Incharge.gg Privacy Policy

Last modified: 05 Jan 2025

Introduction

This Privacy Policy describes how Incharge LLP (“Incharge.gg”, “we”, “us”, “our”) collects, uses, discloses, and protects personal data in connection with our websites, applications, and services (the “Services”), including https://incharge.gg and related domains (the “Site”). We process personal data in accordance with Singapore’s Personal Data Protection Act 2012 (“PDPA”) and applicable guidelines from the Personal Data Protection Commission (“PDPC”). This policy does not apply to third parties that we do not own or control.

Scope and Consent

By accessing the Site or using the Services, you acknowledge this Privacy Policy and consent to our collection, use, disclosure, and processing of your personal data for the purposes described here. Where required, we will seek fresh consent or rely on applicable PDPA consent exceptions (including deemed consent and the legitimate interests exception assessed with appropriate safeguards). Personal data means data about an identifiable individual, as defined under the PDPA. It does not include anonymised information.

Updates to this Policy

We may amend this Privacy Policy from time to time. We will post updates on the Site with a new “Last modified” date. Your continued use of the Services after an update constitutes acceptance of the changes.

What We Collect

We collect personal data that you provide to us, that is generated through your use of the Services, or obtained from third parties, including: Identification and contact: name, email, phone number, address, date of birth (if required), and similar. Account and transaction data: account credentials, purchase history, payment confirmations (note: payment card/bank details are handled by our payment partners and are not stored by Incharge.gg), top-up/redemption details, support requests, dispute/case logs. Communications: messages via chat or email, support tickets, and correspondence. Technical and usage data: IP address, device identifiers, browser and OS information, logs, pages viewed, referrers, timestamps, cookies/SDKs, and similar telemetry. Third-party data: verification results, fraud/risk signals, marketing preferences, or supplementary information from payment channels, publishers, and anti-fraud providers, as permitted by law.

How We Use Personal Data

We collect, use, and disclose personal data for the following purposes (and related ancillary purposes), consistent with PDPA obligations for consent, purpose limitation, and notification: Provide and operate the Services: account creation, authentication, processing orders and deliveries of digital content, customer service, and troubleshooting. Safety, security, fraud and abuse prevention: detect, investigate, and prevent fraud, chargebacks, unauthorised activity, or violations of our Terms; manage risk and safeguard the Services. Compliance and recordkeeping: comply with laws, regulatory requests, audits, tax and accounting, and to exercise or defend legal claims. Improve and personalise: service quality, research and analytics, feature development, and user experience. Communications: service updates, policy notices, security or incident notices, and transactional messages. Marketing (only with consent or as permitted by law): send offers, promotions, and news; you can opt out at any time. For telemarketing to Singapore numbers, we comply with the Do Not Call (DNC) regime and will check the DNC Registry or rely on clear, unambiguous consent in evidential form where applicable.

Cookies and Similar Technologies

We use cookies, SDKs, and similar technologies to operate the Site (essential cookies), understand usage, and improve our Services. Where required, we seek consent for non-essential cookies and provide controls to manage preferences.

Disclosure of Personal Data

We may disclose personal data to: Payment channels and processors to complete transactions and risk checks. Publishers and content providers to deliver or redeem digital content and for support/investigations. Service providers acting on our behalf (e.g., hosting, security, analytics, customer support, communications). Affiliates, professional advisors, auditors, and insurers for legitimate business purposes. Law enforcement, regulators, or courts as required by law or to protect rights, safety, and security. Business transfers: in connection with a merger, acquisition, or sale of assets (subject to this Policy’s commitments). We do not sell or rent personal data for third-party marketing.

Protection of Personal Data

We implement reasonable administrative, technical, and physical safeguards to protect personal data against unauthorised access, disclosure, modification, or loss, taking into account the nature of the data and risks.

Retention

We retain personal data only for as long as necessary to fulfil the purposes described, or as required for business, legal, or regulatory requirements (e.g., tax, accounting, compliance). When personal data is no longer needed, we will anonymise or securely delete it.

Your Rights and Choices

Subject to exceptions under the PDPA: Access: You may request access to personal data we hold about you and information on how it has been used or disclosed in the past year. Correction: You may request correction of personal data that is inaccurate or incomplete; if not corrected, we will annotate the record. Withdrawal of consent: You may withdraw consent at any time. We will inform you of likely consequences (e.g., we may not be able to provide certain Services). We will continue to retain and use personal data where required or permitted by law.

Data Breach Notification

We maintain processes to manage and assess suspected data incidents. Where a breach is notifiable under the PDPA (e.g., likely to result in significant harm or affects 500 or more individuals), we will notify the PDPC as soon as practicable and no later than 3 calendar days after completing our assessment, and notify affected individuals where required.

Third-Party Sites and Services

Our Services may link to third-party websites or services with their own privacy practices. We are not responsible for their practices. Review the privacy policies of those third parties.