Last updated on 01.06.2022
Matrx (“Matrx”, “Company”, “we”, “us” or “our”) respects your privacy and is committed to protecting your personal data. This Policy will inform you about how we look after your personal data when you interact with or purchase our products and services on our website https://www.matrx.io and our mobile application Matrx (together, the “Site”) regardless of where you visit or access them from and tell you about your privacy rights and how the law protects you.
By using our Site or any of our services, you agree and consent to the use, collection, sharing and other processing of your data by the Company under this Policy. If you do not agree to this Policy, please cease from using our Site or Services in any way.
The nature of our Site requires us to collect user personal data. This Policy aims to give you information on how we collect and process (which may include collecting, storing, using, or disclosing) your personal data when you use our Site, regardless of your relationship with us (for example, whether you are a licensed or unregistered user) including any data you may provide when you purchase a product or service.
We will only collect and process your personal data where you have provided your express consent to the intended purposes of such collection and processing, to the extent possible and required by personal data protection laws. It is important that you read this Policy together with any other privacy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Policy supplements other notices and privacy policies and is not intended to override them. You may withdraw your consent at any time in line with your rights as detailed here.
Please note that we may process your personal data without your knowledge or consent where this is required or permitted by law.
This website is not intended for children aged 16 and below and we do not knowingly collect data relating to children without consent from their parent or guardian. Should you have reasonable grounds to believe we have collected personal data from a minor without the appropriate consent, you may reach out to us through the contact details listed below and we will endeavour to investigate the matter immediately.
Our Company is made up of different legal entities, details of which can be found on the Group’s website www.tsi.tech. This Policy is issued on behalf of the TSI Group so when we mention TSI Tech Pte. Ltd., the “Company”, "we", "us" or "our" in this Policy, we are referring to the relevant company in our Group responsible for processing your data. TSI Tech Pte. Ltd. is the controller responsible for this website. Other companies in the Group may act as joint processors.
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this Policy. If you have any questions about this Policy, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
Full name of legal entity: TSI Tech Pte. Ltd.
Email address: email@example.com.
Postal address: 38 Beach Road, #17-11 South Beach Tower, Singapore 189767
Telephone number: +65 6272 9924
You also have the right to make a complaint at any time to your local data protection regulator regarding this Policy and our personal data related practices. You may contact your local data protection authority for more information. We would, however, appreciate the chance to deal with your concerns before you approach the relevant authority so please contact us in the first instance.
We keep our privacy policies under regular review to reflect any changes in our Site and our personal data processing mechanisms and safeguards. Subsequent updates to this Policy will be available on the Site and will be indicated as such. You will be notified of any substantial changes to this Policy for your perusal prior to continuing your engagement with us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Personal data, or personal information, means any information about an individual from which that person can be identified, and in some jurisdictions include information pertaining to deceased individuals. It does not include data where the identity has been removed (anonymous data).
Where applicable to the product, we may collect and process different kinds of personal data about you which we have grouped together as follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time. For more information, please see our Terms of Service.
We use different methods to collect data from and about you including through:
You may also provide us the personal data of third parties while using our Site, during which you are deemed to have their consent to do so.
We will only collect and use your personal data where the law allows us subject to receiving your express consent. Most commonly, we will use your personal data in the following circumstances:
Click here to find out more about the types of lawful bases that we will rely on to process your personal data.
We rely on your clear and express consent as a primary legal basis for processing your personal data, especially where processing involves sending third-party direct marketing communications to you via email or text message. You have the right to withdraw consent as listed under Your Legal Rights at any time by contacting us.
We have set out below, in a table format, a description of all the ways we plan to use your personal data and the legal bases we rely on to do so. We have also identified our legitimate interests where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
Type of data
Lawful basis for processing including basis of legitimate interest
To register you as a new customer
Performance of a contract with you
To process and deliver your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(c) Responding to your enquiries
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To enable you to complete a survey
(e) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)
To administer and protect our business and our Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
To deliver relevant Site content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you
(e) Marketing and Communications
Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our Site, products/services, marketing, customer relationships and experiences
Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Site updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you
(f) Marketing and Communications
Necessary for our legitimate interests (to develop our products/services and grow our business)
To the extent required by law, we will obtain your express consent for our (and our third parties’) marketing purposes. We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising as seen in Opting Out below.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us, including tele-marketing correspondences where permitted by local regulations, if you have requested information from us and/or purchased products or services from our Site and have expressly consented to our marketing purposes. Similarly, you will continue to receive marketing notifications where you have been provided the opportunity to withdraw your consent or unsubscribe and you have not opted out of receiving such marketing materials.
