As used in this Policy:
“Customer” means an individual who: (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us; and
“Personal Data” means data, whether true or not, about a Customer who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.
- Depending on the nature of your interaction with us, some examples of Personal Data which we may collect from you include your name and identification information, contact information such as your address, email address or telephone number, date of birth, and financial information such as credit card numbers, debit card numbers or bank account information.
- Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context so permits).
GROUNDS FOR DATA PROCESSING
- The legal basis or grounds to process your Personal Data will depend on the particular purpose for which your data is being processed, however, the legal basis generally includes the following:
- performance of a contract: we will use this basis for processing necessary to provide our goods or services to you, to arrange your payment method, or to send you service-related communications from us;
- consent: in limited cases where we cannot process your Personal Data without your consent, we will ask your consent to process your Personal Data. You can withdraw your consent at any time by contacting us;
- legitimate interests: we will process your Personal Data based on our legitimate interests, such as in protecting rights and interests of yours, ours, and other parties related to our services; and
- compliance with a legal obligation: in limited cases such as being required or ordered by applicable laws and regulations, government authorities or regulatory institutions, we may process your Personal Data to be in compliance with them.
PURPOSES OF DATA PROCESSING
- We may collect and use your Personal Data for any or all of the following purposes:
- performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
- verifying your identity;
- responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
- managing your relationship with us;
- processing payment or credit transactions;
- sending your marketing information about our goods or services including notifying you of our marketing events, initiatives and promotions, lucky draws, membership and rewards schemes and other promotions;
- complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
- any other purposes for which you have provided the information;
- transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
- any other incidental business purposes related to or in connection with the above.
- We may disclose your Personal Data:
- where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods or services requested by you; or
- to third party service providers, agents and other organizations we have engaged to perform any of the functions listed in clause 5 above for us.
- The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).
WITHDRAWING YOUR CONSENT
- The consent that you provide for the collection, use and disclosure of your Personal Data will remain valid until such time it is being withdrawn by you in writing such as email. You may withdraw consent and request us to stop using and/or disclosing your Personal Data for any or all of the purposes listed above by submitting your request in writing to our Data Protection Officer at the contact details provided below.
- Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within thirty (30) business days of receiving it.
- While we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing such as email.
- Please note that withdrawing consent does not affect our right to continue to collect, use and disclose your Personal Data where such collection, use and disclose without consent is permitted or required based on the legal basis or grounds such as applicable laws and regulations.
PROTECTION OF PERSONAL DATA
- To safeguard your Personal Data from unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of your Personal Data by us, and disclosing your Personal Data both internally and to our authorized third party service providers and agents only on a need-to-know basis.
- You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
ACCURACY OF PERSONAL DATA
- We generally rely on your Personal Data provided by you (or your Authorized Representative). In order to ensure that your Personal Data is current, complete and accurate, please update us if there are changes to your Personal Data by informing our Data Protection Officer specified in clause 26 in writing or via email at the contact details provided below.
RETENTION OF PERSONAL DATA
- We may retain your Personal Data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
- We will cease to retain your Personal Data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which your Personal Data was collected, and is no longer necessary for legal or business purposes.
TRANSFERS OF PERSONAL DATA OUTSIDE OF THE COUNTRY
- We generally do not transfer your Personal Data to countries outside the country where our data server is located. However, if we do so, we will obtain your consent for the transfer to be made and/or we will take steps to ensure that your Personal Data continues to receive a standard of protection that is at least comparable to that provided under the PDPA, and/or we will comply with other requirements or procedures required by the laws and regulations applicable to the transfer.
YOUR DATA PROTECTION RIGHTS
- In addition to your rights covered in other clauses, you have data protection rights as follows:
- the right to access: you have the right to request us for copies of your Personal Data;
- the right to rectification: you have the right to request that we correct any information you believe is inaccurate. You also have the right to request us to complete the information you believe is incomplete;
- the right to erasure: you have the right to request that we erase your Personal Data under certain conditions;
- the right to restrict processing: you have the right to request that we restrict the processing of your Personal Data under certain conditions;
- the right to object to processing: you have the right to object to our processing of your Personal Data under certain conditions;
- the right to data portability: you have the right to request that we transfer the data that we have collected to another organization, or directly to you under certain conditions; and
- the right to lodge a complaint with a supervisory authority: if you wish to report a complaint or if you feel that we have not addressed your concern in a satisfactory manner, you may contact the government authorities or regulatory institutions of PDPA and equivalent laws and regulations.
- If you would like to exercise any of the above rights, please contact our Data Protection Officer specified in clause 26.
- Please note that a reasonable fee may be charged for your request to exercise the above rights. If so, we will inform you of the fee before processing your request.
- We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) business days after receiving your request, we will inform you in writing within thirty (30) business days of the time by which we will be able to respond to your request.
- Cookies are text files placed on your computer to collect standard internet log information and visitor behavior information. When you visit our websites, we may collect information from you automatically through cookies or similar technology.
- keeping you signed in; and
- understanding how you use our website.
- There are a number of different types of cookies, however, our website uses:
- functionality: we use these cookies so that we recognize you on our website and remember your previously selected preferences; these could include what language you prefer and location you are in; and a mix of first-party and third-party cookies are used; and
- advertising: we use these cookies to collect information about your visit to our website, the content you viewed, the links you followed and information about your browser, device, and your IP address; we sometimes shares some limited aspects of this data with third parties for advertising purposes; we may also share online data collected through cookies with our advertising partners; and this means that when you visit another website, you may be shown advertising based on your browsing patterns on our website.
- You may set your browser not to accept cookies. However, in a few cases, some of our website features may not function as a result.
DATA PROTECTION OFFICER
You may contact our Data Protection Officer if you have any enquiries or feedback on our Personal Data protection policies and procedures, or if you wish to make any request, in the following manner:
Email address: firstname.lastname@example.org
- This Policy applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your Personal Data by us.
- We may revise this Policy from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Policy was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.
- Effective date: April 18, 2022
- Last updated: April 18, 2022