Privacy Policy
- OVERVIEW
- Pinheads Interactive is committed to protecting and respecting your privacy.
- This Privacy Policy applies to all persons and entities that access the Platform. By accessing and / or using the services available on or through the Platform, you hereby acknowledge that you have read and agree to the terms of this Privacy Policy.
- The Privacy Policy is designed to assist you to understand how we collect, use, disclose and/or process the Personal Data you have provided to us, as well as to assist you in making an informed decision before providing us with any of your Personal Data. Please read the following carefully to understand our views and practices regarding your Personal Data and how we will treat it.
- Pinheads Interactive is committed to protecting and respecting your privacy.
- DEFINITIONS
- “Personal Data” means information or data which can be used to directly or indirectly identify an individual who is a natural person including:-
- full name;
- identification number (for example, identification card, passport or social security number);
- date of birth;
- correspondence address;
- the type of Service and/or Product utilised;
- banking and financial record; and
- your personal details from Third Party Sites for e.g. Facebook.
- full name;
- “Selected Third Parties” refers to the third parties set out at section 4.5 below.
- “Personal Data” means information or data which can be used to directly or indirectly identify an individual who is a natural person including:-
- INFORMATION COLLECTION
- From time to time, Pinheads Interactive may collect information and data about you, including information and data:
- that you provide or is provided to by any person authorised by you;
- in relation to each of your visit to our Platform; and
- from such other third parties authorised by you and publicly available sources.
- Through you, Pinheads Interactive may also collect information and data about your family members, friends and other individuals (collectively all of the foregoing who are natural persons, (“Relevant Individuals”).
- In this regard, Pinheads Interactive may collect the following information and data stated at section 3.1 and 3.2 as follows:
- Any information or data about you and/or such Relevant Individual(s) that can identify you or such Relevant Individual(s), including but not limited to name, date of birth, passport, national identity card number or other identification number or particulars, address, email address, phone number, contact details, financial and credit card information, personal description and photograph, products and services portfolio information, transaction patterns and behaviour, financial background, educational background and demographic data;
- Any information and data about you and/or such Relevant Individual(s) generated and/or provided to us in the course of accessing our Platform and undertaking any activity on our Platform. For example, your registered username for the Platform, search results and history for Service and Product within our Platform, Service and Product Submissions history, records of transactions for Service and Product provided via our Platform, records of participation in any Interactive Service on our Platform, and your answers to questions intended for security verification;
- Any information and data about you and such Relevant Individual(s) generated and/or provided to us in the course of maintaining the relationship between us and you including account review reports and records of correspondence with you over the phone or via email;
- Any information and data about you collected in relation to each of your visit to our Platform including:
- technical information, including the Internet protocol (IP) address used to connect your computer or Device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- site visit information, including the full Uniform Resource Locators (URL) clickstream to, through and from our Platform (including date and time); products you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page and any phone number used to call our customer service number; and
- information and data from Cookies or other technologies deployed on our Platform. For detailed information on such Cookies and technologies and the purposes for which we use them see our Cookie Policy.
- technical information, including the Internet protocol (IP) address used to connect your computer or Device to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
- Any information and data about you collected by us when you participate in events organised by us, such as functions, seminars, contests or reward programs, which may include photographs, videos and voice recording of you;
- Any information and data about you which we receive if you use any of the other websites operated by us, our Affiliates or the other services provided by us, our Affiliates. In such a case, we will have informed you and obtained your consent for the collection of such information or data about you by the relevant Privacy Policy contained from such other websites operated by us.
- Any information and data about you which we receive from Selected Third Parties (set out at section 4.5 below);
- Any information or data about you and/or such Relevant Individual(s) that can identify you or such Relevant Individual(s), including but not limited to name, date of birth, passport, national identity card number or other identification number or particulars, address, email address, phone number, contact details, financial and credit card information, personal description and photograph, products and services portfolio information, transaction patterns and behaviour, financial background, educational background and demographic data;
- Information and data about you and such Relevant Individual(s) which are referenced above at section 3.3 shall collectively form part of Personal Data.
