Platform Terms of Use, Privacy Policy & Data Protection Notice of AestheticsLeads.sg

These Platform Terms of Use, Privacy Policy and Data Protection Notice (“Terms” or “Notice”) govern access to and use of AestheticsLeads.sg and explain how Leads Paid (Singapore) Private Limited (“AestheticsLeads”, “we”, “us” or “our”) collects, uses, discloses and otherwise processes personal data in accordance with the Singapore Personal Data Protection Act 2012 (“PDPA”).

1. Organisation and Platform Information

AestheticsLeads.sg is a technology and lead-generation platform through which businesses and service providers (“Clients”) may create, participate in or receive leads generated from advertising and lead-generation campaigns relating to aesthetics, beauty, wellness and related services.

Campaigns may operate through AestheticsLeads.sg itself or through websites, landing pages, forms and other digital properties operated by or on behalf of Leads Paid.

Platform accounts may only be registered and used by persons aged 18 or older who are legally capable of entering into agreements.

By registering for, accessing or using AestheticsLeads.sg as a Client, you agree to these Terms.

2. PDPA Roles

2.1 Processing on Behalf of a Client

Where Leads Paid processes Lead Data solely on behalf of a Client and for purposes determined by that Client under the applicable campaign arrangement, Leads Paid may act as a data intermediary for that processing to the extent provided under the PDPA.

2.2 Processing for Leads Paid's Own Purposes

Where Leads Paid independently determines the purposes for which personal data is collected, used or disclosed, including platform administration, security, fraud prevention, account management, operation of its own websites or allocation of enquiries through a general lead-generation service, Leads Paid is responsible for its own activities under the PDPA.

2.3 Client Responsibility After Lead Delivery

Once Lead Data is lawfully delivered, disclosed or made available to a Client, the Client is independently responsible for its subsequent collection, use, disclosure, communications, storage, security, retention, deletion and compliance with applicable law.

3. Personal Data

For the purposes of this Notice, “personal data” means data, whether true or not, about an individual who can be identified from that data, or from that data together with other information to which the relevant organisation has or is likely to have access.

“Lead Data” means personal data and other information voluntarily submitted through a campaign, website, landing page, form, application or related lead-generation service.

Depending on the nature of the interaction or Campaign, information collected may include:

• name, email address and telephone number;
• company, account and business contact information for platform users;
• billing, transaction and campaign information;
• IP address, browser/device information, usage and security logs;
• information about the aesthetics, beauty, wellness or related service enquired about;
• profile, preference, budget or appointment-related information voluntarily submitted by the individual; and
• other information voluntarily submitted through the relevant Campaign or form.

4. Collection, Use and Disclosure of Personal Data

We generally collect personal data when it is voluntarily provided directly by the individual, provided by an authorised representative, submitted through a Campaign or form, or where collection without consent is otherwise permitted or required by applicable law.

Before or at the time personal data is collected, the applicable form, notice or Campaign information will describe the purposes for which the information may be collected, used or disclosed.

Where required by applicable law, consent will be obtained before collecting additional personal data or using or disclosing personal data for a materially different purpose that has not previously been notified.

We may collect and use personal data for purposes including:

• operating AestheticsLeads.sg and related Campaigns;
• creating, administering and managing Client accounts and Campaigns;
• generating, matching, allocating, delivering and administering Leads;
• operating websites, landing pages and enquiry forms;
• providing customer or Client support;
• billing, reporting, analytics and campaign administration;
• fraud prevention, duplicate detection, security and system monitoring;
• maintaining submission, consent, campaign and delivery records;
• administering agreements, disputes and complaints; and
• complying with applicable laws and lawful regulatory or governmental requests.

5. Disclosure of Personal Data

Personal data may be disclosed, as applicable, to:

• the Client or Clients participating in the relevant Campaign;
• service providers supporting hosting, CRM, communications, security, payments, analytics, software, storage, backup or administration;
• professional advisers where reasonably necessary;
• governmental, regulatory, judicial or law-enforcement authorities where required or permitted by law; and
• other persons where the individual has consented or applicable law otherwise permits the disclosure.

Lead Data must not be used by a Client for unrelated marketing or materially different purposes unless the applicable notice, consent or law permits that use.

