience with our Services;
(m) where you give us your prior consent, for marketing and in this regard, to send you by various modes of communication such as postal mail, email, location-based services or otherwise, marketing and promotional information and materials relating to products and/or services (including, without limitation, products and/or services of third parties whom we may collaborate or tie up with) that we may be selling, marketing or promoting, whether such products or services exist now or are created in the future. If you are in Singapore, In the case of the sending of marketing or promotional information to you by voice call, SMS/MMS or fax to your Singapore facsimile number, we will not do so unless we have complied with the requirements of Singapore’s Privacy Laws in relation to use of such latter modes of communication in sending you marketing information or you have expressly consented to the same;
(n) to respond to legal processes or to comply with or as required by any applicable law, governmental or regulatory requirements of any relevant jurisdiction, including, without limitation, meeting the requirements to make disclosure under the requirements of any law binding on us;
(o) to produce statistics and research for internal and statutory reporting and/or record-keeping requirements;
(p) to carry out due diligence or other screening activities (including, without limitation, background checks) in accordance with legal or regulatory obligations or our risk management procedures that may be required by law or that may have been put in place by us;
(q) to audit our Services or business;
(r) to prevent or investigate any actual or suspected violations of our terms of Service, fraud, unlawful activity, omission or misconduct, whether relating to your use of our Services or any other matter arising from your relationship with us, and whether or not there is any suspicion of the aforementioned;
(s) to store, host, back up (whether for disaster recovery or otherwise) of your personal data, whether within or outside of your jurisdiction; and
(t) any other purposes which we notify you of at the time of obtaining your consent.

(collectively, the “Purposes”).

6.2 You acknowledge, consent and agree that Refract may access, preserve and disclose your account information and content if required to do so by law or pursuant to an order of a court or by any governmental or regulatory authority having jurisdiction over Refract or in a good faith belief that such access preservation or disclosure is reasonably necessary to: (a) comply with legal process; (b) comply with a request from any governmental or regulatory authority having jurisdiction over Refract; (c) enforce the Refract terms of service or this Privacy Policy; (d) respond to any threatened or actual claims asserted against Refract or other claim that any content violates the rights of third parties; (e) respond to your requests for customer service; or (f) protect the rights, property or personal safety of Refract, its Users and/or the public.

6.3 As the purposes for which we will/may collect, use, disclose or process your personal data depend on the circumstances at hand, such purposes may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of the applicable data without your consent is permitted by the Privacy Laws.

7. How Does Refract Protect And Retain Customer Information?


7.1 All data is stored and secured by Microsoft through their provided authentication and authorisation mechanisms via the Microsoft Azure platform. The Azure portal is secured by Microsoft and requires user credentials to sign in. Likewise, Microsoft Azure Playfab is secured behind a login mechanism provided by Microsoft. There can be no guarantee of absolute security. We will not be responsible for the same in any way.

7.2 We will retain your personal data in accordance with the Privacy Laws and/or other applicable laws. In particular, we will destroy or anonymize your personal data when we have reasonably determined that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; (ii) retention is no longer necessary for any legal or business purposes; and (iii) no other legitimate interests warrant further retention of such personal data. If you cease using the App, or your permission to use the App and/or the Services is terminated or withdrawn for any reason whatsoever, we may continue storing, using and/or disclosing your personal data in accordance with this Privacy Policy and our obligations under the Privacy Laws. Subject to applicable law, we may also securely dispose of your personal data without prior notice to you.

8. Does Refract Disclose The Information It Collects From Its Users To Outside Parties?


8.1 In conducting our business, we will/may need to disclose your personal data to our third party service providers, agents and/or our affiliates or related corporations, and/or other third parties, whether sited in Singapore or outside of Singapore, for one or more of the above-stated Purposes. Such third party service providers, agents and/or affiliates or related corporations and/or other third parties would be processing your personal data either on our behalf or otherwise, for one or more of the above-stated Purposes.

Such third parties include, without limitation:
(a) our subsidiaries, affiliates and related corporations;
(b) other Users of our Platform for one or more of the above-stated Purposes;
(c) contractors, agents, service providers and other third parties we use to support our business. These include but are not limited to the Taekwondo Federation, and Rock Nano Global Pte Ltd which is our partner which provide customer support, product development, support and marketing; and
(d) third parties to whom disclosure by us is for one or more of the Purposes and such third parties would in turn be collecting and processing your personal data for one or more of the Purposes

8.2 This may require, among other things, share statistical and demographic information about the Users of our App and their use of the Services with suppliers of advertisements and programming.

8.3 For the avoidance of doubt, in the event that Privacy Laws or other applicable laws permit an organisation such as us to collect, use or disclose your personal data without your consent, such permission granted by the laws shall continue to apply.