- From time to time, Pinheads Interactive may collect information and data about you, including information and data:
- Use and Disclosure of Personal
Information and Data
- Where
deemed necessary and appropriate by Pinheads Interactive and in
accordance with applicable laws, rules, regulations, Personal Data may be
used and disclosed by Pinheads Interactive for the following purposes to:
- grant
you access and facilitate the use of our Platform and to ensure that the
Site Content, Service, Product, Interactive Services, User Content,
Third Party Content and Third Party Sites are presented in the most
effective manner for you and for your Device;
- provide
you with information, Site Content, Service, Product, Interactive
Services and User Content that you request from us and access to Third
Party Sites and Third Party Content;
- carry
out our obligations arising from any contracts entered into between you
and us;
- provide
you with information about other Service and Product we offer that are
similar to those that you have already purchased or enquired about;
- provide
you, or permit Selected Third Parties to provide you, with information
about Service and Product that we feel may interest you. If you are an
existing User, we will only contact you by email, SMS or phone with
information about Service and Product similar to those that you had
previously considered, booked, registered, subscribed, scheduled or
purchased. If you are a new customer, and where you consented to the
disclosure of your Personal Data to Selected Third Parties, we (or such
Selected Third Parties) may contact you by email or SMS with information
about Service and Product;
- notify
you about changes to our Site Content, Service, Product, Interactive
Services, User Content, Third Party Content and Third Party Sites;
- administer
our Platform and for internal operations, including troubleshooting,
data analysis, testing, research, statistical and survey purposes;
- improve
our Platform to ensure that the Site Content, Service, Product,
Interactive Services, User Content, Third Party Content and Third Party
Sites are presented in the most effective manner for you and for your
Device;
- allow
you to participate in Interactive Services and any other interactive
features of our Platform, Service and Product, should you choose to do
so;
- implement
and review safety and security measures on our Platform so as to keep
our Platform safe and secure;
- measure
or understand the effectiveness of our advertising and third party
advertising on our Platform and on other third party websites, and to
deliver relevant advertising to you;
- make
suggestions and recommendations to you and other Users of our Platform
about Service, Products or third party products and services that may
interest you or them;
- make
decisions relating to the opening or continuation of User Account and
the establishment, provision or continuation of Service and Product otherwise
maintaining accurate “know your customer” information and conducting
anti-money laundering, credit and background checks;
- provide,
operate, process and administer User Account, Service and Product or to
process applications for User Account, Service and Product, any
transactions (including remittance transactions), and to maintain
service quality and train staff;
- undertake
activities related to the provision of User Account, Service and
Product, including the provision of articles, education materials,
research reports or similar materials;
- provide
Product-related services and support, including without limitation,
provision of processing or administrative support or acting as an
intermediary / nominee / agent in connection with your participation in
Product;
- provide
or grant access to Product-related materials;
- fulfil
foreign and domestic legal, regulatory and compliance requirements
applicable to Pinheads Interactive under any Applicable Laws (including
anti-money laundering and tax obligations applicable to Pinheads
Interactive, and disclosure to any court, governmental authority,
supervisory authority or any other authority or regulator pursuant to
relevant guidelines, regulations, orders, guidance or requests from such
organisations);
- verify
the identity and/or authority of your representatives who contact
Pinheads Interactive or may be contacted by Pinheads Interactive and to
carry out or respond to requests, questions or instructions from
verified representatives or other parties pursuant to our prevailing
security procedures;
- to carry
out data processing and perform statistical, trend analysis and
planning, for present and future reference;
- monitor
and record calls and electronic communications with you for record
keeping, quality, training, investigation and fraud prevention purposes;
- detect,
prevent, investigate and prosecute crime and fraud including to aid in
any criminal investigation by the relevant authorities of you, such
Relevant Individuals or any other person;
- enforce
(including, without limitation, collection of such outstanding amount(s)
owed to Pinheads Interactive) or defend the rights of Pinheads
Interactive, contractual or otherwise;
- perform
internal management to operate control and management information systems
and to carry out internal audits or enable the conduct of external
audits;
- comply
with contractual arrangements by or between industry self-regulatory,
industry bodies, associations of industry providers or other
institutions similar to Pinheads Interactive;
- to
manage Pinheads Interactive’s relationship with you, which may include
providing information to you or a Relevant Individual, about Pinheads
Interactive’s products and services, including without limitation,
Service and Product, where specifically consented to or where
permissible under applicable laws and regulations;
- for
marketing products or services by various modes of communication
including mail, telephone call, SMS, fax, electronic mail, internet,
market research, and designing or refining any similar products or
services including by conducting market research, data analysis, and
surveys; and
- to
comply with any obligations, requirements, policies, procedures,
measures or arrangements for sharing data and information within
Pinheads Interactive and any other use of data and information in
accordance with any Pinheads Interactive programs for compliance with
sanctions or prevention or detection of money laundering, terrorist
financing or other unlawful activities.