6. Client Responsibilities for Lead Data

After receiving Lead Data, the Client must:

• use the Lead only for permitted and lawful purposes;
• comply with applicable personal-data, advertising, marketing and sector-specific laws;
• maintain reasonable security for the Lead Data;
• not unlawfully sell, re-supply or disclose the Lead Data to unrelated third parties;
• honour applicable withdrawal or cessation-of-contact requests;
• retain the Lead Data only for as long as reasonably required for legitimate legal or business purposes; and
• obtain any further consent required for materially different purposes or communications.

Nothing in these Terms transfers to AestheticsLeads responsibility for independent acts or omissions of a Client after lawful Lead delivery.

7. Communications and Do Not Call Requirements

The Client independently determines whether, when and how it communicates with a Lead after receiving Lead Data and is responsible for complying with the laws applicable to those communications.

Where the Singapore Do Not Call provisions apply, the Client is responsible for complying with those provisions in relation to communications made or authorised by the Client.

AestheticsLeads does not represent that a Lead has provided consent overriding registration on the Do Not Call Registry unless such consent is expressly identified or evidenced as part of that Lead or Campaign.

8. Withdrawing Consent

Consent remains valid until withdrawn, unless processing without consent is permitted or required by applicable law.

An individual may withdraw consent in relation to personal data held by Leads Paid by contacting our Data Protection Officer in writing or by email using the contact details below.

Upon receiving a withdrawal request, we may inform the individual of the likely consequences of the withdrawal and will take reasonable steps to give effect to a valid request as soon as reasonably practicable.

Where Lead Data has already been lawfully delivered to a Client, that Client is independently responsible for handling withdrawal or cessation-of-contact requests relating to its subsequent activities. Where reasonably necessary, Leads Paid may inform the relevant Client of a withdrawal request.

Withdrawal does not affect collection, use or disclosure that lawfully occurred before the withdrawal took effect, or processing otherwise permitted or required by law.

9. Access to and Correction of Personal Data

An individual may contact our Data Protection Officer to request access to personal data in Leads Paid's possession or control, information about how that personal data was used or disclosed within the applicable period, or correction of an error or omission.

A reasonable fee may be charged for an access request where permitted by law. If a fee applies, we will inform the requester before processing the request.

We will respond as soon as reasonably possible. If we are unable to complete an access or correction request within 30 calendar days after receiving it, we will inform the requester in writing within that period of when we expect to respond.

Where the request concerns Lead Data independently held by a Client after delivery, the individual may also need to contact that Client.

10. Accuracy of Personal Data

We generally rely on personal data provided by the individual, the individual's authorised representative or the Client, as applicable.

Where personal data in Leads Paid's possession or control is likely to be used to make a decision affecting an individual or disclosed to another organisation, reasonable steps appropriate to the circumstances will be taken to ensure that the personal data is sufficiently accurate and complete.

11. Protection of Personal Data

We maintain reasonable administrative, physical and technical measures designed to protect personal data in our possession or control against unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks.

Measures may include, where appropriate, authentication and access controls, secure transmission, restricted administrative access, software/security updates, backups, logging and periodic review of security arrangements.

No method of Internet transmission or electronic storage is completely secure. We review security arrangements where reasonably appropriate.

Clients are independently responsible for protecting copies of Lead Data after delivery.

12. Retention of Personal Data

We generally retain full identifiable Lead Data only for as long as reasonably necessary for lead generation, delivery, administration, lead-quality review, replacement or dispute handling.

Unless a longer period is reasonably required for an active complaint, dispute, investigation, legal obligation or other legitimate business purpose, full identifiable Lead Data will normally be deleted or anonymised within 60 days after delivery to the Client.

Minimal records reasonably necessary to evidence the submission, consent, applicable consent or policy version, campaign source, delivery and related compliance matters may be retained for a longer period where reasonably necessary for legal, compliance, audit or dispute-resolution purposes.

Withdrawal or Do-Not-Contact records may be retained in a minimal form for as long as reasonably necessary to ensure the request continues to be respected.

Clients are independently responsible for their own copies of Lead Data after delivery.

13. Transfers of Personal Data Outside Singapore

Our systems, hosting providers or service providers may process or store personal data outside Singapore.

Where Leads Paid transfers personal data outside Singapore, we will take steps required under the PDPA to ensure that the transferred personal data receives a standard of protection comparable to that provided under the PDPA, unless an applicable exception applies.

