Privacy Policy

Effective Date: [22 July 2019]

SILOAM TECHNOLOGIES PTE LTD (“Siloam”) is the legal and beneficial owner of the software programme and App “Overwrite” (hereinafter referred to as “Overwrite”). Overwrite is a platform that provides content contributors an avenue to interact with their crowd and to provide users with questions and learning materials while understanding their strengths and weaknesses. In using our product and services (collectively referred to as “we”, “us”, “Overwrite”, “Overwrite platform”), information is entrusted to us and we want to make our intentions and processes, and your options, as transparent and easily accessible as possible in clear and plain language. Our Privacy Policy will help you understand what information we collect, how it is used and the choices you have as a user.

Overwrite provides a platform for users in any capacity to post content including but not limited to questions, learning materials, comments, information and any other materials that contribute to user experience on Overwrite.

Depending on the discretion of your interactions with us and other users of the Overwrite platform, this Content may be publicly available, visible to and shareable by other users on the platform in accordance with the terms and conditions of this Privacy Policy and our Terms of Service (Terms of Service or EULA whichever is applicable). Our Policy applies to users of Overwrite in every capacity.

We will explain the following:

  • What information we collect and why we do so
  • How that information is used
  • Your options in accessing and managing that information

User Roles

If you join Overwrite as a Content Contributor and/or create a User account, or if you are a Content Contributor by virtue of providing Content to Overwrite. You are a “User”, as further described in the Terms of Service and EULA (whichever is applicable). If you are using Overwrite by (explicit and implicit*) invitation of an Administrator – regardless of whether the Administrator is your employer, another organization, or an individual – that Administrator will determine any additional policies regarding storage, access, modification, deletion, sharing, and retention of user data which applies to your use of Overwrite. *Implicit invitation refers to an Administrator publishing his organisations’ project(s) publicly, allowing any User to access and join the Project(s).

We follow the “what’s yours is yours” guideline, where the creator of the intellectual property owns their own content. This means that you retain all your ownership rights in any Content you upload onto the Overwrite platform.

You license to SILOAM for an indefinite period all patent, trademarks, trade secret, copyright or other proprietary rights in and to such Content for publication on the Overwrite platform.

You grant SILOAM a worldwide, non-exclusive, royalty-free, sub-licensable and transferable license to anonymize, use, prepare derivative works of and display the Content in connection with the Overwrite platform and SILOAM’s (and its successors’ and affiliates’) business, including without limitation for promoting and redistributing part or all of the Overwrite platform (and derivative works thereof) in any media formats and through any media channels.

The above licenses granted by you in Content will terminate within a commercially reasonable time after you remove or delete your Content from Overwrite.

You are required to report personal data breaches to the Supervisory Authority or Administrator or Data Protection Officer no later than 72 hours after becoming aware of any data breach.

You understand and agree that Overwrite may retain, remove, or delete Content, but not display or use Content for purposes other than analytics and internal research.

The above permissions do not apply to Personal Data. Overwrite will not use Personal Data under any circumstances for preparing derivative works or for any purposes other than what has been expressed. Upon your request for deletion, Overwrite will not retain any Personal Data for any purposes.

Information we collect

Content and Personal Data

1. Content

Content and information submitted by Content Contributors to Overwrite are referred to in this policy as “Content”. Users of the Content are referred to as the “User(s)” and in the context of an organisation through an Administrator. Here are some examples of Content: any data and content created, uploaded, posted, shared or otherwise made available by Content Contributors through the Overwrite platform, and any data and content by Content Contributors and Users including text, photos, sounds, music, videos, audiovisual combinations, interactive features, profile information and anything else entered or uploaded onto Overwrite.

