1. Definitions and Interpretation

1.1 In this Privacy Policy, unless the context otherwise requires:

Experience means any experience, activity, event, product or service offered, organised, operated or made available by Project Xperience through the Platform.

PDPA means the Personal Data Protection Act 2012 of Singapore, as amended, supplemented or replaced from time to time.

Personal Data has the meaning given to that term under the PDPA.

Platform means Project Xperience’s website, web application and any other digital platforms, products or services operated or made available by Project Xperience from time to time.

Project Xperience, “we”, “us” or “our” means Xperience Creation Pte. Ltd. (UEN: 202106049Z).

User Account means an account registered with Project Xperience that enables a user to access or use certain features, products or services available through the Platform.

1.2 Unless the context otherwise requires:

(a) headings are included for convenience only and do not affect the interpretation of this Privacy Policy;

(b) words importing the singular include the plural and vice versa;

(c) references to any law or legislation include any amendment, re-enactment or replacement of that law or legislation from time to time; and

(d) references to “including” or similar expressions are to be construed without limitation.

2. Introduction

2.1 This Privacy Policy (“Privacy Policy”) explains how Xperience Creation Pte. Ltd. (“Project Xperience”, “we”, “us” or “our”) collects, uses, discloses, stores, transfers and otherwise processes your Personal Data when you access or use our website, web application, products and services (collectively, the “Platform”), or otherwise interact with us.

2.2 We are committed to protecting your Personal Data and handling it responsibly in accordance with the Personal Data Protection Act 2012 of Singapore (“PDPA”) and other applicable laws and regulations.

2.3 This Privacy Policy forms part of the legal terms governing your use of the Platform and should be read together with our Terms & Conditions, Experience Policy, Auction Terms & Conditions and any other policies or notices that we may publish from time to time.

2.4 By creating an account, accessing or using the Platform, submitting information to us, or otherwise interacting with Project Xperience, you acknowledge that your Personal Data may be collected, used, disclosed and otherwise processed in accordance with this Privacy Policy, to the extent permitted by applicable law.

2.5 If you do not agree with this Privacy Policy, you should not access or use the Platform or provide your Personal Data to us.

2.6 Where required by applicable law, we will obtain your consent before collecting, using or disclosing your Personal Data for specific purposes. You may also withdraw your consent in accordance with Clause 17 of this Privacy Policy, subject to applicable legal or contractual restrictions and reasonable notice.

3. Scope of this Privacy Policy

3.1 This Privacy Policy applies to the collection, use, disclosure, storage, transfer and other processing of Personal Data by Project Xperience in connection with:

(a) your access to or use of the Platform;

(b) your registration for, maintenance of or use of a User Account;

(c) your purchase of, participation in or interaction with any Experience offered through the Platform;

(d) your participation in auctions conducted through the Platform, including auction registration, bidding activities, payment processing and related services;

(e) your communications and interactions with Project Xperience, including customer support enquiries, feedback, surveys and other correspondence;

(f) your attendance at Experiences or events organised, arranged or facilitated by Project Xperience;

(g) your subscription to newsletters, promotional communications or marketing materials where you have chosen to receive them; and

(h) any other products, services or interactions that refer or are subject to this Privacy Policy.

3.2 This Privacy Policy applies to Personal Data relating to:

(a) registered users of the Platform;

(b) prospective users who interact with Project Xperience before creating a User Account;

(c) purchasers, bidders and participants of Experiences;

(d) individuals who communicate or otherwise interact with Project Xperience; and

(e) any other individual whose Personal Data is provided to Project Xperience in connection with the provision of our products or services.

3.3 This Privacy Policy does not apply to the collection, use or disclosure of information by third-party websites, applications, payment providers or other services that are not owned or controlled by Project Xperience, even if they are accessible through links or integrations available on the Platform. Such third parties are governed by their own privacy policies and terms, and we encourage you to review them before providing your Personal Data.

3.4 Where applicable law requires a different standard of protection or grants additional rights relating to the processing of Personal Data, Project Xperience will comply with such legal requirements to the extent they apply.

4. Personal Data We Collect

4.1 Depending on how you interact with the Platform and our services, Project Xperience may collect, use and process the following categories of Personal Data:

(a) Identity Information, including your name, date of birth, gender (where applicable), nationality (where applicable), government-issued identification information where reasonably required for identity verification, regulatory compliance, fraud prevention, security purposes or the administration of an Experience, and other information used to identify you.

