For the purposes of the PDPA the relevant legal entity is Indulged Pte. Ltd. and our nominated Data Protection Officer is Jerry Ng who can be reached at email@example.com (please include “PDPA” in the email subject).
COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
COLLECTION OF GENERAL INFORMATION
Like most website operators, we aim to collect non-personally-identifying information of the sort that web browsers and servers typically make available, such as the browser type, language preference, referring website, and the date and time of each visitor request. We collect non-personally identifying information to better understand how our visitors use our Site. The information collected will also help us troubleshoot problems, analyse our resources and improve our services and/or products. There is nothing in that kind of information that could enable anyone to identify who you are.
COLLECTION OF PERSONAL INFORMATION
We may collect personal information in a number of ways, including:
- when you visit and interact with our Site and related software (including any mobile applications);
- when you sign up for a client account;
- when you contact us via our Site or sign up for our newsletter/mailing list;
- when you engage in transactions with us;
- through cookies and other technologies that allow us to give you a better experience on our Site; and
- when you or a third party contacts us independently of our Site, such as by email, phone or in person.
You may refuse to supply personal information, however this may prevent you from engaging in certain Site-related activities and we may not be able to provide our services and/or products or assistance to you or on your behalf.
You consent to us posting and using any photographs, content and/or personal information you might upload on our Site or have otherwise provided consent to publish on our Site, blog, in our marketing material or social media channels, which we may use in order to provide information on our services and/or products, the marketing of our services and/or products or for the purpose of our functions and/or activities.
- to carry out our obligations and to provide you with agreed services and/or products;
- to establish, maintain and administer your account;
- to send you service and/or product or promotional communications;
- to notify you about changes to our services and/or products;
- to create or distribute marketing material that is relevant to you;
- for quality assurance and training purposes;
- to promote and market ourselves, our services and/or products and our websites (including any social media pages maintained or operated by us such as Facebook, Instagram, Snapchat, Twitter, YouTube etc); and
DISCLOSURE OF YOUR PERSONAL INFORMATION
We may disclose your personal information to other entities or individuals for the Purposes including but not limited to:
- our employees, trusted third parties and other people we work with to provide services and/or products to you;
- third party service providers for the purpose of enabling them to provide a service such as (but not limited to) IT service providers, data storage, web-hosting and server providers, debt collectors, payment processing and insurers;
- any third party partners or entities with whom we have a commercial relationship;
- any related entity of ours;
- prospective sellers or buyers of our business or assets;
- any applicable or relevant regulator or third party for the purpose of legislative or contractual compliance and/or reporting or when we believe in good faith that disclosure is reasonably necessary to protect our property or rights, those of third parties or the public at large; or
- other entities or individuals, provided you have given your consent.
ACCESS TO AND CORRECTION OF PERSONAL DATA
Accessing your personal information
You may review, edit, correct or delete any personal information you submit to us.
On request we will, as soon as reasonably possible, provide you with:
- personal data about you that is in our possession or under our control; and
- information about the ways in which the personal data referred to in paragraph (a) has been or may have been used or disclosed by us during the year preceding the date of the request.
However, we reserve the right not to provide you with your personal data or other related information if providing it could reasonably be expected to:
- threaten the safety or physical or mental health of another individual;
- cause immediate or grave harm to your safety, physical or mental health;
- reveal personal data about another individual;
- reveal the identity of an individual who has provided personal data about another individual and the individual providing the personal data does not consent to the disclosure of his identity; or
- be contrary to the national interest.
If you wish to access the personal information we hold about you, you should contact us at firstname.lastname@example.org and we will respond to your request within a reasonable period after the request is made. If we deny you access, we will provide our reason for doing so at the time of your request.
While we do not charge a fee for a request for accessing your personal information, we may charge a reasonable fee (which will be notified to you once you make a request) for time and cost in the following circumstances:
- if an extended amount of time is required to collate and prepare material for you; and
- if you wish to have your files photocopied for you.
CORRECTING AND UPDATING YOUR PERSONAL INFORMATION
Please contact us at email@example.com as soon as possible if there are any changes to your personal information or if you believe the personal information we hold about you is not accurate, complete or up-to-date so that we can update your file accordingly. We will process any requested changes as soon as practicable and send the corrected personal data to every other organisation to which the personal data was disclosed during the year preceding the date of the correction, unless that other organisation no longer needs the corrected personal data for any legal or business purpose or you otherwise agree that we do not need to resend the corrected information to any other organisation.
CARE OF PERSONAL DATA
We take reasonable steps to ensure that the personal information we hold about you is accurate, complete and up-to-date. However, you must advise us of any changes to your personal information.
PROTECTION OF PERSONAL DATA
We aim to take reasonable steps to ensure that your personal information is treated securely and to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks.
Although we aim to create a safe, secure environment by trying to limit access to the Site to legitimate users, we cannot guarantee that unauthorised parties will not gain access. To the extent permitted by applicable law, we expressly exclude any liability arising from any unauthorised access to your personal information.
Please contact us at firstname.lastname@example.org immediately if you become aware of any unauthorised use of your account by anyone else or any other breach of security.
RETENTION OF PERSONAL DATA
We will cease to retain its documents containing personal data, or remove the means by which the personal data can be associated with particular individuals, as soon as it is reasonable to assume that the Purpose for which that personal data was collected is no longer being served by retention of the personal data, or retention is no longer necessary for legal or business purposes.
TRANSFER OUTSIDE SINGAPORE
We do or may use the following cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of our Site. They include, for example, cookies that enable you to log into secure areas of our Site, use a shopping cart or make use of e-billing services.
- Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our Site when they are using it. This helps us to improve the way our Site works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognise you when you return to our Site. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Targeting cookies. These cookies record your visit to our Site, the pages you have visited and the links you have followed. We will use this information to make our Site and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
USE OF PERSONAL INFORMATION FOR DIRECT MARKETING
From time to time we may use the personal information we collect from you to identify particular services and/or products that we believe may be of interest to you. We may then contact you to let you know about these services and/or products, new features and how they may benefit you, solicit your feedback, or just keep you up to date with what’s going on with us and our services and/or products.
Direct marketing from us generally takes the form of an electronic marketing email. Where we use your personal information to send you marketing information by email, SMS, MMS or other electronic means we may do so with your express or deemed consent. Every directly addressed marketing contact sent or made by us will include a means by which you may unsubscribe (or opt out) of receiving further marketing information. Additionally, you may instruct us at any time to remove any previous consent you provided to receive marketing communications from us. Contact us at email@example.com to make a request.
LINKS TO THIRD PARTY WEBSITES