3. What Personal Data is Collected
3.1. When you use our Website, Application or any services we provide, in order to provide a better service to you, we may collect and process the following data about you:
a) Data Collected Directly From You. This may be done through our Website, Application, over the phone, by email, or in person. The data collected may include, but is not limited to:
i.Information provided at the time of registering to use our site, subscribing to our service, posting material or requesting further services, your contact information, including your (first and last) name, (billing and/or delivery) address, birthdate and email address and, optionally, your telephone number. We need your e-mail address and (optionally) telephone number so that we may contact you if we have questions or information for you regarding your order or the service that we are providing or will provide to you;
ii. If you contact us, we may keep a record of that correspondence;
iii.Information required to be able to process your order or to provide you with the service, such as information concerning the products you have ordered or the service we are providing to you, the billing and/or delivery address, banking and/or credit card details;
iv.We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them;
v.Details of transactions you carry out through our Website or Application and of the fulfilment of your orders;
vi.Details of your visits to our Website or Applications and the resources that you access;
b) Data Collected By Automated Means. Various technologies may be used on our Website and our mobile and web-based applications in order to make them more user-friendly, effective and secure. Such technologies may lead to data being collected automatically by us or by third parties on behalf of us. This data does not generally, but may, contain a User’s personal data. Examples of such technologies include:
i. Click-Stream Data. A visit to one of our websites results in data that is transmitted from your browser to our server being automatically collected and stored by us or by third parties on behalf of us. This data can include, in particular, the following:
a. the visitor’s IP address;
b. the date and time of the visit;
c. the referral URL (the site from which the visitor has come);
d. the pages visited on our website;
e. information about the browser used (browser type and version, operating system, etc).
iii.Flash Cookies. A particular form of cookie is the flash cookie. In contrast to normal cookies, these cookies are not created and saved by the web browser but are governed by the Adobe Flash plug-in. These can contain more information than normal cookies and cannot be deleted or disabled via the browser; this is only possible if you follow instructions available from the Adobe Flash Player website. You can also obtain more information about these cookies on that website.
c) Website Or Application Beacons And Tracking Links. Web beacons (also known as pixel tags and clear GIFs) involve graphics that are not apparent to the user. Tracking links and/or similar technologies consist of a few lines of programming code and can be embedded in our website or our (mobile) applications. In conjunction with cookies, these are primarily used for statistical analysis purposes. This technology can also be used for tracking traffic patterns on websites, as well as finding out if an e-mail has been received and opened and to see if there has been any response.
i.Website Or Application Analytics. Web analytics is the term given to a method for collecting and assessing the behaviour of visitors to websites and (mobile) applications. This includes the analysis of traffic patterns in order, for example, to determine the frequency of visits to certain parts of a website or (mobile) application, or to find out what information and services our visitors are most interested in. For these purposes, we primarily make use of click-stream data and the other techniques listed above. Web analytics are carried out by Google Analytics and/or other selected parties. You can find out more information about the processing of web analytics data by Google Analytics in paragraph 9 below.
3.2. We only retain personal data for so long as it is necessary. Data may be archived as long as the purpose for which the data was used still exists.
4. Uses Made Of The Information
4.1. The purposes for which information may be used by us to serve you in and outside Singapore include:
a) Providing you with the products and services that you have requested;
b) Contacting you for feedback after a sale of a product or service;
c) Resolving any problems or disputes you may encounter in relation to our products and services;
d) Ensuring that content from our site is presented in the most effective manner for you and for your computer;
e) Providing you with alerts, newsletter, education materials or information that you requested or signed up to;
f) Allowing you to participate in interactive features of our service, when you choose to do so;
g) Designing and conducting surveys/questionnaires for client profiling/segmentation, statistical analysis, improving and furthering the provision our products and services;
h) Complying with laws and regulations applicable to us or any of our affiliates in or outside Singapore;
i) Legal proceedings, including collecting overdue amounts to SGeBiz and seeking professional advices;
j) Accounting, risk management, compliance and record keeping purposes;
k) Researching, planning, statistical analysis and developing new products and services or improving existing products and services of SGeBIZ including seminars/events/forums;
l) Staff training;
m) Promoting and marketing services and products subject to your exercise of the opt-out right (please see further details in paragraph 4.2 and 4.3 below); or
n) Purposes directly related or incidental to the above.
