- 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 an individual 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; and
“process”, “processed” and “processing” means any operations or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
- 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. It also includes internet protocol (“IP”) address, cookie strings or device IDs, as well as information that may not on its own identify you, but which we store alongside such identifiers, such as how you are using our services or the country you are in when you do so.
- Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context so permits).
COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
- 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 applicable laws for the time being in force. 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).
- 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 (whether made available by us or through us);
(b) verifying your identity;
(c) responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
(d) managing your relationship with us, including addressing or investigating any claims or disputes and enforcing any agreements and/or terms and conditions that govern our relationship;
(e) processing payment or credit transactions in relation to your use of our products and services;
(f) communicating with you, including providing you with information that is relevant to your existing relationship with us and updates on changes to goods and/or services provided by us;
(g) to customise and improve our website and/or any other platform and their content to your particular preferences;
(h) sending you marketing information about our goods and/or services, including notifying you of our marketing events, initiatives and promotions, lucky draws, membership and rewards schemes and other promotions;
(i) complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any local or foreign authorities, including governmental, regulatory, tax and law enforcement authorities;
(j) any other purposes for which you have provided the information;
(k) transmitting the information 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
(l) any other incidental business purposes related to or in connection with the above.
- We may, for the above purposes, contact you via mail, electronic mail, telephone, SMS, facsimile or other forms of communication through mobile applications. In respect of sending marketing information to your Singapore telephone number, we will also require your express consent in writing or other recorded form to do so or if you have not otherwise made the appropriate registration of that number with the Do Not Call Registry. Should you wish to opt-out of our contact list for any reason, please submit your request in writing or via email to the contact details provided below.
- We may from time to time and in compliance with all applicable laws on data privacy, disclose your personal data:
(a) to any personnel of Social Innovation Park, 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 in order to perform any of the functions listed in Clause 5 above;
(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.
- Please be assured that when we disclose your personal data to such parties, we require them to ensure that any personal data disclosed to them are kept confidential and secure.
- For more information about the third parties with whom we share your personal data, you may, where appropriate, wish to refer to the agreement(s) and/or terms and conditions that govern our relationship with you. You may also contact us for more information at the contact details provided below.
- For the avoidance of doubt, if we have reasonable grounds to believe that you are in breach of any of the terms of this Policy or any agreement(s) and/or terms and conditions that govern our relationship with you, we reserve the right, in our sole and absolute discretion, to cooperate fully with governmental authorities, private investigators, all the rightful owner(s) or interest holder(s) and/or injured third parties in the investigation of any potential or ongoing criminal or civil wrongdoing. Further, we may disclose your identify and contact information, or such other personal data, if requested by a government or law enforcement body, private investigator, rightful owner or interest holder and/or any injured third party or as a result of a subpoena or other legal action, or if we are of the view, in our sole and absolute discretion, that it would be in its best interest to do so. We shall not be liable for damages or results arising from such disclosure, and you agree not to bring action or claim against us for such disclosure.
- 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).
LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA
- The legal basis for the processing of your personal data will generally fall under one or more of the following:
(a) it is necessary for the performance of our contractual relationship with you for the supply of any goods or services;
(b) it is necessary for our legitimate interests;
(c) it is necessary to comply with our legal obligations;
(d) it is authorised under any applicable law or regulations; and/or
(e) you are deemed to have consented to such processing under any applicable law or regulations.
- Please note that we may process your personal data on more than one lawful ground depending on the specific purpose(s) for our use of your personal data. Please contact us if you need details about the specific legal ground(s) we are relying on to process your personal data.
COOKIES AND RELATED TECHNOLOGIES
- A pixel tag, also known as a web beacon, is an invisible tag placed on certain pages of our website but not on your computer. Pixel tags are usually used in conjunction with cookies and are used to monitor the behaviour of users visiting the website.
- You may set up your web browser to block cookies which will in turn disable the pixel tags from monitoring your website visit. You may also remove cookies stored from your computer or mobile device. However, if you do block cookies and pixel tags, you may not be able to use certain features and functions of our websites.
- Our websites may contain links to other websites which are not maintained by us. This Policy only applies to our website. When visiting third party websites, you should read their privacy policies which will apply to your use of the said websites.
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. You may withdraw your consent and request us to stop using and/or disclosing your personal data for any or all the purposes listed above by submitting your request in writing or via email to 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 ten (10) business days of receiving it.
- 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 and/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 18
- Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclosure without consent is permitted or required under applicable laws.
ACCESS TO AND CORRECTION OF PERSONAL DATA
- 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.
- Please note that a reasonable administrative fee may be charged for an access request. If so, we will inform you of the applicable 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) days after receiving your request, we will inform you in writing within thirty (30) days after receiving your request 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
- 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.
- You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure and for this reason we cannot guarantee the security or integrity of any personal data which is transferred from you or to you via the Internet. 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 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 us 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 the personal data was collected, and is no longer necessary for legal or business purposes.
TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
- 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.
EFFECT OF NOTICE AND CHANGES TO POLICY
- This Policy applies in conjunction with any notices, contractual clauses and consent clauses and other terms and conditions which you have agreed to that apply in relation to the collection, use and disclosure of your personal data by us (collectively, the “Other Terms & Conditions”.
[In the event of inconsistency between the Other Terms & Conditions and this Policy, the terms in the Other Terms & Conditions shall prevail]
- We may revise this Policy from time to time without any prior notice. If we revise our Policy, we will make available the updated policy on this website so that you may be aware of the information we collect and how we use it. Such revisions to our Policy shall apply from the time that we post the same on this website. 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 website and/or services constitutes your acknowledgement and acceptance of such changes.
- Note that as we are a Singapore registered company, this Policy has been drafted solely in accordance with the laws of Singapore. Any disputes arising out of or in connection with this Policy shall be resolved in the courts of Singapore.
- We do not represent or warrant that this Policy complies with the privacy laws of any other jurisdiction and accordingly, you shall not construe this Policy as such.
|If you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to contact us on any aspect of this Policy or your personal data, you may contact us at:
Data Protection Officer
Social Innovation Parks Ltd
50 Punggol East
Phone: 6312 8802
Last updated: 1 July 2018