Online Privacy Policy

Updated on October 1, 2021

Northern Ray’s Commitment to Privacy 

Your privacy is important to us. This Online Privacy Policy (“Privacy Policy”) explains how we protect your privacy when you visit this Web site and the other Northern Ray Web sites that display this Privacy Policy, or when you use any Northern Ray digital application, such as a mobile app, that links towhich refers this Privacy Policy (collectively, our “Website(s)”). This Privacy Policy describes what types of information we gather and track when you use our Sites, how this information is used and with whom it is shared. If you have any questions about this Privacy Policy, please contact us. 

Scope of This Privacy Policy 

This Privacy Policy covers the “Personal Information” we collect through our Websites. 

“Personal Information” is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you personally, either alone or in combination with other information available to us. Examples of Personal Information include your name, contact details, IP address, credit card information, job applications, the information you provide when you create an account or a personal profile on one of our Sites and information about the pages you have viewed and the path you have taken through our Sites. 

Your Consent and other legal basis for using your Personal Information 

Please take a few minutes to review this Privacy Policy. By accessing or using this Website, you are consenting to the collection, use and disclosure of your Personal Information as set forth in this Privacy Policy. 



We also collect, use and disclose your Personal Information where it is necessary for the performance of a contract with you or where it is necessary for our legitimate interests of operating, protecting and improving our business. 


Changes to This Privacy Policy 

As we add new features and functionality to our Sites, we may need to update or revise this Privacy Policy. We reserve the right to do so, at any time and without prior notice, by posting the revised version on our Websites. These changes will be effective as of the date we post the revised version on our Websites. They will apply only to the Personal Information we collect after we have posted the revised version. Your use of one of our Websites following any such change constitutes your consent to the terms of the revised Privacy Policy. For this reason, it is important to review this Privacy Policy regularly. 

If we modify this Privacy Policy, we will provide a notice at the top of this Privacy Policy for at least 30 days after the new effective date, so that you can see at a glance whether our Privacy Policy has changed since your last visit. You may access the current version of this Privacy Policy at any time by clicking on the link marked “Privacy Policy” or “Privacy Notices” at the bottom of each page or within our Websites. 

Privacy Notices 

This Privacy Policy may be supplemented or amended from time to time by “Privacy Notices” posted on our Websites. Generally, Privacy Notices provide details about the Personal Information we collect on particular pages or particular areas of a Website, why we need that information, and choices you may have about the ways we use that information. 

Agreements Governing Your Use of Special Features and Password-Protected Areas of This Website 

Some of our Websites include special features, such as licensed content or an online store, or password protected areas, such as a discussion forum, a chat room, a careers area, or a customers-only area. 

When you sign up to use a special feature or password-protected area, you may be asked to agree to special terms governing your use of the special feature or password-protected area. In such cases, you will be asked to expressly consent to the special terms, for example, by checking a box or clicking on a button marked “I agree.” This type of agreement is known as a “click-through” agreement. If any of the terms of the click-through agreement are different than the terms of this Privacy Policy, the terms of the click-through agreement will supplement or amend this Privacy Policy, but only with respect to the matters governed by the “click-through agreement.” 

What Personal Information Do We Collect Through Our Websites? 

Information You Provide. We collect the Personal Information you knowingly provide (using your mouse and keyboard) when you use our Websites. The information we collect depends on how you use our Websites. For example, if you sign up to receive email communications from us, we collect your email address and any related information you provide. If you communicate with us using the “Contact Us” feature, we collect the information you provide when you complete the “Contact Us” form. 

Generally, our Websites distinguish between information we need to provide you with a particular product, service or to fulfill your request (“mandatory fields”), and information that although useful is optional with respect to that particular product, service or your request. Please be aware that if you do not provide us with mandatory fields we will not be able to provide you with the product or service or to fulfil your request. 

