1.1 “user” means an individual who (a) has contacted us through any means to find out more about any Service we provide, or (b) may, or has, entered into a contract with us for the supply of any Service by us, (c) or otherwise interacted with us and/or through the various apps and online platforms that we maintain;
1.2. “personal data” means data, whether true or not, about a user 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. Examples of Persona Data collected
Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include name, residential address, email address, telephone number, nationality, gender, date of birth, marital status, employment information, geo-localisation, working habits such as use of printing facilities, financial information, biometric data such as your profile picture, age group, country of residence, travel information, and hobbies and interests.
3. Collection, use and disclosure of personal data
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 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 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).
4. Purposes for data collection and use
We may collect and use 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 Service to you;
(b) verifying your identity;
(c) responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
(d) managing your relationship with us and with Hosts;
(e) processing payment or credit transactions;
(f) 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;
(g) transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes;
(h) any other incidental business purposes related to or in connection with the above;
(i) to develop, test and improve our Service, including by conducting surveys and research, and testing and troubleshooting new products and features;
(j) to send you marketing and promotional communications (including that of our business partners and sponsors), communicate with you about our Service, surveys and let you know about our policies and terms. We also use your information to respond to you when you contact us;
(k) where applicable, to administer the award and grant of prizes in surveys or other non-commercial competitions that we may run from time to time;
(l) any other purposes for which you have provided the information; and
(m) use and share your personal data with our affiliates globally, including our subsidiaries and parent company where applicable, for the purposes set out in this Section 5, including to send you marketing and promotional on the Service, offered by our affiliates.
5. 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 Service to you;
(b) to third party service providers, vendors, contractors, agents and other organisations we have engaged to perform any of the functions with reference to the above-mentioned purposes; or
The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, our commercial, business and/or employment relationship has come to an end) 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 a contract with you).
6. 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 in writing or 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 shall 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 Service 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 8 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 disclose without consent is permitted or required under applicable laws.
7. Right of access and correction
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. 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. We will respond to your request as soon as reasonably possible. In general, our response will be within twenty-one (21) days. 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).
8. 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 and agents only on a need-to-know basis, and other measures introduced from time to time as appropriate. 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.
9. Accuracy of Personal Data
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.
10. 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.
11. Transfer of Personal Data outside of Singapore
You agree that we may transfer your personal data outside of Singapore, to any jurisdiction where we are established, to enable you to use the Service in these jurisdictions and to administer the Service, where necessary. Outside of this purpose, 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.
12. 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:
Name of DPO: Raphael Cohen
Contact No.: +65 3129 5551
Email Address: firstname.lastname@example.org
Last revised on Aug 16, 2022