Privacy Policy

Date of Update : 25 June 2024

  1. OVERVIEW

Spatial Labs Pte. Ltd. (UEN: 202306739R), an exempt private limited company limited by shares incorporated under the laws of Singapore and operating under the trade name KinetixPro ("Spatial Labs"), is located at 2 Venture Drive #14-02 Vision Exchange, Singapore (608526). Spatial Labs has developed a computer vision software platform aimed at automating the detection and prevention of safety risks. This Privacy Policy ("Policy") is designed to inform individuals about the personal data collected through the website and software, the purposes and legal bases for processing such data, the transfer of personal data, and the rights of individuals regarding their personal data under applicable law.

  1. DEFINITIONS AND INTERPRETATION

Data Controller: Any individual or organization that determines the purposes and methods for processing personal data.

Data Processing (or Processing): Any action or series of actions performed on personal data, encompassing collection, storage, transfer, and deletion (but not limited to these).

Data Processor:  An individual or organization that processes personal data on behalf of the designated Data Controller.

Data Subject: The individual to whom the personal data pertains.

EU: The European Union.

EEA: European Economic Area. 

GDPR: Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, concerning the protection of individuals with regard to the processing of personal data and the free movement of such data.

PDPA: The Personal Data Protection Act 2012 of Singapore.

Personal Data: Any information related to an identified or identifiable natural person.

Software: The AI-powered image processing-based workplace safety and security Software application developed and owned by Spatial Labs. This includes any third-party Software and all new versions, updates, revisions, improvements, and modifications to which Spatial Labs provides remote access as part of its services.

Website: Spatial Labs' Website accessible at https://www.kinetixpro.ai 

  1. PROCESSING STANDARDS & PRINCIPLES

Spatial Labs processes personal data in strict compliance with applicable laws, ensuring lawfulness, transparency, and fairness. Data subjects receive clear and comprehensive information about how their personal data is handled.

Personal data is processed solely for specific, explicit purposes disclosed at the time of collection and outlined in this Privacy Policy. Processing beyond these stated purposes is strictly prohibited. Data minimization principles are rigorously observed, ensuring that only the necessary personal data required for processing purposes is collected and maintained.

Spatial Labs implements measures to maintain the accuracy, completeness, and timeliness of personal data. Inaccurate data is promptly corrected or erased as necessary. Personal data is retained only for the duration necessary to fulfill the purposes for which it was collected or as required by applicable legal obligations. Upon completion of these purposes, data is securely deleted or anonymized.

Spatial Labs employs appropriate technical and organizational measures to ensure the confidentiality and integrity of personal data. Access to personal data is restricted to authorized personnel who require it for their job functions, and stringent safeguards are in place to protect against unauthorized access, unlawful processing, accidental loss, destruction, or damage.

  1. PRACTICES FOR DATA COLLECTION
  1. PERSONAL DATA PROVIDED DIRECTLY

    Newsletter Subscriptions: To subscribe to our electronic newsletters containing updates on products, services, and activities, we require your email address for delivery.

    Contact Form Inquiries: Our "Contact" webpage provides designated email addresses categorized by inquiry topic. When you use these addresses, we collect your email address and any additional information you provide in your message.

    Potential Customer Data: For visitors seeking product demonstrations, we may collect personal data, including name, surname, professional email address and title, company industry and location, requested products & services, and any other voluntarily provided information.

    Potential Employee Data: Job applicants submitting applications through our "Careers" section may have their personal data collected, such as name, surname, email address, phone number, current employer and location, resume data (if submitted), LinkedIn profile, links to other relevant websites, and any additional voluntarily provided information.

    Potential Partner Data: Visitors seeking potential partnerships with Spatial Labs via our "Partner with Us" section may have their personal data collected, such as name, surname, company name, location, and any other voluntarily provided information.

    Software Registration & Login: To create your user account and enable access to the Software, we collect data including name, surname, email address, and optional profile picture.

    Software Usage Data: We collect data on software usage patterns, including utilized modules and customer facility locations.

    Support Services Data: To provide software-related support, including handling requests and complaints, we collect your email address and any additional information included in your communication.

    Service Notifications (Opt-in): With your explicit consent, we use your email address and phone number to send notifications related to software usage, such as alerts regarding non-compliance within your facilities.