Supplemental Information. From time to time, we may supplement the information you give us with information from business partners, social media, or other sources. For example, we may obtain additional information to validate your address or information about your business. We may also supplement the information you give us with information we collect from you through other Northern Ray Web Websites, digital apps, or other channels. For example, if you are a Northern Ray customer, we may supplement the information you provide online with information you provide in your other business dealings with Northern Ray. 

Information Sent to Us by Your Web Browser. We collect information that is sent to us automatically by your Web browser. This information typically includes your IP address, the identity of your Internet Service Provider, the name and version of your operating system, the name and version of your browser, the date and time of your visit, and the pages you visit. An “IP address” is a unique number that is automatically assigned to your computer when you connect to the Internet. It is used to identify your computer’s “location” in cyberspace, so that the information you request can be delivered to you. If you use a dial-up connection or a connection that assigns dynamic IP addresses, your computer will be assigned a new IP Address each time you connect to the Internet. If, however, your computer is permanently connected to the Internet using a static IP address, the IP address assigned to your computer will generally be the same each time you use your computer. Although it does not identify you by name, we treat your IP address as your Personal Information. 

You should be aware that when you respond to an electronic communication you receive from us, for example, by opening an email, downloading images or clicking on a link in an electronic newsletter, your browser tells us that you (or someone using your email address) have done so. We use this information to improve our marketing efforts. In addition, we review our server logs – which contain visitors’ IP addresses – for security and fraud prevention purposes. If criminal activity is suspected, we may share our server logs and the Personal Information we have collected through this Website with the appropriate investigative authorities who could use that information to trace and identify individuals. 

Device and Location Information. For digital app users, we may also collect information about the device you use to download the app, including, where available, the device’s unique device identifiers, operating system, or mobile network information for system administration purposes. We may also automatically collect and store certain information in our server logs to get a better understanding of how people use the app, for system administration purposes, and to ensure we provide a good user experience and customer service. This type of information includes details about when, how, and what parts of the app you used, viewed and when you exited pages on the app as well as date or time stamps. 

Cookies and Similar Technologies. A cookie is a small file sent by a Web site Website or digital app and stored on a user’s computer which enables the Web site or digital app to remember information about you and your preferences. We use “cookies” and other Web technologies in a number of ways. For example, we may use these technologies: 

  • to collect information about the ways visitors use our Websites – which pages they visit, which links they use, and how long they stay on each page; 
  • to support the features and functionality of our Websites – for example, to save you the trouble of reentering information already in our database or to prompt the settings you established on previous visits to our Websites; 
  • to personalize your experience when you use our Websites; 
  • to enable third parties (e.g. social media sites) to prepare online ‘audiences’ of its users who are either existing Northern Ray customers or who share characteristics with Northern Ray customers, subject always to that third party respecting your privacy settings; 
  • to ‘recognize’ you as someone who has visited a Northern Ray website before or interacted with Northern Ray online, so we may serve you with relevant ads as you browse elsewhere online, including third- party websites; and 
  • to measure the success of our web or e-mail advertising. For example, if you interact with an ad served by a third party on our behalf, we may receive non-identifying information, such as demographic information or general information about your interests. 

Where required by applicable law, such as in the EEA, we will obtain your Cconsent before using your data, typically, via a consent management platform (CMP). In those cases, you may withdraw your Cconsent at any time via Northern Ray’s CMP. 

The cookies we use can be classified into two categories: 

  • “Session cookies” which are allocated to your computer for the duration of your visit of our Websites and which will be automatically removed from your computer when you close your browser. 
  • “Persistent cookies” which expire after a reasonable period of time or until the user deletes the cookie. 

Some of these uses may involve the use of “third party cookies”; that is, cookies that are set by software used by third parties, such as to carry out statistical analysis of page use, page interactions and paths through the SWebsite, or for the purposes of serving internet advertisements using an online advertising supplier. Third -party cookies may collect information about your online activities over time and across different websites following your visit to our Websites. 

Generally, the information collected using these Web technologies does not identify you by name. If, however, you have created a user identity, for example, by signing up to use a password-protected area on one of our Websites, we may link the information we collect using Web technologies to other information that identifies you personally. 

