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Privacy Policy
1. Introduction
Creative Foundry Pte. Ltd ("we," "us," "our") is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, disclose, and protect your personal information when you use our digital photograph download service (the "Service").
This Privacy Policy complies with Singapore's Personal Data Protection Act 2012 (PDPA) and other applicable privacy laws.
2. Personal Data We Collect
2.1 Information You Provide
When you create an account or use our Service, we collect:
- Name: Your full name for account identification
- Email Address: For account communication, service updates, and marketing (with consent)
- Account Information: Username, password, and account preferences
2.2 Information Automatically Collected
We automatically collect certain information when you visit our website:
- Technical Data: IP address, browser type, device information, operating system
- Usage Data: Pages visited, time spent on site, downloads, click patterns
- Cookies and Similar Technologies: See our Cookie Policy for detailed information
2.3 Photograph-Related Data
- Event Participation: Information about sporting events you attended
- Photo Metadata: Technical information about photographs you download
- Download History: Records of photographs you have accessed
3. How We Use Your Personal Data
We use your personal data for the following purposes:
3.1 Service Provision
- Creating and managing your user account
- Providing access to your sporting event photographs
- Processing your download requests
- Providing customer support and technical assistance
3.2 Communication
- Sending service-related notifications and updates
- Responding to your inquiries and requests
- Sending marketing emails and newsletters (only with your explicit consent)
3.3 Service Improvement
- Analyzing usage patterns to improve our Service
- Conducting research and analytics to enhance user experience
- Developing new features and functionality
3.4 Legal and Security
- Ensuring compliance with applicable laws and regulations
- Protecting against fraud, abuse, and security threats
- Enforcing our Terms of Service
4. Legal Basis for Processing (PDPA Compliance)
Under Singapore's PDPA, we process your personal data based on:
4.1 Consent
- Marketing communications (you can withdraw consent at any time)
- Non-essential cookies for analytics and advertising
- Optional features that require additional data processing
4.2 Legitimate Interests
- Service provision and account management
- Service improvement and analytics
- Security and fraud prevention
- Business operations and administration
4.3 Legal Obligations
- Compliance with Singapore laws and regulations
- Responding to legal requests from authorities
5. Cookies and Tracking Technologies
We use cookies and similar technologies for:
5.1 Essential Cookies
- Purpose: Website functionality, user authentication, security
- Legal Basis: Legitimate interest (necessary for service provision)
- Duration: Session cookies and up to 1 year
5.2 Analytics Cookies
- Purpose: Understanding website usage, improving user experience
- Legal Basis: Your consent (can be withdrawn)
- Duration: Up to 2 years
- Third Parties: Google Analytics, Meta Pixel
5.3 Advertising Cookies
- Purpose: Delivering relevant advertisements, measuring ad effectiveness
- Legal Basis: Your consent (can be withdrawn)
- Duration: Up to 2 years
- Third Parties: Google Analytics, Meta Pixel
For detailed information about our cookie usage, please see our separate Cookie Policy.
6. Sharing Your Personal Data
6.1 We Do Not Sell Your Data
We do not sell, trade, or rent your personal information to third parties.
6.2 Limited Sharing
We may share your personal data only in the following circumstances:
6.2.1 Service Providers
- Cloud hosting providers: For website and data hosting
- Email service providers: For sending communications (with your consent)
- Analytics providers: For website analytics and improvement
- All service providers are contractually required to protect your data and use it only for specified purposes.
6.2.2 Legal Requirements
- When required by Singapore law or legal process
- To protect our rights, property, or safety, or that of others
- In connection with legal proceedings or investigations to the extent that we are required to by the relevant authority
6.2.3 Business Transfers
- In the event of a merger, acquisition, or sale of business assets
- Personal data would be transferred subject to equivalent privacy protections
6.3 International Transfers
Currently, we do not transfer your personal data outside of Singapore. If this changes in the future, we will:
- Notify you of such transfers
- Ensure adequate protection through approved mechanisms
- Obtain your consent where required by PDPA
7. Data Security
We implement appropriate technical and organizational measures to protect your personal data:
7.1 Technical Safeguards
- Encryption of data in transit and at rest
- Secure server infrastructure and access controls
- Regular security monitoring and updates
- Multi-factor authentication for administrative access
7.2 Organizational Safeguards
- Staff training on data protection principles
- Regular security audits and assessments
- Incident response procedures for data breaches
- Designated Data Protection Officer oversight
8. Data Retention
8.1 Retention Periods
- Account Data: Retained while your account is active, plus 7 years after closure for legal compliance
- Marketing Data: Until you withdraw consent, then deleted within 30 days
- Usage Analytics: Aggregated and anonymized after 2 years
- Security Logs: Retained for 1 year for security monitoring
8.2 Deletion Process
When retention periods expire, we securely delete or anonymize your personal data using industry-standard methods.
