Privacy Notice

The Privacy Notice below discloses the privacy practices for SES Holdings Pte. Ltd., its affiliates, and its websites (“SES”).

Effective Date: 8/26/21

This Privacy Notice discloses the privacy practices for SES Holdings Pte. Ltd. and its affiliates.(“SES,” “we,” “us,” “our”). It describes how we collect, use, and disclose information in connection with your access and use of all websites and other online products and services provided by us that link to this Privacy Notice, including https://ses.ai (and all related subdomains) (the “Sites”) and related online and offline services thereto (collectively the “Services”). SES is the controller of the data controller of your information. This notice will inform you of the following:

  • What personal information we collect;
  • With whom it is shared;
  • How it can be corrected;
  • How it is secured;
  • How long it will be stored;
  • How policy changes will be communicated; and
  • How to address concerns over misuse of personal information.

 

Personal Information Collection, Use, and Sharing

We have access to/collect personal information that you give us via email, our website, or other direct contact from you. We are the sole owners of the personal information that is collected. We may combine the personal information you give us with other information sources, including third-party sources, and use it for the purposes identified below.

The general categories of personal information that we collect about you may include, but are not limited to:

  • Commercial information, including your interests in SES products and Services
  • Personal identifiers, including your contact information (name, address, telephone #, email address, candidate information (for job applicants))
  • Protected classifications, including your demographic information
  • Other data collected that could directly or indirectly identify you; and
  • Internet or other electronic network activity information
 

Unless you ask us not to, we may contact you via mail, telephone, e-mail, text message[1], social media and other electronic messages for the purposes of:

  • describing new products or services;
  • providing products or services updates;
  • maintaining customer relationships;
  • marketing and analytics purposes;
  • investor communications;
  • changes to this privacy policy; and
  • complying with legal, regulatory, or contractual obligations.
 

We may use the categories of personal information described above for the following business or commercial purposes:

  • Maintain or Service customer accounts;
  • Provide customer service;
  • Audit customer activity;
  • Process or fulfil orders and transactions;
  • Verify customer information
  • Provide advertising or marketing Services;
  • Comply with applicable law and law enforcement requirements;
  • Protect against malicious, deceptive, fraudulent or illegal activity;
  • Prosecute those responsible for malicious, deceptive, fraudulent or illegal activity; and
  • Defend against or bring legal action, claims and other liabilities.

We collect or obtain personal information about you from the following sources:

  • Data provided to us: We obtain personal information when it is provided to us (e.g., where you create an account, where you contact us via email or telephone, or by any other means).
  • Relationship data: We collect or obtain personal information in the ordinary course of our relationship with you (e.g., when you purchase any products or Services from us).
  • Data you make public: We collect or obtain personal information that you manifestly choose to make public, including via social media (e.g., hashtags, contents, communications, comments, photos, video,).
  • Site data: We collect or obtain personal information when you visit any of our Sites or use any features or resources available on or through a Site.
  • Registration details: We collect or obtain personal information when you use, or register to use our Site.
  • Content and advertising information: If you interact with any third party content or advertising on a Site (including third party plugins and cookies) we receive personal information from the relevant third party provider of that content or advertising.
  • Third party information: We collect or obtain personal information from third parties who provide it to us (e.g., credit reference agencies; law enforcement authorities; etc.).
 

We may aggregate and/or de-identify any information collected through the Services so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors, in our discretion.

Privacy Information for California Residents

Terms used in this section and not otherwise defined have the meaning given to them under the California Consumer Privacy Act (“CCPA”). Consistent with the requirements of the CCPA, this section provides additional information about our collection and use of your “personal information” and your choices with respect to such information.

We do not “sell” (as that term is defined under the CCPA) California residents’ personal information. In particular, we do not sell the personal information of minors under 16 years of age.  SES may share personal information in the following situations:

  • sharing with service providers who perform services (including but not limited to security, analytics, and marketing services) on our behalf;
  • in connection with the sale, transfer, or financing of a significant part of SES’ business or its assets, including bankruptcy
  • when required by law in response to a subpoena, government inquiry, litigation, dispute resolution or similar legal situation

In the preceding 12 months, we may have disclosed the following categories of personal information to the following categories of recipients:

Recipient Category: Vendors who may need access to your personal information to help us provide our Services.

