Calm Labs Pte Ltd, trading under the name 'vineprice,' with its registered address at 11 Silat Avenue, #41-33 Avenue South Residence, Singapore 168877 ('we', 'us', 'our', the 'Provider' or 'vineprice') welcomes you ('you' or the 'User') on our website www.vineprice.com (the 'Website').

This Privacy Policy (the 'Policy' or 'Privacy Policy') describes the types of information we gather from people visiting our Website and/or using our Platform and Services. Terms starting with a capital letter used in this Policy have the meaning defined in our General Terms and Conditions (the 'Terms'). By accessing the Website, Platform, or using our Services, you agree to adhere to this Policy. If you do not agree to the terms of this Policy, please do not use the Website, Platform, or any of our Services. Each time you use the Website, Platform, or our Services, the current version of the Privacy Policy will apply.

• General principles: We may collect two types of information about you, personal data and aggregate information.
• Personal data: Personal data are a special type of data that can be used to identify you, such as your email. Use of personal data by other persons is limited by regulations such as the GDPR.
• Aggregate information: Aggregate information cannot be used to identify you, but it holds data about your behavior on our website and platform. We use it to improve our services.
• Cookies: Cookies are a piece of data that we store in your browser to identify you and enable you to use the platform without having to log in every time.
• Security pertaining to your information: We keep your information safe by using industry standard encryption and security practices.
• Integrity of your data: We make sure that your information is correct and that we never store more information than we really need for running our platform.
• Children and privacy: We will not store children’s Personal Data without the consent of their parent or legal guardian.
• Links to other websites: We are not responsible for 'content' on any other websites that we 'link' to from our website.
• Business transfers: If someone buys vineprice as a company, the information we manage will be transferred to this new entity.
• Corrections, information removal, opt-out: You can always change or remove the information we store about you by contacting support@vineprice.com.
• Liability and indemnity: If we break this policy, we will accept liability for our actions.
• Final provisions: Laws of Singapore govern this policy. We can change the policy from time to time and we will let you know before we do.

Vineprice may collect two types of information from Users: “Personal Data” and “Aggregate Information” (as defined below).

Processing personal data in a secure, fair, and transparent way is extremely important to us at vineprice. We process personal data in accordance with the Personal Data Protection Act (PDPA) of Singapore and best industry standards.

• Data Subjects: Individuals who are our Users or personnel.
• Personal Data: Any data relating directly or indirectly to an identifiable data subject. Personal data does not include any data that is anonymized, aggregated, de-identified, and/or compiled on a generic basis and which does not name or identify a specific individual, directly or indirectly.
• Processing: Collecting, recording, using, storing, amending, adapting, disclosing, transferring or transmitting, structuring, using, combining, deleting or destroying personal data.
• Controller: A party that determines the purposes and means of the processing of personal data; vineprice is the controller with respect to your personal data.
• Processor: The party that processes personal data on behalf of the controller; vineprice is the processor of your personal data.
• Incident: A complaint or a request with respect to the exercise of an individual's rights under the PDPA; an investigation into or seizure of the personal data by government officials, or a specific indication that such an investigation or seizure is imminent; or any breach of the security and/or confidentiality as set out in this Policy leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, the personal data, or any indication of such breach having taken place or being about to take place.

Vineprice collects personal data that is voluntarily provided when a User on our Website creates an account or logs into their account.

• It will not modify, alter, delete, publish or disclose any User personal data to any third party, nor allow any third party to process such personal data on vineprice's behalf unless the third party is bound to similar confidentiality and data handling provisions.
• Only its personnel, contractors, or third-party providers who “need-to-know” will be given access to User personal data to the extent necessary to perform its obligations under the Terms. It shall provide adequate training to its staff and ensure that they comply with the obligations in this Policy.
• It will implement and maintain a reasonable and appropriate security program comprising adequate security, technical, and organizational measures to protect against unauthorized, unlawful, or accidental processing, use, erasure, loss, or destruction of, or damage to, User's personal data.
• It will only process User personal data to the extent necessary to perform its obligations under the Terms, upon written instructions of the User (only as mutually agreed upon), and in accordance with applicable laws.

Upon your request or termination of your user account, vineprice will delete, destroy, or anonymize the personal data in accordance with our standard backup and retention Policy (no later than 60 days), unless we have terminated your account for violation of the Terms or in other cases foreseen by PDPA and applicable regulation in which we are not obliged to delete, destroy, or anonymize your personal data.

By accepting this Policy, the User warrants that it has all necessary rights to provide to vineprice the personal data for processing in connection with the provision of the services by vineprice. To the extent required by applicable law, the User is responsible for ensuring that any data subject consents that may be necessary to this processing are obtained, and for ensuring that a record of such consents is maintained, including any consent to use personal data that is obtained from third parties. Should such consent be revoked by a data subject, the User is responsible for communicating the fact of such revocation to vineprice, and vineprice remains responsible for implementing any User instruction with respect to the further processing of that personal data, or, as may be in accordance with any of vineprice's legal obligations.

Vineprice shall assist the User by implementing appropriate technical and organizational measures, insofar as this is reasonably and commercially possible (in vineprice's sole determination and discretion), in fulfilling the User's obligations to respond to individuals' requests to exercise rights under the PDPA.

When either party becomes aware of an incident that impacts the processing of personal data, it shall promptly notify the other about the incident and shall reasonably cooperate in order to enable the other party to perform a thorough investigation into the incident, to formulate a correct response, and to take suitable further steps in respect of the incident.

