Last Updated Date: 27th Apr 2023
“Data Protection Laws” means all applicable laws and regulations in any jurisdiction which relate to the collection, disclosure, use or Processing of Personal Data, including without limitation to the PDPA, including all amendments thereto and subsidiary legislation enacted thereunder, whether now or in the future.
“PDPA” means the Personal Data Protection Act 2012 of Singapore, including all amendments thereto and subsidiary legislation enacted thereunder, whether now or in the future.
“Personal Data” means data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which a party has or is likely to have access.
“Process”, in relation to Personal Data, means the carrying out of any operation or set of operations in relation to the Personal Data, including without limitation to recording, holding, organizing, adapting, altering, modifying, retrieving, combining, transmitting, erasing or destroying, and “Processing” shall be construed accordingly.
1.2 Any capitalised term not defined herein shall have the meaning ascribed to them in the Agreement.
2.1 We may collect the following Personal Data about you when you access or use the Website, App, and/or Services, or register for an Account to become a Registered User:
(a) Account registration information. This is the Personal Data that is provided by you or collected by us to enable you to create an Account and log in and access your Account and our Services. We may also use such Personal Data to verify your identity or contact you. This includes your name, email address, and phone number.
(b) Services usage information. This can be Personal Data and other information that is collected about you when you are using our Website, App and/or Services, and this may include:
(i) Information about your interactions with our Website, App and/or Services, which includes the date and time of any information you enter into our Website, App and/or Services.
(ii) Your interactions with our customer service team.
(iii) Technical data, which may include URL information, cookie data, web beacons and other tracking technology information, your IP address, the types of devices you are using to access or connect to our Services, unique device IDs, device attributes, network connection type (e.g., Wi-Fi, 3G, LTE, Bluetooth) and provider, network and device performance, browser type, language, and operating system.
(c) Your location data. We may collect your location data to provide you with location-based and traffic-based products and Services. You can withdraw your consent and turn off this functionality at any time by turning off the location services settings for the App on your User Device.
(d) Information from third parties. We may from time to time allow you to link your Account with, or otherwise access the Website, App, or Services from Third Party Accounts. If you choose to do so, we may collect your username and public profile for that Third Party Account.
3.1 We may collect, use and Process your Personal Data for any or all of the following purposes:
(a) To provide you with the Website, App and/or Services.
(b) To perform obligations in the course of or in connection with our provision of the goods and/or services requested by you.
(c) To process, administer, or manage your Account, to verify your identity and to assess your suitability and/or eligibility for certain Services.
(d) To respond to, handle, and process queries, requests, applications, complaints, and feedback from you.
(e) To manage your relationship with us.
(f) To contact you in order to provide you with information or services where required by Law or that you request from us.
(g) To analyse and utilize Personal Data in order to present content and information on the Website, App and Services in the most suitable manner for users and the equipment and devices from which users view the Website, App and Services.
(h) To personalise or customise the content and services that we provide to you, including providing you with location-based or traffic-based Services.
(i) To process your payments or purchases on the Website, App and/or Services.
(j) To store, host and/or back up Personal Data for disaster recovery purposes, whether within or outside Singapore.
(k) To conduct research, analysis and development activities (including but not limited to data analytics, surveys and/or profiling) to improve the Website, App and Services.
(l) To respond to any legal processes, pursue legal rights and remedies, and manage any complaints or claims.
(m) To respond to requests for information from public and governmental/regulatory authorities, statutory boards, related companies and for audit, compliance, investigation and inspection purposes.
(n) To comply 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, whether within or outside Singapore.
(o) To transmit 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.
(p) To achieve any other incidental business purposes related to or in connection with the above.
3.2 The purposes listed above may continue to apply even in situations where your relationship with us has been terminated or altered in any way, for a reasonable period thereafter.
4.1 You acknowledge and agree that Personal Data provided to us by you may be disclosed and/or transferred to the following third parties, and used or Processed by such third parties, whether within or outside Singapore, for the purposes set out above or otherwise permitted/ required by Law:
(a) Our Affiliates. We may share your Personal Data with our Affiliates to enable us to provide you with the Website, App and Services.
(b) Service Providers. We use third party service providers to operate and maintain the Website and App, store our data, and otherwise provide the Services. We may share your Personal Data with our service providers to provide you with access to and use of the Website, App and Services. For example,
(i) We use financial institutions, credit card companies and other payment processors to receive payments from you.
