Personal Data Policy
Your privacy is important to us. The purpose of this Personal Data Policy is to inform you of how allrites Holdings Pte Ltd manages personal data in accordance with the Personal Data Protection Act 2012 (the “Act”).
Please take a moment to read this Personal Data Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data. The definitions in the Terms of Service will be adopted in this Personal Data Policy as well.
By interacting with us; using any part of our Service; submitting information to us; or signing up for any services offered by us, you agree and consent to allrites Holdings Pte Ltd, our related corporations and affiliates, (collectively referred to hereinafter as “allrites“, “us“, “we” or “our“), as well as our respective representatives collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to our authorised service providers and relevant third parties in the manner set forth in this Personal Data Policy.
This Personal Data Policy supplements but does not supersede nor replace any other consents you may have previously provided to allrites nor does it affect any rights which allrites may have at law in connection with the collection, use or disclosure of your Personal Data. allrites may from time to time update this Personal Data Policy to ensure that it 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 Personal Data Policy as updated from time to time on the Site; the mobile application; and the Third Party Sites. Please check regularly for updated information on the handling of your Personal Data.
For avoidance of doubt, this Personal Data Policy; the Terms of Service; and other terms and conditions and policies which you may find throughout our Service, or which may communicated to you in connection with certain functionality or features, all of which are deemed a part of our Agreement with you constitute the Agreement between you and us in relation to your use of any part of the Service (the “Agreement”).
In the event of any conflict, inconsistency or conflict between this Personal Data Policy and the rest of the Agreement in relation to our collection, use and disclosure of your Personal Data, this Personal Data Policy shall prevail. All defined terms contained elsewhere in the Agreement shall apply to this Personal Data Policy unless otherwise specifically stated.
1. YOUR PERSONAL DATA
In this Personal Data 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:
- 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;
- information about your use of allrites’ website and services, including cookies, IP address, subscription account details and membership details, but only to the extent that allrites may identify you from such information;
- your payment related information, such as your bank account or credit card information, and your credit history; and
- 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.
2. COLLECTION OF PERSONAL DATA
2.1 Generally, allrites collects your Personal Data in the following ways:
- when you submit forms relating to any of our products or services;
- when you register for or use any of our services on the Site; the mobile application; and the Third Party Sites;
- when you interact with our customer service officers;
- when you use any part of our services;
- when you establish any online account with us;
- when you request that we contact you;
- when you are contacted by, and respond to, our marketing representatives and agents;
- when you respond to our request for additional Personal Data
- when you ask to be included in an email or other mailing list;
- when you respond to our promotions and other initiatives;
- when we receive references from business partners and third parties, for example, where you have been referred by them
- when you submit your Personal Data to us for any other reason.
2.2 When you browse our website, you generally do so anonymously, but please see the section below on cookies in Clause 5, below.
2.3 If you provide us with any Personal Data relating to a third party, 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.
2.4 You should ensure that all Personal Data submitted to us is complete, accurate, true and correct; and that these are from time to time updated. Failure on your part to do so may result in our inability to provide you with products and services you have requested.
3. PURPOSES FOR THE COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL DATA
3.1 Generally, allrites collects, uses and discloses your Personal Data for the following purposes:
- responding to your queries and requests and responding to complaints;
- managing the infrastructure and business operations of allrites and complying with internal policies and procedures;
- facilitating business asset transactions (which may extend to any merger, acquisition or asset sale;
- matching any Personal Data held which relates to you for any of the purposes listed herein;
- verifying your identity;
- preventing, detecting and investigating crime, including fraud and money-laundering, and analyzing and managing other commercial risks
- protecting and enforcing our contractual and legal rights and obligations;
- managing commercial risks, conducting audits, reviews and analysis of our internal processes, action planning and;
- 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
- any other purpose relating to any of the above.
3.2 In addition, allrites may collect, use and disclose your Personal Data for the following purposes, depending on the nature of our relationship with you:
(a) If you have an account with us:
(i) to process your application for an account;
(ii) to maintain your account with us;
(iii) to verify and process your personal particulars and payments in relation to provision of services to you;
(iv) communicating with you to inform you of changes and development to our policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you;
(v) resolving complaints and handling requests and enquiries;
(vi) conducting market research for statistical, profiling and statistical analysis for the improvement of services provided to you; and
(vii) the processing of your Personal Data in relation to any of the purposes stated above.
(b) If you use download or use any part of our Service (including the Site; any Third Party Sites; or any app):
(i) where the app includes app subscription services, to process your application for these services;
(ii) to maintain your account with us and to ensure your access of the app is within the scope of your subscription;
(iii) to verify and process your personal particulars and payments in relation to provision of goods and services to you;
(iv) to provide you with the goods and services which you have signed up for and to push messages to you which may be relevant to you;
(v) communicating with you to inform you of changes and development to allrites policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you;
(vi) resolving complaints and handling requests and enquiries;
(vii) conducting market research for statistical, profiling and statistical analysis for the improvement of services provided to you; and
(viii) the processing of your Personal Data in relation to any of the purposes stated above.
