At Sphere, we respect your privacy.

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This Privacy Policy (this “Policy”) explains the types of personal data that we collect and how we use, disclose and protect that data. In this Policy, references to “Sphere”, “we”, “us” and “our”, collectively refer to the separate and distinct legal entities that that manage, operate, franchise, license, own and/or provide services to Sphere, including Sphere Cecil Pte Ltd and its affiliates.

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What does this policy cover?

This Policy applies to personal data collected by Sphere in connection with the services we offer. This includes data collected offline at Sphere, direct marketing campaigns, contests, sweepstakes and online through our websites and apps.

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This Policy also applies to targeted Sphere content, including offers and advertisements for Sphere services and products, which we (or a service provider acting on our behalf) may send to you on third-party websites, platforms and applications based on your usage of Sphere websites. These third-party sites may have their own privacy policies and terms and conditions. We encourage you to read them before using those third-party sites.

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While this Policy is intended to describe the broadest range of our personal data processing activities globally, those processing activities may be more limited in some jurisdictions based on the restrictions of their laws. For example, the laws of a particular country may limit the types of personal data we can collect or the manner in which we process that personal data. In those instances, we adjust our internal policies and/or practices to reflect the requirements of local law.

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What does this policy cover?

The term “personal data” in this Policy refers to information that does or is capable of identifying you as an individual. The types of personal data that we process (which may vary by jurisdiction based on applicable law) include:

• your name, gender, contact details, date of birth, and image;
• data on your usage of Sphere services and products, when you used the facilities, requests made and observations about your service preferences;
• your credit card or other payment data;
• any data necessary to fulfil special requests (e.g. health conditions that require specific accommodation or services);
• data, feedback or content you provide regarding your marketing preferences, in surveys, sweepstakes, contests, or promotional offers, or to our websites or apps and those of third parties;
• data collected whilst at Sphere through the use of closed circuit television systems, internet systems (including wireless networks that collect data about your computer, smart or mobile device, or your location) and other security and technology systems;
• data collected whilst you access a Sphere website or app (we describe this in more detail in Section 7 below); and
• contact and other relevant details concerning the employees of corporate accounts.

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Much of the personal data we process is data that you or someone acting on your behalf knowingly provides to us. However, in other instances, we process personal data that we are able to infer about you based on other data you provide to us or during our interactions with you, or personal data about you that we receive from a third party. This Policy also applies to the personal data about you that we receive from a third party, unless specifically covered by such third party’s privacy policy.

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There may be instances in which the personal data that you provide to us or that we collect is considered Sensitive Personal Data (or another similar term) under the privacy laws of some countries. Those laws define “Sensitive Personal Data” to mean personal data from which we can determine or infer, for example, an individual’s physical or mental health or condition. We only process Sensitive Personal Data in your jurisdiction if and to the extent permitted or required by applicable law.

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When you agree to this Policy you are, to the extent required under your local law, granting your express and written consent to the processing of any personal data that you provide to Sphere that is considered to be Sensitive Personal Data. Save to the extent required by law, you are not obliged to provide Sphere with any of your Sensitive Personal Data, and should you choose not to, this will not prevent you from purchasing any services or products from Sphere. However, should you chose not to, depending on the nature of the Sensitive Personal Data you choose not to provide, our ability to provide our services or products to you may be affected.

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How do we use your personal data?

We use your personal data in order to fulfil our commitment to provide you with an excellent experience in connection with all your interactions with Sphere (the “Purpose”).

Generally, subject to applicable laws, we may collect, use and disclose relevant portions of your personal data in order to:

• provide you with services or products that you request from us;
• contact you regarding services and products which may be of interest to you, provided you have given us consent to do so or you have previously requested a product or service from us and the communication is relevant or related to that prior request and made within any timeframes established by applicable laws; or
• improve our services and products and your experience on Sphere websites and apps.

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Without limiting the generality of the foregoing, subject to applicable laws, we may collect, use and disclose relevant portions of your personal data in order to:

• provide and charge you for Sphere memberships and other services and products;
• provide you with a better or more personalized level of service;
• administer our membership referral program;
• fulfil contractual obligations to you and vendors (e.g. credit card companies and third party loyalty programs);
• conduct market research, customer satisfaction and quality assurance surveys, and direct marketing and sales promotions;
• test and evaluate new services and products;
• evaluate the use of the Sphere websites and apps;
• offer you the opportunity to take part in contests or promotions;
• analyse the effectiveness of our advertisements, contests and promotions;
• personalise your website and app experiences, as well as to evaluate (anonymously and in the aggregate) statistics on website activity;
• make the Sphere websites and apps easier to use and to better tailor Sphere websites, Sphere apps and our services and products to your interests and needs;
• help speed up your future activities and experience on Sphere websites and apps;
• collect data about the device you are using to view Sphere websites and apps, such as your IP address or the type of internet browser or operating system you are using, and link this to your personal data so as to ensure that Sphere websites and apps present the best web and app experiences for you;
• suggest services or products (including those of relevant third parties) which we think may be of interest to you;
• provide for the safety and security of Sphere staff, Sphere users and other visitors;
• administer general record keeping; and
• meet legal and regulatory requirements.