- grant
you access and facilitate the use of our Platform and to ensure that the
Site Content, Service, Product, Interactive Services, User Content,
Third Party Content and Third Party Sites are presented in the most
effective manner for you and for your Device;
- We may
combine any information and data, regardless of how such information and
data were provided to us or collected by us, and use the combined
information or data for the purposes set out at section 4.1 above.
- We may
also use and disclose Personal Data for any other purposes relating
to any of the above set out at sections 4.1 and 4.2, which a reasonable
person would consider appropriate in the circumstances.
- As the
purposes for which we may collect, use, disclose or process your Personal
Data depend on the circumstances at hand, such purpose(s) may not appear
above. However, we will notify you of such other purpose at the time of obtaining
your consent for the collection of such Personal Data, unless processing
of your Personal Data without your consent is permitted by law.
- We may
also share Personal Data with Selected Third Parties including:
- business
partners, suppliers and sub-contractors for the performance of any
contract we enter into with them or you;
- advertisers
and advertising networks that require the data to select and serve
relevant adverts to you and others. We do not disclose information about
identifiable individuals to our advertisers, but we may provide them
with aggregate information about our Users (for example, we may inform
them that 500 men aged under 30 have clicked on their advertisement on
any given day). We may also use such aggregate information to help
advertisers reach the kind of audience they want to target. We may make
use of information or data collected from you to enable us to comply
with our advertisers’ wishes by displaying their advertisement to that
target audience;
- analytics
and search engine providers that assist us in the improvement and
optimisation of our Platform;
- prospective
seller or buyer of business or assets in the event that we sell or buy
any business or assets, in which case we may transfer your Personal Data
to such buyer or seller as part of the transaction;
- any such
organisations or persons, if we are under a duty to disclose or share
your Personal Data in order to comply with any legal obligation, or in
order to enforce or apply any agreements, or to protect the rights,
property, or safety of Pinheads Interactive, our customers, Users or
others. This includes exchanging information with other companies and
organisations for the purposes of fraud protection and credit risk
reduction;
- agent,
contractor or third party service provider who provides administrative,
mailing, telemarketing, direct sales telecommunications, call centre,
business process, travel, visa, knowledge management, human resource,
data processing, information technology, computer, payment or other background
checks or other services (including backup services) to Pinheads
Interactive in connection with the operation of the business of Pinheads
Interactive;
- person
or entity which is part of the Pinheads Interactive although only to the
extent necessary to fulfil the relevant Permitted Purpose;
- drawee
or drawer bank in connection with any cheque or equivalent processed by
Pinheads Interactive;
- financial
institution with whom you have or propose to have dealings in relation
to any Service and/or Product;
- person
or entity to whom Pinheads Interactive is under an obligation or
otherwise required to make disclosure pursuant to legal process or under
the requirements of any foreign or domestic law, regulation, court order
or agreement entered into, binding on or applying to Pinheads
Interactive, or agreement entered into by Pinheads Interactive and any
government authority, domestic or foreign, or between or among any two
or more domestic or foreign governmental authorities, or any disclosure
under and for the purposes of any guidelines or guidance given or issued
by any legal, regulatory, governmental, tax, law enforcement or other
authorities, or self-regulatory or industry bodies or associations with
which Pinheads Interactive is required or expected to comply, or any
disclosure pursuant to any contractual, best practices or other
commitment of Pinheads Interactive with local or foreign legal,
regulatory, governmental, tax, law enforcement or other authorities, or
self-regulatory or industry bodies or associations of financial services
providers, all of which may be within or outside whichever country you
access the Platform from including disclosure to courts, tribunals,
legal, regulatory, tax and government authorities or
self-regulatory or industry bodies or associations, whether such legal
process, obligation, request, requirement, agreement or guidance may be
existing currently or created in the future;
- financial
institution, processing agent, Payment Gateway or any other person who
will be involved in remittance transactions or any banking/financial
activities; and
- actual
or proposed assignee of Pinheads Interactive, or participant or
sub-participant or transferee of Pinheads Interactive’s rights in
respect of you or any other Relevant Individual, all or any part of the
assets or business of Pinheads Interactive.
- business
partners, suppliers and sub-contractors for the performance of any
contract we enter into with them or you;
- In this regard, the purposes for the use and disclosure of information and data about you which is referenced under this section 4 shall collectively be referred to as “Permitted Purposes”.