4.2. We may also use your data for purposes connected or relevant to the business in direct marketing and we require your consent (which includes an indication of no objection) for that purpose for example:
a) Your name, contact details (including address, contact number, email address), products and services information, transaction pattern and behaviour, background and demographic data held by us from time to time may be used by us in direct marketing;
b) The following classes of services, products and subjects may be marketed in direct marketing:
i.Services and products related to our site and/or our affiliates (including marketing affiliates programs we are a part of);
ii. Reward, loyalty or privileges programmes, promotional offers and related services; and
iii.Invitations to events such as seminars/webinars/tele-seminars, conferences, live programs or events.
4.3. We may conduct direct marketing via fax, email, direct mail, telephone and other means of communication or send e-newsletters to you. You may choose not to receive promotional materials, by simply telling us (see below for contact details), and we will cease to do so, without charge.
4.4. Your personal data may also be anonymised for use by SGeBIZ for other purposes.
4.5. If you have contacted us with any complaints, feedback, comments, suggestions, we will use and disclose your personal data (including your contact history) to respond to you and provide you with the best service possible. If you are the complainant and you do not want us to disclose your identity to the party you are complaining about, you must let us know immediately. However, it may not always be possible to handle your complaint on the basis of anonymity.
4.6. If we need to use your personal data for any other purposes, we will notify you and obtain your consent beforehand. You will be given the opportunity to withhold or withdraw your consent for the use of your personal data for these other purposes.
5. Uses Made Of The Information
5.1. Your data may be disclosed and shared within SGeBIZ to allow us to provide the products and services which you have requested.
5.2. We will not sell your data to third parties.
5.3. We will only disclose your data to third parties where you have provided us consent, and in the situations expressly set out in in this Policy. If you have consented to receiving marketing information from us, our strategic partners and business associates, we will be disclosing your personal data to them.
5.4. We will keep the data we hold confidential but may provide information to:
a) Personnel, agents, advisers, lawyers, accountants, auditors, contractors, financial institutions, and service providers in connection with our operations or services;
b) Our overseas offices, affiliates, business partners and counterparts (if any). When transferring your personal data outside of Singapore we will protect your personal data to a standard comparable to the protection accorded to your personal data under the Singapore Personal Data Protection Act 2012 by ensuring that the recipient is either in a jurisdiction which has comparable data protection laws, or is contractually bound to protect your personal data;
c) Persons under a duty of confidentiality to us;
d) Persons to whom we are required to make disclosure under applicable laws and regulations in or outside Singapore; or
e) Actual or proposed transferees or participants of our services in or outside Singapore.
5.5. We will also disclose your personal data to third parties in order to comply with legal obligations or industry requirements. This includes disclosures to legal, regulatory, governmental, tax and law enforcement authorities.
5.6. Our website may have the functionalities to allow you to share your personal data with other third parties such as other users of our website. You are responsible for your choice(s) and are deemed to have provided consent for any sharing of your personal data in the manner provided by the website.
5.7. You fully understand and consent that we may transfer your personal data to any location outside of Singapore for the purposes set out in this paragraph 5. When transferring your personal data outside of Singapore we will protect your personal data to a standard comparable to the protection accorded to your personal data under the Singapore Personal Data Protection Act 2012 by ensuring that the recipient is either in a jurisdiction which has comparable data protection laws, or is contractually bound to protect your personal data.
6. Third Parties
7. Social Networks
7.1. Our website and mobile or web-based applications may provide you with social plug-ins from various social networks (such as Facebook, Instagram, LinkedIn and Twitter). If you choose to interact with a social network, your activity on our website or via our mobile or web-based applications will also be made available to social networks such as Facebook and Twitter.
7.2. If you are logged in on one of the social networks during the visit of one of our websites or mobile or web-based applications, the social network might add this information to your profile. If you are interacting with one of the social plug-ins, this information will be transferred to the social network. In case you do not wish such a data transfer, please log off on your social network before you enter one of our websites or mobile or web-based applications.
7.3. We cannot influence this data collection and data transfer via the social plug-ins. Please read the privacy policies of those social networks for detailed information about the collection and transfer of personal data, what rights you have and how you can achieve satisfactory privacy settings.
8. Geo-location Services
8.1. Our website and mobile or web-based applications may offer location-enabled services, such as Google Maps and Bing Maps. If you use those mobile or web-based applications, they may receive information about your actual location (such as GPS signals sent by a mobile device) or information that can be used to approximate a location. You are always asked if the geo-location service can be activated and you can also object to this geo-location service within the respective mobile or web-based application.