Clients are independently responsible for overseas transfers subsequently undertaken by them.

14. Data Breach Management

We maintain processes for responding to suspected or confirmed personal-data breaches affecting data in Leads Paid's possession or control.

Where a breach is notifiable under applicable law, Leads Paid will make the notifications required of it. Where Leads Paid is acting solely as a data intermediary for a Client, it will notify the relevant Client as required by applicable law.

15. AI and Automated Technology

AestheticsLeads may use artificial intelligence or automated technology to assist with campaign content, advertising creatives, landing pages, optimisation, analytics or platform operations.

Clients are responsible for reviewing Client-facing claims, representations and materials supplied or approved by them.

16. Lead Quality, Payments and Platform Use

AestheticsLeads does not guarantee that every Lead will answer, purchase services or convert into a customer, nor does it guarantee the accuracy of information voluntarily submitted by an individual.

Campaign services may operate using prepaid balances, subscriptions, campaign budgets, per-Lead charges or other agreed billing arrangements. Applicable prices, billing rules and replacement policies may be specified separately.

Clients must not use Lead Data unlawfully, create fake or fraudulent Leads, manipulate Campaigns using bots, compromise platform security or infringe privacy or intellectual-property rights.

17. Client Content, Intellectual Property and Service Availability

A Client grants AestheticsLeads a limited licence to use materials, names, branding, logos, images and other content supplied by the Client solely as reasonably necessary to provide the Platform or Campaign services.

The Platform, technology, software, design, systems and AestheticsLeads branding belong to Leads Paid or its licensors.

AestheticsLeads may modify, suspend or discontinue parts of the Platform and does not guarantee uninterrupted or error-free operation.

18. Limitation of Liability and Client Indemnity

To the maximum extent permitted by law, Leads Paid shall not be liable for indirect, consequential, incidental, special or loss-of-profit damages arising from the Platform, Campaigns or Leads, or for losses caused by a Client's independent acts or omissions.

Except for liability that cannot lawfully be excluded or limited, Leads Paid's aggregate liability arising from the Platform or these Terms shall not exceed the amount paid by the Client to Leads Paid during the three months immediately preceding the event giving rise to the claim.

To the maximum extent permitted by law, the Client shall indemnify Leads Paid against third-party claims, regulatory claims, reasonable legal costs and losses to the extent arising from the Client's unlawful use of Lead Data, communications, security failures, unauthorised disclosure, breach of applicable law or breach of these Terms.

This clause does not make the Client responsible for breaches caused solely by Leads Paid's own unlawful acts.

19. Suspension, Termination and Independent Parties

AestheticsLeads may suspend or terminate Client access where the Client materially breaches these Terms, fails to make required payments, creates a security or fraud risk, unlawfully handles Lead Data or otherwise uses the Platform in a manner reasonably likely to cause legal or regulatory harm.

AestheticsLeads and each Client act as independent businesses. Nothing in these Terms creates a partnership, joint venture, employment relationship or agency.

20. Children

AestheticsLeads.sg platform accounts are not intended for children. Personal data collected through individual lead-generation websites, forms or Campaigns is subject to the privacy notice and consent requirements applicable to that website, form or Campaign.

21. Data Protection Officer

You may contact our Data Protection Officer regarding this Notice, access or correction requests, withdrawal of consent, privacy concerns or other personal-data matters.

Data Protection Officer
Leads Paid (Singapore) Private Limited
Email:

22. Effect of Notice and Changes

This Notice applies together with any other privacy notices, Campaign notices, contractual clauses or consent statements applicable to the collection, use or disclosure of personal data.

We may revise this Notice from time to time. The current version and last-updated date will be published on AestheticsLeads.sg.

Where a proposed use or disclosure is materially different from a purpose previously notified and additional consent is required by applicable law, that consent will be obtained before the new use or disclosure.

23. Business Transfers and External Services

Where Leads Paid undergoes a merger, restructuring, acquisition, financing or sale of business or assets, information may be transferred as part of that transaction subject to applicable law.

The Platform may contain links to or integrations with third-party services. Leads Paid is not responsible for the independent privacy practices, services or content of third parties.

24. Governing Law

These Terms are governed by the laws of Singapore and the courts of Singapore shall have jurisdiction over disputes arising from these Terms.