2. Personal Data

During the creation of an account, Overwrite collects your name, email address, country, date of birth, gender, phone number and choice of domain. This information is used for evaluating your interaction with the Overwrite platform, such as log information and device information. In addition, we collate this data to compute participation rates on the Overwrite platform as a whole. As a User, there may be projects in which Content Contributors request for Personal Data. Content Contributors are required to adhere to our Privacy Policy and take the same measures in protecting Personal Data of their Users as Overwrite would its users. That said, we always encourage due diligence before divulging Personal Data in any form, especially so on the Overwrite platform where content is created independently by registered Content Contributors. Other than email services pertaining to the functionality of the Overwrite platform, Overwrite will not use your email address to send you marketing collaterals, promotions or corporate communications unless you have expressly agreed to receive such material. Here is a breakdown of the data points collected on how we use this information: § Account creation information. Users provide information such as an email address and password to create an account. If you sign up via social media such as Facebook Connect, Google+ and LinkedIn, you explicitly grant Overwrite access to any information you make public on your social media profile. Some of this collected user information may be publicly listed on Overwrite. This information is used for account creation and authentication on the Overwrite
platform. Additionally, names and email addresses may be accessible and downloadable to Administrators of Projects you have joined. § Billing and other information. For Content Contributors and/or Users who provide or purchase Content on Overwrite, our corporate affiliates and third-party payment processors may collect and store your billing address and credit card information on our behalf. Our payment gateway is powered by Stripe Connect. This information is strictly used for billing purposes only. § Services usage information. This is information about how you are accessing and using Overwrite, which may include administrative and support communications with us and information about the projects, people, features, content, links you interact with, and third-party integrations you use (if any). This information is used for internal evaluation on platform interaction patterns, engagement rates and analytics. This may also be used by Overwrite for research and development on the Overwrite product. In the event third parties are involved, all data points are anonymized and aggregated to protect your privacy. § Contact information. With your permission, any contact information you choose to upload is collected when using the Overwrite platform. This information is used only for communications between Overwrite and you, and will not be used as a channel for marketing and corporate communications unless you have consented to being to receiving such communications. This information is accessible by Overwrite and Administrators of Projects you have joined in which you provided this information. § Log data. When you use Overwrite, our servers automatically record information, including information that your browser sends whenever you visit a website or your mobile app sends when you are using it. This log data may include your Internet Protocol address, the address of the web page you visited before using Overwrite, your browser type and settings, the date and time of your use of Overwrite, information about your browser configuration and plug-ins, language preferences, and cookie data. This information is primarily used for internal purposes, such as establishing usage patterns, troubleshooting, interaction patterns and product development. This information may be shared with third parties to facilitate co-development or troubleshooting. In the event third parties are involved, all data points are anonymized and aggregated to protect your privacy. § Device information. We may collect information about the device you are using Overwrite on, including what type of device it is, what operating system you are using, device settings, application IDs, unique device identifiers, and crash data. Whether we collect some or all of this information often depends on what type of device you are using and its settings. This information is primarily used for internal purposes, such as establishing usage patterns, troubleshooting, interaction patterns and product development. This information may be shared with third parties to facilitate co-development or troubleshooting. In the event third parties are involved, all data points are anonymized and aggregated to protect your privacy. § Geo-location information. Precise GPS location from mobile devices is collected only with your permission. WiFi and IP addresses received from your browser or device may be used to determine approximate location. This information is used to enable certain functionalities of the Overwrite platform. This information is also used for internal purposes, such as establishing usage patterns, troubleshooting, interaction patterns and product development. This information may be shared with third-parties to facilitate co-development or troubleshooting. In the event third parties are involved, all data points are anonymized and aggregated to protect your privacy. § Services integrations. If, when using Overwrite, you integrate with a third-party service, we will connect that service to ours. The third-party provider of the integration may share certain information about your account with Overwrite. However, we do not receive or store your passwords for any of these third-party services. § Third-party data. Overwrite may also receive information from affiliates in our corporate group, our partners, or others that we use to improve Overwrite. This might be aggregate level information, such as which IP addresses go with which zip codes, or it might be more specific information, such as the performance of an online marketing or email campaign.

