LIGHTSPEED STUDIOS Privacy

LIGHTSPEED STUDIOS Website
Privacy Policy

Last Updated: 17 March 2023

Thank you for using our products and services! We respect your concerns about privacy and appreciate your trust and confidence in us.

Please note that this privacy policy (“Privacy Policy”) only applies to www.lightspeed-studios.com (together with the sub-pages thereof and other webpages of LIGHTSPEED STUDIOS linked therein, the “Site”). If you use any other products or services, please refer to the privacy policy for that particular product or service.

If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, our contact information can be found here.

For the purpose of data protection laws, the data controller of your personal information in relation to the Site services is Proxima Beta Pte. Limited.

SUMMARY

Here is a summary of the information contained in this Privacy Policy. You can find more detail by clicking ‘More Information’.

What information do we need to be able to provide the Site services? • We use use cookies and other similar technologies to collect information about you when you use the Site, including your standard internet log information and details of visitor behaviour patterns. More Information.
How will we use your information? • We use the information collected through the cookies and similar technologies to find out things such as the number of visitors to the various parts of the Site, to maintain and monitor the performance of the Site and to improve the Site and the services it offers to our visitors. More Information.
Who do we share your information with?

• We use third party service providers and work with our affiliates to help us deliver the best possible experience.

• All third party service providers providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose except where strictly necessary for the Site services (i.e., to fulfil the purpose(s) described above).

• In some cases we may be required by a court or be under a legal obligation (such as a valid search warrant or subpoena) to disclose certain information.

More Information.
Where do we process your information?

• Pursuant to our contract with you, we may transfer data outside of the location in which you are based for the purposes described in this Privacy Policy.

• We have servers for the Site services in Singapore. We also have support, engineering and other teams who may support the Site services, including from Singapore.

• For UK users, transfers between our affiliates and to third parties use applicable safeguards, such as incorporating standard contractual clauses, obtaining your consent first or taking into account adequacy assessments.

More Information.
How long do we keep your information?

• Unless otherwise required or permissible by applicable laws, we only retain your information for 2 months. We then delete or anonymise such data, in accordance with applicable laws.

More Information.
How can I exercise my rights over my information?

• Certain jurisdictions offer users specific rights with respect to their information, so you may have a right to access or receive a copy of your data, or to delete your data or restrict or object to our processing of your data.

More Information.
How will we notify you of changes?

• Changes to this Privacy Policy will be posted here. We will also notify you of changes in accordance with relevant legal requirements.

More Information.

Welcome to the LIGHTSPEED STUDIOS Website!

This Privacy Policy explains the when, how and why when it comes to the processing of your personal information in connection with your access to www.lightspeed-studios.com (together with the sub-pages thereof and other webpages of LIGHTSPEED STUDIOS linked therein, the “Site”), and sets out your choices and rights in relation to that information. Please read it carefully – it will allow you to understand how we collect and use your information, and how you can control it.

Please note that this Privacy Policy only applies to the Site services. If you use any other products or services please refer to the privacy policy for that particular product or service.

If you do not agree to the processing of your personal information in the way this Privacy Policy describes, please do not provide your information when requested and stop using the Site services. By using the Site services you are acknowledging how we process your personal information as described in this Privacy Policy.

For the purpose of data protection laws, the data controller of your personal information in relation to the Site services is Proxima Beta Pte. Limited (“we”, “us”, “our”).

If you have any questions about anything in this Privacy Policy, or want to exercise any rights you may have, our contact information can be found here. You can also reach out to our data protection officer at dpo_lqstudios@proximabeta.com. Our UK representative for data protection purposes is listed here.

1. Cookies

We use cookies and other similar technologies (“Cookies”) to enhance your experience using the Site services. Cookies are small files which, when placed on your device, enable us to provide certain features and functionalities. For more information about our Cookies policy, click here.

2. Children

Children must not use the Site services for any purpose, except where their parent or guardian has provided lawful consent (to the extent this option is available in your jurisdiction).

