1. Your Personal Data
(a) your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address and any other information relating to you which you have provided us in any forms you may have submitted to us, or in other forms of interaction with you;
(b) information about your use of our website and services, including cookies, IP address, subscription account details and membership details, but only to the extent that we may identify you from such information;
(c) your payment related information, such as your bank account or credit card information, and your credit history; and
(e) information about your usage of and interaction with our website and/or services including computer and connection information, device capability, bandwidth, statistics on page views, and traffic to and from our website.
2. Collection of Personal Data
2.1 Generally, we collect your Personal Data in the following ways:
(a) when you submit forms or other documents relating to any of our products or services;
(b) when you register for or use any of our services on websites owned or operated by us or when you register as a member of websites owned and/or operated by us, or use services on such websites;
(c) when you respond to our request for additional Personal Data;
(d) when you ask to be included in an email or other mailing list;
(e) when you respond to our promotions and other initiatives;
(f) when you submit a job application;
(g) when we receive references from business partners and third parties, for example, where you have been referred by them;
(h) when you submit your Personal Data to us for any other reason.
2.2 When you browse our website or Apps, you generally do so anonymously but please see the section below on cookies and other related technologies which we have implemented on our website. We do not, at our website, automatically collect Personal Data unless you provide such information to us
2.3 If you provide us with any Personal Data relating to a third party (e.g. information of spouse, children, parents, employees and/or authorised representatives), by submitting such information to us, you represent to us that you have obtained the consent of the third party to you providing us with their Personal Data for the respective purposes.
2.4 You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with products and services you have requested, or processing any requests and applications you may have made to us.
3. Purposes for the Collection, Use and Disclosure of Your Personal Data
3.1 Generally, we collect, use and disclose your Personal Data for the following purposes:
(a) responding to, processing and handling your queries, requests, complaints and feedback;
(b) managing our infrastructure and business operations and complying with internal policies and procedures;
(c) facilitating business asset transactions (which may extend to any merger, acquisition or asset sale);
(d) matching any Personal Data held which relates to you for any of the purposes listed herein;
(e) verifying your identity;
(f) preventing, detecting and investigating crime, including fraud and money-laundering, and analyzing and managing other commercial risks;
(g) protecting and enforcing our contractual and legal rights and obligations;
(h) conducting audits, reviews and analysis of our internal processes, action planning and managing commercial risks;
(i) compliance with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities; and/or
(j) any other purpose relating to or reasonably necessary for any of the above.
3.2 In addition, we may collect, use and disclose your Personal Data for the following purposes, depending on the nature of our relationship with you:
(a) If you have a subscription or membership account with us:
(i) to maintain your account with us;
(ii) to verify and process your personal particulars and payments in relation to provision of services to you;
(iii) to provide you with the goods and services which you have signed up for;
(iv) communicating with you to inform you of changes and development to our policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you;
(v) resolving complaints and handling requests and enquiries;
(vi) conducting market research for statistical, profiling and statistical analysis for the improvement of services provided to you; and
(vii) any other purpose relating to or reasonably necessary for any of the above;
3.3 In relation to particular products or services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, then we will collect, use and disclose your Personal Data for these purposes as well.
3.4 You may withdraw your consent for receiving marketing or promotional materials/communication by contacting us using the contact details below. Once we receive confirmation that you wish to withdraw your consent for marketing or promotional materials/communication, it may take up to 30 calendar days for your withdrawal to be reflected in our systems. Therefore, you may still receive marketing or promotional materials/communication during this period of time. Please note that even if you withdraw your consent for the receipt of marketing or promotional materials, we may still contact you for other purposes in relation to the products and services that you have requested or purchased from us.
4. Disclosure of Personal Data
4.1 We will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, this Personal Data may be disclosed, for the purposes listed above (where applicable), to the following third parties, whether they are located overseas or in Singapore:
(a) our affiliates;
(b) agents, contractors or third party service providers who provide operational services to us, such as telecommunications, information technology, payment, payroll, processing, training, market research, shipping services, storage, archival or other services to us;
(c) vendors or any third party business partners who offer goods and services or sponsor contests or other promotional programs on our sites, whether in conjunction with us or not;
(d) external business and charity partners in relation to corporate promotional events;
(e) the Credit Bureau, or in the event of default or disputes, any debt collection agencies or dispute resolution centres;
(f) any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale);
(g) anyone to whom we transfer or may transfer our rights and duties;
(h) banks, credit card companies and their respective service providers;
(i) our professional advisors such as our auditors and lawyers;
(j) relevant government regulators or authority or law enforcement agency to comply with any laws or rules and regulations imposed by any governmental authority; and
(k) any other party to whom you authorise us to disclose your personal data.
5. Deemed consent
5.1 In addition to the matters set forth above, subject to and in accordance with applicable law, you shall be deemed to have consented to us collecting, using, disclosing and sharing amongst ourselves your Personal Data, and disclosing such Personal Data to our authorised service providers and relevant third parties:
(a) where in response to a request for your Personal Data in connection with identified purposes, you voluntarily provide such Personal Data to us for such purpose(s);
(c) where we have brought to your attention our intention to collect, use or disclose your personal data for identified purposes, and you have not taken any action to opt out within the period specified in our notices. For this purpose, you agree that we may provide you such notices via the our website, or via other forms of communication (e.g. SMS or email) based on the contact particulars that we may have of you in our records from time to time.
6. Other Bases for Handling or Processing Your Personal Data
(b) for improving our products, services, processes or business, understanding customer preferences and personalising experiences and recommendations, based on your Personal Data records with us.
7.1 When you interact with us on our websites, applications or services, we may collect or analyse anonymised information from which individuals cannot be identified (“Aggregate Information”), such as number of users and their frequency of use, the number of page views (or page impressions) that occur on the website and common entry and exit points into website.
7.3 Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser. However, you may not be able to enter certain part(s) of our website.
8. Third-Party Sites
8.1 Our website may contain links to other websites operated by third parties, such as our business partners. We are not responsible for the privacy practices of websites operated by third parties that are linked to our website. We encourage you to learn about the privacy policies of such third party websites. Some of these third party websites may be co-branded with our logo or trademark, even though they are not operated or maintained by us. Once you have left our website, you should check the applicable terms, conditions and policies of the third party website to determine how they will handle any information they collect from you.
9. Withdrawal, Access and Correction of your Personal Data
9.1 Should you wish to withdraw consent to use of your Personal Data or make corrections to your Personal Data records or delete your Personal Data records, please log in to the relevant account through which the Personal Data was provided, or contact us at email@example.com.
9.2 Please note that if your Personal Data has been provided to us by a third party, you should contact such third party directly to make any queries, feedback, and access and/or correction requests to us on your behalf.
9.3 Please note that if you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, we may not be in a position to continue to provide its products or services to you or administer any contractual relationship in place, and this may also result in the termination of any agreements with us and your being in breach of your contractual obligations or undertakings, and our legal rights and remedies in such event are expressly reserved.
10. Governing Law