- As used in this Notice:
A “Client” means an individual who (a) has contacted us through any means to find out more about the services that we provide, or (b) may, or has, signed into a contract with us for the use of the space serviced by us or programs carried out by us; and “personal data” means data, whether true or not, about a client who can be identified from that data or other information to which we have or are likely to have access.
- Depending on the type of engagement (programs, membership or event) with us, some examples of personal data which we may collect from you include your name and identification information such as your FIN/NRIC number; contact information such as your address; email address or telephone number; nationality; gender; date of birth; marital status; photographs; and some employment information and financial information such as credit card number, debit card number, or bank account information.
- 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
We do not collect your personal data unless:
It is provided to us voluntarily by you or via a third party who has been duly authorized by you to disclose your personal data to us after:
- You have been notified of the purposes for which the data is collected, and;
- You have provided written consent to the collection and usage of your personal data for those purposes, or;
Collection and use of personal data without consent is legally required. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose of which has not been notified to you (except where permitted or authorized by law).
We may collect and use your personal data for any or all of the following purposes:
- Performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
- Verifying your identity;
- Responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
- Managing your relationship with us;
- Processing payment or credit transactions;
- Sending you notifications for our marketing events, initiatives, announcements, and other promotions;
- Complying with any applicable laws, regulations, code of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
- Any other purposes for which you have provided the information;
We may disclose your personal data:
- Where such disclosure is required for performing obligations in the course of or in connection with our provision of the services requested by you, or;
- To event organizers we have engaged to perform any of the functions in the space.
The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, your contract) has been terminated or altered in any way, for a period of 90 days thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).
Withdrawing your Consent
- 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 formal writing. You may withdraw consent and request to 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 at the end of this notice.
- 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 consequence 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.
- While 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 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 or email in the manner described in clause 8 above.
- 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
- If you wish to make (a) a 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 at the end of this notice.
- 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.
- 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
- To safeguard your personal data from unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks, we are using appropriate administrative, physical and technical measures such as up-to-date firewall 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 authorized third party service providers and vendors only on a need-to-know basis.
- You should be aware, however, that no method of transmission over the internet, cloud, or any method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and will be constantly reviewing and enhancing our information security measures.
We are required to notify the affected individuals as soon as practicable (no later than 72 hours) after establishing that the data breach is likely to result in significant harm or impact to the individuals to whom the information relates.
We are not responsible if the cause of data breach is due to:
Accuracy of Personal Data
- We generally rely on personal data provided by you. 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 at the end of this notice.
Retention of Personal Data
- We may retain your personal data for as long as it is necessary to fulfill the purpose for which it was collected, or as required or permitted by applicable laws.
- 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
- We do not transfer your personal data to countries outside 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
- To contact our Data Protection Officer/s, please send us an email at email@example.com and we will respond to you accordingly.
Effect of Notice and Changes to Notice
- 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.