“Personal Data” refers to data, whether true or not, about an individual who can be identified from that data, or from that data in combination with other information to which the organisation may have access and includes the meaning otherwise as defined in the Act as amended from time to time.
1 Collection & Consent
1.1 Personal Data may be collected from you in one or more of the following ways:
(a) when you order or purchase products or services from us;
(b) when you post a feedback or interact with our customer service officers/sales, eg. via meetings, emails or telephone calls (which may be recorded for training, quality control, business and/or other lawful purposes);
(c) when you request that we contact you, be included in an email or other mailing list;
(d) when you respond to our promotions, campaigns or other initiatives or attend our events;
(e) when we receive references from business partners and third parties, for example, where you have been referred by them;
(f) when you visit our websites;
(g) during CCTV recordings when you visit our premises or photo taking or video recording at events;
(h) when you provide or contemplate providing security to us for a transaction;
(i) when you submit your Personal Data to us for any other reasons; and/or
(j) when we collect your Personal Data by other lawful means.
Unless permitted by applicable laws, we will not collect Personal Data without your consent.
You warrant and represent to us that (a) Personal Data which you disclose to us is accurate and complete; and (b) where you volunteer Personal Data of another person to us, that you are authorized by such other person to disclose such Personal Data to us, and that such Personal Data is accurate and complete.
1.4 You shall consult your parent or guardian before giving us your Personal Data if you are under the age of eighteen.
2 Purposes for which we collect, use and disclose your Personal Data
2.1 Your Personal Data may be collected, used and/or disclosed for the following purposes:
(a) to verify and process your personal particulars and payments;
(b) to provide goods and services to you;
(c) to respond and deal with enquiries, complaints and other customer-care matters or otherwise communicate with you;
(d) to monitor or record phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes;
(e) to manage payment, billing, account, credit checks and debt-recovery matters;
(f) to send you information, promotions, updates, and marketing and advertising materials in relation to our goods and services and that of our group companies;
(g) to manage, develop and improve our business and operations to serve you better;
(h) to carry out marketing promotions and campaigns, and personalising your experience at our customer touchpoints;
(i) to carry out market research and customer surveys;
(j) to conduct investigations or audits or carry out crime and fraud prevention and risk management activities;
(k) to comply with legal and regulatory requirements;
(l) to enforce our legal rights and obligations;
(m) to facilitate business asset transactions (which may extend to any mergers, acquisitions or asset sales);
(n) for other purposes for which we have obtained your consent; and
(o) for any other purposes reasonably necessary, ancillary or related to the above specified purposes.
2.2 Your Personal Data may be disclosed for the purposes indicated above to our officers and employees, third parties, affiliates, service providers, advisors, which include without limitation, the following persons or entities:
(a) banks, credit card companies, and payment vendors;
(b) debt collection agencies;
(c) logistics and courier services companies;
(d) call centre services providers;
(e) our business partners and authorised distributors, dealers or resellers;
(f) relevant government regulators or authorities or law enforcement agencies;
(g) our insurers and advisors, including consultants, auditors and lawyers;
(h) data intermediaries; and
(i) any other party to whom you authorise us to disclose your Personal Data to.
Save for relevant government regulators and authorities or law enforcement agencies, we will ensure that such parties receiving your Personal Data (i) are under duty of confidentiality to us with respect to the use, holding, processing, retention and/or transfer of your Personal Data; and (ii) have the need to know or handle such Personal Data.
2.3 If you have provided us with your Singapore telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your Singapore telephone number(s), then from time to time, we may contact you using such Singapore telephone number(s) (including via voice calls, text, fax or other means) with information about our products and services.
2.4 Your Personal Data may be transferred, stored and/or processed in a country or territory outside Singapore and you consent to any such transfer, storage and/or processing of your Personal Data outside Singapore. We will however ensure that any party to whom we transfer your Personal Data outside Singapore provides to such Personal Data a standard of protection at least comparable to the protection under the Act. This includes without limitation ensuring that any party coming into contact with the Personal Data outside Singapore:
(b) takes all appropriate measures to ensure such compliance by implementing such Data Handling Principles as notified by us to them from time to time and appropriate technical and organisational measures and providing a standard of protection for the Personal Data that is comparable to the protection under the Act; and
(c) protects the Personal Data by making reasonable security arrangements to prevent unauthorised access, use, disclosure or modification.
3 Withdrawal of Consent & Access
3.1 You may withdraw your consent to our continued use and disclosure of your Personal Data or seek access to your Personal Data (to a reasonable extent and as permitted by the Act) at any time by writing to the Office of our Data Protection Officer. You may also withdraw your consent for specific forms of communication and on specific communications via the unsubscribe options as stated on our email or other marketing messages.
3.2 In withdrawing your consent, you acknowledge that we may not be able to provide or continue providing certain goods and/or services to you and that we may cease such provision accordingly without any liability. Please note that it may take up to 30 working days for any request for consent withdrawal to be reflected in our systems.
3.3 We will, at your request, endeavour to provide you with an account of your Personal Data in our possession or control within a reasonable time. Such account shall be in respect of how your Personal Data has been or may have been generally used or disclosed within the year before the date of your request. We reserve the right to charge a reasonable administrative fee for carrying out your request.
4 Accuracy & Correction
4.1 We will endeavour to ensure that your Personal Data we use is sufficiently accurate and complete in making any decision that impacts you.
4.2 To help us maintain the accuracy of your Personal Data, we encourage you to inform us when there are any changes to your Personal Data which you have provided us by writing to the Office of our Data Protection Officer. We will correct or complete your Personal Data as soon as reasonably practicable.
5 Protection, Policies and Procedures
We will endeavour to protect your Personal Data in our possession or control against risks of unauthorised access, collection, use, disclosure, copying, modification, disposal or destruction, through reasonable and appropriate security measures. We strive to ensure that our systems are secure and that they meet industry standards. To prevent unauthorized access, maintain data accuracy and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the Personal Data we collect. Notwithstanding our security measures for protecting your Personal Data, you acknowledge that no data transmission over the Internet is completely secure and by providing your Personal Data, you are transmitting information at your own risk.
6 Retention of Personal Data
We will retain your Personal Data for as long as you use our products or services and it is necessarily required or relevant for business or legal purposes.
7.1 We gather Information on our website activity, such as data on the number of visitors, the pages they visit, the duration of their stay, etc. Such information is collected on an aggregate, anonymous basis, which means no Personal Data is associated with this data and gathered through the use of web server logs and cookies. We do not at our website automatically collect Personal Data unless you provide such information.
7.2 Cookies are small bits of data automatically stored in the hard drive of the end user and are commonly used to track preferences in relation to the subject of such website. If you enable these cookies, then your web browser adds the text in a small file. You may wish to set your web browser to notify you of a cookie placement request or refuse to accept cookies by modifying relevant internet options or browsing preferences of your computer system, but to do so you may not be able to utilize or activate certain available functions on our website.
7.3 By accessing and using our website and services, you consent to the storage of cookies, other local storage technologies, beacons and other information on your devices. You also consent to the access of such cookies, local storage technologies, beacons and information by us or our representatives or agents.
8 Third-Party Links and Products on Our Services
9 Contact us
We have appointed Data Protection Officer(s) to oversee our compliance with the Act. Should you have any query, request or feedback relating to your Personal Data, please contact us at the following:
The Office of the Data Protection Officer
Igloo Systems Pte. Ltd.
65 Ubi Road #01-87 Oxley Bizhub 1 Singapore 408729
For more information about the Singapore Personal Data Protection Act, please visit http://www.pdpc.gov.sg.