Privacy Policy of （PCLL)  
This Application collects some Personal Data from its Users.  
This document can be printed for reference by using the print command in the settings of any  
browser.  
Owner and Data Controller  
PCLL Technology Pte. Ltd. - 37 Rama9 Huai Khwang Huai Khwang Bangkok 10310  
Owner contact email: support@PCLL.com.sg  
Types of Data collected  
Notice: Your email and phone number are required to use this APP.  
Among the types of Personal Data that this Application collects, by itself or through third parties,  
there are: Tracker; unique device identifiers for advertising (Google Advertiser ID or IDFA, for  
example); device information; geography/region; number of Users ; number of sessions; session  
duration; Application opens; launches; operating systems; email address; Usage Data; Universally  
unique identifier (UUID); Data communicated while using the service; payment info; first name; last  
name; billing address; phone number; password; social media accounts ; geographic position;  
Precise location permission (continuous); Precise location permission (non-continuous);  
Approximate location permission (continuous); Approximate location permission (non-continuous);  
Camera permission, without saving or recording; shipping address.  
Complete details on each type of Personal Data collected are provided in the dedicated sections of  
this privacy policy or by specific explanation texts displayed prior to the Data collection.  
Personal Data may be freely provided by the User, or, in case of Usage Data, collected automatically  
when using this Application.  
Unless specified otherwise, all Data requested by this Application is mandatory and failure to  
provide this Data may make it impossible for this Application to provide its services. In cases where  
this Application specifically states that some Data is not mandatory, Users are free not to  
communicate this Data without consequences to the availability or the functioning of the Service.  
Users who are uncertain about which Personal Data is mandatory are welcome to contact the  
Owner.  
Any use of Cookies – or of other tracking tools – by this Application or by the owners of third-party  
services used by this Application serves the purpose of providing the Service required by the User, in  
addition to any other purposes described in the present document and in the Cookie Policy, if  
available.  
Users are responsible for any third-party Personal Data obtained, published or shared through this  
Application and confirm that they have the third party's consent to provide the Data to the Owner.  
Mode and place of processing the Data  
Methods of processing  
The Owner takes appropriate security measures to prevent unauthorised access, disclosure,  
modification, or unauthorised destruction of the Data.  
The Data processing is carried out using computers and/or IT enabled tools, following organisational  
procedures and modes strictly related to the purposes indicated. In addition to the Owner, in some  
cases, the Data may be accessible to certain types of persons in charge, involved with the operation  
of this Application (administration, sales, marketing, legal, system administration) or external parties  
(such as third-party technical service providers, mail carriers, hosting providers, IT companies,  
communications agencies) appointed, if necessary, as Data Processors by the Owner. The updated  
list of these parties may be requested from the Owner at any time.  
Legal basis of processing  
The Owner may process Personal Data relating to Users if one of the following applies:  
Users have given their consent for one or more specific purposes;  
provision of Data is necessary for the performance of an agreement with the User and/or for  
any pre-contractual obligations thereof;  
processing is necessary for compliance with a legal obligation to which the Owner is subject;  
processing is related to a task that is carried out in the public interest or in the exercise of  
official authority vested in the Owner;  
processing is necessary for the purposes of the legitimate interests pursued by the Owner or  
by a third party.  
In any case, the Owner will gladly help to clarify the specific legal basis that applies to the processing,  
and in particular whether the provision of Personal Data is a statutory or contractual requirement, or  
a requirement necessary to enter into a contract.  
Place  
The Data is processed at the Owner's operating offices and in any other places where the parties  
involved in the processing are located.  
Depending on the User's location, data transfers may involve transferring the User's Data to a  
country other than their own. To find out more about the place of processing of such transferred  
Data, Users can check the section containing details about the processing of Personal Data.  
Users are also entitled to learn about the legal basis of Data transfers to a country outside Singapore  
or to any international organisation governed by public international law or set up by two or more  
countries, such as the UN, and about the security measures taken by the Owner to safeguard their  
Data.  
If any such transfer takes place, Users can find out more by checking the relevant sections of this  
document or enquire with the Owner using the information provided in the contact section.  
Retention time  
Personal Data shall be processed and stored for as long as required by the purpose they have been  
collected for.  