  1. PERSONAL DATA COLLECTED AUTOMATICALLY

    Log Data: During your visit to our Website and Software, our servers automatically record standard data provided by your web browser. This data may include your computer's IP address, browser type and version, accessed pages, visit times and durations, and other relevant details.

    Device Data: We may collect information about the device used to access our Website and Software, including device type, operating system, unique identifiers, settings, and location data (subject to your device and software settings).

    Cookies: We use cookies to gather information about your activities on our Website. Cookies are small data files stored on your computer by our Website and accessed during subsequent visits, enabling us to understand your usage patterns.

  1. PRACTICES FOR DATA PROCESSING

As a data processor, Spatial Labs handles personal data on behalf of our clients, adhering to their authorization and specified timelines to ensure occupational health and safety and fulfill contractual obligations. Our Software, an AI-based occupational health and safety platform, processes personal data in specific ways.We manage non-biometric images from camera recordings provided by our clients. Rather than continuously recording footage, we analyze video frames and issue alerts if the Software detects potential health or safety risks. If no such risks are detected, the analyzed frames are promptly deleted. Data is also collected from selected cameras for labeling and model training to improve our AI's accuracy. To ensure privacy, all processed images have human faces blurred or masked and pseudonymized. Spatial Labs connects to cameras at our clients' facilities, acting strictly as a data processor. Consequently, we are not positioned to directly inform data subjects (employees) about data processing activities. Clients must include relevant statements about occupational health and safety or other purposes in their existing camera surveillance notices.

  1. LEGAL GROUNDS FOR PROCESSING

We only collect and process your personal data when we have a legal basis to do so under applicable law. As the data controller, we process your personal data based on the following legal grounds:

  1. CONSENT

    Marketing Communications (Email): Your explicit consent constitutes the lawful basis for processing your data to deliver electronic newsletters containing updates on products, services, and other relevant activities.

  1. CONTRACTUAL NECESSITY

    Sales Applications (Name, Surname, Work Email, etc.): Processing your data related to demo requests, sales applications, and associated information is necessary to fulfill our contractual obligations with you or to take preliminary steps at your request prior to entering into such a contract. Additionally, we have a legitimate interest in managing our sales processes and assessing potential customers.

    Conducting Sale and After-Sale Operations (Name, Surname, Email, etc.): Processing your data is necessary to fulfill our contractual obligations towards you or to take preliminary steps at your request before entering into a contract. We also maintain a legitimate interest in effectively managing our sales operations.

    Managing Requests and Complaints (Name, Surname, Email, etc.): Processing your data enables us to fulfill our contractual obligations towards you or to take preliminary steps at your request before entering into a contract.

    Sending Software and Service Updates (Name, Surname, Email Address): Processing your data is necessary to fulfill our contractual obligations towards you or to take preliminary steps at your request before entering into a contract.

  1. LEGITIMATE INTERESTS

    Operating, Customizing, and Improving Website and Software (Log Data, Device Data, Cookies): We have a legitimate interest in continuously enhancing our Website and Software to provide a more user-friendly, transparent, and accessible experience, thereby delivering higher-quality services.

    Analytics and Market Research (Log Data, Device Data, Cookies): We maintain a legitimate interest in analyzing your Website usage patterns, conducting market research, and striving to improve our service offerings. Where required by law, we will obtain your explicit consent for such processing activities.

  1. LEGAL COMPLIANCE

    We reserve the right to process your data when necessary to comply with our legal obligations.

  1. RIGHT TO WITHDRAW CONSENT

    Please note that if you have provided consent for specific processing purposes, you retain the right to withdraw your consent at any time. It is important to understand that withdrawing consent will not affect the lawfulness of processing activities conducted based on your consent prior to its withdrawal.

  1. PURPOSE AND PROCESSING LIMITATIONS

We collect, retain, utilize, and disclose Personal Data solely for the following enumerated purposes, and we will not further process the data in a manner incompatible with these stated intentions without first obtaining your express consent:

Personalized User Experience: We process your Personal Data to personalize your experience on our Website and applications.

Functionality, Communications, and Support: We may process your Personal Data to ensure the proper functioning of our Software and to facilitate communication with you, conduct sales and after-sales services, manage requests and complaints, and provide other support services.