(b) Contact Information, including your email address, telephone number, mailing address and other contact details that you provide to us.

(c) Account Information, including your User Account details, login credentials, encrypted password, email verification status, account preferences, profile information and other information relating to the administration of your User Account.

(d) Transaction Information, including details relating to your purchases, auction participation, bids submitted, Experiences purchased, payment status, refunds, invoices, receipts, order history and other transaction records.

(e) Payment Information, including payment transaction identifiers, payment status, payment method, billing information and other information received from our payment service providers in connection with payments processed through the Platform. Project Xperience does not store your complete payment card details.

(f) Experience Information, including your selected Experiences, attendance confirmations, participant information, guest information that you choose to provide, preferences, special requests and other information reasonably required for the delivery of an Experience.

(g) Communications Information, including enquiries, feedback, customer support requests, correspondence, survey responses and other communications between you and Project Xperience.

(h) Technical Information, including your IP address, browser type and version, device type, operating system, language settings, time zone, session identifiers, diagnostic information and other technical information generated through your access to or use of the Platform.

(i) Usage Information, including information about how you access and use the Platform, pages viewed, features used, clicks, navigation paths, referring websites, session duration, timestamps and other usage analytics.

(j) Security Information, including authentication records, login history, security logs, device information, fraud detection records, suspicious activity reports and other information reasonably required to maintain the security, integrity and proper operation of the Platform.

(k) Marketing Information, including your communication preferences, subscription status, marketing consent records and your preferences regarding promotional communications from Project Xperience.

4.2 In certain circumstances, we may also collect additional Personal Data where reasonably necessary to:

(a) verify your identity;

(b) comply with applicable laws or regulatory requirements;

(c) investigate fraud, suspected unlawful activity or security incidents;

(d) resolve disputes or complaints;

(e) enforce our legal rights or contractual rights; or

(f) provide or administer a particular product, service or Experience requested by you.

4.3 You are responsible for ensuring that the Personal Data you provide to Project Xperience is accurate, complete and up to date. Where you provide Personal Data relating to another individual, you represent that you have the authority or consent to provide such Personal Data to Project Xperience for the relevant purpose.

4.4 You are not required to provide Personal Data where it is optional. However, if you choose not to provide certain Personal Data that is necessary for the provision of our products or services, we may be unable to create or maintain your User Account, process transactions, provide Experiences, or otherwise make certain features of the Platform available to you.

5. How We Collect Personal Data

5.1 Project Xperience may collect Personal Data from a variety of lawful sources, including directly from you, automatically through your use of the Platform, and from third parties where permitted by applicable law.

5.2 We may collect Personal Data directly from you when you:

(a) create, verify or manage your User Account;

(b) purchase, reserve or participate in an Experience;

(c) register for or participate in an auction;

(d) submit bids or make payments through the Platform;

(e) communicate with us through email, contact forms, customer support or other communication channels;

(f) subscribe to newsletters or marketing communications;

(g) complete surveys, questionnaires or promotional activities;

(h) submit reviews, feedback or other content; or

(i) otherwise provide Personal Data to us.

5.3 We may automatically collect certain Personal Data when you access or use the Platform, including through cookies, system logs and similar technologies. Such information may include Technical Information, Usage Information, Security Information and other information generated through your interaction with the Platform.

5.4 We may receive Personal Data from third parties, including:

(a) payment service providers and payment processors in connection with payment transactions;

(b) technology service providers, application platform providers, hosting providers, cloud service providers, database hosting providers, automation service providers, email delivery service providers and infrastructure providers that support the operation of the Platform;

(c) analytics, security and fraud prevention service providers;

(d) business partners, collaborators, Experience providers or event venues where reasonably necessary for the administration or delivery of an Experience;

(e) professional advisers, auditors, insurers and legal advisers where reasonably necessary;

(f) government authorities, regulatory bodies, law enforcement agencies or other public authorities where required or authorised by applicable law; and

(g) any other third party where you have authorised the disclosure or where otherwise permitted by applicable law.

5.5 We may combine Personal Data collected from different sources where reasonably necessary to provide our products and services, administer the Platform, improve user experience, protect the security and integrity of the Platform, comply with legal obligations or for other purposes described in this Privacy Policy.

