Privacy Policy
DATA PROTECTION NOTICE
This Data Protection Notice (“Notice”)
sets out the basis which Reluzzo PTE LTD (“we”, “us”, or “our”) may
collect, use, disclose or otherwise process personal data of our customers in
accordance with the Personal Data Protection Act (“PDPA”). This Notice applies
to personal data in our possession or under our control, including personal
data in the possession of organisations which we have engaged to collect, use,
disclose or process personal data for our purposes.
PERSONAL DATA
1.
As
used in this Notice:
“customer” means an individual who
(a) has contacted us through any means to find out more about any goods or
services we provide, or (b) may, or has, entered into a contract with us for
the supply of any goods or services by us; and
“personal data” means data, whether
true or not, about a customer 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.
Depending
on the nature of your interaction with us, some examples of personal data which
we may collect from you include your name and identification information such
as your NRIC number, contact information such as your address, email address or
telephone number, nationality, gender, date of birth, marital status,
photographs and other audio-visual information, employment information and
financial information such as credit card numbers, debit card numbers or bank
account information.
3.
Other
terms used in this Notice shall have the meanings given to them in the PDPA
(where the context so permits).
COLLECTION, USE AND DISCLOSURE OF
PERSONAL DATA
4.
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).
5.
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 goods
and/or services requested by 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;
(e)
processing
payment or credit transactions;
(f)
sending
your marketing information about our goods or services including notifying you
of our marketing events, initiatives and promotions, lucky draws, membership
and rewards schemes and other promotions;
(g)
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;
(h)
any
other purposes for which you have provided the information;
(i)
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; and
(j)
any
other incidental business purposes related to or in connection with the above.
6.
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 goods or services requested by you; or
(b)
to
third party service providers, agents and other organisations we have engaged
to perform any of the functions listed in clause 5 above for us.
7.
The
purposes listed in the above clauses may continue to apply even in situations
where your relationship with us (for example, pursuant to a contract) 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
any contract with you).
WITHDRAWING YOUR CONSENT
8.
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 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.
9.
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.
10.
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 goods
or services 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.
11. 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.
ACCESS TO AND CORRECTION OF
PERSONAL DATA
12.
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.
13.
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.
14.
We
will respond to your request as soon as reasonably possible. 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).
PROTECTION OF PERSONAL DATA
15.
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 and the use of privacy filters to
secure all storage and transmission of personal data by us, and disclosing
personal data both internally and to our authorised third party service
providers and agents only on a need-to-know basis.
16.
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.
ACCURACY OF PERSONAL DATA
17.
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.
RETENTION OF PERSONAL DATA
18.
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.
19.
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.
TRANSFERS OF PERSONAL DATA OUTSIDE
OF SINGAPORE
20.
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.
DATA PROTECTION OFFICER
21. 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 for data deletion or modification to your personal data, in the following manner:
Email our DPO at [email protected]
EFFECT OF NOTICE AND CHANGES TO
NOTICE
22.
This
Notice applies in conjunction with any other notices, contractual clauses and
consent clauses that apply in relation to the collection, use and disclosure of
your personal data by us.
We may revise this Notice from time to time
without any prior notice. You may determine if any such revision has taken
place by referring to the date on which this Notice was last updated. Your
continued use of our services constitutes your acknowledgement and acceptance
of such changes.