- Personal Data
- Depending on the nature of your interaction with us, on the Sites or through any Service we provide, the type of information that we may collect includes but is not limited to the following (in no particular order)
- Personal data and information - We may collect information with personal identifiers, including your name and identification information such as your NRIC number, contact information such as your address, email address, telephone, mobile and facsimile numbers, nationality, gender, date of birth, marital status, photographs and other audio-visual information.
- Employment details – We may collect information from your CV in relation to your current and past occupation (including position, job title and company name), employment history, salary, and/or benefits or education history.
- Financial information – We may collect financial information such as credit card numbers, debit card numbers or bank account information and details of any other information that allows us to transact with you and/or provide you with our Services.
- Usage – We may collect information about your use of the Group’s website and services, including cookies, IP address, policy, claims history information and your usage of and interaction with our website and/or services including computer and connection information, device capability, bandwidth statistics, statistics on page views and traffic to and from our websites.
- Other anonymised data - We may collect information that is not associated with or linked to your personal data and cannot be used to identify you or any other individuals (“Anonymised Data”).
- Generally, we may collect your personal date in the following ways when you:
- access our website or perform an online transaction;
- interact with any of our employees (including customer service officers and front line service staff);
- submit an application to us to purchase our products or use our Services;
- respond to our request for additional Personal Data;
- ask to be included in an email or other mailing list;
- request that we contact you;
- request to receive marketing or other communications;
- respond to our promotions;
- use our Wi-Fi networks, kiosks or other in-store technologies;
- enter in one of our contests, competitions, prize draws, or sweepstakes;
- register with us for an account and/or membership;
- submit information when providing feedback; and
- submit your Personal Data to us for any other reason.
- However, we may also use various technologies on the Sites which may lead to information being collected automatically by us or from other sources such as advertising, sub-contractors in technical and payment services, analytics providers, search information providers and mailing lists. This information does not generally, but may, contain your personal data. In particular, information is likely to be collected as web beacons, web analytics, cookies.
- The Purposes For Which We Use your Personal Data
- As there are many circumstances in which we may collect information, we will endeavour to ensure that you are always aware of the information being collected, in particular by third parties. 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”, for example Facebook or any other non-digital platform) 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)
- The purposes for which we use your personal data may include (but are not limited) to any of the following:
- evaluating and providing advice and/or recommendations to you regarding the type of Services and products suited to your needs;
- assessing and processing any applications or requests made by you for Services and products offered to you;
- communicating with you to inform you of changes and updates to our policies, terms and conditions and other administrative information, including without limitation for the purposes of servicing you in relation to Services and products offered to you;
- administering, maintaining, managing and operating the Services and products offered to you;
- processing payment or credit transactions;
- processing and administering benefits or entitlements in connection with our Services or your membership which you have applied for, including the administration of loyalty and rewards programmes;
- verification of your identity for the purpose of providing you with our Services;
- responding to your queries and requests and handling complaints;
- providing you with personalised service;
- detecting usage, tracking user movements and analysing trends;
- conducting market research for statistical profiling and other purposes to understand and determine customer preferences and demographics in order for us to review, develop and improve the products and services which we are providing to you (including without limitation to ensure that the products and services offered are relevant to you);
- providing benefits to you, including without limitation promotions, loyalty and reward programmes and sending you details of products, services, special offers and rewards, either to our customers generally, or which may be of interest to you;
- matching your personal data with other data collected for other purposes and from other sources (including third parties) in connection with the provision or offering of products and services, whether by any of the group company, or other third parties;
- administering contests and competitions;
- participation in the Group's marketing initiatives;
- participation in the Group's branding activities (including without limitation written or video/audio recordings of your quotes and testimony for media pitching, press releases and the Group's internal publications and broadcasts);
- developing special offers and marketing programmes;
- administering the sites;
- troubleshooting crashes associated with specific hardware and software used to access the sites and Services;
- managing our infrastructure and business operations and complying with internal policies and procedures;
- archival of documents and records in both electronic and physical form for record keeping purposes;
- maintaining records of customer instructions, whether through hard copy documents, soft copy documents or instructions given via electronic or other means;
- compliance with any applicable statute, rule, law, regulation, judgment, decree, directive, code of practice, guideline, administrative requirement, sanctions regime, court order, agreement between any Dewgather group company and an regulatory authority, internal policies or procedures, which may apply to any Dewgather group company or which any such company is subject to, or to assist in or with law enforcement and investigations by any government, regulatory authority or to comply with any request from any government, regulatory authority;
- 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;
- any other purposes for which you have provided the information; and
- any other incidental business purposes related to or in connection with the above.
