THE PERANAKAN ASSOCIATION SINGAPORE’S DATA PROTECTION POLICY

INTRODUCTION

1. Under the Personal Data Protection Act 2012 of Singapore, (No. 26 of 2012) (“PDPA”), the Peranakan Association Singapore (“TPAS”) recognises its responsibility on the privacy and confidentially of your Personal Data (as defined under Clause 4 below). TPAS undertakes to properly manage, protect and process the Personal Data provided in compliance with the PDPA.

2. By interacting with us, submitting information to us, or signing up for any of the events organised by us, you agree and consent to TPAS as well as our representatives collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to TPAS’s authorised service providers and relevant third parties in the manner set forth in this Privacy Policy.

3. This Privacy Policy supplements but does not supersede nor replace any other consents you may have previously provided to TPAS nor does it affect any rights which TPAS may have at law in connection with the collection, use or disclosure of your Personal Data. TPAS may from time to time update this Privacy Policy to ensure that this Privacy Policy is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of the Privacy Policy as updated from time to time on our website. Please check regularly for updated information on the handling of your Personal Data.

YOUR PERSONAL DATA

4. In this Privacy Policy, “Personal Data” refers to any data or information about you from which you can be identified either (a) from that data; or (b) from that data and other information to which we have or are likely to have access. Examples of such Personal Data which you may provide to us include (depending on the nature of your interaction with us:

(a) your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address and any other information relating to you which you have provided us in any forms you may have submitted to us, or in other forms of interaction with you;

(b) information about your use of TPAS’s website, including cookies, IP address, and membership details, but only to the extent that TPAS may identify you from such information;

(d) your payment-related information, such as your bank account or credit card information, and your credit history; and

(e) information about your usage of and interaction with our website and / or services including computer and connection information, device capability, bandwidth, statistics on page views, and traffic to and from our website.

COLLECTION OF PERSONAL DATA

4.1 Generally, TPAS collects your Personal Data in the following ways:

(a) when you apply to become a member via our website or by submitting a physical form;

(b) when you register for or use any of our services on our website or use services on our website;

(d) when you use some of our services;

(e) when you request that we contact you;

(f) when you are contacted by, and respond to, our authorised representatives;

(g) when you respond to our request for additional Personal Data;

(h) when you ask to be included in an email or other mailing list;

(i) when you respond to our promotions and other initiatives; and

(j) when you submit your Personal Data to us for any other reason.

4.2 When you browse our website, you generally do so anonymously but please see the section below on cookies.

4.3 If you provide us with any Personal Data relating to a third party (e.g. information of spouse, children, parents, employees and/or authorised representatives), by submitting such information to us, you represent to us that you have obtained the consent of the third party to you providing us with their Personal Data for the respective purposes.

4.4 You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with the products and services you have requested.

5. Purposes for the Collection, Use and Disclosure of Your Personal Data

5.1 Generally, TPAS collects, uses and discloses your Personal Data for the following purposes:

(a) responding to your queries and requests and responding to complaints;

(b) managing the affairs of TPAS and complying with internal policies and procedures;

(d) verifying your identity;

(e) preventing, detecting and investigating crime, including fraud and money-laundering, and analysing and managing other risks;

(f) protecting and enforcing our contractual and legal rights and obligation;

(g) conducting audits, reviews and analysis of our internal processes, action planning and managing risks;

(h) preventing, detecting and investigating crime and managing the safety and security of our services and events that we organise (including but not limited to carrying out CCTV surveillance and conducting security clearances);

(i) compliance with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities; and/or

(j) any other purpose relating to any of the above.

5.2 In addition, TPAS may collect, use and disclose your Personal Data if you download or use any of our Apps:

(a) where the App includes App Subscription Services, to process your application for these services;

(b) to maintain your account with us and to ensure your access of the App is within the scope of your subscription;

(c) to verify and process your personal particulars and payments in relation to the provision of goods and services connected to the App;

(d) to provide you with the goods and services which you have signed up for and to push articles to you which may be relevant to you;

(e) communicating with you to inform you of changes and development to TPAS, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you;

(f) resolving complaints and handling requests and enquiries;

(g) conducting market research for statistical, profiling and statistical analysis for the improvement of services provided to you; and

(h) the processing of your Personal Data in relation to any of the purposes stated above.

6.3 In addition, where permitted under the Act, TPAS may also collect, use and disclose your Personal Data for the following purposes:

(a) providing services, products and benefits to you, including promotions, loyalty and reward programmes;

(b) matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision or offering of products and services, whether by TPAS or other third parties;

(c) administering contests, competitions and conducting lucky draws, including, where necessary, in order to announce the results of these contests, competitions and lucky draws and identify and contact the winners, and in order to publicise and conduct marketing strictly related to these contests, competitions and lucky draws;

(d) sending you details of products, services, special offers and rewards, either to our customers generally, or of particular products and services which may be of interest to you; and

(e) conducting market research, understanding and determining customer location, preferences and demographics for us to review, develop and improve our products, services and also develop special offers and marketing programmes.

