Privacy Policy

Updated 16 February 2024

Pencil AI Limited (we, us, our) complies with applicable  privacy and data protection laws when dealing with Personal Data.  

This privacy policy has been compiled to better serve those who are concerned with how their 'Personally Identifiable Information', as described in US privacy law and information security, or ‘Personal Data’ as described in the Act, is being used online (Personal Data).  Personal Data is information about an identifiable individual (a natural person) that can be used on its own or with other information to identify, contact, or locate a single person, or to identify that individual in context.

PLEASE READ OUR PRIVACY POLICY CAREFULLY TO GET A CLEAR UNDERSTANDING OF HOW WE COLLECT, USE, PROTECT OR OTHERWISE HANDLE YOUR PERSONAL DATA.

This policy does not limit or exclude any of your rights under the Act and other applicable laws.  If you wish to seek further information on the Act, see https://www.pdpc.gov.sg/overview-of-pdpa/the-legislation/personal-data-protection-act.

We may change this policy by uploading a revised policy onto the website.  The change will apply from the date that we upload the revised policy.

What Personal Data do we collect from the people that visit our blog, website or app?
We collect, hold and process two categories of Personal Data that we collect about you:

1. Account and Marketing Data is Personal Data that we collect about you:

  • in connection with the creation or administration of a customer account
  • if you ask to receive information about us or our services or sign up to our newsletter
  • when you sign up to or access or use our services
  • when you contact us directly (e.g. website enquiry form, email, live chat features or through your user dashboard) or visit our website
  • if you participate in customer feedback surveys

The Account and Marketing Data we collect may include company/personal names, usernames, phone numbers, email addresses and any other contact information you provide to us, your location, billing information, purchase history, information about how you use our website or services (for example, traffic volumes, time spent on pages), your IP address and/or other device identifying data, information contained in your correspondence with us or survey responses and other information required to provide a service or information you have requested from us.

2. Personal Data that forms part of the Data (as defined in our Terms of Use) (Client Data).  This may include any Personal Data collected by our clients, including our clients’ end users’ names, addresses, contact details or other details to help you with your experience.

We will not collect or process Client Data except as provided in our Terms of Use and/or other agreements with our clients that govern the processing of Client Data (as applicable) and we require our clients to comply with applicable privacy and data protection laws.

The remainder of this privacy policy sets out how we will collect, use, disclose and protect Account and Marketing Data and does not apply to Client Data.

Who do we collect your data from?
We collect Personal Data about you from:

  • you, when you provide that Personal Data to us, including via our website and services through any registration, subscription or purchase process on our website, through any contact with us (including Live Chat or email), by entering information on our site in any other way, or by providing us with feedback on our products or services.
  • third parties where you have authorised this or the information is publicly available.  If possible, we will collect Personal Data from you directly.

When you visit or use our website or services, we may collect information about you:

  • by recording clickstream data, which is non-personal information that is recorded when you click anywhere on a webpage and is used for the purposes of collecting, analysing and reporting data about how you use our website and related services; and
  • through the use of cookies, web beacons and similar storage technologies (see more detail about our use of cookies below).  

How do we use your data?
We may use the Personal Data about you in the following ways:

  • to verify your identity
  • to provide the website and services to you;
  • to personalise your experience and to allow us to deliver the type of content and product offerings in which you are most interested;
  • to improve our website in order to better serve you;
  • to allow us to better service you in responding to your customer service requests;
  • to send periodic emails regarding your order or other products and services, you can stop receiving our marketing emails by following the unsubscribe instructions included in those emails;
  • to bill you and to collect money that you owe us, including authorising and processing credit card transactions;
  • to respond to communications from you, including enquiries and complaints;
  • to conduct research and statistical analysis (on an anonymised basis);
  • to protect and/or enforce our legal rights and interests, including defending any claim;
  • for any other purpose authorised by you, the Act or other applicable law; and
  • to respond to lawful requests by public authorities, including to meet law enforcement requirements.

We may transfer your information in the case of  sale, merger, consolidation, liquidation, reorganisation or acquisition.

How do we protect your data?
Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible.

Your Personal Data is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, any sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.

We implement a variety of security measures when a user enters, submits, or accesses their information to maintain the safety of your Personal Data.

Any transactions are processed through a gateway provider and are not stored or processed on our servers.

You can play an important role in keeping your Personal Data secure by maintaining the confidentiality of any password and accounts used in relation to our services.  Please do not disclose your password to third parties.  Please notify us immediately if there is any unauthorised use of your account or any other breach of security.

Do we use 'cookies'?
Yes. Cookies are small files that a site or its service provider transfers to your computer's hard drive through your Web browser (if you allow) that enables the site's or service provider's systems to recognize your browser and capture and remember certain information. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

We use cookies to:

  • Understand and save user's preferences for future visits.
  • Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf.

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Since browser is a little different, look at your browser's Help Menu to learn the correct way to modify your cookies. If you turn cookies off, it won't affect your experience on our site.

Third-party disclosure
We do not sell, trade, or otherwise transfer to outside parties your Personal Data unless we provide users with advance notice. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or serving our users, so long as those parties agree to keep this information confidential. We may also release information when its release is appropriate to comply with the law, enforce our site policies, or protect ours or others' rights, property or safety.

However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses for anonymised statistical information.

‍Assessing and correcting your Personal Data
Subject to certain grounds for refusal set out in the Act or other applicable law, you have the right to access your readily retrievable Personal Data that we hold and to request a correction to your Personal Data.  Before you exercise this right, we will need evidence to confirm that you are the individual to whom the Personal Data relates.

In respect of a request for correction, if we think the correction is reasonable and we are reasonably able to change the Personal Data, we will make the correction.  If we do not make the correction, we will take reasonable steps to note on the Personal Data that you requested the correction.

If you want to exercise either of the above rights, email us at support@trypencil.com.  Your email should provide evidence of who you are and set out the details of your request (e.g. the Personal Data, or the correction, that you are requesting).

Third-party links
We do not include or offer third-party products or services on our website.

Google
Google's advertising requirements can be summed up by Google's Advertising Principles. Please refer to Google's Privacy Policy http://www.google.com/policies/privacy. They are put in place to provide a positive experience for users. We have not enabled Google AdSense on our site but we may do so in the future.

YouTube
The Pencil platform utilizes the YouTube API service. By using the Pencil platform you agree to be bound by the YouTube Terms https://www.youtube.com/t/terms. Please also refer to the Google security settings to manage these permissions https://security.google.com/settings/security/permissions

Does our site allow third-party behavioural tracking?
It's also important to note that we do not allow third-party behavioural tracking.

COPPA (Children Online Privacy Protection Act)
When it comes to the collection of Personal Data from children under the age of 13 years old, the Children's Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States' consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children's privacy and safety online.

We do not specifically market to children under the age of 13 years old.

CAN SPAM Act
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

We collect your email address in order to:
Send information, respond to inquiries, and/or other requests or questions

To be in accordance with CANSPAM, we agree to the following:
- Not use false or misleading subjects or email addresses.
- Identify the message as an advertisement in some reasonable way.
- Include the physical address of our business or site headquarters.
- Monitor third-party email marketing services for compliance, if one is used.
- Honour opt-out/unsubscribe requests quickly.
- Allow users to unsubscribe by using the link at the bottom of each email.

If at any time you would like to unsubscribe from receiving future emails:
Follow the instructions at the bottom of each email and we will promptly remove you from ALL correspondence.

Contacting Us
If there are any questions regarding this document, you may contact us using the information below.

Pencil AI Limited

151 Rosebery Avenue London EC1R 4AB

support@trypencil.com