DATA PROTECTION NOTICE
This Data Protection Notice
(“Notice”) sets out the basis which [Letrain Events And Marketing Pte Ltd]
(“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal
data of our customers in accordance with the Personal Data
Protection Act (“PDPA”).
This Notice applies to personal data in our possession or under our control,
including personal data in the possession of organisations which we have engaged
to collect, use, disclose or process personal data for our
PERSONAL DATA
1.
As used in this Notice:
“customer”
means an individual who (a) has contacted us through any means to find out more
about any goods or services we provide, or (b) may, or has, entered into a
contract with us for the supply of any goods or services by us; and
“personal
data” means data, whether true or not, about a customer who can be identified:
(a)
from that data; or (b) from that data and other information to which we
have or are likely to have access.
2.
Depending on the nature of your interaction with us, some examples of
personal data which we may collect from you include your name and identification
information such as your NRIC number, contact information such as your address,
email address or telephone number, nationality, gender, date of birth, marital
status, photographs and other audio-visual information, employment information
and financial information such as credit card numbers, debit card numbers or
bank account information.
3.
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
4.
We generally do not collect your personal data unless (a) it is provided
to us voluntarily by you directly or via a third party who has been duly
authorised by you to disclose your personal data to us (your “authorised
representative”) after (i) you (or your authorised representative) have been
notified of the purposes for which the data is collected, and (ii) you (or your
authorised representative) have provided written consent to the collection and
usage of your personal data for those purposes, or (b) collection and use of
personal data without consent is permitted or required by the PDPA or other
laws. We shall seek your consent before collecting any additional personal data
and before using your personal data for a purpose which has not been notified to
you (except where permitted or authorised by law).
5.
We may collect and use your personal data for any or all of the following
purposes:
(a)
performing obligations in the course of or in connection with our
provision of the goods and/or services requested by you;
(b)
verifying your identity;
(c)
responding to, handling, and processing queries, requests, applications,
complaints, and feedback from you;
(d)
managing your relationship with us;
(e)
processing payment or credit transactions;
(f)
sending your marketing information about our goods or services including
notifying you of our marketing events, initiatives and promotions, lucky draws,
membership and rewards schemes and other promotions;
(g)
complying 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;
(h)
any other purposes for which you have provided the information;
(i)
transmitting 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;
and
(j)
any other incidental business purposes related to or in connection with
the above.
6.
We may disclose your personal data:
(a)
where such disclosure is required for performing obligations in the
course of or in connection with our provision of the goods or services requested
by you; or
(b)
to third party service providers, agents and other organisations we have
engaged to perform any of the functions listed in clause 5 above for us.
7.
The purposes listed in the above clauses may continue to apply even in
situations where your relationship with us (for example, pursuant to a contract)
has been terminated or altered in any way, for a reasonable period thereafter
(including, where applicable, a period to enable us to enforce our rights under
any contract with you).
WITHDRAWING YOUR
CONSENT
8.
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 writing. You may withdraw consent and request 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 below.
9.
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 consequences 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.
10.
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 goods
or 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 in the manner described in clause 8 above.
11.
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
12.
If you wish to make (a) 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
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 below.
13.
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.
14.
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
15.
To safeguard your personal data from unauthorised access, collection,
use, disclosure, copying, modification, disposal or similar risks, we have
introduced appropriate administrative, physical and technical measures such as
up-to-date antivirus 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 authorised third party service
providers and agents only on a need-to-know basis.
16.
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 information and
are constantly reviewing and enhancing our information security measures.
ACCURACY OF PERSONAL
DATA
17.
We generally rely on personal data provided by you (or your authorised
representative). 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 below.
RETENTION OF
PERSONAL DATA
18.
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.
19.
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
20.
We generally do not transfer your personal data to countries outside of
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
21.
You may contact our Customer Service Officer if you have any enquiries or
feedback on our personal data protection policies and procedures, or if you wish
to make any request, in the following manner:
Email:
enquires@letrain.com.sg
Address: 2
Havelock Road, Havelock II, #03-01 Singapore 059763
Tel: (65) 6336
4688
EFFECT OF NOTICE AND
CHANGES TO NOTICE
22.
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.
23.
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.
Effective date
: 1 January 2017
Managed by Letrain Events And Marketing Pte Ltd