Data-Driven Improvement: We process your Personal Data to perform analytics, market research, and business development activities to enhance the quality of our services.

Responsible AI Development: We may process your Personal Data to improve the accuracy of our artificial intelligence, employing anonymization techniques where feasible.

Internal Operations and Legal Compliance: We process your Personal Data for internal recordkeeping for administrative purposes, conducting audits, furnishing information and documents to authorized bodies upon request, complying with legal obligations, and resolving disputes.

Partnership and Employment Evaluation: We process your Personal Data to review applications for partnerships and employment opportunities.

Legitimate Business Interests (subject to applicable laws and regulations): We may process your Personal Data to offer additional benefits and engage in advertising and marketing activities (including sending promotional information about our products and services and third-party offerings).

  1. DATA RETENTION

We retain personal data only for the duration necessary to provide services and fulfill contractual obligations, with a minimum retention period of thirty (30) days. You have the option to adjust retention periods for different data categories via our Software or by direct communication, provided the new period exceeds thirty (30) days and does not affect data acquired before the adjustment. Your right to request data erasure under applicable law remains intact.

  1. DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES

We may share personal data with third-party service providers involved in delivering our services, such as IT support, data storage, and hosting. Additionally, personal data may be disclosed to our employees, contractors, or related entities. In cases of non-payment disputes, we may provide personal data to courts, tribunals, and regulatory authorities. Furthermore, legal entities and law enforcement agencies may receive personal data for legal proceedings. Third parties that assist in providing information, products, services, or direct marketing may also have access to personal data. For a detailed list of our sub-processors, please contact  

  1. PERSONAL DATA INTERNATIONAL TRANSFERS

The personal data we collect is stored and processed in locations where we or our partners, affiliates, and third-party providers maintain facilities. For GPU server rentals and for static media storage involving visual data processing as a data processor we utilize AWS Cloud. Upon request, we can transfer your data to other regions as permitted by our cloud service providers. By providing us with your personal information, you consent to its disclosure to these overseas third parties. At Spatial Labs, we strive to ensure that appropriate measures are taken to protect your data in compliance with applicable laws, international standards, and industry practices during such transfers. For individuals in the EU, any transfer of personal data from the EEA to countries outside the EEA will be safeguarded by suitable measures, such as standard contractual clauses approved by the European Commission, ensuring a level of protection equivalent to that of the EEA. When transferring personal data from a non-EEA country to another, you acknowledge that third parties in other jurisdictions may not be subject to similar data protection laws as those in our jurisdiction. This may pose risks if such third parties engage in practices that conflict with our jurisdiction's data privacy laws, potentially affecting your ability to seek recourse under our jurisdiction's privacy laws.

  1. SECURITY MEASURES FOR DATA PROTECTION

We implement and maintain administrative and technical measures designed to reasonably safeguard your personal data against unauthorized access, use, disclosure, alteration, and loss. These measures include firewalls, data encryption, dedicated servers, physical access controls to our data centers and offices, strict information access authorization controls, pseudonymization, anonymization, and randomization. However, please note that no method of electronic transmission or storage is entirely secure, and we cannot guarantee absolute data security.

  1. RIGHTS OF DATA SUBJECTS

In accordance with applicable data protection laws, you possess the following rights concerning your Personal Data:

Right to Information (Transparency): You have the right to request clear and concise information about how we use your Personal Data. This includes the purposes of processing, the categories of personal data involved, the recipients of the data, and the intended retention period.

Right of Access (Subject Access Request): You have the right to request a copy of your Personal Data in a commonly used and machine-readable format (e.g., CSV).

Right to Rectification: You have the right to request the correction of any inaccurate or incomplete Personal Data we hold about you.

Right to Erasure (Right to be Forgotten): You have the right to request the deletion or erasure of your Personal Data unless we have a compelling legitimate interest in retaining it (e.g., legal obligations).

Right to Restriction of Processing: You have the right to request the restriction of processing of your Personal Data, meaning we may only store it but not use it further under certain circumstances. We will inform you of the implications of restricting processing on your use of our Website and Software.

Right to Data Portability: You have the right to request the transfer of your Personal Data to another controller in a structured, commonly used, and machine-readable format.