6.4 If you have provided your e-mail address(s) and have indicated that you consent to receive information on events organised by from TPAS and on matters related to the Peranakan culture via your e-mail address(s), then from time to time, TPAS may send you such updates.

6.5 In relation to particular products or services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, then we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.

7. DISCLOSURE OF PERSONAL DATA

7.1 TPAS will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, this Personal Data may be disclosed, for the purposes listed above (where applicable), to the following third parties, whether they are located overseas or in Singapore:

(a) agents, contractors or third-party service providers who provide operational services to TPAS such as telecommunications, information technology, payment, processing, training, market research, printing, delivery, storage, archival or other services to TPAS;

(b) vendors or any third-party business partners who offer goods and services or sponsor contests or other promotional programs on TPAS’s website, whether in conjunction with us or not;

(d) anyone to whom we transfer or may transfer our rights and duties;

(e) our professional advisors such as our auditors and lawyers;

(f) relevant government regulators or authority or law enforcement agency to comply with any laws or rules and regulations imposed by any governmental authority; and

(g) any other party to whom you authorise us to disclose your personal data.

8. USE OF COOKIES

8.1 When you interact with us on our websites, we may collect or analyse anonymised information from which individuals cannot be identified (“Aggregate Information”), such as the number of users and their frequency of use, the number of page views (or page impressions) that occur on the website and common entry and exit points into the website.

8.2. TPAS uses “cookies”, where a small data file is sent to your browser to store and track Aggregate Information about you when you enter our websites. The cookie is used to track information such as the number of users and their frequency of use, profiles of users and their preferred sites.

8.3 TPAS may use an independent company (the “Third Party Market Research Company”) to measure and analyse the Internet usage across TPAS’s website by collecting the following core information on the usage of its website, including:

(a) The number of page views (or page impressions) that occur on TPAS’s website;

(b) The number of unique visitors to TPAS’s website;

(d) Common entry and exit points into TPAS’s website.

8.4 This information would be aggregated by the Third Party Market Research Company and provided to TPAS to assist in analysing the usage of TPAS’s website. Such data would also be accessible by media organisations and research companies, for the purpose of conducting industry comparisons with other Internet portals.

8.5 Pages on TPAS’s website may be coded with software which will enable the Third Party Market Research Company to track visitors to its website.

8.6 Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser. However, you may not be able to enter certain part(s) of our website.

9. Third-Party Sites

TPAS’s website may contain links to other websites operated by third parties, such as our business partners. We are not responsible for the privacy practices of websites operated by third parties that are linked to our website. We encourage you to learn about the privacy policies of such third party websites. Some of these third-party websites may be co-branded with our logo or trademark, even though they are not operated or maintained by us. Once you have left our website, you should check the applicable terms, conditions and policies of the third party website to determine how they will handle any information they collect from you.

10. Withdrawal, Access and Correction of your Personal Data

10.1 Should you wish to withdraw consent to use of your Personal Data or obtain access to or make corrections to your Personal Data records, please contact the Personal Data Protection Officer, contact details of which are as follows:

Name:

E-mail address:

Postal address:

Contact number:

10.2 Please note that if your Personal Data has been provided to us by a third party, you should contact such party directly to make any queries, feedback, and access and correction requests to TPAS on your behalf.

10.3 Please note that if you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, TPAS may not be in a position to continue to provide the services that you are entitled to as a member or administer any contractual relationship in place, and this may also result in the termination of any agreements with TPAS and your being in breach of your contractual obligations or undertakings, and TPAS’s legal rights and remedies in such event are expressly reserved.

11. DATA MANAGEMENT

11.1 TPAS will adopt appropriate measures to keep your personal data accurate, complete and updated. It will also ensure that there are appropriate precautions and preventive measures to ensure that your personal data is adequately protected and secured. While appropriate security arrangements will be taken to prevent any unauthorised access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data, TPAS cannot assume responsibility for any unauthorised use of your personal data by third parties which are wholly attributable to factors beyond our control.

11.2 In the event that the purpose in which your personal data collected is no longer legally required or to be retained by TPAS, the association will ensure that all related records under our control are removed.

12. GOVERNING LAW

This Privacy Policy shall be governed in all respects by the laws of Singapore.

Dated 28 August 2018

Disclaimer

THE PERANAKAN ASSOCIATION SINGAPORE’S DATA PROTECTION POLICY

INTRODUCTION

YOUR PERSONAL DATA

COLLECTION OF PERSONAL DATA