Therefore:  
Personal Data collected for purposes related to the performance of a contract between the  
Owner and the User shall be retained until such contract has been fully performed.  
Personal Data collected for the purposes of the Owner’s legitimate interests shall be  
retained as long as needed to fulfill such purposes. Users may find specific information  
regarding the legitimate interests pursued by the Owner within the relevant sections of this  
document or by contacting the Owner.  
The Owner may be allowed to retain Personal Data for a longer period whenever the User has given  
consent to such processing, as long as such consent is not withdrawn. Furthermore, the Owner may  
be obliged to retain Personal Data for a longer period whenever required to do so for the  
performance of a legal obligation or upon order of an authority.  
Once the retention period expires, Personal Data shall be deleted. Therefore, the right of access, the  
right to erasure, the right to rectification and the right to data portability cannot be enforced after  
expiration of the retention period.  
The purposes of processing  
The Data concerning the User is collected to allow the Owner to provide its Service, comply with its  
legal obligations, respond to enforcement requests, protect its rights and interests (or those of its  
Users or third parties), detect any malicious or fraudulent activity, as well as the following: Analytics,  
User database management, Handling payments, Registration and authentication, Content  
performance and features testing (A/B testing), Social features, Managing contacts and sending  
messages, Infrastructure monitoring, Location-based interactions, Device permissions for Personal  
Data access, Hosting and backend infrastructure, Platform services and hosting, Managing support  
and contact requests and Location processing.  
For specific information about the Personal Data used for each purpose, the User may refer to the  
section “Detailed information on the processing of Personal Data”.  
Device permissions for Personal Data access  
Depending on the User's specific device, this Application may request certain permissions that allow  
it to access the User's device Data as described below.  
By default, these permissions must be granted by the User before the respective information can be  
accessed. Once the permission has been given, it can be revoked by the User at any time. In order to  
revoke these permissions, Users may refer to the device settings or contact the Owner for support at  
the contact details provided in the present document.  
The exact procedure for controlling app permissions may be dependant on the User's device and  
software.  
Please note that the revoking of such permissions might impact the proper functioning of this  
Application.  
If User grants any of the permissions listed below, the respective Personal Data may be processed  
(i.e accessed to, modified or removed) by this Application.  
Approximate location permission (continuous)  
Used for accessing the User's approximate device location. This Application may collect, use, and  
share User location Data in order to provide location-based services.  
Approximate location permission (non-continuous)  
Used for accessing the User's approximate device location. This Application may collect, use, and  
share User location Data in order to provide location-based services.  
The geographic location of the User is determined in a manner that isn't continuous. This means that  
it is impossible for this Application to derive the approximate position of the User on a continuous  
basis.  
Camera permission, without saving or recording  
Used for accessing the camera or capturing images and video from the device.  
This Application does not save or record the camera output.  
Precise location permission (continuous)  
Used for accessing the User's precise device location. This Application may collect, use, and share  
User location Data in order to provide location-based services.  
Precise location permission (non-continuous)  
Used for accessing the User's precise device location. This Application may collect, use, and share  
User location Data in order to provide location-based services.  
The geographic location of the User is determined in a manner that isn't continuous. This means that  
it is impossible for this Application to derive the exact position of the User on a continuous basis.  
Detailed information on the processing of Personal Data  
Personal Data is collected for the following purposes and using the following services:  
Analytics  
The services contained in this section enable the Owner to monitor and analyse web traffic and can  
be used to keep track of User behaviour.  
Google Analytics for Firebase (Google LLC)  
Google Analytics for Firebase or Firebase Analytics is an analytics service provided by Google LLC.  
In order to understand Google's use of Data, consult Google's partner policy.  
Firebase Analytics may share Data with other tools provided by Firebase, such as Crash Reporting,  
Authentication, Remote Config or Notifications. The User may check this privacy policy to find a  
detailed explanation about the other tools used by the Owner.  
This Application uses identifiers for mobile devices and technologies similar to cookies to run the  
Firebase Analytics service.  
Users may opt-out of certain Firebase features through applicable device settings, such as the device  
advertising settings for mobile phones or by following the instructions in other Firebase related  
sections of this privacy policy, if available.  