Categories of personal information for the above category include:

  • Personal Identifiers;
  • Protected Classification (if provided)
  • Commercial Information
  • Internet or other electronic network activity information
  • Inferences for use in creating a consumer profile
 

Recipient Category: Entities who provide us with e-mail address management, communication contact services, and those who analyse and enhance our marketing campaigns and service.
Categories of personal information for the above category include:

  • Personal Identifiers;
  • Protected Classification (if provided)
  • Internet or other electronic network activity information
  • Inferences for use in creating a consumer profile

Recipient Category: Payment processors, entities who provide labelling and shipping services to help us deliver the products you may order.
Categories of personal information for the above category include:

  • Personal Identifiers;
  • Commercial Information

If you are a Consumer, the CCPA grants you the following rights regarding your personal information. Generally, in order to verify your requests to exercise your rights, we will compare the personal information we have about you to pieces of personal information we will request in the course of processing your request. The personal information required for verification may, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, include your name, email address, phone number, or postal address. To exercise your rights under the CCPA, please follow the instructions described in this section.

Right to Know About Personal Information. Consumers have the right to submit a verifiable consumer request that we disclose the following in a readily useable format, covering the 12 month period preceding the verifiable consumer request:

  • The categories of personal information we collected about you.
  • The purposes for which the categories of personal information collected about you will be used.
  • The categories of sources for the personal information we collected about you.
  • The categories of third parties with whom we share personal information.
  • Our business or commercial purpose for collecting personal information.
  • The specific pieces of personal information we collected about you.
  • The categories of personal information we have disclosed for a business purpose.

Verifiable consumer requests to know may be submitted through one of the following methods:

Right to Request Deletion of Personal Information. Consumers have the right to request that we delete any personal information that we have collected from them. However, we are not required to comply with a request to delete where it is necessary for us to retain the personal information in order to:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with legal obligations.
  • Make other internal and lawful uses of that personal information that are compatible with the context in which you provided it.

Verifiable consumer requests to delete may be submitted through one of the following methods:

 

Right to Non-Discrimination. Consumers have the right to be free from discrimination when they exercise their Consumer rights under the CCPA, and should you exercise those rights we cannot:

  1. Deny you goods or services.
  2. Charge you a different price or rate for goods or services, including through granting discounts or other benefits, or imposing penalties.
  3. Provide you a different level of quality of goods or services.
  4. Suggest that you may receive a different rate for goods or services or a difference level or quality of goods or services.

Authorized Agent. Under the CCPA, you may appoint an authorized agent to submit requests to exercise your rights on your behalf. Should you choose to do so, for your and our protection, we will require your authorized agent to provide us with a signed permission demonstrating they are authorized to submit a request on your behalf. We note, should your authorized agent fail to submit proof that they have been authorized to act on your behalf, we will deny their request.

California “Shine the Light” Disclosure. The California “Shine the Light” law gives residents of California the right under certain circumstances to opt out of the sharing of certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. We do not share your personal information with third parties for their own direct marketing purposes within the meaning of that law.

Legal Bases for Use of Your Information.

The laws of some jurisdictions, including the European Economic Area and the United Kingdom, require that companies only process your “Personal Data” (as that term is defined in the applicable law, like the EU General Data Protection Regulation) if they have a “legal basis” (or justifiable need) for processing your Personal Data. To the extent those laws apply, our legal bases for processing Personal Data are as follows:

  • To perform our obligations pursuant to a contract (or pending contract) with you. For example, we will process your Personal Data to enter into a contract with you, and to honor our commitments in any contracts that we have with you.
  • For our legitimate interests or the legitimate interests of others. For example, we will process your Personal Data to: operate our business and our Services; identify and fix any issues with our Services; secure the Services; learn more about how our customers use the Services; perform internal analytics; improve the Services and users’ experiences; conduct marketing; provide you with certain information about new products, special offers or other information that we think you may find interesting using the email address which you have provided in accordance with applicable law; make and receive payments; comply with legal requirements and defend our legal rights; prevent fraud; engage in a business change (e.g., sale, merger); and to know the customer to whom we are providing Services.
  • To comply with our legal obligations, such as our obligation to share data with tax authorities.
  • With your consent. Where we rely on this basis, you have the right to withdraw your consent at any time as described in the “Your Access to and Rights with Respect to Your Information” section below.