We may use third-party marketing and analytics providers to assist us in the comprehensive evaluation of user demand in the market for our products and services and accordingly conduct marketing to promote the same to the public and targeted groups. This is referred to as interest-based marketing. We do not currently permit our partners to use your personal data to advertise through our Site, although we may do so in the future.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes. Nevertheless, we do not disclose your personal data to third parties for the purpose of direct marketing.
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of purchasing our products or services, experience or other any other transactions with us. Nor does this option apply to necessary messages, alerts and notifications sent regarding our products and services as outlined in our Terms of Service.
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Where you have provided your express consent as required by applicable laws, we may share your personal data with selected parties as set out below for the purposes addressed in the table Purposes for Which We Will Use Your Personal Data above.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
As an international group, our Site is available globally and subject to your express consent we may transfer your personal data to any of our internal third parties which may be located outside the data’s initial country of origin for storage and processing as necessary and permitted under this Policy.
We ensure your personal data is protected by requiring all our group of companies to follow the same rules when processing your personal data. These rules are called "binding corporate rules".
Many of our external third parties operate internationally so their processing of your personal data will involve a transfer of data outside your country.
The countries to which the international transfers may be made may have different regulations which provide lesser protection than that of your country. Therefore, where we are legally authorised to transfer your personal data, we safeguard it by ensuring that a sufficient degree of protection is afforded through the implementation of at least one of the below rules:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data.
We have put in place appropriate physical, electronic and administrative security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Our security safeguards will be applied depending on the nature of the data (for example, where it is in transit or at rest). You can find the full details of our security safeguards by visiting our comprehensive data security page here.
In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach immediately where we are legally required to do so in accordance with the applicable laws.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider its amount, nature and sensitivity, the potential risk of harm from unauthorised use or disclosure of your personal data, the length of our relationship with you (such as the period until you cease interacting with or utilising our products and services or our Site, cancel your account with us and/or terminate your subscription with us), the purposes for which we process your personal data and whether we can achieve those purposes through other means, the applicable legal, regulatory, tax and accounting laws as well as other requirements.
In some circumstances, you can ask us to delete your data: see Your Legal Rights below for further information.
Once the purposes for which your personal data was collected have been achieved, we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. Otherwise, where there is no longer a legitimate interest and legal basis in retaining your personal data, it will be destroyed and deleted from our data centres.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please click on the links below to find out more about these rights:
If you wish to exercise any of the rights set out above, please contact our PDO. You will not be discriminated against for doing so.
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). Alternatively, we may refuse to comply with your request to the extent allowed by applicable laws if your request is clearly unfounded, repetitive or excessive.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally, it could take us longer if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Our Site uses different types of cookies such as:
You may set your browser to not accept cookies from our Site by adjusting your browser settings. However, kindly note that disabling cookies may lead you to losing access to certain sections or features of our Site.
We strive to limit the processing of personal data to the extent you have expressly authorized us and where we have a lawful basis to do so. These lawful bases include but are not limited to the following:
Legitimate Interest means the interest of our Company in conducting and managing our business to enable us to give you the best service/product and the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). Legitimate interests may include monitoring, testing, improving and developing our products and services through the analysis of user data in line with our business needs; overseeing product usage and conducting safety and compliance analysis on accounts where required to safeguard public safety, us and our Site. We may also conduct automatic scans across personal data in this regard.
You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the execution of an agreement to which you are a party or to take steps at your request before entering into such a contract.
Comply with a Legal Obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
Internal Third Parties means other companies in our Group acting as joint processors.
External Third Parties refer to the below selected parties based in the relevant jurisdictions:
Subject to local data protection laws, the right to enforce the following legal rights may be limited to you and your authorized representative, and serving us written notice may be a pre-requisite. Regardless, we may have to verify your identity to facilitate any request.
Request Access to Your Personal Data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you, its sources and to check that we are lawfully processing it.
California-based users may request on an annual basis to see how their personal data has been shared to third parties for direct marketing purposes in the previous year under the California Civil Code Section 1798.83. Nevertheless, personal data is not shared with third parties for such purposes. Additionally, while we do not sell the personal data of Californian users, interest-based marketing may be construed locally as selling. For more information, please see Third-Party Marketing.
Request Correction of the Personal Data That We Hold About You. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request Erasure of Your Personal Data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to Processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request Restriction of Processing of Your Personal Data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
Request the Transfer of Your Personal Data to You or to a Third Party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw Consent at any time where we are relying on consent to process your personal data.However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.