Effective date: February 2019
- Your Personal Data
- “Personal Data” refers to any data or information about you from which you can be identified either (a) from that data; or (b) from that data and other information to which we have or are likely to have access. Examples of such Personal Data which you may provide to us include (depending on the nature of your interaction with us):
- your name, contact details 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;
- information about your use of our Site and services, including cookies, IP address and account details to the extent that we may identify you from such information;
- your payment related information, such as your bank account or credit card information; and
- information about your usage of and interaction with our Site and/or services including computer and connection information, device capability, bandwidth, statistics on page views, and traffic to and from our Site.
- Collection of Personal Data
- We may collect your Personal Data in the following ways:
- when you submit forms;
- when you register for an account with us;
- when you interact with us;
- when you request that we contact you;
- when you submit any content to us; and
- when you submit your Personal Data to us for any other reason.
- When you browse our Site, you generally do so anonymously but please see the section below on cookies.
- If you provide us with any Personal Data relating to a third party, 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.
- 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 the services you have requested.
- Purposes for the Collection, Use and Disclosure of Your Personal Data
- We may collect, use and/or disclose your Personal Data for the following purposes:
- responding to your queries and requests;
- managing our business operations and complying with internal policies and procedures;
- matching any Personal Data held which relates to you for any of the purposes listed herein;
- verifying your identity;
- protecting and enforcing our contractual and legal rights and obligations;
- conducting audits, reviews, and analysis of our internal processes, action planning and managing commercial risks;
- complying with applicable rules, laws, regulations, and investigations by relevant authorities; and/or
- any other purpose relating to any of the above.
- In addition, we may collect, use and/or disclose your Personal Data for the following purposes:
- to process your application for subscription service;
- to maintain your account with us;
- to verify and process your personal particulars and payments in relation to the provision of subscription service to you;
- to communicate with you to inform you of changes and development to our policies, terms, and conditions or other administrative information;
- to handle requests and enquiries;
- to handle and/or publish any content submitted by you;
- to conduct market research for statistical, profiling and statistical analysis for the improvement of our services; and
- to process your Personal Data in relation to any of the purposes stated above.
- In addition, where permitted under the Act, we may also collect, use and/or disclose your Personal Data for the following purposes (which we may describe in our documents and agreements as “Additional Purposes” for the handling of Personal Data):
- providing additional services and benefits to you;
- matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision or offering of services, whether by us or third parties; and
- conducting market research, understanding and determining customer location, preferences and demographics for us to review, develop and improve our services and develop special offers and marketing programmes.
- In relation to particular services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use and/or disclose your Personal Data. If so, then we may collect, use and/or disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.
- You also consent to the collection, use and/or disclosure of your Personal Data by us in connection with any transaction relating to the acquisition, divestment, securisation, amalgamation, listing or other transaction relating to any interest in us, our shares or assets, and any other corporate transaction involving us, including any evaluation or due diligence relating thereto, as well as to the collection, use and disclosure of such information by the counterpart(ies) thereto for the same purposes, and the provision of goods and services by such counterpart(ies) following such transaction, as may be relevant.
- Disclosure of Personal Data
- We will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, your 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:
- our Associates;
- agents, contractors or third party service providers who provide operational services to us, such as telecommunications, information technology, payment, payroll, processing, training, market research, storage, archival or other services;
- vendors or any third party business partners who offer goods or services on our Site, whether in conjunction with us or not;
- the Credit Bureau Singapore, or in the event of default or disputes, any debt collection agencies or dispute resolution centres;
- 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;
- anyone to whom we transfer or may transfer our rights and duties;
- banks, credit card companies and their respective service providers;
- our professional advisors such as our auditors and lawyers;
- relevant government regulators or authorities; and
- any other party to whom you authorise us to disclose your Personal Data or to whom we are required to disclose pursuant to applicable laws, rules and regulations.
- When you interact with us on our Site, 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 Site and common entry and exit points into our Site.
- We use “cookies”, where a small data file is sent to your browser to store and track Aggregate Information about you when you enter our Site. The cookie is used to track information such as the number of users and their frequency of use, profiles of users and their preferred sites.
- We may use an independent company (the “Third PartyMarket Research Company”) to measure and analyse the Internet usage on our Site. We use the Third Party Market Research Company’s services to collect the following information, including but not limited to:
- the number of page views (or page impressions) that occur on the Site;
- the number of unique visitors to the Site;
- how long these unique visitors (on average) spend on our Site when they do visit; and
- common entry and exit points into our Site.
- This information is aggregated by the Third Party Market Research Company and provided to us to assist in analysing the usage of our Site. Such data is also accessible by media organizations and research companies, for the purpose of conducting industry comparisons with other Internet portals.
- Pages on our Site may be coded with software which enables the Third Party Market Research Company to track visitors to our Site.
- Third-Party Sites
- Our Site 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 Site. 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 Site, you should check the applicable terms, conditions and policies of the third party website to determine how it will handle any information collected from you.]
- Withdrawal, Access and Correction of your Personal Data
- Should you wish to withdraw consent to use of your Personal Data or obtain access to or make corrections to your Personal Data records, please log in to the relevant account through which the Personal Data was provided, if any, failing which please contact email@example.com.
- Please note that if your Personal Data has been provided to us by a third party, you should contact such party directly to make queries, provide feedback, or request access and corrections, to us on your behalf.
- 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 our 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.
- Governing Law
(Last updated Feb 2019)
- By email: firstname.lastname@example.org