If you do not wish to receive cookies, in addition to controlling your their use via any choice mechanism offered by Northern Ray (e.g. via a consent management platform), you may set your browser to reject cookies or to alert you when a cookie is placed on your computer. You may also delete our cookies as soon as you leave a Website. For more information on how to do so, please refer to your browser ‘help’ section or see or Although you are not required to accept our cookies when you visit our Websites, if you set your browser to reject cookies, you will not be able to use all of the features and functionality of our Websites. 

Except as otherwise disclosed in this policy, we do not currently respond to web browser “do not track” signals or other mechanisms that indicate your preference for not having information collected over time and across different Web sites or digital apps following your visit to one of our Websites. If we do so in the future, we will describe how we do so in this Privacy Policy. Visit to learn more. 

How Does Northern Ray Use Your Personal Information? 

Generally, we use the Personal Information we collect through our Websites 

  • to provide the products, information, and services you request; 
  • for security, credit, or fraud prevention purposes; 
  • to provide you with effective customer service; 
  • to provide you with a personalized experience when you use our Websites; 
  • to display personalized advertising when you visit our Websites or a third party website; 
  • to contact you with special offers and other information we believe will be of interest to you; 
  • to contact you with information and notices related to your use of our Websites; 
  • to invite you to participate in surveys and provide feedback to us; 
  • to better understand your needs and interests; 
  • to improve the content, functionality, and usability of our Websites; 
  • to improve our products and services; 
  • to improve our marketing and promotional efforts; and 
  • for any other purpose identified in an applicable Privacy Notice or other agreement between Northern Ray and you. 

To Whom Do We Disclose Personal Information? 

We may share the Personal Information we collect through our Websites as described below: 

Our Service Providers. We share Personal Information with companies and organizations, including subsidiaries and other business entities controlled by Northern Ray, that perform services on our behalf, for example, companies that provide Web site or digital app support or online advertising services to us. 

Within Northern Ray. We may share your Personal Information within Northern Ray (that is, among the business units within Northern Ray) and with any of our affiliates where there is a “need to know” for the purposes set forth in this Privacy Policy. 

Business Transactions. Northern Ray may decide, for strategic or other reasons, to sell, buy, merge or otherwise reorganize one or more of its businesses. A transaction of this type may involve the disclosure of Personal Information to prospective purchasers. 

Business Transfers. Your Personal Information may be transferred to a company that has acquired the stock or assets of Northern Ray or one of our business units, for example, as the result of a sale, merger, reorganization, or liquidation. 

Compliance With Laws and Protection of Our Rights and the Rights of Others. We may disclose Personal Information when we, in good faith, believe disclosure is appropriate to comply with the law, a court order, or a subpoena. We may also disclose Personal Information to prevent or investigate a possible crime, such as fraud or identity theft; to enforce or apply our online terms of use or other agreements; or to protect our own rights or property or the rights, property, or safety of our users or others. 

As Described in a Privacy Notice. We reserve the right to disclose your Personal Information as described in any Privacy Notice posted on the Web page or Northern Ray digital app where you provide that information. By providing your Personal Information on that Web page or Northern Ray digital app, you will be consenting to the disclosure of your Personal Information as described in that Privacy Notice. 

As Described in a Click-Through Agreement. We reserve the right to disclose your Personal Information as described in any click-through agreement to which you have agreed. 

Your Choices 

In some circumstances, we give you choices about the ways we collect, use and disclose your Personal Information. If so, we may ask you to indicate your choices at the time we collect your Personal Information. If you have created an account or a personal profile on one of our Websites, you may be able to update some or all of your privacy choices by changing the settings on your account settings or profile page at any time. 

How Can You Access, Update or Correct Your Personal Information? 

If you have created an account or a personal profile on one of our Websites, you may be able to access and update some or all of your Personal Information on your account settings or profile page. In most cases, however, you will need our help. If you wish to access, update or correct your Personal Information, please contact us. We will respond to you within a reasonable time and within the time limits established by applicable law. We may ask you for additional information to verify your identity. In most cases, we will provide access and correct or delete any inaccurate information you discover. In some cases, however, we may limit or deny your request if the law permits or requires us to do so or if we are unable to verify your identitfy. 

