Privacy Policy

Last updated: March 10, 2025

This Privacy Policy describes how Five Five Seven Seven Consulting Pte. Ltd. (“we”, “us”, or “our”) collects, uses, stores, and protects your personal data when you use the Ultrivia platform (the “Service”) — a football-focused platform offering trivia, quizzes, news reports, and editorial articles about the latest football matches.

We are committed to protecting your privacy in accordance with:

• The Personal Data Protection Act 2012 (PDPA) of Singapore, and
• The General Data Protection Regulation (GDPR) of the European Union, where applicable.

If you have any questions, please contact our privacy team at privacy@5577media.com.

1. Who We Are

Data Controller / Data Intermediary:
Five Five Seven Seven Consulting Pte. Ltd.
UEN: 201426429N
51 Goldhill Plaza, #07-10/11, Singapore 308900
privacy@5577media.com

2. What Personal Data We Collect

We may collect the following categories of personal data:

We do not intentionally collect sensitive personal data (e.g. health, financial, or biometric data).

3. How We Use Your Personal Data

We use your personal data for the following purposes:

• To provide and operate the Service — creating and managing your account, enabling gameplay and leaderboards.
• To improve the Service — analysing usage patterns to fix bugs and enhance features.
• To communicate with you — responding to support requests, sending service-related notifications.
• To ensure security — detecting and preventing fraud, abuse, or unauthorised access.
• To comply with legal obligations — meeting our obligations under applicable laws.

4. Legal Basis for Processing (GDPR)

If you are located in the European Economic Area (EEA), we process your personal data under the following legal bases:

• Performance of a contract — to provide you with the Service you signed up for.
• Legitimate interests — to improve our Service, ensure security, and conduct analytics.
• Consent — where you have given explicit consent (e.g. marketing communications). You may withdraw consent at any time.
• Legal obligation — where processing is required to comply with applicable law.

5. Consent and Purpose Limitation (PDPA)

Under the Singapore PDPA, we collect, use, and disclose personal data only for purposes that a reasonable person would consider appropriate in the circumstances, and for which we have obtained your consent unless an exception applies.

You may withdraw consent at any time by contacting us at privacy@5577media.com. Please note that withdrawing consent may affect our ability to provide some or all of the Service to you.

6. Data Sharing and Disclosure

We do not sell your personal data. We may share your data with:

• Service providers — third-party vendors who assist us in operating the Service (e.g. cloud hosting, analytics), bound by confidentiality and data processing agreements.
• Legal authorities — where required by law, court order, or to protect our legal rights.
• Business transfers — in the event of a merger, acquisition, or sale of assets, your data may be transferred to the successor entity.

7. International Data Transfers

Ultrivia is operated from Singapore. If you access the Service from outside Singapore, your data may be transferred to and processed in Singapore or other countries. Where we transfer data from the EEA to countries without an adequacy decision, we ensure appropriate safeguards are in place (such as Standard Contractual Clauses).

8. Cookie Policy

What Are Cookies?

Cookies are small text files placed on your device when you visit Ultrivia. They help us recognise you, remember your preferences, and understand how you use the Service. Similar technologies such as local storage and pixel tags may also be used for the same purposes.

Cookies We Use

We do not currently use advertising or third-party targeting cookies.

Legal Basis for Cookies (GDPR)

For users in the EEA, we rely on:

• Legitimate interests for essential and performance cookies, which are strictly necessary to operate the Service.
• Consent for functional and analytics cookies. You may withdraw consent at any time via your cookie preferences or browser settings.

Your Cookie Choices

You can manage or disable cookies at any time through your browser settings. Please note that disabling essential cookies may prevent Ultrivia from functioning correctly.

Common browser cookie controls:

• Chrome: Settings -> Privacy and Security -> Cookies
• Firefox: Settings -> Privacy & Security -> Cookies and Site Data
• Safari: Preferences -> Privacy -> Manage Website Data

You may also opt out of analytics tracking by enabling the “Do Not Track” setting in your browser, where supported.

Cookie Retention

Third-Party Cookies

We may use third-party analytics services (such as Google Analytics) that set their own cookies. These providers process data in accordance with their own privacy policies. We encourage you to review those policies separately.

9. Data Retention

We retain your personal data for as long as your account is active or as necessary to provide the Service. We may also retain data for longer periods where required by law or for legitimate business purposes (e.g. dispute resolution).

When data is no longer needed, we securely delete or anonymise it.

10. Data Security

We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, loss, alteration, or disclosure. These include encryption, access controls, and regular security reviews. However, no method of transmission over the internet is 100% secure.

If you believe your data has been compromised, please contact us immediately at privacy@5577media.com.

11. Your Rights

Depending on your location, you may have the following rights:

Under GDPR (EEA users):

• Right of access — request a copy of the personal data we hold about you.
• Right to rectification — request correction of inaccurate data.
• Right to erasure (“right to be forgotten”) — request deletion of your personal data.
• Right to restriction — request that we limit how we use your data.
• Right to data portability — receive your data in a structured, machine-readable format.
• Right to object — object to processing based on legitimate interests.
• Right to lodge a complaint — with your local data protection authority (e.g. the CNIL in France, the ICO in the UK).

Under PDPA (Singapore users):

• Right of access — request access to your personal data and information about how it has been used.
• Right to correction — request correction of inaccurate or incomplete personal data.
• Right to withdraw consent — as described in Section 5.
• Right to data portability — where applicable under the PDPA.

To exercise any of these rights, please contact us at privacy@5577media.com. We will respond within the timeframe required by applicable law (30 days under GDPR; 10 business days under PDPA).

12. Children’s Privacy

Ultrivia is not directed at children under the age of 13. We do not knowingly collect personal data from children under 13. If we become aware that we have collected such data without verifiable parental consent, we will delete it promptly. If you believe a child has provided us with personal data, please contact privacy@5577media.com.

13. Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will revise the “Last updated” date at the top of this page. We encourage you to review this page periodically. Continued use of the Service following any update constitutes your acceptance of the revised Policy.

14. Contact & Data Protection Enquiries

For any privacy-related questions, requests, or complaints:

Five Five Seven Seven Consulting Pte. Ltd.
51 Goldhill Plaza, #07-10/11
Singapore 308900
privacy@5577media.com