5.6 Where we receive Personal Data from a third party, we will process such Personal Data in accordance with this Privacy Policy and applicable law.

6. How We Use Personal Data

6.1 Project Xperience may collect, use and otherwise process your Personal Data for one or more of the following purposes, where permitted or required by applicable law:

Account Administration

(a) creating, verifying, administering and maintaining your User Account;

(b) authenticating your identity and managing your access to the Platform;

(c) communicating with you regarding your User Account, including email verification, password resets, account security notifications and other administrative communications;

Provision of Products and Services

(d) providing, administering and delivering Experiences, products and services offered through the Platform;

(e) processing purchases, reservations, auction participation, bids, payments, refunds and related transactions;

(f) facilitating communications relating to your purchases, Experiences or transactions;

(g) issuing confirmations, receipts, invoices and other transaction records;

(h) administering customer support, enquiries, requests, complaints and feedback;

Operation of the Platform

(i) operating, maintaining, monitoring and improving the Platform and our services;

(j) developing, testing and introducing new products, services, features or functionality;

(k) personalising your experience on the Platform where appropriate;

(l) monitoring usage of the Platform, analysing performance and improving user experience;

Security and Fraud Prevention

(m) protecting the security, integrity and availability of the Platform;

(n) verifying identities and detecting, preventing or investigating fraud, unauthorised access, suspicious activity, abuse or other unlawful conduct;

(o) maintaining audit logs, security records and authentication records;

(p) enforcing our Terms & Conditions, Auction Terms & Conditions, Experience Policy and other applicable policies;

Legal and Regulatory Compliance

(q) complying with applicable laws, regulations, regulatory requirements, court orders and lawful requests from governmental or regulatory authorities;

(r) establishing, exercising or defending legal rights and claims;

(s) conducting internal investigations, dispute resolution, risk management, auditing and compliance activities;

(t) maintaining accounting, taxation, financial reporting and other business records required by applicable law;

Communications and Marketing

(u) sending service-related announcements, operational notices and other communications necessary for the administration of your User Account or our services;

(v) sending newsletters, promotional materials, marketing communications or information regarding products, services or Experiences that may be of interest to you, where permitted by applicable law or where you have provided the necessary consent;

(w) administering promotions, surveys, competitions or other marketing initiatives;

Business Operations

(x) managing our day-to-day business operations and internal administration;

(y) evaluating, analysing and improving our products, services, business operations, business planning and customer experience; and

(z) carrying out any other purpose reasonably related to the purposes described above or otherwise permitted or required by applicable law.

6.2 Where required by applicable law, Project Xperience will obtain your consent before collecting, using or disclosing your Personal Data for a purpose requiring such consent.

6.3 Project Xperience may also use Personal Data that has been anonymised or aggregated in a manner that no longer identifies any individual for business analytics, statistical reporting, service improvement, research or other lawful purposes.

6.4 We will only use your Personal Data for the purposes for which it was collected, unless we reasonably consider that it is necessary to use the Personal Data for another purpose that is compatible with the original purpose of collection or otherwise permitted or required by applicable law.

7. Legal Bases for Processing Personal Data

7.1 Project Xperience collects, uses and discloses Personal Data only where permitted or required under applicable law. Depending on the circumstances, we may process your Personal Data on one or more of the following legal grounds:

(a) where you have provided your consent;

(b) where the processing is reasonably necessary for the performance of a contract or to provide the products or services that you have requested;

(c) where the processing is reasonably necessary to comply with applicable laws, regulations, regulatory requirements or lawful requests from governmental or regulatory authorities;

(d) where the processing is reasonably necessary to protect the security, integrity or proper operation of the Platform, our business operations, our users or other persons;

(e) where the processing is reasonably necessary to establish, exercise or defend legal rights or claims, investigate disputes, prevent fraud or unlawful activities, or enforce our contractual or legal rights; or

(f) where the processing is otherwise permitted or required under applicable law.

7.2 Where your consent is required under applicable law, you may withdraw your consent at any time by contacting us in accordance with Clause 17 of this Privacy Policy. Withdrawal of consent will not affect the lawfulness of any collection, use or disclosure of your Personal Data that occurred before your withdrawal took effect.