By children, we mean users under the age of 18 years old; or in the case of a region where the minimum age for processing personal information differs, such different age. For users located in certain regions we have listed the relevant minimum age as of the date of this policy in the table below. You should in any case refer to the laws in your jurisdiction to ensure you are above the relevant legal minimum age.

Other than as provided above, we do not knowingly collect personal information from children under these ages for any purpose. If you believe that we have personal information of a child under these ages without lawful consent, or if you are the parent or guardian of the user and wish to withdraw consent, please contact us.

Region in which the user is located Minimum age of the user
Singapore 13
United Kingdom 13 13
Region in which the user is located 13

3. How We Process Your Personal Information

This section provides more detail on the types of personal information we collect from you, and why.

For users who live in the United Kingdom, it also identifies the legal basis under which we process your data.

Personal Information Use Legal Basis (where applicable)
Cookies information (collected via Google Analytics) including the following:

• Your browsing behaviour while using the Site, including time on the Site (the total time spent on the Site; the time spent on each page and in what order the pages were visited), what internal links were clicked (based on the URL of the next pageview)

• User agent string

• Initial page inspection

• Geographic location

• Operating system information

• Browser information

• Device information including screen size

• Referring site

• Whether Java or Flash is installed

• IP Address

To maintain and monitor the performance of the Site and to improve the Site and the services it offers to our visitors.

Please refer to our Cookies Policy here for more details.

We use a cookies banner on the Site to gain consent for the optional cookies we use.

4. How We Store and Share Your Personal Information

Pursuant to our contract with you, we may transfer data outside of the location in which you are based for the purposes described in this Privacy Policy.

We have servers for the Site services in Singapore. We also have support, engineering and other teams who may support the Site services, including from Singapore.

For UK users, transfers between our affiliates and to third parties use applicable safeguards, such as incorporating standard contractual clauses, obtaining your consent first or taking into account adequacy assessments.

We use a third-party service, Google Analytics, to collect the above information and we share your information with them. You may find more information on how Google Analytics processes and safeguards data here.

Only where necessary will we share your personal information with third parties. Situations where this occur are:

• Third parties that provide services in support of the Site services. All third party service providers providing services for us are prohibited from retaining, using, or disclosing your personal information for any purpose except where strictly necessary for the Service (i.e., for the purpose(s) described above).

• Companies within our corporate group who process your personal information solely for the purpose of providing the Site services to you. All such group companies may only use your personal information in accordance with this Privacy Policy.

• Regulators, judicial authorities and law enforcement agencies. There are circumstances in which we may be legally required to disclose information about you, such as to comply with legal obligations or processes. In complying with the terms of valid legal processes, such as a subpoena, or search warrant, unfortunately we may not be able to seek your consent to or notify you in advance of such disclosure.

• Third parties to ensure safety, security, or compliance with laws. We may disclose your information to:
    o enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;
    o detect, prevent or otherwise address security, fraud or technical issues; or
    o protect the rights, property or safety of us, our users, a third party or the public as required or permitted by law.

• A third party that acquires all or substantially all of us or our business. We may also disclose your information to third parties if we either: (a) sell, transfer, merge, consolidate or re-organise any part(s) of our business, or merge with, acquire or form a joint venture with, any other business, in which case we may disclose your data to any prospective buyer, new owner, or other third party involved in such change to our business; or (b) sell or transfer any of our assets, in which case the information we hold about you may be sold as part of those assets and may be transferred to any prospective buyer, new owner, or other third party involved in such sale or transfer.

5. The Security of Your Personal Information

We have information security and access policies that limit access to our systems and technology, and we protect data through the use of technological protection measures such as encryption.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will implement and maintain reasonable measures to protect your personal information, we cannot guarantee the security of the information transmitted through the Site services or otherwise via the Internet; any transmission is at your own risk.

6. Data Retention

We do not keep your data for longer than is necessary to fulfil the relevant purpose described above unless we are required or permitted to do so under law. If we retain your information beyond the retention periods set out below, for example to comply with applicable laws, we will store it separately from other types of personal information.