Your Rights 

In some circumstances, you have a right to request the erasure of your Personal Information or for a restriction on its use, to object to its use, to receive it in a portable format or to have it transmitted to another organization. You may also request that we no longer send you direct marketing communications. If you wish to exercise any of these rights, please contact us using the contact details below. 

Where you have the right under applicable law, such as in the EEA, you may complain to a Data Protection Authority if you think we have processed your Personal Information in a manner thatwhich is unlawful or breaches your rights.  

How Long Do We Retain Your Information? 

We may keep your Personal Information for as long as is necessary for our business purposes, and in particular to protect ourselves in the event of a legal claim. After this period, your Personal Information will be deleted or, in some instances, anonymized. If you subsequently withdraw your Cconsent and we have no other lawful basis to continue processing your Personal Information, we will delete your Personal Information. 


Although we take commercially reasonable measures to protect the confidentiality, integrity, and security of your Personal Information, we cannot guarantee the security of your Personal Information. For this reason, we urge users to take every precaution to protect their Personal Information while using the Internet. 

Password Protection. Certain areas of our Websites are password protected. You are responsible for maintaining the confidentiality of your passwords. We have the right to assume that anyone accessing one of our Websites using a password assigned to you has the right to do so. You will be solely responsible for the activities of anyone accessing our Websites using a password assigned to you, even if the individual is not, in fact, authorized by you. If you have reason to believe that your password has been compromised or used without authorization, you must promptly change it using the functionality provided on the Website. 

Links to Other Northern Ray Webs Sites and Digital Applications 

Northern Ray operates many different Web sites and digital apps, each with its own content, features, and functionality. Each Northern Ray Web site and digital app serves a different purpose. For this reason, not all of our Web sites and digital apps are governed by this Privacy Policy. When you use a link on one of our Websites to access another Northern Ray Web sSite, take a minute to review the privacy policy posted on that Web sSite. 

Links to Third-Party Web Sites 

This Site may also contain links to web sites operated by other companies, including web sites operated by our third-party service providers, and unrelated third parties. This Privacy Policy does not apply to Personal Information collected on any of these other Web sites. When you access third -party Web sites through a link on one of our Websites, please take a few minutes to review the privacy policy posted on that site. 

Children’s Privacy 

Our Websites are not directed at children under the age of 13. We do not use our Websites to knowingly solicit Personal Information from or market to children under the age of 13, or the relevant minimum age under applicable local legal requirements, except as permitted under applicable law. 

International transfers 

Northern Ray is a global organization doing business in many countries and we may transfer your Personal Information across national borders for the purposes described in this Privacy Policy.  Our Web servers and databases are located in the United States or in other countries and the information on these servers and databases may be accessed by our staff (or staff of our service providers) located in other countries where they have a “need to know”. Different countries have different privacy laws and requirements, and some, including the United States, provide less legal protection for your Personal Information than others. Please know, however, that no matter where your Personal Information is collected, used, transferred or stored, if it was collected through our Websites, it will be processed in accordance with this Privacy Policy and any privacy notices or click-through agreements that apply to you. 

With respect to Personal Information from the EEA, we have implemented a legal mechanism known as ‘Binding Corporate Rules’ to provide appropriate safeguards to protect Personal Information from the EEA when it is transferred to another Northern Ray company. A summary of our Binding Corporate Rules for Business Information may be found here

With respect to Personal Information from the EEA, please note that some of our service providers may be members of the EU-US Privacy Shield (see Alternatively, where necessary, it is our practice to implement other means of providing appropriate safeguards for Personal Information transferred from the EEA.  



Contact us 

If you have questions about this Privacy Policy or our privacy practices, contact us at: 

Send an e-mail to Global Privacy Office: 


Write to us at: 

150 Cecil Street #10-05 

Singapore 069543 

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