3.3 In addition, where permitted under the Act, allrites may also collect, use and disclose your Personal Data for the following purposes (which we may describe in our documents and agreements as “Additional Purposes” for the handling of Personal Data):
- providing services, products and benefits to you, including promotions, loyalty and reward programmes;
- 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 allrites or other third parties;
- 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;
- 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
- 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.
3.4 If you have provided your telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your telephone number(s), then from time to time, allrites may contact you using such telephone number(s) (including via voice calls, sms, fax or other means) with information about our products and services (including discounts and special offers).
3.5 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.
3.6 You also consent to the collection, use and disclosure of your Personal Data by allrites in connection with any transaction relating to the acquisition, divestment, securisation, amalgamation, listing or other transaction relating to any interest in allrites, the shares or assets of allrites, and any other corporate transaction involving allrites, including any evaluation or due diligence relating thereto, as well as to the collection, use and disclosure of such information by the counterpart(ies) thereto for the same purposes, and the provision of goods and services by such counterpart(ies) following such transaction, as may be relevant.
4. DISCLOSURE OF PERSONAL DATA
4.1 allrites 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:
- allrites affiliates;
- agents, contractors or third party service providers who provide operational services to allrites, such as telecommunications, information technology, payment, payroll, processing, training, market research, newspaper vendor services, newspaper delivery services, storage, archival or other services to allrites;
- vendors or any third party business partners who offer goods and services or sponsor contests or other promotional programs on allrites sites, whether in conjunction with us or not;
- external business and charity partners in relation to corporate promotional events;
- the Credit Bureau, or in the event of default or disputes, any debt collection agencies or dispute resolution centres;
- any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale;
- anyone to whom we transfer or may transfer our rights and duties;
- banks, credit card companies and their respective service providers;
- our professional advisors such as our auditors and lawyers;
- relevant government regulators or authority or law enforcement agency to comply with any laws or rules and regulations imposed by any governmental authority; and
- any other party to whom you authorise us to disclose your personal data
5.1 When you interact with us on parts of our Service, we may collect or analyse anonymised information from which individuals cannot be identified (“Aggregate Information”), such as 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 website.
5.2 allrites 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.
5.3 allrites may use an independent company (the “Third Party Market Research Company”) to measure and analyse the Internet usage across allrites web sites. allrites uses the Third Party Market Research Company’s services to collect the following core information on the usage of our web sites, including:
- The number of page views (or page impressions) that occur on any part of the Service;
- the number of unique visitors to any part of the Service;
- how long these unique visitors (on average) spend on any part of the Service when they do visit; and
- common entry and exit points into any part of the Service.
5.4 This information is aggregated by the Third Party Market Research Company and provided to allrites to assist in analysing the usage of the Service. Such data is also accessible by media organizations and research companies, for the purpose of conducting industry comparisons with other Internet portals.
5.5 Pages on the Service may be coded with software which enables the Third Party Market Research Company to track visitors to our web sites.
5.6 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 access certain part(s) of our Service.
6. THIRD-PARTY SITES
Parts of our Service 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 Service. 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 trade mark, even though they are not operated or maintained by us. Once you have left our Service, 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.
7. WITHDRAWAL, ACCESS AND CORRECTION OF YOUR PERSONAL DATA
7.1 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 write to our Personal Data Protection Officer at firstname.lastname@example.org.
7.2 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 allrites on your behalf.
7.3 Please note that if you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, allrites may not be in a position to continue to provide its products or services to you or administer any contractual relationship in place, and this may also result in the termination of any agreements with allrites and your being in breach of your contractual obligations or undertakings, and allrites’s legal rights and remedies in such event are expressly reserved.
7.4 You may to pay a fee to access your Personal Data (or to exercise any of the other rights) if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.
7.5 We may need to request specific information from you to help us confirm your identity and ensure your right to access your Personal Data (or to exercise any of your other rights). This is a security measure to ensure that Personal Data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
7.6 We try to respond to all legitimate requests within one (1) month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
8. GOVERNING LAW
This Personal Data Policy shall be governed in all respects by the laws of Singapore.
9. DATA RETENTION
9.1 We will only retain your Personal Data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
9.2 To determine the retention period for your Personal Data, we (amongst other things) consider whether there remain legal or business bases for our retention; the nature of the Personal Data, the risk of unauthorised use or disclosure of your Personal Data, the purposes for which we process it and the applicable legal requirements.
9.3 In some circumstances we may anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
10 HOW TO CONTACT US
Please contact our Data Protection Officer (“DPO”) by post or email if you have any questions about this Personal Data Policy or the information we hold about you using the details are shown below:
Our DPO’s contact details are stated below:
ALLRITES HOLDINGS PTE. LTD.