Updated as at: [March 2019]
We take our responsibilities under the Singapore Personal Data Protection Act 2012 (“PDPA”), and where applicable, the European Union General Data Protection Regulation (“GDPR”) seriously. We also recognise the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data.
If you, at any time, have any queries on this policy or any other queries in relation to how we may manage, protect and/or process your personal data, please do not hesitate to contact our Data Protection Officer at the contact details below.
In addition, our Website may, from time to time, contain links to and from the websites of our partner networks, advertisers, affiliates or other third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies. As these websites are not owned or operated by us, we do not accept any responsibility or liability for the contents of these websites and their privacy policies and you access and provide your personal data to these third party websites at your own risk. Please check these policies before you submit any personal data to any such websites.
2. Personal data we collect
We may collect and process personal data about you such as:
(a) Personal data that you may provide when submitting or making available personal data to, our Website. This includes but is not limited to any personal data provided when you contact us through our contact page such as your name, email address and contact details.
(b) If you contact us for any reason, we may keep a record of that correspondence.
(c) Personal data that may be captured via any error logging and reporting tool that captures error report data and, at your option and with your consent, sends this data to us in order for us to be informed of any software errors or problems that may occur during your use of our Website or the services provided on it.
(d) Details of your visits to our Website, the activities you engage in when accessing our Website and the resources that you access on or via our Website.
You have the ability to accept or decline cookies by modifying the setting in your browser. If you would like to do this, please see the help menu of your browser. However, you may not be able to use all the interactive features of our Website if cookies are disabled.
4. How we use your personal data
We may use your personal data that we possess for the following purposes:
(a) To contact you through the contact information provided by you in order to provide you with information that you request from us.
(b) To manage and administer your use of the Website and contact you as may from time to time be necessary in connection with your use of the Website.
(c) To collect information relating to your online interactions with us (including, for example, your IP address and the pages you view) so that we can offer you a more consistent and personalised experience in your relationship with us and better serve your needs by customising the content that we share with you.
(d) To store, host and/or back up (whether for disaster recovery or otherwise) your personal data, whether within or outside Singapore.
(e) For record-keeping purposes.
(f) To verify, facilitate and/or process your transaction with us.
(g) To provide goods and services by us or by our designated representatives and/or business partners to you or to parties designated by you and matters ancillary thereto.
(h) To provide you with information and/or updates on products, services and promotions offered by us and selected third parties, including personalised content and information such as online advertisements or other forms of marketing to you.
(i) To conduct research, analysis and development activities (including but not limited to statistical analysis, data analytics, surveys and/or profiling) to improve the Website, services and facilities in order to enhance the services we provide to you, where you have consented to be contacted for such purposes.
(j) To conduct statistical analysis of the users of the App including the number of users, the frequency of use, profile of users and using such analysis for our business plans, the enhancement of our products and services, targeted advertisements and conveying such information in broad terms (but not information in relation to specific individuals) to third parties who have or propose to have business dealings with us
(k) To responding to legal process, pursuing legal rights and remedies, defending litigation and managing any complaints or claims.
(l) To respond to requests for information from public and governmental / regulatory authorities, statutory boards, related companies and for audit, compliance, investigation and inspection purposes.
(m) To comply with any applicable law, regulation, legal process or government request.
5. Disclosure of your information
Your personal data may be used, disclosed, maintained, accessed, processed and/or transferred to the following third parties, whether sited in Singapore or outside of Singapore, for one or more of the purposes set out above:
(a) our headquarters, subsidiaries and group companies;
(b) third party service providers which require the processing of your data, for example, third party service providers which have been engaged by us to: (i) to provide and maintain any IT equipment used to store and access your personal information; (ii) to host and maintain our Website; or (iii) otherwise in connection with the provision of certain services provided to you on or via our Website;
(c) our auditors and legal advisors;
(d) public and governmental/regulatory authorities, statutory boards, industry associations; and /or
(e) courts and other alternative dispute forums.
In certain circumstances we may provide third parties (whether or not located in Singapore) with aggregate information about our Website’s users. This may include information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is anonymised statistical data about our users’ browsing actions and patterns, and does not identify any individual.
Please rest assured that we never sell or rent your personal data.
6. Transfer of your personal data outside of Singapore
The personal data that we collect from you may be transferred to, used, processed and stored outside of Singapore for one or more of the purposes set out above. By submitting your personal data and/or using our Website, you agree and consent to such transfer, storing or processing.
Whenever we transfer your personal data outside of Singapore, we will employ our best efforts to ensure a similar degree of protection is afforded to it by requiring such third parties to protect your data and to, as far as possible, only transfer your personal data to third parties in countries where your personal data will be protected to a comparable standard as under the laws of the Republic of Singapore.
We will take reasonable steps to maintain appropriate physical, technical and administrative security to help prevent loss, misuse, unauthorized access, disclosure or modification of your personal information.
7. Updating your information
Where you submit your personal data on our Website, you should try to ensure such personal data is accurate, and let us know if such personal data changes so that we are not holding any inaccurate personal data about you.
8. Your rights
You may request to access and/or correct the personal data currently in our possession by writing to the Data Protection Officer using the contact details provided below. Please note that we may charge you a reasonable fee for the handling and processing of your requests to access your personal data.
10. Further information about the protection of personal data and the Singapore Personal Data Protection Act 2012