Personal Data processed: Application opens; device information; geography/region; launches;  
number of sessions; number of Users ; operating systems; session duration; Tracker; unique device  
identifiers for advertising (Google Advertiser ID or IDFA, for example).  
Place of processing: United States – Privacy Policy.  
Content performance and features testing (A/B testing)  
The services contained in this section allow the Owner to track and analyse the User response  
concerning web traffic or behaviour regarding changes to the structure, text or any other  
component of this Application.  
Firebase Remote Config (Google LLC)  
Firebase Remote Config is an A/B testing and configuration service provided by Google LLC.  
Personal Data processed: various types of Data as specified in the privacy policy of the service.  
Place of processing: United States – Privacy Policy.  
Device permissions for Personal Data access  
This Application requests certain permissions from Users that allow it to access the User's device  
Data as described below.  
Device permissions for Personal Data access (this Application)  
This Application requests certain permissions from Users that allow it to access the User's device  
Data as summarized here and described within this document.  
Personal Data processed: Approximate location permission (continuous); Approximate location  
permission (non-continuous); Camera permission, without saving or recording; Precise location  
permission (continuous); Precise location permission (non-continuous).  
Handling payments  
Unless otherwise specified, this Application processes any payments by credit card, bank transfer or  
other means via external payment service providers. In general and unless where otherwise stated,  
Users are requested to provide their payment details and personal information directly to such  
payment service providers. This Application isn't involved in the collection and processing of such  
information: instead, it will only receive a notification by the relevant payment service provider as to  
whether payment has been successfully completed.  
Apple Pay (Apple Inc.)  
Apple Pay is a payment service provided by Apple Inc., which allows Users to make payments using  
their mobile phones.  
Personal Data processed: billing address; email address; first name; last name; payment info;  
shipping address.  
Place of processing: United States – Privacy Policy.  
Google Pay (Google Ireland Limited)  
Google Pay is a payment service provided by Google Ireland Limited, which allows users to make  
online payments using their Google credentials.  
Personal Data processed: billing address; email address; first name; last name; payment info;  
shipping address.  
Place of processing: Ireland – Privacy Policy.  
Hosting and backend infrastructure  
This type of service has the purpose of hosting Data and files that enable this Application to run and  
be distributed as well as to provide a ready-made infrastructure to run specific features or parts of  
this Application.  
Some services among those listed below, if any, may work through geographically distributed  
servers, making it difficult to determine the actual location where the Personal Data are stored.  
Google BigQuery (Google Ireland Limited)  
Google BigQuery is a hosting and backend service provided by Google Ireland Limited.  
Personal Data processed: various types of Data as specified in the privacy policy of the service.  
Place of processing: Ireland – Privacy Policy.  
Google Cloud Storage (Google Ireland Limited)  
Google Cloud Storage is a hosting service provided by Google Ireland Limited.  
Personal Data processed: various types of Data as specified in the privacy policy of the service.  
Place of processing: Ireland – Privacy Policy.  
Infrastructure monitoring  
This type of service allows this Application to monitor the use and behaviour of its components so its  
performance, operation, maintenance and troubleshooting can be improved.  
Which Personal Data are processed depends on the characteristics and mode of implementation of  
these services, whose function is to filter the activities of this Application.  
Firebase Performance Monitoring (Google LLC)  
Firebase Performance Monitoring is a monitoring service provided by Google LLC.  
Personal Data processed: various types of Data as specified in the privacy policy of the service.  
Place of processing: United States – Privacy Policy.  
Sentry (Functional Software, Inc. )  
Sentry is a monitoring service provided by Functional Software, Inc. .  
Personal Data processed: various types of Data as specified in the privacy policy of the service.  
Place of processing: United States – Privacy Policy.  
Location processing  
Radar (Radar Labs, inc)  
Radar is a geolocation service provided by Radar Labs, Inc.  
Personal data processed: location data (latitude, longitude), device IDs, IP addresses, and device info  
Place of processing; United States - https://radar.com/privacy  
Location-based interactions  
Geolocation (this Application)  
This Application may collect, use, and share User location Data in order to provide location-based  
services.  