Our Cookie Policy Overwrite uses cookies and similar technologies, such as single-pixel gifs and web beacons, to record log data. We use both session-based and persistent cookies. Cookies are small text files sent by us to your computer or mobile device, and from your computer or mobile device to us each time you visit our website or use our desktop application. They are unique to your account or your browser. Session-based cookies last only while your browser is open and are automatically deleted when you close your browser. Persistent cookies last until you or your browser deletes them or until they expire. Some cookies are associated with your account and personal information in order to remember that you are logged in and which projects you are a part of. Other cookies are not tied to your account but are unique and allow us to carry out site analytics and customization, among other similar things. If you access Overwrite through your browser, you can manage your cookie settings there. However, if you disable some or all cookies, the Overwrite platform may not function as intended. Overwrite sets and reaches out to our own cookies on the domains operated by Overwrite and its corporate affiliates. In addition, we use third parties including but not limited to Fabric for website analytics. You may opt out of third-party cookies from these services by visiting their websites. We do not currently recognize or respond to browser-initiated Do Not Track signals as there is no consistent industry standard for compliance.

How we use your information We use your information to provide and improve Overwrite and the Overwrite platform. Content Overwrite may access and use Content as reasonably to: § provide, maintain and improve Overwrite; § prevent or address service, security, technical issues or at a Content Contributor, an Administrator’s or User’s request in connection with customer support matters; § comply with the law Other information We use other kinds of information in providing Overwrite, specifically: § To understand and improve Overwrite. We carry out research and analyze trends to better understand how users are interacting with Overwrite and improve on feedback. § To communicate with you by: 1. Responding to your requests. If you contact us with a problem or question, we will use your information to respond. 2. Sending emails and Overwrite-related messages. We may send you emails and messages as necessary for the full functionality and performance of the Overwrite platform as intended. We may also contact you to inform you about changes in the Overwrite platform,
Overwrite offerings, and important Overwrite-related notices, such as security and fraud notices. These emails and messages are considered part of the Overwrite platform. § Billing and account management. We use account data to administer accounts and keep track of billing and payments. This information is also used to communicate with you for invoicing and payment matters. § Marketing and corporate communications. We may need to contact you for marketing and corporate communications such as product updates, new offerings and promotions. Upon your explicit consent, we may also use your information to send marketing collaterals or for advertising purposes. You can also opt out of these at any time. § Security and keeping your information safe. We work hard to keep the Overwrite platform secure and to prevent abuse and fraud. From time to time, your information may be accessed by personnel of Overwrite to facilitate this process.

Your choices Content Administrators may control your access to the Overwrite platform, enable or disable third-party integrations, vote, share, and moderate User Completions and User Comments and these choices and instructions may result in the access, use, disclosure, modification, or deletion of certain or all Content. Invitations to the Overwrite Platform When an Administrator (usually for corporate Users) invites someone to join the Overwrite platform through a project, the Administrator’s name may will be disclosed in the invitation message sent to the email address of the invited individual. This information is necessary to ensure the invitee knows who has contacted them, and to ensure that the invitee knows the invitation has been sent by a trusted person in order to make an informed decision to join the Project. Deleting of Personal Information At any given time, if you do not wish to share your information, you may delete your account by: § Contacting our Data Protection Officer at admin@myoverwrite.com You will be required to specify the email address registered to your account, full name, and any additional information to facilitate identification and deletion of your Personal Data. Our Data Protection Officer will contact you regarding your request. By deleting your account, all personal information associated with your profile including but not limited to name, address, phone number, credit card details will be permanently deleted, without undue delay. However, you may indicate that you wish to remain in our mailing list by email, as Overwrite is constantly updating interesting and stimulating Content and offering new and improved product recommendations.

Other information If you have any questions about your information, our use of this information, your rights or anything pertaining to your data and how its managed, reach out to us at admin@myoverwrite.com

Other Choices In addition, the browser you use may provide you with the ability to control cookies or other types of local data storage. Your mobile device may provide you with choices around how and whether location or other data is collected and shared. Overwrite does not control these choices, or default settings, which are offered by makers of your browser or mobile device operating system.

Sharing and Disclosure There are times when information described in this Privacy Policy may be shared by Overwrite. This section discusses only how Overwrite may share such information. While Overwrite holds Content Contributors and Administrators to the same standards of data protection as we do, Overwrite does not control how Content Contributors and/or Administrators or their third parties choose to share or disclose Content. We will not share this data with anyone unless you explicitly consent to us doing so. We respect your rights to privacy and will comply with your wishes to remove your data from our systems if so required. Based on the information you provide to us, we may create or append other information to your profile in the interest of better serving you (for example, your interests). As is the case with all data we collect, this will be kept private and for our business purposes only.

