PDPA Policy

DATA PROTECTION NOTICE

This Data Protection Notice (“Notice”) sets out the basis which (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of our customers in accordance with the Personal Data Protection Act (“PDPA”). This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.

PERSONAL DATA

1. As used in this Notice:

“customer” means an individual who (a) has contacted us through any means to find out more

about any services we provide, or (b) may, or has, entered into a contract with us for

the supply of any 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.

2. 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 such as your

contact information such as your address, email address or telephone number,

nationality, gender, date of birth, marital status, photographs and other audio-visual

information.

3. Other terms used in this Notice shall have the meanings given to them in the PDPA (where the

context so permits).

 

COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

4. We generally do not collect your personal data unless (a) it is provided to us voluntarily by you

directly or via a third party who has been duly authorised by you to disclose your personal

data to us (your “authorised representative”) after (i) you (or your authorised representative)

have been notified of the purposes for which the data is collected, and (ii) you (or your

authorised representative) have provided written consent to the collection and usage of your

personal data for those purposes, or (b) collection and use of personal data without consent

is permitted or required by the PDPA or other laws. We shall seek your consent before

collecting any additional personal data and before using your personal data for a purpose

which has not been notified to you (except where permitted or authorised by law).

5. We may collect and use your personal data for any or all of the following purposes:

(a) performing obligations in the course of or in connection with our provision of the

goods and/or services requested by you;

(b) verifying your identity;

(c) responding to, handling, and processing queries, requests, applications, complaints,

and feedback from you;

(d) managing your relationship with us;

(e) processing payment or credit transactions;

(f) sending your marketing information about our services including notifying

you of our marketing events, initiatives and promotions, lucky draws, membership

and rewards schemes and other promotions;

(g) 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;

(h) any other purposes for which you have provided the information;

(i) 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

(j) any other incidental business purposes related to or in connection with the above.

6. We may disclose your personal data:

(a) where such disclosure is required for performing obligations in the course of or in

connection with our provision of the  services requested by you; or

(b) to third party service providers, agents and other organisations we have engaged to

perform any of the functions listed in clause 5 above for us.

7. 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

8. 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. 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 or via email to our Data Protection Officer

at the contact details provided below.

9. 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 ten (10) business days of receiving

it.

10. Whilst 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 in the manner described in clause 8 above.

11. Please note that withdrawing consent does not affect our right to continue to collect, use and

disclose personal data where such collection, use and disclose without consent is permitted

or required under applicable laws.

ACCESS TO AND CORRECTION OF PERSONAL DATA

12. If you wish to make (a) an access request for access to a copy of the personal data which we

hold about you or information about the ways in which we use or disclose your personal data,

or (b) a correction request to correct or update any of your personal data which we hold about

you, you may submit your request in writing or via email to our Data Protection Officer at the

contact details provided below.

13. Please note that a reasonable fee may be charged for an access request. If so, we will inform

you of the fee before processing your request.

14. We will respond to your request as soon as reasonably possible. Should we not be able to

respond to your request within thirty (30) days after receiving your request, we will inform

you in writing within thirty (30) days of the time by which we will be able to respond to your

request. If we are unable to provide you with any personal data or to make a correction

requested by you, we shall generally inform you of the reasons why we are unable to do so

(except where we are not required to do so under the PDPA).

PROTECTION OF PERSONAL DATA

15. To safeguard your personal data from unauthorised 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 personal data by us, and

disclosing personal data both internally and to our authorised third party service providers

and agents only on a need-to-know basis.

16. 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

17. We generally rely on personal data provided by you (or your authorised 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 in writing

or via email at the contact details provided below.

RETENTION OF PERSONAL DATA

18. 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.

19. 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 the personal data was collected, and is no longer necessary for legal or

business purposes.

TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE

20. We generally do not transfer your personal data to countries outside of Singapore. However,

if we do so, we will obtain your consent for the transfer to be made and 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.

DATA PROTECTION OFFICER

21. 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:

  1. Write to our company email. 

EFFECT OF NOTICE AND CHANGES TO NOTICE

22. This Notice 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.

23. We may revise this Notice 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 Notice was last

updated. Your continued use of our services constitutes your acknowledgement and

acceptance of such changes.