1.1 This Policy statement provides information on the obligations and policies of the Group in respect of an individual customer’s Personal Data. The Group undertakes to use reasonable efforts in applying, where practicable, those principles and the processes set out herein to its operations.
1.2 The Group’s officers, management, and members of staff shall use reasonable endeavours to respect the confidentiality of and keep safe any and all Personal Data collected and/or stored and/or disclosed and/or used for, or on behalf of, the Group. The Group shall use reasonable endeavours to ensure that all collection and/or storage and/or disclosure and/or usage of Personal Data by the Group shall be done in an appropriate manner and in accordance with the Act and this Policy.
1.3 By interacting with us, submitting information to us, or signing up for any products or services offered by us, you agree and consent to the Group as well as to its respective representatives and/or agents (“Representatives”) (collectively referred to herein as “The Group”, “us”, “we” or “our”) collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to the Group’s authorised service providers and relevant third parties in the manner set forth in this Privacy Statement.
1.4 This Policy supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your Personal Data, and your consents herein are additional to any rights which we may have at law to collect, use or disclose your Personal Data.
1.5 For the purposes of this Policy, in line with the provisions under the Singapore Personal Data Protection Act 2012 (No. 26 of 2012) (the “Act”), “Personal Data” shall mean data, whether true or not, about an individual customer who can be identified — from that data; or from that data and other information which an organisation has or is likely to have access. Such Personal Data shall also refer to that which is already in the possession of the Group or that which shall be collected by the Group in future.
2. Contacting the Data Protection Officer
2.1 Where you legitimately request access to and/or correction of Personal Data relating to you, such Personal Data which is in the possession and control of the Group, the Group shall provide and/or correct that data in a reasonable time and manner in accordance with its standard procedures as stated hereinafter.
2.2 In accordance with the Act, the Group has established a process for receiving and responding to any query or complaint that may arise with respect to the application of this Act. To ensure that the Group receives your complaints and enquiries, please send the same via email, with the subject heading of the email starting with “Personal Data Matter:” to the Data Protection Officer (the “DPO”) of the Group at the following email address: firstname.lastname@example.org
2.3 Please note that if your personal data has been provided to us by a third party (e.g. a member via a referral process), you should contact that individual to make such queries, complaints, and access and correction requests to the Group on your behalf.
2.4 Should you not wish the Group to use your Personal Data for any of the purposes listed in Clauses 3.2 to 3.4, or not to receive promotional materials from the Group, you may opt out by sending a clearly worded email, with the subject heading of the email starting with “Personal Data Matter:” to the DPO via the email address provided in Clause 2.2. Your request shall be processed within a reasonable time.
3. Statement of Practices
Types of Personal Data Collected:
3.1 As part of its day-to-day activity, the Group may collect from you, through various means, including via our website(s), telephone queries, emails, smart phone applications, marketing events such as road shows and any forms used by the Group from time to time, some or all of the following Personal Data:
• Name (first and surname);
• NRIC/ Passport Details
• Postal Address;
• Phone number (including mobile);
• Company registration number;
• Office number;
• Fax number;
• Email address;
• Bank account/credit card details;
• Personal Data of your emergency contacts;
• IP addresses; and
• Photographs and images.
Purpose of Collection of Personal Data
3.2 The above Personal Data mentioned in Clause 3.1 is collected for the purposes of providing you with the Group’s services and to ascertain if you are eligible for discounts, privileges or benefits or other related purposes; to conduct market research and analysis; for direct marketing through voice calls; text messages; email; direct mail and facsimile messages; for payment and/or credit control purposes; to notify you of any changes to our policies or services which may affect you; to respond to queries and feedback; and informing you of new developments, services, promotions of the Group and other third parties which we are associated with.
Disclosure of Personal Data
3.4 Without derogating from any of the above, the Group may also disclose your Personal Data to the following third parties:
• Regulators and law enforcement officials;
• Third party service providers and consultants;
• Credit, debit and charge card companies, banks and other entities processing payment;
• Potential buyers or investors of the Group or any of the Group’s companies; and
• Any agent or subcontractor acting on the Group’s behalf for the provision of the Group’s services.
The Group may disclose your Personal Data to the abovementioned parties also in the occurrence of any of the following events:
• To the extent that the Group is required to do so by the law;
• In connection with any legal proceedings or prospective legal proceedings;
• To establish, exercise or defend the Group’s legal rights;
• To the purchaser (or prospective purchaser) of any business or asset which the Group is (or is contemplating) selling; • To any person and/or entity for the purpose of processing such information on the Group’s behalf;
• To third parties who provide services to the Group or on its behalf;
• To any third party that purchases the Group or the Group’s business or any part of the Group or the Group’s business; and
• For the purposes of disaster recovery.