Your Access to and Rights with Respect to Your Information

You may opt out of any future commercial communications from us. Removing your name from the email list may take a reasonable amount of time. Please note that, regardless of your request, we may still use and share certain information as permitted by this Privacy Policy or as required by applicable law. For example, you may not opt out of certain operational emails, such as those reflecting our relationship or transactions with you.

Depending on where you live, you may have certain rights with respect your personal information. For example, under local laws, including in the European Economic Area and the United Kingdom, and Canada, you may have some or all of the following rights:

  • see what personal information we have about you
  • change/correct any personal information we have about you
  • have us delete any personal information we have about you
  • express any concern you have about our use of your personal information

To exercise your data protection rights or to receive more details in connection with them, you can submit requests by contacting us via email at [email protected]. You may be required to provide additional information necessary to confirm your identity before we can respond to your request.

We will consider all such requests and provide our response within the time period required by applicable law. Please note, however, that certain information may be exempt from such requests, for example if we need to keep the information to comply with our own legal obligations or to establish, exercise, or defend legal claims. Your rights and our responses will vary based on your state or country of residency. Please note that you may be located in a jurisdiction where we are not obligated, or are unable, to fulfill a request. In such a case, your request may not be fulfilled. If you are a California resident (i.e., a Consumer), please see the “Privacy Information for California Residents” section above for information about your specific rights under California law.

If applicable, you may make a complaint to your local data protection supervisory authority in the country where you are based. Alternatively, you may seek a remedy through local courts if you believe your rights have been breached.

International Transfers. Your personal information may be transferred to, stored in, accessed from, or processed in the United States or other jurisdictions in which we or our service providers maintain facilities. You understand that these jurisdictions may have different data protection regimes than in the country in which you are located.

Cookies/Tracking Technologies

We may use cookies, web beacons, IP addresses, browser/canvas fingerprinting and other tracking technologies on our websites or in our emails. Using tracking technologies allows us to provide benefits to you such as using cookies to identify you so we can suggest content that is likely more relevant to you, thereby saving time while on our Site.  Tracking technologies can also enable us to track and target the interests of our users to enhance their experience on our Site. Usage of tracking technologies is in no way linked to any personally identifiable information on our Site.  We also automatically collect data to measure website performance including metadata, log files, page load time, page linger time, click throughs and abandonments, network routing and server configurations. Much of the data collected is aggregated or statistical data about how visitors use our Sites and is not linked to any personal information.

At this time, we do not honor “Do Not Track” flags from your web browser. You may delete or refuse any cookies we send to your computer. If you choose to decline cookies, some of the functionality of our websites may be impaired or broken. Please refer to your browser help pages to learn how to manage tracking technologies.

Security

 We take a variety of physical, technical, administrative, and organizational security measures to protect your information against accidental or unlawful destruction or accidental loss, alteration, unauthorized disclosure or access. However, no method of transmission over the Internet, and no means of electronic or physical storage, is absolutely secure. As such, you acknowledge and accept that we cannot guarantee the security of your information transmitted to, through, or on our Services or via the Internet and that any such transmission is at your own risk.

How Long We Keep Your Personal Information

We may keep the personal information we collect for as long as necessary to provide products or Services to you, to operate our business, to enable us to communicate with you, or to satisfy our legal or contractual obligations. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws. Where required, we may anonymize or dispose of the personal information we collect.

Notification of Changes

Whenever material changes are made to our Privacy Notice this page will be updated.

Contact Us

If you have any questions about this Privacy Notice, you should contact us via telephone at +1.800.495.0061 or via email at [email protected]

[1] Opting into receiving text messages is not a requirement to buy products or services from SES, and message and data rates may apply.