9. Your Rights Under PDPA
As a Singapore resident, you have the following rights:
9.1 Access Rights
- Request confirmation of personal data we hold about you
- Obtain copies of your personal data we are processing
9.2 Correction Rights
- Request correction of inaccurate or incomplete personal data
- We will correct data within 30 days of verified requests
9.3 Withdrawal of Consent
- Marketing Communications: Unsubscribe via email links or account settings
- Cookies: Manage preferences through our cookie banner or browser settings
- Account: Delete your account through account settings or by contacting us
9.4 Data Portability
- Request your personal data in a structured, commonly used format
- Transfer your data to another service provider where technically feasible
9.5 Limitation of Processing
- Request restriction of processing in certain circumstances
- Object to processing based on legitimate interests
10. Marketing Communications
10.1 Consent Requirements
- We will only send marketing emails with your explicit opt-in consent
- You can withdraw consent at any time without penalty
- Consent withdrawal will not affect the lawfulness of processing before withdrawal
10.2 Unsubscribe Options
You can opt out of marketing communications by:
- Clicking the unsubscribe link in our emails
- Updating your preferences in your account settings
- Emailing us directly at hello@creativefoundry.sg
- We will process unsubscribe requests within 10 working days
10.3 Do Not Call Registry
We comply with Singapore's Do Not Call Registry requirements and do not send SMS marketing messages without proper consent.
11. Data Breach Notification
11.1 Our Obligations
In the event of a data breach that may cause harm to individuals, we will:
- Notify the Personal Data Protection Commission within 3 calendar days
- Inform affected individuals without undue delay
- Provide details about the breach and steps taken to address it
11.2 Your Actions
If you suspect unauthorized access to your account:
- Change your password immediately
- Contact us promptly at hello@creativefoundry.sg
- Monitor your account for unusual activity
12. Children's Privacy
Our Service is not intended for individuals under 18 years of age. We do not knowingly collect personal data from children under 18. If we become aware of such collection, we will delete the information promptly.
13. Third-Party Links
Our Service may contain links to third-party websites. This Privacy Policy does not apply to such external sites. We recommend reviewing the privacy policies of any third-party websites you visit.
14. Changes to This Privacy Policy
14.1 Updates
We may update this Privacy Policy periodically to reflect:
- Changes in our data processing practices
- New legal requirements
- Service enhancements or modifications
14.2 Notification
We may notify you of material changes by:
- Posting the updated policy on our website
- Sending an email notification (for significant changes)
- Providing prominent notice on our Service
14.3 Continued Use
Your continued use of our Service after policy changes constitutes acceptance of the updated Privacy Policy.
15. Contact Information and Data Protection Officer
15.1 General Inquiries
For questions about this Privacy Policy or our data practices:
Creative Foundry Pte. Ltd
Email: dpo@creativefoundry.sg
Address: 160 Robinson road, #14-04, Singapore - 068914
15.2 Data Protection Officer
For specific PDPA-related matters or to exercise your rights:
Data Protection Officer
Email: dpo@creativefoundry.sg
Subject Line: "PDPA Rights Request"
15.3 Regulatory Authority
If you have concerns about our data handling practices, you may contact:
Personal Data Protection Commission Singapore
Website: https://www.pdpc.gov.sg
Email: info@pdpc.gov.sg
16. Effective Date and Version
This Privacy Policy is effective as of 01-09-2025 and supersedes all previous versions.
Version: 1.0
Last Updated: 28-09-2025
Next Review Date:
28-09-2026
By using our Service, you acknowledge that you have read, understood, and agree to this Privacy Policy.