- Where
deemed necessary and appropriate by Pinheads Interactive and in
accordance with applicable laws, rules, regulations, Personal Data may be
used and disclosed by Pinheads Interactive for the following purposes to:
- ADMINISTRATION AND MANAGEMENT
OF YOUR PERSONAL DATA
- We will
take reasonable efforts to ensure that your Personal Data is accurate and
complete, if your Personal Data is likely to be used by Pinheads
Interactive to make a decision that affects you, or disclosed to another
organisation. However, this means that you must also update us of any
changes in your Personal Data that you had initially provided us with. We
will not be responsible for relying on inaccurate or incomplete Personal
Data arising from your not updating us of any changes in your Personal Data
that you had initially provided us with.
- We will
also put in place reasonable security arrangements to ensure that your
Personal Data is adequately protected and secured. Appropriate security
arrangements will be taken to prevent any unauthorised access,
collection, use, disclosure, copying, modification, leakage, loss, damage
and/or alteration of your Personal Data. However, we cannot assume
responsibility for any unauthorised use of your Personal Data by third
parties which are wholly attributable to factors beyond our control.
- We will
also put in place measures such that your Personal Data in our possession
or under our control is destroyed and/or anonymized as soon as it is
reasonable to assume that (i) the purpose for which that Personal Data
was collected is no longer being served by the retention of such Personal
Data; and (ii) retention is no longer necessary for any other legal or
business purposes.
- Where
your Personal Data is to be transferred out of whichever country you
access this Site from, we will comply with the Applicable Laws in doing
so.
- We will
take reasonable efforts to ensure that your Personal Data is accurate and
complete, if your Personal Data is likely to be used by Pinheads
Interactive to make a decision that affects you, or disclosed to another
organisation. However, this means that you must also update us of any
changes in your Personal Data that you had initially provided us with. We
will not be responsible for relying on inaccurate or incomplete Personal
Data arising from your not updating us of any changes in your Personal Data
that you had initially provided us with.
- RIGHT TO REFUSE USE OF PERSONAL
DATA FOR MARKETING PURPOSES
- You have
the right to ask us not to process your Personal Data for marketing
purposes. Even after you have given us your consent for your Personal
Data to be used for marketing purposes, you may, at any time thereafter,
withdraw your consent. You can exercise your right to opt out of such
processing by contacting us at email address specified at Section 12
below or by marking on the relevant online forms we use to collect your
data.
- You have
the right to ask us not to process your Personal Data for marketing
purposes. Even after you have given us your consent for your Personal
Data to be used for marketing purposes, you may, at any time thereafter,
withdraw your consent. You can exercise your right to opt out of such
processing by contacting us at email address specified at Section 12
below or by marking on the relevant online forms we use to collect your
data.
- LINKS TO OTHER SITES
- Our Platform may, from time to time, contain links to Third Party
Sites and from the websites of our partner networks, advertisers or Affiliates.
If you follow a link to any of these Third Party Sites, please note that
these Third Party Sites may or may not have their own privacy policies and that
we do not accept any responsibility or liability for these policies or lack
thereof. Please check these policies before you submit any information
including your Personal Data to these Third Party Sites.
- If you access a page on our Platform that includes a social plugin,
your browser may set up a direct connection to the servers of third parties and
transfer the social plugin’s content directly to your browser which will then
integrate the content with the Third Party Sites and/or our Platform. We have
no influence on the extent of the data that third parties collect via its
social plugins. If you do interact with the social plugins, e.g. by using the
“Like”, “Share”, “Follow” buttons or by posting a commentary, your browser will
transfer such information directly to the Third Party Sites where it is being
stored and/or published.
- If you are an user of a Third Party Site and do not wish the Third Party Site to collect data on you via our Platform and to combine such data with your user data, you may need to log off from the Third Party Site before accessing our Platform. You may also wish to block social plugins by downloading and installing the relevant add-ons for your browser.
- Our Platform may, from time to time, contain links to Third Party
Sites and from the websites of our partner networks, advertisers or Affiliates.
If you follow a link to any of these Third Party Sites, please note that
these Third Party Sites may or may not have their own privacy policies and that
we do not accept any responsibility or liability for these policies or lack
thereof. Please check these policies before you submit any information
including your Personal Data to these Third Party Sites.
- ACCESS TO INFORMATION
- You have
the right to request from us Personal Data about you held by Pinheads
Interactive. If you wish to access, update or otherwise change or
remove any information that you provide to us, please contact us at
email address specified at Section 12 below for assistance. Any access
request may be subject to a fee to meet our costs in providing you with
details of the information we hold about you.
- In
exceptional circumstances, Pinheads Interactive may deny you access to
your Personal Data but we will provide you with an explanation of
the reason(s) which prevent us from doing so under the applicable laws.