Most browsers and devices provide tools to opt out from this feature by default. If explicit  
authorisation has been provided, the User’s location data may be tracked by this Application.  
Personal Data processed: geographic position.  
Managing contacts and sending messages  
This type of service makes it possible to manage a database of email contacts, phone contacts or any  
other contact information to communicate with the User.  
These services may also collect data concerning the date and time when the message was viewed by  
the User, as well as when the User interacted with it, such as by clicking on links included in the  
message.  
Firebase Notifications (Google LLC)  
Firebase Notifications is a message sending service provided by Google LLC. Firebase Notifications  
can be integrated with Firebase Analytics to target analytics-based audiences and track opening and  
conversion events.  
Personal Data processed: various types of Data as specified in the privacy policy of the service.  
Place of processing: United States – Privacy Policy.  
Firebase Cloud Messaging (Google Ireland Limited)  
Firebase Cloud Messaging is a message sending service provided by Google Ireland Limited. Firebase  
Cloud Messaging allows the Owner to send messages and notifications to Users across platforms  
such as Android, iOS, and the web. Messages can be sent to single devices, groups of devices, or  
specific topics or User segments.  
Personal Data processed: various types of Data as specified in the privacy policy of the service.  
Place of processing: Ireland – Privacy Policy.  
Managing support and contact requests  
This type of service allows this Application to manage support and contact requests received via  
email or by other means, such as the contact form.  
The Personal Data processed depend on the information provided by the User in the messages and  
the means used for communication (e.g. email address).  
Platform services and hosting  
These services have the purpose of hosting and running key components of this Application,  
therefore allowing the provision of this Application from within a unified platform. Such platforms  
provide a wide range of tools to the Owner – e.g. analytics, user registration, commenting, database  
management, e-commerce, payment processing – that imply the collection and handling of Personal  
Data.  
Some of these services work through geographically distributed servers, making it difficult to  
determine the actual location where the Personal Data are stored.  
Apple App Store (Apple Inc.)  
This Application is distributed on Apple's App Store, a platform for the distribution of mobile apps,  
provided by Apple Inc.  
By virtue of being distributed via this app store, Apple collects basic analytics and provides reporting  
features that enables the Owner to view usage analytics data and measure the performance of this  
Application. Much of this information is processed on an opt-in basis.  
Users may opt-out of this analytics feature directly through their device settings. More information  
on how to manage analysis settings can be found on this page.  
Personal Data processed: Usage Data.  
Place of processing: United States – Privacy Policy.  
Google Play Store (Google Ireland Limited)  
This Application is distributed on the Google Play Store, a platform for the distribution of mobile  
apps, provided by Google Ireland Limited.  
By virtue of being distributed via this app store, Google collects usage and diagnostics data and share  
aggregate information with the Owner. Much of this information is processed on an opt-in basis.  
Users may opt-out of this analytics feature directly through their device settings. More information  
on how to manage analysis settings can be found on this page.  
Personal Data processed: Usage Data.  
Place of processing: Ireland – Privacy Policy.  
Registration and authentication  
By registering or authenticating, Users allow this Application to identify them and give them access  
to dedicated services.  
Depending on what is described below, third parties may provide registration and authentication  
services. In this case, this Application will be able to access some Data, stored by these third-party  
services, for registration or identification purposes.  
Some of the services listed below may also collect Personal Data for targeting and profiling  
purposes; to find out more, please refer to the description of each service.  
Firebase Authentication (Google LLC)  
Firebase Authentication is a registration and authentication service provided by Google LLC. To  
simplify the registration and authentication process, Firebase Authentication can make use of third-  
party identity providers and save the information on its platform.  
Personal Data processed: email address; first name; last name; password; phone number; social  
media accounts .  
Place of processing: United States – Privacy Policy.  
Facebook Authentication (Meta Platforms Ireland Limited)  
Facebook Authentication is a registration and authentication service provided by Meta Platforms  
Ireland Limited and is connected to the Facebook social network.  
Personal Data processed: Tracker; various types of Data as specified in the privacy policy of the  
service.  
Place of processing: Ireland – Privacy Policy.  
