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For the purpose of this Policy, “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. COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
We generally do not collect your personal data unless:
(a) you provide it to us or via a third party who has been 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 will obtain your consent before collecting any additional personal data and before using your personal data for a purpose that 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) to perform obligations in the course of or in connection with our provision of the goods or services requested by you;
(b) to respond to, handle, and process queries, requests, applications, complaints, and feedback from you;
(c) to manage your relationship with us;
(d) to enable us to comply 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;
(e) to inform or update you about products or services that you request from us or that may interest you where you have consented to be contacted for such purposes;
(f) to conduct statistical or other forms of analysis for purposes of maintaining or improving our services in general;
(g) any other purposes for which you have provided the information;
(h) transmitting to any unaffiliated third parties including our third-party service providers, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
(i) for fraud detection and for the prevention of financial crime prevention purposes;
(j) for detecting and preventing misuse of services; and
(k) any other incidental business purposes related to or in connection with the above.
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 and services requested by you; or
(b) to third-party service providers and other organizations, we have engaged to perform any of the functions with reference to the above-mentioned purposes.
3. 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 consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request via email to our Data Protection Officer at 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 will 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 or services to you and we shall, in such circumstances, notify you before completing the processing of your request. If you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 3.1 above.
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.
4. 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, use of privacy filters, and disclosing personal data both internally and to our authorised third-party service providers only on a need-to-know basis. However, no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we will strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
5. ACCURACY OF PERSONAL DATA
We generally rely on personal data provided by you. 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 via email at the contact details provided below.
6. 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.
7. 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.
8. COOKIES AND OTHER INFORMATION
We may collect certain information from you without you actively providing the information when you navigate the Website or mobile application via cookies. Cookies are small data text files stored in your local browser cache that send information about your previous visits to and activities on the Website or mobile application. These cookies will not give us any personal information about you. We may use the cookies to recognize your browser and thereby customise and optimize the Website to your preferences.
You can accept or delete cookies. For security reasons, you may wish to deactivate the storing of cookies or adjust your browser to inform you before the cookies are stored on your computer. However, please note that if you do erase or block the cookies, you may not be able to utilize some features on the Website or mobile application.
9. DATA PROTECTION OFFICER
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, in the following manner:
+65 8860 4019
Last updated: 1 October 2021
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