Cookie Policy
1. Introduction
This Cookie Policy explains how Creative Foundry Pte. Ltd ("we," "us," "our") uses cookies and similar tracking technologies on our digital photograph download service website (the "Service").
This policy should be read together with our Privacy Policy and Terms of Service. By using our Service, you consent to our use of cookies in accordance with this policy and Singapore's Personal Data Protection Act (PDPA).
2. What Are Cookies?
Cookies are small text files that are downloaded and stored on your computer or mobile device when you visit a website. They allow the website to recognize your device and remember certain information about your visit.
2.1 Types of Cookies We Use
Session Cookies: Temporary cookies that are deleted when you close your
browser
Persistent Cookies: Cookies that remain on your device for a set period or until you
delete them
First-Party Cookies: Cookies set directly by our website
Third-Party
Cookies: Cookies set by external services we use (e.g., analytics providers)
3. How We Use Cookies
We use cookies for three main purposes: functionality, analytics, and advertising.
3.1 Essential/Functional Cookies
Purpose: These cookies are necessary for our Service to function properly
Legal
Basis: Legitimate interest (essential for service provision)
Consent Required: No -
these are strictly necessary cookies
Duration: Session cookies and up to 1 year
Specific Uses:
- User authentication and account management
- Remembering your login status
- Security and fraud prevention
- Shopping cart functionality (future payment features)
- Language and accessibility preferences
- Load balancing and performance optimization
Cookie Names:
_sports_app_key- User session identification_sports_app_web_user_remember_me- User session preferenceuser_token- Authentication token_csrf- CSRF protectionpreferences- User preferences and settings
3.2 Analytics Cookies
Purpose: Help us understand how visitors use our Service to improve user experience
Legal
Basis: Your explicit consent
Consent Required: Yes - you can opt out at any
time
Duration: Up to 2 years
Information Collected:
- Pages visited and time spent on each page
- How you navigate through our Service
- Which features you use most frequently
- Technical information about your device and browser
- General location information (country/city level)
- Download patterns and popular content
Third-Party Services:
- Google Analytics: Website traffic and user behavior analysis
- Cookies:
_ga,_ga_*,_gid,_gat - Data shared: Anonymized usage statistics
- Privacy policy: https://policies.google.com/privacy
- Opt-out: https://tools.google.com/dlpage/gaoptout
- Cookies:
3.3 Advertising Cookies
Purpose: Deliver relevant advertisements and measure advertising effectiveness
Legal
Basis: Your explicit consent
Consent Required: Yes - you can opt out at any
time
Duration: Up to 2 years
Information Collected:
- Your interests based on pages visited
- Previous interactions with our Service
- Demographic information (age range, general location)
- Ad engagement and conversion tracking
Third-Party Advertising Partners:
-
Google Ads: Retargeting and conversion tracking
- Cookies: Various (see Google's cookie policy)
- Data shared: Anonymized user behavior for ad targeting
- Privacy policy: https://policies.google.com/privacy
- Opt-out: https://adssettings.google.com
-
Facebook Pixel: Social media advertising and analytics
- Cookies:
_fbp,fr,sb,datr - Data shared: Website visits, conversions, custom audiences
- Privacy policy: https://www.facebook.com/privacy/policy/
- Opt-out: https://www.facebook.com/settings?tab=ads
- Cookies:
4. Cookie Consent Management
4.1 Initial Consent
When you first visit our Service, you will see a cookie banner that allows you to:
- Accept all cookies
- Reject non-essential cookies
- Customize your cookie preferences
- Learn more about our cookie practices
4.2 Managing Your Preferences
You can change your cookie preferences at any time by:
- Clicking the "Cookie Preferences" link in our website footer
- Accessing cookie settings through your account dashboard
- Using your browser's cookie management settings
4.3 Withdrawal of Consent
- You can withdraw your consent to non-essential cookies at any time
- Withdrawal will not affect cookies already placed before consent was withdrawn
- Essential cookies cannot be disabled as they are necessary for Service functionality
5. Third-Party Cookies and Services
5.1 Third-Party Services We Use
We work with trusted third-party service providers who may place cookies on your device:
Analytics Providers:
- Google Analytics - Website analytics and reporting
Advertising Partners:
- Google Ads - Online advertising and retargeting