Optional Provision of Personal Data
In some instances, you may also be requested to provide certain Personal Data that may be used to further improve the Group’s products and services and/or better tailor the type of information presented to you. In most cases, this type of data is optional although, where the requested service is a personalised service, or provision of a product or dependent on your providing all requested data, failure to provide the requested data may prevent the Group from providing the service to you. This type of data includes, but is not limited to:
• Your age;
• Salary range and employment details;
• Education and Profession;
• Hobbies and leisure activities;
• Other related products and services subscribed to; and
• Family and household demographics.
3.7 Under certain circumstances, telephone calls made to any of the Group’s companies to order and/or service hotlines and/or inquiry telephone numbers are recorded for the purposes of quality control, appraisal, as well as staff management and development. In such an event, by agreeing to this Policy, you hereby give your clear and unambiguous consent for the collection, use and disclosure of such Personal Data in accordance to this Policy.
4. Transfer of Personal Data Overseas
Your Personal Data may be processed by the Group, its affiliates, agents and third parties providing services to the Group, in jurisdictions outside of Singapore. In this event the Group will comply with the terms of the Act.
5. Accuracy of Personal Data
Where possible, the Group will validate data provided using generally accepted practices and guidelines. This includes the use of check sum verification on some numeric fields such as account numbers or credit card numbers. In some instances, the Group is able to validate the data provided against pre-existing data held by the Group. In some cases, the Group is required to see original documentation before we may use the Personal Data such as with Personal Identifiers and/or proof of address. To assist in ensuring the accuracy of your Personal Data in the possession of the Group, please inform us of any updates of any parts of your Personal Data by sending a clearly worded email to the DPO at the email address provided at Section 2.2.
6. Protection of Personal Data
The Group uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your Personal Data and will not knowingly allow access to this data to anyone outside the Group, other than to you or as described in this Policy. However, the Group cannot ensure or warrant the security of any information you transmit to the Group and you do so entirely at your own risk. In particular, the Group does not warrant that such information may not be accessed, altered, collected, copied, destroyed, disposed of, disclosed or modified by breach of any of the Group’s physical, technical, or managerial safeguards.
7. Access and Correction of Personal Data
7.1 In accordance with Clause 2.1 of this Policy, you have the right to:
a) check whether the Group holds any Personal Data relating to you and, if so, obtain copies of such data; and
b) require the Group to correct any Personal Data relating to you which is inaccurate for the purpose for which it is being used.
7.2 The Group reserves the right to charge a reasonable administrative fee in order to meet your requests under Clause 7.1. Upon payment of the requisite fee, your request shall be processed within a reasonable time.
7.3 If you wish to verify the details you have submitted to the Group or if you wish to check on the manner in which the Group uses and processes your personal data, the Group’s security procedures mean that the Group may request proof of identity before we reveal information. This proof of identity will take the form of full details of name and NRIC or Passport or Fin number. You must therefore keep this information safe as you will be responsible for any action which the Group takes in response to a request from someone using the abovementioned details.
8. Storage and Retention of Personal Data
The Group will delete, as reasonably possible, or otherwise anonymise any Personal Data in the event that the Personal Data is not required for any reasonable business or legal purposes of the Group and where the Personal Data is deleted from the Group’s electronic, manual, and other filing systems in accordance with the Group’s internal procedures and/or other agreements.
9. Contacting you
To the extent that any of the communication means which you have provided the Group with (which may include, your telephone number and fax number) is/will be listed on the Do Not Call Registry (the “DNC”), by agreeing to this Policy through the usage of our services, or by any other means of indication, you hereby grant the Group your clear and unambiguous consent to contact you using all of your communication means you have provided to the Group including using via voice calls, SMS, Whatsapp, MMS, fax or other similar communications applications or methods, for the purposes as stated above in Paragraph 3.2. This will ensure your continued enjoyment of the Group’s promotional rates and services
10. Change Policy
The Group reserves the right to alter any of the clauses contained herein in compliance with local legislation and/or to meet its global policy requirements, and for any other purpose deemed reasonably necessary by the Group. You should look at these terms regularly. If you do not agree to the modified terms, you should inform us as soon as possible of the terms to which you do not consent. Pending such notice, if there is any inconsistency between these terms and the additional terms, the additional terms will prevail to the extent of the inconsistency.
11. Governing Law
This Policy is governed by and shall be construed in accordance with the laws of Singapore. You hereby submit to the non-exclusive jurisdiction of the Singapore courts.
12.1 This Policy only applies to the collection and use of Personal Data by the Group. It does not cover third party sites to which we provide links, even if such sites are co-branded with our logo. The Group does not share your Personal Data with third party websites. The Group is not responsible for the privacy and conduct practices of these third party websites, so you should read their own privacy policies before disclosure of any Personal Data to these websites.
12.2 The Group will not sell your personal information to any third party without your permission, but we cannot be responsible or held liable for the actions of third party sites which you may have linked or been directed to the Group’s website.
12.3 The Group’s website(s) does not target and is not intended to attract children under the age of 18 years old. The Group does not knowingly solicit personal information from children under the age of 18 years old or send them requests for personal data.