CL Singapore PTE ltd. with its registered office in Singapore at 6 Raffles Quay #11-07, Singapore 048580, ACRA Singapore number 201615510K (further referred to as “Netleaders”) receives requests from users and government agencies to disclose or perform some operations on data other than in the ordinary operation and provision of the Services.
This Data Request Policy outlines Netleader’s policies and procedures for such requests for User Data.
All terms written with capital letters and not defined in this Policy shall bear the meaning specified in the official Netleaders’ documents such as Terms and Conditions, Rules and Regulations and KYC Policy.
Netleaders will notify Customer before disclosing any of Customer’s Customer Data so that the Customer may seek protection from such disclosure, unless the disclosure is necessary to to fulfill Netleaders obligations under the Advocate’s agreement or the License Agreement or Netleaders is prohibited from doing so or there is a clear indication of illegal conduct or risk of harm to people or property associated with the use of such Customer Data.
If Netleaders is legally prohibited from notifying Customer prior to disclosure, Netleaders will take reasonable steps to notify Customer of the demand after the nondisclosure requirement expires.
The Customer controls the User Data and generally gets to decide what to do with all personal User Data.
Under no circumstances will confidential information be released to a private individual who is not the "owner" of the information. Netleaders staff will immediately notify the internal Data Protection Officer when they receive such inquiries about someone else's activities.
If your personal data is being collected and processed by Netleaders you can exercise the following rights in respect of your data:
For any request relating to your personal data please contact us , we will reply you the soonest possible, however not later that within one month of receipt of the request. That period may be extended by two further months where necessary, taking into account the complexity and number of the requests. We shall inform you of any such extension within one month of receipt of the request, together with the reasons for the delay.
Information to Include in a Request
The following information must be included in a request for data:
Netleaders may not be able to respond to a request without this information. Additionally, Netleaders reserves the right to request further identification, and a reason as of why the information is requested.
Netleaders will not disclose information about individual users to any requester unless required to do so by law. Netleaders requires a search warrant issued by a court of competent jurisdiction (a federal court or a court of general criminal jurisdiction of a State authorized by the law of that State to issue search warrants) to disclose User Data.
Netleaders does not accept legal process directly from law enforcement entities outside Singapore and European Union countries. Foreign law enforcement agencies should proceed through a Mutual Legal Assistance Treaty or other diplomatic or legal means to obtain data through a court where Netleaders is located. Netleaders responds to legal process in a manner consistent with the relevant Singapore or EU legislation, and relevant case law.
Netleaders does not disclose account content, including but not limited to, User-created data, absent a search warrant in criminal cases.
We will only consider law enforcement requests that are:
In civil cases, Netleaders cannot disclose content without sufficient legal process and the consent of the appropriate Netleaders customer(s).
Netleaders is committed to the importance of trust and transparency for the benefit of our Customers and does not voluntarily provide governments with access to any data about users for surveillance purposes.
Information to Include in a Request
The following information must be included in a request for User’s data:
Netleaders may not be able to respond to a request without this information.
Netleaders reserves the right to request a copy of the reason and any supporting documentation that demonstrates how the information requested is related to the pending litigation and the underlying subpoena.
All requests by courts, government agencies, or parties involved in litigation for Customer Data disclosures should be sent to [email protected] and include the following information:
A preservation request asks Netleaders to preserve customer account records in connection with official criminal investigations or other official legal proceedings. Preservation requests must include the following information:
Netleaders may seek reimbursement for costs in responding to requests as provided by law and may charge additional fees for costs in responding to unusual or burdensome requests. If legally permitted, Customer will be responsible for any costs arising from Netleaders response to data requests. However the Customer shall not be charged for any requests stemming from his/her rights as described in this Policy. We will provide the Customer a copy of the personal data free of charge. For the following copies we may charge a fee.
Depending on the type of formal legal process provided, Netleaders may be able to respond with one or more of the following types of data
Data will be provided to the requesting party by electronic means unless otherwise requested.
How to contact us about data requests