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Sphere uses and retains your personal data for as long as is necessary to fulfil the Purpose.

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Who do we share your personal information with?

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From time to time, we may disclose your personal data. We would always make that disclosure in accordance with applicable law. In some jurisdictions, data privacy laws may require us to obtain your consent before we transfer your information from your originating country to other countries. When you agree to this Policy, you are, to the extent required and permitted under your local law, granting your consent to the transfer of your personal information to such other countries for the Purpose and to the extent stated in this Section 4 and as described in Section 3 above.

Circumstances where we might make such disclosure (in addition to those described in Section 3 above) include:
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Our Agents, Service Providers and Suppliers

Like most international brands, we may outsource the processing of certain functions and/or information to third parties. We may also engage market research firms to assist us in contacting Sphere users for the purpose of market research and quality assurance. When we do outsource the processing of your personal data to third parties or provide your personal data to third-party service providers, we oblige those third parties to protect your personal data in accordance with the terms and conditions of this Policy, with appropriate security measures.

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Consumer Insights

Where we hold personal data about you, we may disclose this personal data to other companies that also hold data about you. These companies may combine the data in order to better understand your preferences and interests, thereby enabling them and us to serve you better. If your personal data is used for direct marketing purposes, you have the right to object to that by contacting us using the contact information provided under Section 11 below.

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Legal Requirements

We reserve the right to disclose any personal data we have concerning you if we are compelled to do so by a court of law or lawfully requested to do so by a governmental entity or if we determine it is necessary or desirable to comply with the law or to protect or defend our rights or property in accordance with applicable laws. We also reserve the right to retain personal data collected and to process such personal data to comply with accounting and tax rules and regulations and any specific record retention laws.

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Transferring your personal information

Like most international businesses, we have centralized certain aspects of our data processing activities. We may transfer your personal data to servers located outside the country in which you live or to affiliates or other trusted third parties based in other countries so that they may process personal data on our behalf. By using a Sphere website or app or otherwise providing Sphere with personal data, you agree to us doing so in accordance with the terms of this Policy and applicable data protection laws and regulations.

You should be aware that many countries do not afford the same legal protection to personal data as you might enjoy in your country of origin. Nevertheless, whenever your personal data is transferred within Sphere, your personal data will be processed in accordance with this Policy and applicable laws. All third parties processing your personal data outside your country of origin are required to implement measures to protect it and are only entitled to process it in accordance with Sphere’s instructions.

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Safeguarding your personal information

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We take all reasonable precautions to keep your personal data secure and require any third parties that handle or process your personal data for us to do the same. Access to your personal data is restricted to prevent unauthorized access, modification, or misuse, and is only permitted among Sphere staff and agents on a need-to-know basis.

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Information we collect when you visit us online

If you access any Sphere website, you may wish to know the following:

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You Can Browse Without Revealing Who You Are

You can always visit our websites without logging in or otherwise revealing who you are.

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Usage Information

When you visit our websites, we collect information about how you use those websites. Examples of such data include the IP address automatically assigned to your computer each time you browse the internet, the date and time of your visit, the pages you access and the amount of time you spend on each page, the type of internet browser you use, your device’s operating system and the URL of any websites that you visited before and after visiting our website. That data is not linked to you as an individual unless you have a member profile, but we may keep records of the device being used.

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Cookies and Other Similar Technology

We use cookie technology on our websites and apps to allow us to evaluate and improve their functionality. Cookies by themselves cannot be used to reveal your identity. They identify your browser, but not you, to our servers when you visit our websites and apps. If you do not want to accept cookies, you can block them by adjusting the settings on your internet browser. However, if you block them, you will not be able to use all of the features of our websites, including the customization features associated with creating a user profile. Further information about cookies and other similar technology and how they work is available at http://www.allaboutcookies.org.

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Your Member Profile

If you are a Sphere member, the personal data you provided to us will be used to create a member profile for you. A member profile allows you to, among other things, book training sessions and make online purchases of our services and products. We may use the data you provide in your member profile to populate other databases maintained by us and our service providers, as applicable.You can view, update or remove any personal data that you have provided to us for inclusion in your member profile by amending your member profile online via our websites or apps. If you subsequently cease to be a Sphere member, we reserve the right to use any personal data previously provided by you for inclusion in your user profile for record keeping and quality assurance purposes (unless we are required by law to delete or cease to process or use your personal data).