- Your personal data may also be anonymized for use by us and/or our affiliates for other purposes
- It may be necessary for us to disclose your personal data to our affiliates or to third parties in a manner compliant with the PDPA in order to carry out the purposes set out above. We may disclose or share personal data with such parties who provide necessary services to us, such as for processing activities like verification, website hosting, data analytics and payment processing. We may disclose your personal data in the following circumstances:
- where such disclosure is required for performing obligations in the course of or in connection with our provision of the Services requested by you;
- third party online payment processing companies who will process your payments so that you can use the Services and/or make any related purchases;
- our consultants and professional advisers (e.g. accounting firms, audit firms, law firms and/or other professional advisory firms) who are maintaining our records in accordance with legal requirements;
- governmental, regulatory or law enforcement bodies who have a legal right to demand for your personal data, in response to a legal request such as a court order, to investigate or report an illegal activity, or to enforce our rights or defend claims;
- our affiliated or related companies and/or third parties to whom we may sell, divest, transfer, assign, share or otherwise engage in a transaction that involves, some or all of the our assets (which may include your personal data), in the course of a corporate divestiture, corporate restructuring, merger, acquisition, joint venture, bankruptcy, dissolution, reorganisation, or any other similar transaction or proceeding; or
- third party service providers, agents and other organisations we have engaged to perform any of the functions listed in clause 2.2 above for us.
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.
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 Services and products you have requested. Where personal data is submitted by you on behalf of another individual or concerns another individual other than yourself, you represent and warrant to us that all the necessary consents (procured in accordance with all applicable data protection legislation, including without limitation the PDPA, for such purposes stated in the relevant sections of this Data Protection Policy) have been obtained from the relevant individuals and that you have retained proof of these consents, such proof to be provided to us upon our request.
Protection of Personal Data
We will take reasonable steps to protect your personal data which we hold from misuse and loss and from unauthorised access, modification or disclosure.
We will not keep your personal data for longer than is necessary and will take reasonable steps to destroy or permanently de-identify your personal data if it is no longer needed.
- Access to and Correction of Personal Data
- As a general rule, you are entitled to have access to the personal data about you that is in our possession or control, and information about the ways in which your personal data has been or may have been used or disclosed within a year before the date of the request. This can be done by you making a written application to the Designated Person (as defined below) requesting for any such information. We reserve the right to charge a fee (representing our costs in administering your request) for supplying such information to you, and to refuse requests which, in our opinion, occur with unreasonable frequency.
- We will also, where you have requested that we correct an error or omission in your personal data that is kept with us, correct such data as soon as practicable and send the corrected personal data to every organisation to which the personal data was sent before it had been corrected, if applicable, unless that organisation does not need the corrected personal data for any legal or business purpose.
- We may, however choose not to provide you with access to or correct such information, in accordance with the exceptions under the PDPA. This would include cases where:
- We are satisfied on reasonable grounds that the correction should not be made;
- The request for access is frivolous or vexatious or the information requested is trivial;
- The personal data are related to a prosecution and all the proceedings related to the prosecution have not been completed;
- The personal data, if disclosed, would reveal confidential commercial information that could, in the opinion of a reasonable person, harm our competitive position; and
- The personal data was collected, used or disclosed for the purposes of an investigation and associated proceedings and appeals have not been completed.
To the fullest 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 unauthorized or unintended use, access or disclosure of your personal data.
Transborder of Personal Data Outside of Singapore
If your personal data is transferred to a country or territory outside Singapore, for instance, if some services are sub-delegated to overseas resource centres, we will ensure that the recipients thereof provide a standard of protection to your personal data so transferred that is comparable to that which is provided herein.
Data Protection of Officer
We have designated the person whose details are set out below as the person (“Designated Person”) who will be responsible for ensuring our compliance with applicable data protection laws. If you have any queries or requests or wish to make any applications concerning your personal information or data, please contact the Designated Person:-
Office Address: 60 PAYA LEBAR ROAD, #08-05 SINGAPORE 409051 (Attention to the “Data Protection Officer”)