7.3 If you withdraw your consent to the collection, use or disclosure of Personal Data that is necessary for Project Xperience to provide the Platform or certain products or services, we may be unable to continue providing all or part of the Platform, maintain your User Account, process transactions or provide certain products, services or Experiences.

7.4 Nothing in this Privacy Policy limits any right of Project Xperience to collect, use or disclose Personal Data without consent where such collection, use or disclosure is permitted or required under the PDPA or any other applicable law.

8. Marketing Communications

8.1 Subject to applicable law, Project Xperience may send you newsletters, promotional materials, updates regarding Experiences, special offers, events, new products or services, and other marketing communications that we believe may be of interest to you.

8.2 Where required by applicable law, we will obtain your consent before sending you marketing communications.

8.3 Where Project Xperience sends marketing communications by telephone call, text message, SMS, WhatsApp or other telephone number-based communication channels, Project Xperience will do so in accordance with applicable laws and regulations, including the Do Not Call provisions under Singapore law where applicable.

8.4 You may withdraw your consent to receive marketing communications or opt out at any time by:

(a) following the unsubscribe instructions contained in the relevant marketing communication;

(b) updating your communication preferences through your User Account, where such functionality is available; or

(c) contacting Project Xperience using the contact details provided in this Privacy Policy.

8.5 Your decision to opt out of marketing communications will not affect:

(a) service-related communications;

(b) account administration communications;

(c) security notifications;

(d) transaction confirmations;

(e) payment receipts, invoices or refund notifications;

(f) auction-related notifications;

(g) updates relating to your purchases, bookings or Experiences; or

(h) any other communications that are necessary for the administration of your User Account, the performance of our contractual obligations or compliance with applicable law.

8.6 We may continue to send communications described in Clause 8.4 even if you have opted out of receiving marketing communications, as such communications are necessary for the operation of the Platform, the provision of our products and services, or compliance with applicable law.

9. Sharing and Disclosure of Personal Data

9.1 Project Xperience may disclose your Personal Data where reasonably necessary for the purposes described in this Privacy Policy, including to the following categories of recipients:

(a) our employees, officers, directors and authorised personnel who require access to the Personal Data for the performance of their duties;

(b) our service providers, contractors and vendors who provide services on our behalf, including application platform services, database hosting, payment processing, cloud hosting, automation services, email delivery services, information technology, cybersecurity, communications, customer support, analytics, data storage and other operational services;

(c) payment service providers, financial institutions and payment processors involved in processing payments, refunds and related financial transactions;

(d) collaborators, Experience providers, venues, event organisers and other third parties involved in organising, administering or delivering an Experience, but only to the extent reasonably necessary for the relevant Experience;

(e) our professional advisers, including lawyers, auditors, accountants, insurers and other professional consultants;

(f) government authorities, regulatory bodies, statutory boards, law enforcement agencies, courts or other public authorities where disclosure is required or permitted by applicable law;

(g) any person where disclosure is necessary to establish, exercise or defend legal rights or claims, investigate fraud or suspected unlawful activity, resolve disputes or enforce our legal or contractual rights;

(h) any person in connection with a proposed or actual merger, acquisition, restructuring, financing, sale of assets or other corporate transaction involving Project Xperience, subject to appropriate confidentiality obligations; and

(i) any other person where you have authorised the disclosure or where such disclosure is otherwise permitted or required by applicable law.

9.2 Project Xperience does not sell or rent your Personal Data to third parties for their own direct marketing purposes.

9.3 Where Project Xperience engages third-party service providers to process Personal Data on our behalf, we take reasonable steps to require such service providers to protect Personal Data appropriately and to process it only for authorised purposes and in accordance with applicable law.

9.4 Where Personal Data is disclosed to collaborators, Experience providers, venues or other third parties for the administration or delivery of an Experience, such recipients are expected to use the Personal Data only for the purposes for which it was disclosed and in accordance with their applicable legal obligations.

9.5 Project Xperience may also disclose Personal Data where we reasonably believe that such disclosure is necessary to protect the rights, property, safety or security of Project Xperience, our users, collaborators or any other person, or to prevent, detect or investigate fraud, security incidents or unlawful activities.

10. International Transfers of Personal Data

10.1 In the course of operating the Platform and providing our products and services, Project Xperience may engage third-party service providers that process or store Personal Data in Singapore or in other jurisdictions.

