By providing information to us, contacting or interacting with us, accessing and/or using our services and products or signing up for any promotions, accounts, programs, products and services (or the like) offered by us, you acknowledge that you have read and understood this Policy and consent to the collection, use and disclosure of your personal data by us as well as our representatives and/or agents, for the purposes set out in the Policy.
Kindly read this Policy so that you are aware of the purposes for which we collect, use, disclose or otherwise process your personal data.
1. As used in this Policy:
“personal data” means any data, whether true or not, about the 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.
2. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include your name, contact information such as your address, email address or telephone number, nationality, gender, date of birth, age, marital status, signature, photographs and other audio-visual information, employment information and financial information such as credit card numbers, debit card numbers or bank account information.
3. 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
4. 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 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 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).
5. We may collect, use or disclose 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 to you;
(b) verifying your identity;
(c) responding to, handling, and processing queries, requests, applications, complaints and feedback from you;
(d) to process exchanges refunds;
(e) managing your relationship with us;
(f) providing customer service and support to you;
(g) to enable or assist changes, enhancements or improvements to our products, services and customer experience;
(h) managing our business operations and/or complying with our internal policies and procedures;
(i) auditing, risk management, compliance, security processes and internal investigations;
(j) processing of and/or management of payment and/or credit transactions;
(k) understanding and analysis of your needs and preferences;
(l) providing you information about our products or services including informing you of our marketing campaigns, events, launches, new products and services, initiatives and promotions, lucky draws, competitions, membership and rewards schemes and other promotional activities;
(m) enabling and/or facilitating your proposed participation/participation in our promotional activities, surveys and/or research groups;
(n) conducting investigations to disputes, billing or fraud;
(o) preventing, detecting and investigating crime and/or analysing and managing commercial risks;
(p) legal proceedings;
(q) complying 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;
(r) monitoring and/or recording interactions for quality assurance, employee training and performance evaluation;
(s) facilitating your use of our website;
(t) creating and maintaining your personal data in our system database for internal records and reference;
(u) matching any personal data held which relates to you for any of the purposes listed herein;
(v) matching personal data with other data collected for other purposes and from other sources (including third parties) in connection with the provision, marketing or offering of products and services by us;
(w) any other purposes for which you have provided the information;
(x) any other purposes for which you have been notified;
(y) any other purposes a person would consider to be reasonable; and
(z) any other purposes incidental to or related to or in connection with the above.
6. We will take reasonable steps to protect your personal data against unauthorised disclosure. Subject to the provisions of any applicable law, we may also 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 or services requested by you; or
(b) to vendors, contractors, sub-contractors, third party service providers, agents, business partners, affiliates and other organisations which we engaged, in relation to provision of operational services to us or the performance of any of the functions listed in clause 5 above.
(c) entities providing services relating to insurance to us;
(d) external banks, credit card companies, other financial institutions/companies and their respective service providers;
(e) our professional advisers such as consultants, auditors and lawyers;
(f) relevant government ministries, regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority;
(g) prospective purchasers and/or new owners and their representatives, agents and/or advisers in the event of business asset transactions such as merger, acquisitions or asset sale; and/or
(h) any other party to whom you authorise us to disclose your personal data to.
7. The purposes listed in the clauses 5 and 6 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).
8. We (including our website and mobile or web-based applications) may provide you with social plug-ins from various social networks (such as Facebook, Instagram and Twitter). If you are logged in to a social network while visiting our website, mobile or web-based applications and/or when you interact with a social network (including social plug-ins), your activity information will also be made available to social networks. If you do not wish for such data transfer, please log off on your social network before you enter one of our websites or mobile or web-based applications. We cannot control such data collection and/or data transfer. Please read the privacy policies of the social networks for information about the collection, transfer, use or disclosure of personal data, your rights and the methods available for your privacy settings.
COOKIES AND WEB ANALYTICS
9. Our website and mobile or web-based applications may use “cookies” to personalize your online experience. Cookies may be used to ensure a smooth user experience, perform analytics, and for showing relevant advertisements. A cookie is a text file that is placed on your device by a web server at the request of the websites you visit or applications you use and which stores information on your device for a limited period of time. This means that when you visit our website or use any of our mobile or web-based applications, a cookie will be stored on your computer or device, except when your browser settings do not allow for such cookies.
11. Most Web browsers automatically accept cookies, but generally, should you prefer to decline cookies, you may so by modifying your browser setting. Please note that should you choose to decline cookies, you may not be able to access all or parts of our website and mobile or web-based applications or to fully experience the features of our website, mobile or web—based applications.
LINKS TO OTHER WEBSITES
12. Our websites may contain links to other websites, mobile or web-based applications which are not owned or maintained by us (“Third party sites”). When visiting these Third party sites or disclosing your personal data to third parties, you should read their privacy policies before you disclose your personal data. We are not responsible for the collection, use or disclosure of your personal data by such third parties.
WITHDRAWING YOUR CONSENT
13. 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 using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.
14. 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.
15. 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. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 13 above.
16. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
ACCESS TO AND CORRECTION OF PERSONAL DATA
17. 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.
18. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
19. 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 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
20. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. 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
21. 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 our Data Protection Officer in writing or via email at the contact details provided below.
DATA PROTECTION OFFICER
22. 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:
Data Protection Officer
Or write to our Data Protection Officer at:
Data Protection Officer
Captivade Pte Ltd
22 Sin Ming Lane #06-76 Midview City
23. TO THE MAXIMUM EXTENT PERMITTED BY LAW, WE SHALL NOT BE LIABLE IN ANY EVENT FOR ANY LOSS AND/OR DAMAGES OF ANY KIND (INCLUDING INDIRECT, INCIDENTAL OR CONSEQUENTIAL, SPECIAL, EXEMPLARY OR PUNITIVE) OR FOR ANY LOSS OF REPUTATION OR GOODWILL, WHETHER BASED IN TORT (INCLUDING NEGLIGENCE), CONTRACT, EQUITY, STATUTE OR OTHERWISE, INCURRED AND/OR SUFFERED AS A RESULT OF UNAUTHORISED OR UNINTENDED USE, ACCESS OR DISCLOSURE OF YOUR PERSONAL DATA.
EFFECT OF POLICY AND CHANGES TO POLICY
24. This Policy applies in conjunction with any other policies, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
25. We may revise this Policy from time to time without any prior notice. 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 services constitutes your acknowledgement and acceptance of such changes.
26. This Policy is governed by the laws of Singapore.