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Security

Because the security of your personal data is important to us, we use Secured Socket Layer (SSL) software in order to encrypt the personal data that you provide to us. If your browser is SSL-enabled (which most are), your transmission of personal data to us online will be encrypted. You can verify whether your personal data is transmitted using SSL encryption by confirming the symbol of a closed lock or solid key on the bottom bar of your browser window. You can also verify that your personal data will be encrypted using SSL encryption by making sure that the prefix for the web address listed for that page has changed from “http” to “https”. If you do not see the appropriate symbol and the “https” prefix, you should not assume that the personal data that you are being asked to provide will be encrypted prior to transmission.

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The personal data we collect from you online is stored by us and/or our service providers on databases protected through a combination of physical and electronic access controls, firewall technology and other reasonable security measures. Nevertheless, such security measures cannot prevent all loss, misuse or alteration of personal data and we are not responsible for any damages or liabilities relating to any such incidents to the fullest extent permitted by law. Where required under law, we will notify you of any such loss, misuse or alteration of personal data that may affect you so that you can take the appropriate actions for the due protection of your rights.

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Minors

Our websites do not sell services or products for purchase by children and we do not knowingly solicit or collect personal data from children. If you are under the age of 18 (or a minor in the jurisdiction in which you are accessing our websites or apps), you may only use our websites and apps with the involvement of a parent or guardian.

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Targeted Advertising

Where permitted by law, we may work with other companies to show you advertisements we think you may find relevant and useful. This may include advertisements displayed on our own websites or apps, or advertisements from us displayed on other companies' websites. The advertisements you see may be based on information collected by us or third parties and/or may be based on your activities on our websites or third-party websites.

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Apps

When you download or register to use a Sphere app, you may submit personal data to us such as your name, address, email address, phone number, date of birth, username, password and other registration information, financial and credit card information, personal description and/or image.

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Further, when you use our apps, we may collect certain information automatically, including technical information related to your mobile device, your device’s unique identifier, your mobile network information, the type of mobile browser you use and data about the way you use the app.

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Choice

You may always choose what personal data (if any) you wish to provide to us. However, if you choose not to provide certain details, some of your experiences with us may be affected (for example, we cannot take a booking without a name).

If you provide us with your contact details (e.g. mailing address, email address or telephone number), we may contact you to let you know about the products, services, promotions and events offered that we think you may be interested in. We may also share your personal data with carefully-selected third parties, who may communicate directly with you. In some jurisdictions, data privacy laws may require us to obtain a separate consent before we do so. You can always choose whether or not to receive any or all of these communications by contacting us as described in Section 11 below or following the “unsubscribe” instructions contained in the communications.

In some jurisdictions, in addition to you agreeing to this Policy, data privacy laws may require us to obtain a separate consent before we send you information that you have not specifically requested. In certain circumstances, your consent may be implied (e.g. where communications are required in order to fulfil your requests and/or where you have volunteered information for use by us). In other cases, we may seek your consent expressly in accordance with applicable laws (e.g. where the information collected is regarded to be Sensitive Personal Data under local law).

We will abide by any request from you not to send you direct marketing materials. When such a request is received, your contact details will be ‘suppressed’ rather than deleted. This will ensure that your request is recorded and retained unless you provide a later consent that overrides it.

If you are a Sphere member, we reserve the right to send you certain communications relating to the Sphere service such as announcements, administrative messages and the Sphere newsletter, that are considered part of your Sphere account, without offering you the opportunity to opt-out of receiving them.

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Updating or accessing your personal information

With some limited exceptions, you have rights to access and update personal data held about you. If you want to inquire about any personal data we may have about you, you can do so by sending us a written request by letter or email to the addresses set out in Section 11 below. Please be sure to include your full name, address and telephone number and a copy of a document evidencing your identity (such as an ID card or passport) so we can ascertain your identity and whether we have any personal data regarding you, or in case we need to contact you to obtain any additional data we may require to make that determination.

We reserve the right to charge you a fee, if permitted under applicable law, which is usually around SGD$20 for processing any such request. Where you make more than one request in quick succession, we may respond to your subsequent request by referring to our earlier response and only identifying any items that have changed materially.

You may request that we correct, cancel, and/or stop processing or using personal data that we hold about you. If we agree that the personal data is incorrect, or that the processing should be stopped, we will delete or correct the personal data. If we do not agree that the personal data is incorrect we will tell you that we do not agree, explain our refusal to you and record the fact that you consider that personal data to be incorrect in the relevant file(s).

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Changes to this policy

Just as our business changes constantly, this Policy may also change. We may change this Policy from time to time by posting the updated version of the Privacy Policy on the Sphere websites. We encourage you to visit frequently to stay informed about how we use your personal data. To assist you, this Policy has an effective date set out at the end of this document.

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Request for access to personal information/questions or complaints

If you have any questions, comments or concerns about how we handle your personal data, or if you would like to submit a request (in the manner described in Section 9 above) for access to or deletion of the personal data that we maintain about you, please contact us by either of the following means:

• by emailing info@sphere365.sg

Effective Date: 25 July 2022

In the event of any inconsistencies between the English version of this Policy and any version of this Policy in any other language, the English version shall prevail (to the fullest extent permitted under applicable law).