Such exceptional circumstances include but are not limited to where:
- An
investigating authority or government institution objects to Pinheads
Interactive complying with a customer’s request;
- The
information may, in the exercise of Pinheads Interactive’s reasonable
discretion and/or assessment, affect the life or security of an
individual; and
- Data is
collected in connection with an investigation of a breach of contract,
suspicion of fraudulent activities or contravention of law.
- An
investigating authority or government institution objects to Pinheads
Interactive complying with a customer’s request;
- You have
the right to request from us Personal Data about you held by Pinheads
Interactive. If you wish to access, update or otherwise change or
remove any information that you provide to us, please contact us at
email address specified at Section 12 below for assistance. Any access
request may be subject to a fee to meet our costs in providing you with
details of the information we hold about you.
- CHANGES TO OUR PRIVACY POLICY
- We may
from time to time vary or amend this Privacy Policy by posting the
amended Privacy Policy on this Site. Any use of the Platform, Services
and/or Product after the amendment of this Privacy Policy will be deemed
to be an acceptance of the amended Privacy Policy by you. If you do not
agree to the amended Privacy Policy, you have the right to close your
account and/or cease using the Platform, Service and Product. Please
check this page from time to time as the changes, variations and
corrections to the Privacy Policy are binding on you.
- We may
from time to time vary or amend this Privacy Policy by posting the
amended Privacy Policy on this Site. Any use of the Platform, Services
and/or Product after the amendment of this Privacy Policy will be deemed
to be an acceptance of the amended Privacy Policy by you. If you do not
agree to the amended Privacy Policy, you have the right to close your
account and/or cease using the Platform, Service and Product. Please
check this page from time to time as the changes, variations and
corrections to the Privacy Policy are binding on you.
- MINORS
- Pinheads Interactive cannot distinguish the age of persons who access and use its websites. If a minor (according to applicable laws) has provided Pinheads Interactive with Personal Data without parental or guardian consent, the parent or guardian should contact Pinheads Interactive to remove the relevant Personal Data and unsubscribe the minor.
- ACKNOWLEDGEMENT
- You
acknowledge that where you fail to supply relevant information or data or
withdraw consent in respect of the collection, use and/or disclosure of
relevant information or data as described in this Privacy Policy,
Pinheads Interactive may be unable to open or continue User Account(s),
or establish or provide or continue any Service and Product, or continue
to allow you to use or access our Platform, Site Content, User Content,
Service, Product, or Interactive Service. Pinheads Interactive will
inform you of the likely consequences for such withdrawal of consent
should you inform us of your intention to withdraw your consent.
- You
warrant to Pinheads Interactive that where you or your representatives
are responsible for the provision of any information or data relating to
any person(s) to Pinheads Interactive, or has provided any such
information or data to Pinheads Interactive, you have informed and
obtained the consent of the person(s) concerned to allow Pinheads
Interactive to collect, use and/or disclose information relating to the
person(s) concerned as described in this Privacy Policy.
- You agree
that you have obtained the consent of all such Relevant Individual(s) so
that any information or data of a Relevant Individual may be processed,
kept, transferred or disclosed in and to any country as Pinheads
Interactive considers appropriate or necessary, in accordance with
applicable law for the Permitted Purposes. Such data may also be
processed, kept, transferred or disclosed in accordance with the local
practices and laws, rules and regulations (including any regulatory
requests, governmental acts and orders) in such country/jurisdiction.
- You
acknowledge that where you fail to supply relevant information or data or
withdraw consent in respect of the collection, use and/or disclosure of
relevant information or data as described in this Privacy Policy,
Pinheads Interactive may be unable to open or continue User Account(s),
or establish or provide or continue any Service and Product, or continue
to allow you to use or access our Platform, Site Content, User Content,
Service, Product, or Interactive Service. Pinheads Interactive will
inform you of the likely consequences for such withdrawal of consent
should you inform us of your intention to withdraw your consent.
- CONTACT
Questions, comments and requests regarding this Privacy Policy are welcomed and may be directed to Pinheads Interactive’s Data Protection Officer at the following address: [email protected]
DATA PROTECTION NOTICE
This Data Protection Notice (“Notice”) sets out the basis which Pinheads Interactive (“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 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.
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 NRIC number, contact information such as your address, email address or telephone number, nationality, gender, date of birth, marital status, photographs and other audio-visual information, employment information and financial information such as credit card numbers, debit card numbers or bank account 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 goods or 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 goods or 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 at:
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.
Effective date : 1/1/2019
Last updated : 23/8/2019