10.2 Such service providers may include providers of application hosting, cloud infrastructure, database hosting and management, payment processing, information technology, cybersecurity, communications, analytics, customer support and other operational services.

10.3 As a result, your Personal Data may be transferred to, processed in or accessed from jurisdictions outside Singapore where such service providers operate or maintain their systems.

10.4 Where Personal Data is transferred outside Singapore, Project Xperience will take reasonable steps to ensure that the Personal Data continues to receive a standard of protection that is comparable to the protection required under the Personal Data Protection Act 2012 of Singapore (“PDPA”), including by implementing appropriate contractual, technical or organisational safeguards where required or appropriate.

10.5 By using the Platform or otherwise providing your Personal Data to Project Xperience, you acknowledge that your Personal Data may be transferred, processed or stored in accordance with this Clause and this Privacy Policy, to the extent permitted by applicable law.

11. Data Retention

11.1 Project Xperience will retain Personal Data only for as long as it is reasonably necessary to fulfil the purposes for which it was collected, including the purposes described in this Privacy Policy, or as otherwise required or permitted by applicable law.

11.2 The period for which Personal Data is retained may vary depending on factors including:

(a) the nature of the Personal Data;

(b) the purpose for which the Personal Data was collected and processed;

(c) legal, regulatory, accounting, taxation or reporting requirements;

(d) contractual obligations;

(e) the need to establish, exercise or defend legal rights or claims;

(f) the prevention, detection or investigation of fraud, security incidents or unlawful activities; and

(g) operational or business requirements reasonably necessary for the administration of the Platform and our services.

11.3 Where you request the deletion of your User Account, Project Xperience will take reasonable steps to delete, anonymise or otherwise cease retaining your Personal Data where it is no longer required for the purposes for which it was collected, subject to Clause 11.4 and applicable law.

11.4 Notwithstanding Clause 11.3, Project Xperience may retain certain Personal Data where reasonably necessary to:

(a) comply with applicable laws, regulations or lawful requests from governmental or regulatory authorities;

(b) maintain accounting, taxation, financial reporting or transaction records;

(c) complete or administer outstanding transactions, refunds or other contractual obligations;

(d) establish, exercise or defend legal rights or claims;

(e) resolve disputes or complaints;

(f) prevent, detect or investigate fraud, security incidents or unlawful activities;

(g) enforce our Terms & Conditions, Experience Policy, Auction Terms & Conditions or other applicable policies; or

(h) fulfil any other purpose permitted or required under applicable law.

11.5 Where Personal Data is no longer required to be retained, Project Xperience will take reasonable steps to securely delete, anonymise or otherwise dispose of such Personal Data in accordance with our internal policies and applicable law.

12. Security of Personal Data

12.1 Project Xperience is committed to protecting your Personal Data and takes reasonable administrative, physical and technical measures designed to safeguard Personal Data against unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks.

12.2 Such measures may include, where appropriate:

(a) restricting access to Personal Data to authorised personnel who require such access for the performance of their duties;

(b) implementing authentication, access control and account security measures;

(c) using industry-standard encryption and secure communication technologies where appropriate;

(d) maintaining security monitoring, logging and auditing processes;

(e) implementing measures designed to detect, prevent and respond to fraud, unauthorised access and other security incidents; and

(f) engaging reputable third-party service providers that maintain appropriate security measures for the services they provide on our behalf.

12.3 Where Project Xperience engages third-party service providers to provide application hosting, cloud infrastructure, database hosting, payment processing or other technology services, we take reasonable steps to require such service providers to implement appropriate safeguards to protect Personal Data in accordance with applicable law and their contractual obligations.

12.4 You are responsible for maintaining the confidentiality of your User Account credentials and for taking appropriate steps to protect your account, including:

(a) keeping your login credentials confidential;

(b) choosing a strong password;

(c) not sharing your password or verification codes with any other person; and

(d) notifying Project Xperience promptly if you become aware of any unauthorised access to your User Account or any suspected security incident.

12.5 While Project Xperience takes reasonable measures to protect Personal Data, no method of transmission over the Internet or electronic storage is completely secure. Accordingly, we cannot guarantee the absolute security of Personal Data transmitted to or stored by the Platform.