9. Web Analytics By Google Analytics
9.1. Our website and mobile or web-based applications may contain web analytic services provided by Google Analytics. This means that when you visit our website or use any mobile or web-based applications, a cookie will be stored on your computer or mobile device, except when your browser settings do not allow for such cookies.
9.2. This further means that when you visit our website or use any mobile or web-based applications, the personal data described above in paragraph 3 – including the “click-stream data”, the data from “web beacons and tracking links” and information stored in Google Analytics’ cookies – will be sent to Google Analytics for analysis for and on behalf of us. Please note that if you have created an online profile at our website or mobile or web-based application and if you are logged on in this profile, a unique number identifying this profile will also be sent to Google Analytics in order to be able to match the web analytics data to this profile.
10. Retargeting Technologies
10.1. Our Website and mobile or Web-based Applications may use retargeting technologies within the internet. This enables us to show our visitors, who were already interested in our shop and our products, advertisement from us on partner websites.
10.2. We also work with other companies who use tracking technologies to serve advertisements on our behalf across the Internet. These companies may collect non-personally identifiable information about your visits to our websites or mobile or web-based applications and your interaction with our communications, including advertising.
10.3. Retargeting technologies analyse your cookies and display advertisement based on your past surfing behaviour.
10.4. We do not store any personal data about you with this technology.
11.1. We endeavor to take precautions to ensure that the information you have provided is protected against unauthorised or unintended use, access or disclosure. However, we cannot be held responsible for unauthorised or unintended use, access or disclosure that is beyond our control.
11.2. All information you provide to us is stored on our secure servers. We have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
11.3. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk and you agree not to hold us responsible for any breach of security while accessing the internet that is out of our control. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
12.1. To the maximum extent permitted by law, we shall not be liable in any event for any special, exemplary, punitive, indirect, incidental or consequential damages of any kind or for any loss of reputation or goodwill, whether based in contract, tort (including negligence), equity, strict liability, statute or otherwise, suffered as a result of unauthorised or unintended use, access or disclosure of your personal data.
13. Changes To This Policy
13.1. We may amend or modify this Policy from time to time. The amended Policy will be available on our Website.
14. Your Rights
14.1. By using our service, application or visiting our website, you consent to the collection and use of your information and other activities as outlined in this policy.
14.2. If you have any questions about the processing of your personal data or about our Policy, if you do not accept the amended Policy, if you wish to withdraw any consent you have given us at any time, or if you wish to update or have access to your personal data, you are welcome to contact us. The contact details are:
|Attention to||: Singapore E-Business Pte Ltd – Data Protection Officer|
|Telephone number||: +65 6200 8021|
|JTC LaunchPad @ one-north, Blk 79 Ayer Rajah Crescent|
#02-12 Singapore 139955
14.3. All requests for correction or for access to your data must be in writing. We will endeavor to respond to your request within 30 days, and if that is not possible, we will inform you of the time by which we will respond to you.
14.4. We may be prevented by law from complying with any request that you may make. We may also decline any request that you may make if the law permits us to do so.
14.5. In many circumstances, we need to use your data in order for us to provide you with products or services which you require or have requested. If you do not provide us with the required data, or if you do not accept the amended Policy or withdraw your consent to our use and/or disclosure of your personal data for these purposes, it may not be possible for us to continue to serve you or provide you with the products and services that you require or have requested.
14.6. We may charge you a fee for responding to your request for access to the personal data which we hold about you, or for information about the ways in which we have (or may have) used your personal data. If a fee is to be charged, we will inform you of the amount beforehand and respond to your request after payment is received.
15.1. You may send complaints regarding our handling of personal data in the following ways:
a) In Writing Or By Email. Such complaints must be addressed to SGeBIZ Data Protection Officer at:
i. Email: firstname.lastname@example.org
ii. Address : JTC LaunchPad@ one-north, Blk 79 Ayer Rajah Crescent #02-12 Singapore 139955. Please provide the name, contact number and address of the person submitting the feedback, provide the relevant details required such as the relevant time period, our employees or who involved, or copies of relevant documents;
b) By Telephone. Such complaints must be made to the SGeBIZ Data Protection Officer at: +65 6200 8021.
15.2. All complaints will be evaluated by us in a timely manner. After SGeBIZ has completed its evaluation, the Data Protection Officer (or a duly appointed representative) will respond to the person who submitted the complaint or feedback, with the results of the evaluation.
16. Governing Law
16.1. This Policy is governed by the laws of Singapore. You agree to submit to the exclusive jurisdiction of the Courts of Singapore in any dispute relating to this Policy.