1.2 “Personal Data” or “personal data” means data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access. Common examples of personal data could include name, identification number and contact information.
2. WHEN WILL COMPANY COLLECT PERSONAL DATA?
2.1 We will/may collect personal data about you:
(a) when you register and/or use our Services or Website, or open an account with us;
(b) when you submit any form, including, but not limited to, application forms or other forms relating to any of our products and services, whether online or by way of a physical form;
(c) when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our products and services;
(d) when you interact with us, such as via telephone calls (which may be recorded), letters, fax, face-to-face meetings, social media platforms and emails;
(e) when you use our electronic services, or interact with us via our application or use services on our Website. This includes, without limitation, through cookies which we may deploy when you interact with our application or WebWebsite;
(f) when you carry out transactions through our Services;
(g) when you provide us with feedback or complaints;
(h) when you register for a contest; or
(i) when you submit your personal data to us for any reason.
The above does not purport to be exhaustive and sets out some common instances of when personal data about you may be collected.
2.2 When you visit, use or interact with our Website, we may collect certain information by automated or passive means using a variety of technologies, which technologies may be downloaded to your device and may set or modify settings on your device. The information we collect may include, without limitation, your Internet Protocol (IP) address, computer/mobile device operating system and browser type, type of mobile device, the characteristics of the mobile device, the unique device identifier (UDID) or mobile equipment identifier (MEID) for your mobile device, the address of a referring website (if any), and the pages you visit on our Website and the times of visit. We may collect, use disclose and/or process this information only for the Purposes (defined below).
3. HOW DO WE USE THE INFORMATION YOU PROVIDE US?
We may collect, use, disclose and/or process your personal data for one or more of the following purposes:
(a) to consider and/or process your application/transaction with us or your transactions or communications with third parties via the Services;
(b) to manage, operate, provide and/or administer your use of and/or access to our Services and our Website, as well as your relationship and user account with us;
(c) to manage, operate, administer and provide you with as well as to facilitate the provision of our Services, including, without limitation, remembering your preferences;
(d) to tailor your experience through the Services by displaying content according to your interests and preferences, providing a faster method for you to access your account and submit information to us and allowing us to contact you, if necessary;
(e) to respond to, process, deal with or complete a transaction and/or to fulfil your requests for certain products and services and notify you of service issues and unusual account actions;
(f) to enforce our Terms of Service or any applicable end user license agreements;
(g) to deal with or facilitate customer service, carry out your instructions, deal with or respond to any enquiries given by (or purported to be given by) you or on your behalf;
(h) to contact you or communicate with you via voice call, text message and/or fax message, email and/or postal mail or otherwise for the purposes of administering and/or managing your relationship with us or your use of our Services, such as but not limited to communicating administrative information to you relating to our Services. You acknowledge and agree that such communication by us could be by way of the mailing of correspondence, documents or notices to you, which could involve disclosure of certain personal data about you to bring about delivery of the same as well as on the external cover of envelopes/mail packages;
(i) to conduct research, analysis and development activities (including, but not limited to, data analytics, surveys, product and service development and/or profiling), to analyse how you use our Services, to improve our Services or products and/or to enhance your customer experience;
(j) to allow for audits and surveys to, among other things, validate the size and composition of our target audience, and understand their experience with the Company’s Services;
(k) to respond to legal processes or to comply with or as required by any applicable law, governmental or regulatory requirements of any relevant jurisdiction, including, without limitation, meeting the requirements to make disclosure under the requirements of any law binding on the Company or on its related corporations or affiliates;
(l) any other purposes which we notify you of at the time of obtaining your consent. As the purposes for which we will/may collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of the applicable data without your consent0 is permitted by the Privacy Laws.
4. WHEN WILL THE COMPANY DISCLOSE THE INFORMATION IT COLLECTS FROM ITS VISITORS TO OUTSIDE PARTIES?
4.1 In conducting our business, we will/may need to disclose your personal data to our third party service providers, agents and/or our affiliates or related corporations, and/or other third parties for one or more of the above-stated Purposes. Such third party service providers, agents and/or affiliates or related corporations and/or other third parties would be processing your personal data either on our behalf or otherwise, for one or more of the above-stated Purposes. Such third parties include, without limitation:
(a) our subsidiaries, affiliates and related corporations;
(b) contractors, agents, service providers and other third parties we use to support our business. These include but are not limited to those which provide administrative or other services to us such as mailing houses, telecommunication companies, information technology companies and data centres;
(c) a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of The Company’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal data held by the Company about our Service Users is among the assets transferred; or to a counterparty in a business asset transaction that The Company or any of its affiliates or related corporations is involved in; and
(d) third parties to whom disclosure by us is for one or more of the Purposes and such third parties would in turn be collecting and processing your personal data for one or more of the Purposes
4.2 This may require, among other things, share statistical and demographic information about our Users and their use of the Services with suppliers of advertisements and programming. This would not include anything that could be used to identify you specifically or to discover individual information about you.