8.4 You recognise that third parties may unlawfully intercept or access personal data transmitted to or contained within the App, technologies may malfunction or not work as anticipated, others may access, abuse or misuse information through no fault of ours. We will nevertheless deploy reasonable security arrangements to protect your personal data as required by the Privacy Laws. However, we do not in any circumstances guarantee absolute security. We shall not be liable for any unauthorised disclosure that may have arisen from malicious and sophisticated hacking.

9. Information Collected By Third Parties


We, and third parties, may from time to time make software applications available for your use on or through the Services. These applications may separately access, and allow a third party to view your identifiable information, such as your name, your user ID, your computer's IP Address or other information such as any cookies that you may previously have installed or that were installed for you by a third party software application or website. Additionally, these applications may ask you to provide additional information directly to third parties. For avoidance of doubt, the aforementioned third party products or services provided through these applications are not owned or controlled by Refract. You are encouraged to read the terms and other policies published by such third parties on their websites or otherwise. We are not responsible for the actions of such third parties in any way.

10. Disclaimer Regarding Security And Third-Party Sites


10.1 WE DO NOT GUARANTEE THE SECURITY OF PERSONAL DATA AND/OR OTHER INFORMATION THAT YOU PROVIDE ON THIRD-PARTY SITES. We have implemented a variety of security measures to maintain the safety of your personal data that is in our possession or under our control. Your personal data is contained within secure networks, and is only accessible by a limited number of personnel who have special access rights to such systems, and are required to keep the personal data confidential. When you access your personal data, we offer the use of a secure server. All personal data or sensitive information you supply is encrypted into our databases and only to be accessed by the personnel stated above.

10.2 In an attempt to provide you with a better user experience, we may choose various third-party websites to link to, and frame within the App. These linked sites have separate and independent privacy policies as well as security arrangements. Even if that the third party is affiliated with us, we have absolutely no control over these linked sites. Each of the said third parties have separate privacy and data collection practices independent of us. Data collected by our partners or third-party web sites (even if offered on or through our App) may not be received by us.

10.3 Accordingly, we bear no responsibility or liability for the content, security arrangements (or lack thereof) and activities of these said linked sites. These linked sites are only for your convenience and you access them at your own risk. Nonetheless, we seek to protect the integrity of our App and the links placed upon each of them and therefore welcome any feedback about these linked sites (including, without limitation, if a specific link does not work).

11. Will Refract Transfer Your Information Overseas?


Your personal data and/or information may be transferred to, stored or processed outside of your country. In most cases, your personal data will be processed in Singapore, where our servers are located and our central database operates. Refract will only transfer your information overseas in accordance with Privacy Laws.

12. How Can You Opt-out, Remove, Request Access To Or Correct Information You Have Provided To Us?


12.1 Withdrawing Consent
12.1.1 You may at any point in time withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control by sending an email to our Personal Data Protection Officer at support@refract.gg. We will process such requests in accordance with this Privacy Policy and our obligations under the Privacy Laws and any other applicable law. However, your withdrawal of consent may mean that we will not be able to continue providing the Services to you and we may need to terminate your existing relationship and/or the contract you have with us.

12.2 Requesting Access and/or Correction of Personal Data
12.2.1 If you have an account with us, you may personally access and/or correct your personal data currently in our possession or control through the App. If you do not have an account with us, you may request to access and/or correct your personal data currently in our possession or control by submitting a written request to us. We will require information as necessary from you in order to ascertain your identity as well as the nature of your request so as to be able to deal with your request. Please submit your written requests by emailing our Personal Data Protection Officer at support@refract.gg.
12.2.2 We may also charge you a reasonable fee for the handling and processing of your requests to access your personal data. If we do charge, we will provide you with a written estimate of the fees we will be charging. Please note that we are not required to respond to or deal with your access request unless you have agreed to pay the said fee.
12.2.3 We reserve the right to refuse to correct your personal data in accordance with the provisions as set out in Privacy Laws, where they require and/or entitle an organization to refuse to correct personal data in stated circumstances.

12.3 Complaints You may send complaints regarding our handling of personal data in the following ways:
- In writing to support@refract.gg.
- To our ACRA-registered address as the case may be

13. Contact Us


If you have any questions or concerns about this information, our privacy practices or your dealings with the Services, please do not hesitate to contact us by e-mail at support@refract.gg.

14. Governing Law


This Privacy Policy shall be governed in all respects by the laws of Singapore. You agree to submit to the exclusive jurisdiction of the Singapore courts

15. General


Your consent that is given pursuant to this Privacy Policy is additional to and does not supersede any other consent that you had provided to Refract with regard to processing of your personal data.

For the avoidance of doubt, in the event that Singapore personal data protection law permits an organisation such as us to collect, use or disclose your personal data without your consent, such permission

granted by the law shall continue to apply. The failure on our part to enforce any part of this Privacy Policy shall not constitute a waiver of any of our rights hereunder for past or future actions.