- Facebook - Social media advertising
Service Providers:
- CloudFlare - Website security and performance
5.2 Third-Party Privacy Policies
Each third-party service has its own privacy policy and cookie practices. We recommend reviewing their policies:
- We do not control third-party cookies
- Third parties may use your data for their own purposes
- You can opt out directly with each third-party service
6. Your Rights and Choices
6.1 Browser Controls
You can control cookies through your browser settings:
Chrome: Settings > Privacy and Security > Cookies and other site
data
Firefox: Settings > Privacy & Security > Cookies and Site
Data
Safari: Preferences > Privacy > Manage Website Data
Edge:
Settings > Cookies and site permissions
6.2 Opt-Out Tools
For advertising cookies, you can also use these industry opt-out tools:
- Network Advertising Initiative: http://www.networkadvertising.org/choices/
- Digital Advertising Alliance: http://www.aboutads.info/choices/
- European Interactive Digital Advertising Alliance: http://www.youronlinechoices.eu/
6.3 Mobile Device Settings
For mobile devices, you can control advertising through:
- iOS: Settings > Privacy & Security > Apple Advertising > Personalized Ads
- Android: Settings > Google > Ads > Opt out of Ads Personalization
7. Impact of Disabling Cookies
7.1 Essential Cookies
If you disable essential cookies:
- Our Service may not function properly
- You may not be able to access certain features
- Security features may be compromised
- You may need to re-enter information frequently
7.2 Analytics Cookies
If you disable analytics cookies:
- Your visit will not be tracked for analytics purposes
- We cannot improve our Service based on your usage patterns
- All Service functionality will remain available
7.3 Advertising Cookies
If you disable advertising cookies:
- You will still see advertisements, but they may be less relevant
- We cannot measure advertising effectiveness
- You may see the same ads repeatedly
8. Data Protection and Security
8.1 Cookie Data Protection
- Cookie data is encrypted and stored securely
- We use industry-standard security measures
- Access to cookie data is restricted to authorized personnel
- Regular security audits ensure data protection
8.2 Data Retention
- Session cookies are deleted when you close your browser
- Persistent cookies expire according to their specified duration
- You can delete cookies manually through browser settings
- We regularly review and clean up expired cookie data
9. International Data Transfers
9.1 Third-Party Services
Some of our third-party service providers may transfer cookie data outside Singapore:
- All transfers comply with PDPA requirements
- We ensure adequate protection through approved mechanisms
- Data is processed according to service providers' privacy policies
9.2 Your Consent
By accepting cookies from third-party services, you consent to potential international transfers as described in their privacy policies.
10. Children's Privacy
Our Service is not intended for children under 18. We do not knowingly collect cookie data from minors. If you believe a child has provided cookie data, please contact us immediately.
11. Updates to This Cookie Policy
11.1 Policy Changes
We may update this Cookie Policy to reflect:
- Changes in cookie practices
- New third-party services
- Legal requirement updates
- Service enhancements
11.2 Notification of Changes
We will notify you of significant changes through:
- Updated cookie banner on your next visit
12. Contact Information
12.1 Cookie-Related Questions
For questions about our cookie practices:
Creative Foundry Pte. Ltd
Email: dpo@creativefoundry.sg
Subject: "Cookie Policy Inquiry"
Address: 160 Robinson road, #14-04,
Singapore - 068914
12.2 Technical Support
For help managing your cookie preferences:
Email: hello@creativefoundry.sg
Subject: "Cookie Settings Help"
12.3 Data Protection Officer
For PDPA-related cookie matters:
Data Protection Officer
Email: dpo@creativefoundry.sg
Subject: "Cookie Data Rights Request"
12.4 Complaints
If you have concerns about our cookie practices:
Personal Data Protection Commission Singapore
Website: https://www.pdpc.gov.sg
Email: info@pdpc.gov.sg
13. Legal Compliance
This Cookie Policy complies with:
- Singapore's Personal Data Protection Act (PDPA) 2012
- Singapore's Cybersecurity Act requirements
- International best practices for cookie disclosure
14. Effective Date and Version
Effective Date: 01-09-2025Version: 1.0
Last Updated:
28-09-2025
Next Review: 28-09-2026
By continuing to use our Service after reading this Cookie Policy, you consent to our use of cookies as described herein. You can modify your consent preferences at any time through our cookie management tools.