For further details on how long we keep your data, please refer to the time periods set out below

Personal Information Retention Policy
Cookies information (collected via Google Analytics) 2 months. Please refer to our Cookies Policy here for more details.

7. Your Rights

Some jurisdictions’ laws grant specific rights to users of the Site services. Please refer to the Supplemental Jurisdiction-Specific Terms, or the applicable laws in your jurisdiction, for an overview of specific rights that apply to persons subject to data protection laws in the listed jurisdictions and how these can be exercised.

You may have certain rights in relation to the personal information we hold about you. Some of these only apply in certain circumstances (as set out in more detail below). To exercise any of your rights, please contact us.

Access

You may have the right to access personal information we hold about you, how we use it, and who we share it with. You can access the personal information you have made available to us by contacting us at dpo_lqstudios@proximabeta.com.

Portability

You may have the right to receive a copy of certain personal information we process about you. For example, in certain jurisdictions this can comprise personal information we process on the basis of your consent or pursuant to our contract with you, as described above in the section “How We Process Your Personal Information”. We will provide further information to you about transferring this data if you make such a request.

Correction

You may have the right to correct personal information we hold that is inaccurate. f you believe we hold any personal information about you and that information is inaccurate, please contact us at dpo_lqstudios@proximabeta.com.

Erasure

You can request that we delete your personal information by contacting us at . We may need to retain personal information if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or freedom of expression) but we will let you know if that is the case.

Restriction of Processing to Storage Only

You may have a right to require that we stop processing the personal information we hold about you (other than for storage purposes in certain circumstances). Please note, however, that if we stop processing the personal information, we may use it again if there are valid grounds under data protection laws for us to do so (for example, for the defence of legal claims or for another’s protection). Where we agree to stop processing the personal information, we will take steps to tell any third party to whom we have disclosed the relevant personal information so that they can stop processing it too.

Objection

You may have the right to object to our processing of your personal information. If you wish to do so, please contact us at dpo_lqstudios@proximabeta.com or using the contact details set out below, and we will consider your request.

Consent Withdrawal

To the extent provided by applicable laws and regulations, you may withdraw consent you previously provided to us for certain processing activities by contacting us at dpo_lqstudios@proximabeta.com. Where consent is required to process your personal information, if you do not consent to the processing or if you withdraw your consent we may not be able to deliver the expected service. Please note that the right to withdraw consent is only available if the legal basis for processing information is consent.

8. Contact

Please get in touch with us if you have any questions. You can reach us in the first instance at:

Email: dpo_lqstudios@proximabeta.com

Mailing Address:
                         LIGHTSPEED STUDIOS Data Protection Team
                         30 Raffles Place #19-01
                         Singapore
                         048622

We will endeavour to deal with your request as soon as possible. This is without prejudice to any right you may have to launch a claim with a data protection authority in the region in which you live or work where you think we have infringed data protection laws.

9. Changes

If we make any changes to this Privacy Policy, we will post the updated Privacy Policy here and notify you in accordance with relevant legal requirements.

Our Representative in the United Kingdom

Representative Address Contact details
Image Frame Investment (UK) Limited Suite 1, 3rd Floor 11 - 12 St. James's Square, London, United Kingdom, SW1Y 4LB dpo_lqstudios@proximabeta.com

SUPPLEMENTAL TERMS – JURISDICTION-SPECIFIC

Some jurisdictions’ laws contain additional terms for users of the Site services, which are set out in this section. If you are a user located in one of the jurisdictions below, the terms set out below under the name of your jurisdiction apply to you in addition to the terms set out in our Privacy Policy above.

California

This section applies to California residents covered by the California Consumer Privacy Act of 2018 (as amended by the California Privacy Rights Act of 2020) (“CCPA”). For purposes of this section, “personal information” and “sensitive personal information” have the meanings given in the CCPA and do not include information excluded from the CCPA’s scope.

