This Policy describes how we manage Personal Data in compliance with the Singapore Personal Data Protection Act 2012 (No. 26 of 2012) (“Act”). We encourage you to read this Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data.
We may update this Personal Data Protection (“PDP”) Policy from time to time. Subject to your rights at law, you agree to be bound by the prevailing terms of this PDP Policy as updated from time to time. We encourage you to check the latest version of this PDP Policy regularly.
"Personal Data" refers to data, whether true or not, about an individual who can be identified from that data, or from that data in combination with other information to which the organization may have access and includes the meaning otherwise as defined in the Act as amended from time to time.
By signing up for or using any products, services or campaigns offered by APS Lifestyle Marketing Pte Ltd., or submitting information to or otherwise communicating with APS Lifestyle Marketing Pte Ltd., you agree and consent to APS Lifestyle Marketing Pte Ltd. and our related entities, affiliates and subsidiaries (individually and collectively, "Companies"), as well as their respective representatives and/or agents (collectively referred to herein as "APS", "us", "we" or "our") collecting, using and disclosing your Personal Data in accordance with this PDP Policy. “You” or “your” means any individual to whom the Act applies and includes an individual actual or prospective customer but excludes any corporate entity (including corporate customers) and any other entity that is excluded under the Act.
This PDP Policy does not supersede or replace any other consents you may have previously or separately provided to us in respect of your Personal Data, and your consent to this PDP Policy is in addition to any other rights which any of the Companies may have at law to collect, use or disclose custpomer Personal Data.
This PDP Policy shall be governed in all respects by the laws of Singapore.
1. Collection & Consent
1.1 Personal Data may be collected from you in one or more of the following ways:
1.2 Unless permitted by applicable laws, we will not collect Personal Data without your consent.
1.3 You warrant and represent to us that Personal Data which you disclose to us is accurate and complete; and where you volunteer Personal Data of another person to us, that you are authorized by such other person to disclose such Personal Data to us, and that such Personal Data is accurate and complete.
You shall consult your parent or guardian before giving us your Personal Data if you are under the age of eighteen.
2. Purposes for which we collect, use and disclose your Personal Data
2.1 Your Personal Data may be collected, used and/or disclosed for the following purposes:
2.2 Your Personal Data may be disclosed for the purposes indicated above to our employees, third parties, affiliates, service providers and advisors, which include without limitation, the following persons or entities:
2.3 As for relevant government regulators and authorities or law enforcement agencies, we will ensure that such parties receiving your Personal Data are under duty of confidentiality to us with respect to the use, holding, processing, retention and/or transfer of your Personal Data; and have the need to know or handle such Personal Data.
2.4 If you have provided us with your Singapore telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your Singapore telephone number(s), then from time to time, we may contact you using such Singapore telephone number(s) (including via voice calls, text, fax or other means) with information about our products and services.
2.5 Your Personal Data may be transferred, stored and/or processed in a country or territory outside Singapore and you consent to any such transfer, storage and/or processing of your Personal Data outside Singapore. We will however ensure that any party to whom we transfer your Personal Data outside Singapore provides to such Personal Data a standard of protection at least comparable to the protection under the Act. This includes without limitation ensuring that any party coming into contact with the Personal Data outside Singapore:
3. Withdrawal of Consent & Access
3.1 You may withdraw your consent to our continued use and disclosure of your Personal Data or seek access to your Personal Data (to a reasonable extent and as permitted by the Act) at any time by writing to the Office of our Data Protection Officer. You may also withdraw your consent for specific forms of communication and on specific communications via the unsubscribe options as stated on our email or other marketing messages.
3.2 In withdrawing your consent, you acknowledge that we may not be able to provide or continue to provide certain goods and/or services to you and that we may cease such provision accordingly without any liability. Please note that it may take up to 30 working days for any request for consent withdrawal to be reflected in our systems.
3.3 We will, at your request, endeavor to provide you with an account of your Personal Data in our possession or control within a reasonable time. Such account shall be in respect of how your Personal Data has been or may have been generally used or disclosed within the year before the date of your request.We reserve the right to charge a reasonable administrative fee for carrying out your request.
4. Accuracy & Correction
4.1 We will endeavor to ensure that your Personal Data we use is sufficiently accurate and complete in making any decision that impacts you.