Social features  
Firebase Dynamic Links (Google LLC)  
Firebase Dynamic Links is a social feature provided by Google LLC. Dynamic Links are tracked within  
Firebase or Google Analytics for Firebase, which informs the Owner about the details of the User  
journey to and within this Application.  
Personal Data processed: various types of Data as specified in the privacy policy of the service.  
Place of processing: United States – Privacy Policy.  
User database management  
This type of service allows the Owner to build user profiles by starting from an email address, a  
personal name, or other information that the User provides to this Application, as well as to track  
User activities through analytics features. This Personal Data may also be matched with publicly  
available information about the User (such as social networks' profiles) and used to build private  
profiles that the Owner can display and use for improving this Application.  
Some of these services may also enable the sending of timed messages to the User, such as emails  
based on specific actions performed on this Application.  
Information on opting out of interest-based advertising  
In addition to any opt-out feature provided by any of the services listed in this document, Users may  
follow the instructions provided by YourOnlineChoices (EU), the Network Advertising Initiative (US)  
and the Digital Advertising Alliance (US), DAAC (Canada), DDAI (Japan) or other similar initiatives.  
Such initiatives allow Users to select their tracking preferences for most of the advertising tools. The  
Owner thus recommends that Users make use of these resources in addition to the information  
provided in this document.  
The Digital Advertising Alliance offers an application called AppChoices that helps Users to control  
interest-based advertising on mobile apps.  
Users may also opt-out of certain advertising features through applicable device settings, such as the  
device advertising settings for mobile phones or ads settings in general.  
Further information about the processing of Personal Data  
Push notifications  
This Application may send push notifications to the User to achieve the purposes outlined in this  
privacy policy.  
Users may in most cases opt-out of receiving push notifications by visiting their device settings, such  
as the notification settings for mobile phones, and then change those settings for this Application,  
some or all of the apps on the particular device.  
Users must be aware that disabling push notifications may negatively affect the utility of this  
Application.  
Push notifications based on the User's geographic location  
This Application may use the User's geographic location to send push notifications for the purposes  
outlined in this privacy policy.  
Users may in most cases opt-out of receiving push notifications by visiting their device settings, such  
as the notification settings for mobile phones, and then changing those settings for some or all of  
the apps on the particular device.  
Users must be aware that disabling push notifications may negatively affect the utility of this  
Application.  
Selling goods and services online  
The Personal Data collected are used to provide the User with services or to sell goods, including  
payment and possible delivery.  
The Personal Data collected to complete the payment may include the credit card, the bank account  
used for the transfer, or any other means of payment envisaged. The kind of Data collected by this  
Application depends on the payment system used.  
The rights of Users  
Users may exercise certain rights regarding their Data processed by the Owner.  
In particular, Users have the right to do the following:  
Withdraw their consent at any time. Users have the right to withdraw consent where they  
have previously given their consent to the processing of their Personal Data.  
Object to processing of their Data. Users have the right to object to the processing of their  
Data if the processing is carried out on a legal basis other than consent. Further details are  
provided in the dedicated section below.  
Access their Data. Users have the right to learn if Data is being processed by the Owner,  
obtain disclosure regarding certain aspects of the processing and obtain a copy of the Data  
undergoing processing.  
Verify and seek rectification. Users have the right to verify the accuracy of their Data and  
ask for it to be updated or corrected.  
Restrict the processing of their Data. Users have the right, under certain circumstances, to  
restrict the processing of their Data. In this case, the Owner will not process their Data for  
any purpose other than storing it.  
Have their Personal Data deleted or otherwise removed. Users have the right, under  
certain circumstances, to obtain the erasure of their Data from the Owner.  
Receive their Data and have it transferred to another controller. Users have the right to  
receive their Data in a structured, commonly used and machine readable format and, if  
technically feasible, to have it transmitted to another controller without any hindrance. This  
provision is applicable provided that the Data is processed by automated means and that the  
processing is based on the User's consent, on a contract which the User is part of or on pre-  
contractual obligations thereof.  
Lodge a complaint. Users have the right to bring a claim before their competent data  
protection authority.  
Details about the right to object to processing  
Where Personal Data is processed for a public interest, in the exercise of an official authority vested  
in the Owner or for the purposes of the legitimate interests pursued by the Owner, Users may object  
to such processing by providing a ground related to their particular situation to justify the objection.  