Right to Object: You have the right to object to the processing of your Personal Data based on specific grounds, such as direct marketing.

Rights in Relation to Automated Decision-Making and Profiling: You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or significantly affects you.

  1. AGE RESTRICTION AND USER REPRESENTATIONS

Access to and use of the Website and Software are strictly limited to individuals who have reached the age of sixteen (16) years or are otherwise legally capable of entering into binding contracts under applicable law. If you are under the age of sixteen (16), you may only access and use the Website and Software with the express permission of your parent or legal guardian. Such permission includes their consent to our collection and use of your personal data to the fullest extent permitted by law.

  1. DATA RECEIVED FROM THIRD PARTIES

If we receive your personal data from a third party, we will handle it strictly in accordance with the terms outlined in this Policy. If you are a third party disclosing personal data about another individual to us, you represent and warrant that you have obtained explicit consent from that individual for the disclosure of their personal data to us.

  1. REPORTING DATA BREACHES

We are committed to maintaining high standards of data security. In the event of a data breach, we will promptly notify you within seventy-two (72) hours of becoming aware of the incident.

  1. OPTING OUT OF COMMUNICATIONS

You have the right to opt out of receiving communications from us, including marketing materials. To unsubscribe from our email list or to cease receiving communications, please use the opt-out mechanisms provided within our communications or contact us directly using the information below.

  1. BUSINESS TRANSFERS AND ACQUISITIONS

In the event of a merger, acquisition, reorganization, asset sale, dissolution, bankruptcy, or other similar event (collectively "Business Transfer"), your Personal Data may be transferred as part of the assets of Spatial Labs. You hereby acknowledge and agree that such transfers may occur and that your Personal Data may be transferred to a third party, that is, the successor or acquiring party.

  1. CONTINUED PROCESSING OF PERSONAL DATA

    The acquiring party will be obligated to comply with the terms of this Privacy Policy with respect to your Personal Data. However, we reserve the right to amend this Privacy Policy in accordance with the terms herein following a Business Transfer.  We will endeavor to provide you with reasonable notice of any such amendment, but you are encouraged to periodically review this Privacy Policy for any changes.

  1. YOUR RIGHT TO OPT-OUT

    In the event of a Business Transfer where the acquiring party intends to use your Personal Data in a materially different manner than what is described in this Privacy Policy, you will be given the opportunity to opt-out of such use.  We will provide you with reasonable notice and the means to exercise this opt-out right.

  1. APPLICABLE LAWS AND REGULATIONS

At Spatial Labs, we rigorously comply with data protection regulations such as the PDPA and GDPR. The applicable legal framework may vary depending on your geographical location and the Spatial Labs entity with which you engage for services. Our commitment is to ensure that your data receives protection in accordance with applicable laws, international standards, and industry-specific practices.

  1. PRIVACY POLICY LIMITATIONS

Our Website and Software may include hyperlinks to third-party Websites beyond our operational control. We do not assume responsibility for the content, privacy policies, or security measures of such third-party Websites.

  1. UPDATES TO THIS PRIVACY POLICY

We reserve the right to amend this Policy at any time to reflect changes in our data handling practices, applicable laws, or for other legitimate reasons. The updated Privacy Policy will become effective upon its posting on our Website and Software.We will make reasonable efforts to notify you of any material changes to this Policy, which may include prominently posting a notice on our Website and Software, sending an email to users who have provided an email address, or displaying a pop-up notification within the Website and Software.Your continued use of our Website and Software after the posting of any revised Policy constitutes your acceptance of the updated terms.

  1. CONTACT DETAILS

If you have any questions or concerns regarding this Policy or our data processing practices or wish to exercise your rights as a data subject under applicable data protection laws, you can contact us using the information provided below.

Data Controller: Spatial Labs Pte. Ltd.2 Venture Drive #14-02 Vision Exchange, Singapore (608526)

Email: info@kinetixpro.ai 

Data Protection Officer: Niccolò Bombardieri

Email: info@kinetixpro.aiIf you have a complaint regarding our data privacy practices or believe that we have not addressed your inquiries or requests in accordance with applicable data protection laws, you have the right to lodge a complaint with the data protection supervisory authority in your jurisdiction.