Collection and Disclosure of Personal Information

Over the past 12 months, we have collected and disclosed for a business purpose the following categories of personal information from or about you or your device:
    • Cookies information (collected via Google Analytics cookies) such as standard internet log information and details of visitor behaviour patterns, browser information, operating system information, your browsing behaviour while using the Site and information about your device.

We collect your personal information for the following purposes:     • To maintain and monitor the performance of the Site and to improve the Site and the services it offers to our visitors.

For additional information about what each type of personal information is used for, see Section 3 (How We Process Your Personal Information)

We disclose personal information to the following types of entities:
    • Google Analytics, a third-party service, that collects the above information.
    • Other companies within our corporate group who process your personal information in order to operate the Site services.
    • Other companies that provide services on our behalf in support of the Site services and who are prohibited by contract from retaining,        using, or disclosing personal information for any purpose other than for providing their services to us.
    • Regulators, judicial authorities and law enforcement agencies.
    • Entities that acquire all or substantially all of our business.

In the past 12 months, we have not sold or shared personal information of California residents within the meaning of “sold” or “share” in the CCPA, and we have no knowledge of any sale or sharing of personal information of users under 16 years of age.

In addition, we do not use or disclose sensitive personal information about you.

Retention of Your Personal Information

For detailed information about the retention period for the data collected, see this chart in the main portion of the Privacy Policy.

Rights under the CCPA

If you are a California resident and the CCPA does not recognize an exception that applies to you or your personal information, you have the right to:
    • Request we disclose to you free of charge the following information covering the 12 months         preceding your request:
            o the categories of personal information about you that we collected;
            o the categories of sources from which the personal information was collected;
            o the purpose for collecting personal information about you;
            o the categories of third parties to whom we disclosed personal information about you and the categories of personal information that                was disclosed (if applicable) and the purpose for disclosing the personal information about you; and
            o the specific pieces of personal information we collected about you;
    • Request we delete personal information we collected from you, unless CCPA recognises an exception;
    • Request we correct inaccurate personal information that we maintain about you; and
    • Be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or denying goods or       services to you when you exercise your rights under the CCPA.

We aim to fulfil all verified requests within 45 days pursuant to the CCPA. If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay.

How to Exercise Your Rights

If you are a California resident to whom the CCPA applies, you may also exercise your rights, if any, regarding your personal information by contacting us as specified in Section 8 (Contact).

Singapore

You consent to the cross-border transfer of your information to any country where we have databases or affiliates and, in particular, the locations specified in Section 4 (How We Store and Share Your Personal Information) when you use the Site services.

You have the right to access your personal information, how we use it, and who we share it with. You have the right to correct any of your personal information that is inaccurate.

Our designated data protection officer for the purposes of compliance with the Personal Data Protection Act 2012 can be contacted as set out in Section 8 (Contact).

Virginia

This section applies to Virginia residents covered by the Virginia Consumer Data Protection Act (“VCDPA”). For purposes of this section, “personal data” and “sensitive personal data” have the meanings given in the VCDPA and do not include information excluded from the VCDPA’s scope.

If you are a Virginia resident and the law does not recognize an exception that applies to you or your personal data, you have the right to:
    • request that we disclose to you the personal data that we collect, use, or disclose, and information about our data practices;
    • request we delete personal data we collected from you, unless the law recognises an exception;
    • request we correct inaccurate personal data that we maintain about you;
    • be free from unlawful discrimination for exercising your rights including providing a different level or quality of services or denying goods or        services to you when you exercise your rights under the law.

We do not collect sensitive personal data about you. We also do not process personal data for purposes of (i) targeted advertising, (ii) the sale of personal data, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning the consumer.

How to Exercise Your Rights

If you are a Virginia resident to whom the VCDPA applies, you may exercise your rights, if any, regarding your personal data by contacting us at dpo_lqstudios@proximabeta.com.

How to Appeal Decision on Your Request

If you would like to appeal a decision on your request to exercise any right you have under the VCDPA, you may contact us at dpo_lqstudios@proximabeta.com.

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