12.6 In the event of a security incident affecting Personal Data, Project Xperience will take such steps as we consider appropriate under the circumstances, including complying with any applicable legal or regulatory obligations relating to the assessment, management, notification and reporting of data breaches, including any notification obligations where required by applicable law.

13. Cookies and Similar Technologies

13.1 Project Xperience may use cookies, web storage technologies, pixels, tags and other similar technologies (“Cookies”) to operate, maintain, secure and improve the Platform.

13.2 Cookies are small text files or similar technologies that are stored on your device when you access or use the Platform. They help us recognise your browser or device and remember certain information relating to your use of the Platform.

13.3 Project Xperience may use Cookies for purposes including:

(a) enabling the core functionality and operation of the Platform;

(b) maintaining your login session and account authentication;

(c) remembering your preferences and settings;

(d) improving the performance, functionality and usability of the Platform;

(e) monitoring and analysing usage of the Platform to better understand how users interact with our products and services;

(f) protecting the security and integrity of the Platform, including detecting fraudulent or suspicious activities; and

(g) any other purpose reasonably necessary for the operation, maintenance or improvement of the Platform.

13.4 Some Cookies may be placed or managed by third-party service providers that assist Project Xperience in operating, securing, analysing or improving the Platform. Such third-party service providers are authorised to use such Cookies only for the purposes for which they have been engaged by Project Xperience or as otherwise described in their own privacy policies.

13.5 Most web browsers allow you to manage, disable or delete Cookies through your browser settings. However, if you choose to disable certain Cookies, some features or functionality of the Platform may not operate properly or may become unavailable.

13.6 By continuing to access or use the Platform with Cookies enabled in your browser or device settings, you acknowledge that Cookies may be used in accordance with this Privacy Policy, to the extent permitted by applicable law.

14. Third-Party Services and Links

14.1 The Platform may contain links to, integrate with, or otherwise enable access to websites, applications, products or services provided by third parties (“Third-Party Services”).

14.2 Third-Party Services are operated independently of Project Xperience and are subject to their own terms of use, privacy policies and other applicable policies. Project Xperience does not control and is not responsible for the privacy practices, content, security or operation of any Third-Party Services.

14.3 Where you choose to access or use a Third-Party Service, any collection, use, disclosure or other processing of your Personal Data by that third party will be governed by its own privacy policy and applicable terms. We encourage you to review those policies before providing your Personal Data to any Third-Party Service.

14.4 Project Xperience may engage third-party service providers to support the operation of the Platform, including providers of application hosting, cloud infrastructure, database hosting and management, payment processing, communications, analytics, cybersecurity and other operational services. Such service providers process Personal Data only to the extent reasonably necessary to perform services on behalf of Project Xperience and in accordance with applicable law and their contractual obligations.

14.5 References or links to any Third-Party Service on the Platform do not constitute an endorsement, recommendation or representation by Project Xperience unless expressly stated otherwise.

14.6 Project Xperience is not responsible for any loss, damage or liability arising from your access to or use of any Third-Party Service, except to the extent such responsibility cannot be excluded under applicable law.

15. Your Rights

15.1 Subject to the Personal Data Protection Act 2012 of Singapore (“PDPA”) and any other applicable law, you may have certain rights in relation to your Personal Data held by Project Xperience.

15.2 Depending on the circumstances and subject to applicable legal requirements, your rights may include the right to:

(a) request access to Personal Data that Project Xperience holds about you;

(b) request the correction of Personal Data that is inaccurate or incomplete;

(c) withdraw your consent to the collection, use or disclosure of your Personal Data where such processing is based on your consent;

(d) request information regarding how your Personal Data has been used or disclosed, where such rights are provided under applicable law;

(e) request the deletion of your User Account in accordance with our applicable policies and this Privacy Policy; and

(f) make enquiries or complaints regarding Project Xperience’s handling of your Personal Data.

15.3 The exercise of your rights may be subject to:

(a) verification of your identity;

(b) applicable legal or regulatory requirements;

(c) statutory exceptions under the PDPA or other applicable law; and

(d) any reasonable administrative procedures established by Project Xperience for processing such requests.

15.4 Project Xperience will consider and respond to requests relating to Personal Data in accordance with the PDPA and other applicable legal requirements.