(ii) We use cloud service providers to host our data and the Website and App.
(iii) We use data analytics service providers to provide you with customised and tailored Services.
(c) Governmental and regulatory authorities. We may share your personal information with third parties, including law enforcement agencies and governmental or regulatory authorities, whether in Singapore or abroad, where required by applicable Laws (including to respond to valid legal process such as a search warrant or a court order), where it is necessary in connection with our Services or where we have another legitimate interest in doing so.
(d) Buyer or successor of our business. We may share your Personal Data with any buyer or successor in the event of a merger, reorganization, dissolution, or other sale or transfer of title.
(e) Our advisors, including auditors and lawyers. We may share your Personal Data with or disclose your Personal Data to our advisors in the course of seeking professional advice.
4.2 The purposes listed in the above clauses may continue to apply even in situations where your relationship with us has been terminated or altered in any way, for a reasonable period thereafter.
5.2 You have the ability to accept or decline cookies by modifying the setting in your browser. However, you may not be able to use all the interactive features of the Website, App and Services if cookies are disabled.
6.1 Withdrawing consent.
(a) You may withdraw your consent and request us to stop collecting, using, disclosing and/or Processing your Personal Data for any or all of the purposes listed above by submitting your request via email to our Data Protection Officer at the contact details provided above.
(b) Upon receipt of your written request to withdraw your consent, we may require a reasonable period of time to process and respond to your request.
(c) 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 Website, App and/or Services to you. We will, in such circumstances, notify you before completing the processing of your request.
(d) Please note that withdrawing consent does not affect our right to continue to collect, use, disclose or Process your Personal Data where such collection, use, disclosure and Processing without consent is permitted or required under applicable Laws.
6.2 Accessing and Correcting your Personal Data
(a) If you wish to make
(i) 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 had used or disclosed your Personal Data in the one (1) year prior to the date of your request, or
(ii) a correction request to correct or update any of your Personal Data which we hold about you, you may submit your request via email to our Data Protection Officer at the contact details provided above.
(b) 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.
(c) 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 applicable Laws).
7.1 We will take appropriate administrative, physical and technical measures to safeguard your Personal Data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, and the loss of any storage medium or device on which Personal Data is stored.
7.2 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 Personal Data, and are constantly reviewing and enhancing our security measures.
8.1 Where you submit Personal Data through the Website, App or Services, you should ensure such Personal Data is accurate. You should also review your Personal Data from time to time and let us know if there are changes to your Personal Data or update your Personal Data so that we are not holding any inaccurate Personal Data about you.
8.2 You can review and update your Personal Data at any time using the Website and/or the App by logging in to your Account.
9.1 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.
9.2 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.
10.1 The Website, App and Services may from time to time, contain links to and from the websites of our Affiliates, advertisers, or other third parties(“Third Party Websites”). Certain functions and features within the Website, App and Services (such as payment) are provided by Third Parties (such as payment service providers) (such functions and features being “Third Party Services”). Third Party Websites and Third Party Services are operated by third parties (“Third Parties”). When you access or use such Third Party Services, or when you click on the link to Third Party Websites, your Personal Data may be collected directly by such Third Parties.
10.2 As these Third Party Websites and Third Party Services are not owned or operated by us, we do not accept any responsibility or liability for such Third Party Websites and Third Party Service, or the collection of your Personal Data by such Third parties. Your access to such Third Party Websites and Third Party Services, and provision of Personal Data to these Third Parties are entirely at your own risk. Please check the privacy policies that apply to such Third Party Websites and Third Party Services carefully before you provide any Personal Data to such Third Parties.
10.3 By accessing or using Third Party Websites and/or Third Party Services, or providing your Personal Data to Third Parties, you acknowledge and agree that:
(a) you have read and understood such Third Parties’ privacy policies, and consent to the collection, use, disclosure and/or Processing of your Personal Data by such Third Parties pursuant to their privacy policies;
(b) we do not control such Third Parties, and the manner in which and purposes for which your Personal Data may be collected, used, disclosed and/or Processed is determined solely by such Third Parties as data controllers (as defined under applicable Data Protection Laws); and
(c) to the maximum extent permissible by Law, we shall not be liable for any liabilities, losses or damages that may be incurred by you as a result of your use of any Third Party Websites and/or Third Party Services, or the collection, use, disclosure and/or Processing of your Personal Data by any Third Parties.