5. HOW DOES THE COMPANY PROTECT CUSTOMER INFORMATION?
5.2 Third parties may unlawfully intercept or access personal data transmitted to or contained on the Website, technologies may malfunction or not work as anticipated, or someone might access, abuse or misuse information through no fault of ours. We will nevertheless deploy reasonable security arrangements to protect your personal data as required by the Privacy Laws; however there can inevitably be no guarantee of absolute security such as but not limited to when unauthorised disclosure arises from malicious and sophisticated hacking by malcontents through no fault of ours.
6. INFORMATION COLLECTED BY THIRD PARTIES
7. DISCLAIMER REGARDING SECURITY AND THIRD PARTY WEBSITES
7.1 WE DO NOT GUARANTEE THE SECURITY OF PERSONAL DATA AND/OR OTHER INFORMATION THAT YOU PROVIDE ON THIRD PARTY WEBSITES. We do implement a variety of security measures to maintain the safety of your personal data that is in our possession or under our control. Your personal data is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the personal data confidential. When you place orders or access your personal data, we offer the use of a secure server. All personal data or sensitive information you supply is encrypted into our databases to be only accessed as stated above.
7.2 In an attempt to provide you with increased value, we may choose various third party websites to link to, and frame within, the Website. We may also participate in co-branding and other relationships to offer e-commerce and other services and features to our visitors. These linked websites have separate and independent privacy policies as well as security arrangements. Even if the third party is affiliated with us, we have no control over these linked websites, each of which has separate privacy and data collection practices independent of us. Data collected by our co-brand partners or third party websites (even if offered on or through our Website) may not be received by us.
7.3 We therefore have no responsibility or liability for the content, security arrangements (or lack thereof) and activities of these linked websites. These linked websites are only for your convenience and you therefore access them at your own risk. Nonetheless, we seek to protect the integrity of our Website and the links placed upon each of them and therefore welcome any feedback about these linked websites (including, without limitation, if a specific link does not work).
8. HOW CAN YOU OPT-OUT, REMOVE, REQUEST ACCESS TO OR MODIFY INFORMATION YOU HAVE PROVIDED TO US?
8.1 Opting Out and Withdrawing Consent
– To modify your email subscriptions, please let us know by sending an email to firstname.lastname@example.org. Please note that due to email production schedules, you may still receive emails that are already in production.
– You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control by sending an email to email@example.com
– Once we have your clear withdrawal instructions and verified your identity, we will process your request for withdrawal of consent, and will thereafter not collect, use and/or disclose your personal data in the manner stated in your request. If we are unable to verify your identity or understand your instructions, we will liaise with you to understand your request.
– However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal. In this regard, depending on the extent of your withdrawal of consent for us to process your personal data, it may mean that we will not be able to continue providing the Services to you, we may need to terminate your existing relationship and/or the contract you have with us, etc., as the case may be, which we will inform you of.
8.2 Requesting Access and/or Correction of Personal Data
– If you have an account with us, you may personally access and/or correct your personal data currently in our possession or control through the Account Settings page on the Website.
– For a request to access personal data, once we have sufficient information from you to deal with the request, we will seek to provide you with the relevant personal data within 30 days. Where we are unable to respond to you within the said 30 days, we will notify you of the soonest possible time within which we can provide you with the information requested. Note that Privacy Laws may exempt certain types of personal data from being subject to your access request.
– For a request to correct personal data, once we have sufficient information from you to deal with the request, we will correct your personal data within 30 days. Where we are unable to do so within the said period, we will notify you of the soonest practicable time within which we can make the correction. Note that Privacy Laws may exempt certain types of personal data from being subject to your correction request as well as provides for situation(s) when correction need not be made by us despite your request; and we will send the corrected personal data to every other organisation to which the personal data was disclosed by us within a year before the date the correction was made, unless that other organisation does not need the corrected personal data for any legal or business purpose.
– We reserve the right to refuse to correct your personal data in accordance with the provisions as set out in Privacy Laws, where they require and/or entitle an organisation to refuse to correct personal data in stated circumstances.