15.5 Nothing in this Privacy Policy limits any rights or remedies that may be available to you under applicable law, nor does it require Project Xperience to provide access to, correct, disclose or delete Personal Data where we are entitled or required to refuse such a request under applicable law.

16. Access and Correction Requests

16.1 Subject to the Personal Data Protection Act 2012 of Singapore (“PDPA”) and any other applicable law, you may request:

(a) access to Personal Data that Project Xperience holds about you; and

(b) the correction of Personal Data that you believe is inaccurate or incomplete.

16.2 Project Xperience may require you to verify your identity and provide sufficient information to enable us to locate the Personal Data to which your request relates before processing your request.

16.3 Project Xperience will consider and respond to requests for access or correction within a reasonable period and in accordance with the requirements of the PDPA and any other applicable law.

16.4 Where permitted by applicable law, Project Xperience may charge a reasonable administrative fee for processing a request for access to Personal Data. If such a fee is applicable, we will inform you of the estimated fee before processing your request.

16.5 Project Xperience may refuse or limit an access or correction request where permitted or required under the PDPA or any other applicable law, including where:

(a) the request falls within an applicable statutory exception;

(b) we are unable to verify your identity;

(c) the request is manifestly unfounded, unreasonable or repetitive; or

(d) we are otherwise permitted or required by applicable law to refuse or limit the request.

16.6 Where Project Xperience refuses or is unable to comply with an access or correction request, we will inform you of the reasons to the extent required or permitted by applicable law.

16.7 Requests relating to access or correction of Personal Data should be submitted using the contact details provided in Clause 19 of this Privacy Policy.

17. Withdrawal of Consent

17.1 Where Project Xperience relies on your consent to collect, use or disclose your Personal Data, you may withdraw your consent at any time by contacting us using the contact details provided in Clause 19 of this Privacy Policy.

17.2 Upon receiving a request to withdraw consent, Project Xperience may require reasonable time to process your request and to inform you of the likely consequences of withdrawing your consent, including any impact on your continued access to the Platform or our products and services.

17.3 Withdrawal of your consent will not affect the lawfulness of any collection, use or disclosure of your Personal Data that took place before your withdrawal of consent became effective.

17.4 Where you withdraw your consent for the collection, use or disclosure of Personal Data that is necessary for:

(a) the creation or administration of your User Account;

(b) the provision of the Platform or our products and services;

(c) the processing of purchases, auction participation, bids, payments or refunds;

(d) the fulfilment or administration of an Experience; or

(e) compliance with applicable laws or contractual obligations,

Project Xperience may be unable to continue providing all or part of the Platform, your User Account, or the relevant products or services.

17.5 Withdrawal of consent does not require Project Xperience to delete or cease retaining Personal Data where its continued retention, use or disclosure is permitted or required under applicable law or is otherwise provided for in this Privacy Policy.

17.6 Nothing in this Clause limits Project Xperience’s ability to collect, use, disclose or retain Personal Data where such collection, use, disclosure or retention is authorised or required under the Personal Data Protection Act 2012 of Singapore (“PDPA”) or any other applicable law.

18. Changes to this Privacy Policy

18.1 Project Xperience may amend, update or revise this Privacy Policy from time to time to reflect changes in our business operations, products or services, legal or regulatory requirements, technology, security practices or other relevant circumstances.

18.2 Where appropriate, the updated Privacy Policy will be published on the Platform together with its revised Effective Date.

18.3 Where required by applicable law, Project Xperience will take reasonable steps to notify users of material changes to this Privacy Policy through appropriate means.

18.4 Your continued access to or use of the Platform after the revised Privacy Policy takes effect constitutes your acknowledgement of the updated Privacy Policy, to the extent permitted by applicable law.

19. Contact Us

If you have any questions, requests, concerns or complaints regarding this Privacy Policy or Project Xperience’s collection, use, disclosure or other processing of your Personal Data, you may contact us using the contact details below:

Xperience Creation Pte. Ltd.

Email: info@xperience-creation.com

Address: 8 Burn Road #08-10 Trivex, Singapore 369977

Project Xperience will endeavour to respond to enquiries and requests relating to Personal Data within a reasonable period and in accordance with the requirements of the Personal Data Protection Act 2012 of Singapore (“PDPA”) and other applicable laws.

Last Updated: 1 July 2026