Both parties shall at all times have in place written procedures which enable them to promptly respond to the other about an incident. Where the incident is reasonably likely to require a data breach notification under applicable laws, the party responsible for the incident shall notify the other no later than 24 hours of having become aware of such an incident.

Any notifications made under this section shall be made to support@vineprice.com (when made to vineprice) and to our point of contact with you (when made to the User), and shall contain: (i) a description of the nature of the incident, including, where possible, the categories and approximate number of individuals concerned and the categories and approximate number of records concerned; (ii) the name and contact details of the point of contact where more information can be obtained; (iii) a description of the likely consequences of the incident; and (iv) a description of the measures taken or proposed to be taken to address the incident including, where appropriate, measures to mitigate its possible adverse effects.

Vineprice may also collect aggregate information. Aggregate information is information about your activities on the Website and Platform or in connection with the Services that cannot be used to identify, locate, or contact you (such as frequency of visits to the Website, data entered when using the Website, Website pages most frequently accessed, browser type, etc.).

Aggregate information is collected as you visit our Website (Platform) or interact with our Services even if you do not enter any information. Generally, aggregate information is used in a collective manner, and no single person can be identified by that compiled information. Vineprice uses aggregate information to provide its Services, as well as to determine the use of our Website (Platform) and to monitor, audit, and analyze information pertaining to our business metrics.

We may use aggregate information to improve the Website and Services, to monitor traffic and general usage patterns, and for other general business purposes. We may disclose aggregate information to third parties for a variety of business reasons, including to potential investors so that they may better understand our user base, etc. Aggregate information will not include any personal information, and we will not disclose any personal information except as expressly stated elsewhere in this Policy.

When you access our Website, Platform, or use our Services, we may collect some information in the form of cookies (cookie is a small data file placed on your computer's hard drive that contains information that allows us to track your activity on the Website and Platform).

The cookie itself does not contain any personal information; however, if you provide us with some personal information the cookies may act as an identifier to tie your personal information to your IP address or computer. We are committed to follow the highest standards of privacy protection in relation to cookies. Other than the cookies that are necessary for the Website to function, you can always choose not to allow the cookies while using our Website or Platform. Read more information about the cookies we use and how we use them and ensure your privacy at the same time in our Cookie Policy.

We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. These include internal reviews of our data collection, storage, and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where we store personal data.

We restrict access to collected information to vineprice employees, service providers, and agents who need to know that information in order to operate, develop, or improve our services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

We use Secure Socket Layer ('SSL') and Transport Layer Security ('TLS') technology to encrypt and protect the security of your personal information, including but not limited to your credit card number, when it is sent over the Internet.

Vineprice processes your information only for the purposes for which it was collected and in accordance with this Policy. We review our data collection, storage, and processing practices to ensure that we only collect, store, and process the personal information needed to provide or improve our Services.

We take reasonable steps to ensure that the personal information we process is accurate, complete, and current, but we depend on our users to update or correct their personal information whenever necessary.

Our Website, Platform, and Services are not directed to children, and we will not request personally identifiable information from anyone who we know to be under the age of 18, unless we have obtained verifiable parental consent from a parent or legal guardian.

If we become aware that a user under the age of 18 has registered with our Website, Platform, or Services, provided personal information, and vineprice has not obtained prior verifiable consent from a parent or legal guardian, we will immediately remove the user’s personal information from our files.

The Website (Platform) may contain links to websites operated by other people or companies. Those websites may have their own privacy policy or no privacy policy at all. Vineprice does not have any responsibility for those websites, and we provide the links solely for the convenience of our visitors.

In the event that vineprice sells substantially all of its assets, or one of vineprice’s business units is acquired, personal information of Users will likely be one of the transferred assets.

If your name, e-mail or postal address, telephone number, or other personal information changes, you may update, correct, or omit the relevant information by contacting vineprice User service at support@vineprice.com or by updating your personal information on the Account settings page on the Website.

If you prefer not to receive newsletters or other marketing e-mails from vineprice, please let us know by clicking on the unsubscribe link within any newsletter or marketing e-mail you receive. If you prefer not to receive marketing mail via the mail carrier, please let us know by contacting User service at support@vineprice.com. Please note that such requests may take up to ten (10) days to become effective.

Each party indemnifies the other and holds them harmless against all claims, actions, third-party claims, losses, damages, and expenses incurred by the indemnified party and arising directly or indirectly out of or in connection with a breach of this Policy.

This Policy and any other contracts and legal relationships concluded by and between us (unless otherwise explicitly provided) shall be governed by the laws of Singapore.

Any disputes arising here from between us shall be resolved by the courts of general jurisdiction in Singapore.

Should any of the provisions hereof be ascertained as invalid, ineffective, or unenforceable, upon mutual agreement such a provision shall be replaced by a provision whose sense and purpose comes as closely as possible to the original provision. The invalidity, ineffectiveness, or unenforceability of one provision shall not affect the validity and effectiveness of the remaining provisions hereof.

This Policy shall come into effect when published and shall continue until it is changed or terminated in accordance with the Terms and this Policy. We may change this Policy at any time and without prior notice, by posting the revised version of this Policy on our Website. Your continued use of the Website, Platform, and/or Services indicates your consent to our collection of and use of your personal and aggregate information under the then-current Policy. Termination or expiration of this Policy shall not discharge the parties from the confidentiality obligations herein.