Users must know that, however, should their Personal Data be processed for direct marketing  
purposes, they can object to that processing at any time without providing any justification. To learn,  
whether the Owner is processing Personal Data for direct marketing purposes, Users may refer to  
the relevant sections of this document.  
How to exercise these rights  
Any requests to exercise User rights can be directed to the Owner through the contact details  
provided in this document. These requests can be exercised free of charge and will be addressed by  
the Owner as early as possible and always within one month.  
Additional information about Data collection and processing  
Legal action  
The User's Personal Data may be used for legal purposes by the Owner in Court or in the stages  
leading to possible legal action arising from improper use of this Application or the related Services.  
The User declares to be aware that the Owner may be required to reveal personal data upon request  
of public authorities.  
Additional information about User's Personal Data  
In addition to the information contained in this privacy policy, this Application may provide the User  
with additional and contextual information concerning particular Services or the collection and  
processing of Personal Data upon request.  
System logs and maintenance  
For operation and maintenance purposes, this Application and any third-party services may collect  
files that record interaction with this Application (System logs) use other Personal Data (such as the  
IP Address) for this purpose.  
Information not contained in this policy  
More details concerning the collection or processing of Personal Data may be requested from the  
Owner at any time. Please see the contact information at the beginning of this document.  
How “Do Not Track” requests are handled  
This Application does not support “Do Not Track” requests.  
To determine whether any of the third-party services it uses honour the “Do Not Track” requests,  
please read their privacy policies.  
Changes to this privacy policy  
The Owner reserves the right to make changes to this privacy policy at any time by notifying its Users  
on this page and possibly within this Application and/or - as far as technically and legally feasible -  
sending a notice to Users via any contact information available to the Owner. It is strongly  
recommended to check this page often, referring to the date of the last modification listed at the  
bottom.  
Should the changes affect processing activities performed on the basis of the User’s consent, the  
Owner shall collect new consent from the User, where required.  
Definitions and legal references  
Personal Data (or Data)  
Any information that directly, indirectly, or in connection with other information — including a  
personal identification number — allows for the identification or identifiability of a natural person.  
Usage Data  
Information collected automatically through this Application (or third-party services employed in this  
Application), which can include: the IP addresses or domain names of the computers utilised by the  
Users who use this Application, the URI addresses (Uniform Resource Identifier), the time of the  
request, the method utilised to submit the request to the server, the size of the file received in  
response, the numerical code indicating the status of the server's answer (successful outcome, error,  
etc.), the country of origin, the features of the browser and the operating system utilised by the  
User, the various time details per visit (e.g., the time spent on each page within the Application) and  
the details about the path followed within the Application with special reference to the sequence of  
pages visited, and other parameters about the device operating system and/or the User's IT  
environment.  
User  
The individual using this Application who, unless otherwise specified, coincides with the Data  
Subject.  
Data Subject  
The natural person to whom the Personal Data refers.  
Data Processor (or Data Supervisor)  
The natural or legal person, public authority, agency or other body which processes Personal Data on  
behalf of the Controller, as described in this privacy policy.  
Data Controller (or Owner)  
The natural or legal person, public authority, agency or other body which, alone or jointly with  
others, determines the purposes and means of the processing of Personal Data, including the  
security measures concerning the operation and use of this Application. The Data Controller, unless  
otherwise specified, is the Owner of this Application.  
This Application  
The means by which the Personal Data of the User is collected and processed.  
Service  
The service provided by this Application as described in the relative terms (if available) and on this  
site/application.  
European Union (or EU)  
Unless otherwise specified, all references made within this document to the European Union include  
all current member states to the European Union and the European Economic Area.  
Cookie  
Cookies are Trackers consisting of small sets of data stored in the User's browser.  
Tracker  
Tracker indicates any technology - e.g Cookies, unique identifiers, web beacons, embedded scripts,  
e-tags and fingerprinting - that enables the tracking of Users, for example by accessing or storing  
information on the User’s device.  
Legal information  
This privacy statement has been prepared based on provisions of multiple legislations, including the  
Personal Data Protection Act 2012.  
This privacy policy relates solely to this Application, if not stated otherwise within this document.