Content Overwrite may share anonymized and collected Content with parties including: § Third-party service providers and agents. We may engage third-party companies or individuals such as consultancies or training providers to process Content. § Third-party integrations. Overwrite may, on an Administrator’s behalf, share Content with the provider of an integration added by the Administrator. Overwrite is not responsible for how the provider of an integration may collect, use, and share Content as this is subject to the privacy policies of those providers.

Other information Overwrite may share other information as follows: § About Users with the Content Contributor Administrator. There may be times when you, as a User, will contact Overwrite to help resolve an issue specific to a project you have joined. In order to help resolve the issue, we may anonymize and share your concerns with the related
Content Contributor and/or Administrator(s). Alternatively, we may advise you to contact the Content Contributor and/or Administrator(s) directly. § With third-party service providers and agents. We may engage third-party companies or individuals, such as third-party payment processors, to process information on our behalf. Any Personal Data that is being shared with third-party service providers and/or agents is clearly communicated to you through our Privacy Policy and will not be used for purposes other than what has been expressed. § With affiliates. We may engage affiliates in our corporate group to process other information. All Personal Data will be anonymized and aggregated.

Other types of disclosure Overwrite may share or disclose Content and Personal Data as follows: § During changes to our business structure. This includes but is not limited to a merger, acquisition, bankruptcy, dissolution, reorganization, sale of some or all of SILOAM’s assets, financing, acquisition of all or a portion of our business, a similar transaction or proceeding, or steps in contemplation of such activities (e.g. due diligence). In such an event, we will contact you and inform you of the impending data transfer and we will provide a reasonable timeframe for you to withdraw your Personal Data should you wish to do so. § To comply with laws. To comply with legal or regulatory requirements and to respond to lawful requests, court orders and legal proceedings. § To enforce the rights of all stakeholders, prevent fraud and for safety. To protect and defend the rights, property, or safety of Overwrite, our users or third-parties, including enforcing contracts or policies, or in connection with investigating and preventing fraud.
We may occasionally disclose or use anonymized and aggregated information; for instance, information may be shared with our partners or affiliates for business or research purposes involving data points, or partnering with research firm or academics to explore questions about enhancing Overwrite and its potential.

Security, Accountability and Governance We take various steps to protect information you provide to us from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the information we collect, process and store, and the current state of technology. You shall maintain a written record of processing activities carried out. Overwrite implement appropriate measures to:- • ensure that only personal data that is necessary for the specific purpose is processed; • an assessment of the impact of processing on the protection of personal data in certain circumstances (particularly new technologies) is likely to result in high risk to the rights and freedom of individuals; and • appoint / designate a Data Protection Officer if required, to monitor, review and assess your data processing procedures, aiming to minimize date processing and retention of data, and building in safeguards. Our Data Protection Officer shall notify you on becoming aware of any personal data breach without undue delay.

External Websites Overwrite does not take any responsibility for the content and privacy policies of any external website linked through the Overwrite platform. We advise you to click on any external links at your own discretion and to take note of the privacy policies on such external websites to protect yourself.

Data Breach Notification In the case of a personal date breach, the User must:- a) Notify Us and/or the Administrator without undue delay, but not later than 72 hours where feasible; and
b) Notify the individual without undue delay, if the personal data breach is likely to result in a high risk to the rights of the User, in appropriate circumstances.

Changes to this Privacy Policy We may change this policy from time to time and if we do, we will post any changes on this page and in certain circumstances, a notification will be made available to you informing you of the changes. If you continue to use the Overwrite platform after those changes are in effect, you agree to the revised policy.

Amendments to Personal Data Protection Policy Our use of your personal information will always be governed by the latest version of this Privacy Policy, which will always be made accessible to you. By continuing to access or utilize the Overwrite platform following these changes, you agree to be bound by the revised Privacy Policy.

Contacting Overwrite Please feel free to contact us if you have any questions about SILOAM’s Privacy Policy. You may contact us at admin@myoverwrite.com. -The Overwrite Team