4.2 If you would like to review, change or delete the details you have supplied to us with, please contact us by writing to the Office of our Data Protection Officer. We will correct or complete your Personal Data as soon as reasonably practicable.
5. Protection, Policies and Procedures
5.1 We will endeavor to protect your Personal Data in our possession or control against risks of unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction, through reasonable and appropriate security measures. We strive to ensure that our systems are secure and that they meet industry standards. To prevent unauthorized access, maintain data accuracy and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the Personal Data we collect. Notwithstanding our security measures for protecting your Personal Data, you acknowledge that no data transmission over the Internet is completely secure and by providing your Personal Data, you are transmitting information at your own risk.
6. Retention of Personal Data
6.1 We will retain your Personal Data for as long as you use our products or services and it is necessarily required or relevant for business or legal purposes.
7.1 We gather Information on our website activity, such as the number of visitors, the pages they visit, the duration of their stay, etc. This information is collected on an aggregate and anonymous basis. We do not collect Personal Data automatically through the use of web server logs and cookers at our website unless you provide such information or login with your account credentials.
7.2 Cookies are small bits of data automatically stored in the hard drive of the end user and are commonly used to track user’s website preferences. If you enable these cookies, then your web browser adds the text in a small file. You may wish to set your web browser to notify you of a cookie placement request or refuse to accept cookies by modifying relevant internet options or browsing preferences of your computer system, but to do so you may not be able to utilize or activate certain available functions on our website.
7.3 By accessing and using our website and services, you consent to the storage of cookies, other local storage technologies, beacons and other information on your devices. You also consent to the access of such cookies, local storage technologies, beacons and information by us or our representatives or agents.
8. Third-Party Links and Products on Our Services
9. Do Not Call Registry
9.1 The Do Not Call (DNC) Registry prohibits the sending of unsolicited telemarketing messages (“specified messages”) to Singapore telephone numbers through voice calls, text or fax messages registered on the DNC Registers unless the organization sending the messages have the user’s/subscriber’s clear and unambiguous consent in written or other accessible forms.
9.2 In compliance with the DNC Registry provisions, APS Lifestyle Marketing Pte Ltd will not send specified messages to telephone or facsimile numbers that appear on the DNC Registry unless the user/subscriber has given us clear and unambiguous consent to do so.
9.3 If you have given us such consent, we will continue to send you specified messages until you advise us in writing (contact details below) that you wish to withdraw the consent.
9.4 APS Lifestyle Marketing Pte Ltd will continue to contact you at the telephone or facsimile number/s you have provided us in the limited circumstances allowed under the DNC Registry even if these telephone or facsimile number/s are registered with the DNC. You may, however, advise us in writing should you wish not to be contacted by us at your telephone or facsimile number(s) for any given purpose or all purposes.
9.5 Please be informed that we will still contact you via the most effective and efficient mode where required by law.
10. Contact us
10.1 If you have any complaint or grievance regarding about how we are handling your personal data or about how we are complying with the PDPA, we welcome you to contact us with your complaint or grievance through the webpage and using the online form set out therein.
10.2 You may also contact us through one of the following methods with your complaint or grievance:
Data Protection Officer
APS Lifestyle Marketing Pte Ltd
9 Muthuraman Chetty Road APS Building Level 5 Singapore 238931
Singapore Contact No : +65 6233 0530
Email Address : firstname.lastname@example.org
10.3 Where it is an email or a letter through which you are submitting a complaint, your indication at the subject header that it is a PDPA complaint would assist us in attending to your complaint quickly by passing it on to the relevant staff in our organization to handle. For example, you could insert the subject header as “PDPA Complaint”.
10.4 We will certainly strive to deal with any complaint or grievance that you may have speedily and fairly.
11. UPDATES ON DATA PROTECTION POLICY
11.1 As part of our efforts to ensure that we properly manage, protect and process your personal data, we will be reviewing our policies, procedures and processes from time to time.
11.2 We reserve the right to amend the terms of this Personal Data Protection Policy at our absolute discretion. Any amended Personal Data Protection Policy will be posted on our website and can be viewed at www.apsgroup.com.sg/pdpa.
11.3 You are encouraged to visit the above website from time to time to ensure that you are well informed of our latest policies in relation to personal data protection.
For more information about the Singapore Personal Data Protection Act, please visit http://www.pdpc.gov.sg.