This Data Protection Notice (“Notice”) sets out the basis which
Singapore Digital Namecard Pte Ltd Reg ROC 202110964C (“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 purposes.
PERSONAL DATA
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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.
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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 contact
information such as your address, email address or telephone
number, nationality, gender, date of birth, photographs and
other audio-visual information, employment information and
financial information such as credit card numbers, debit card
numbers or bank account information.
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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
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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).
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We may collect and use your personal data for any or all of the
following purposes:
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performing obligations in the course of or in connection
with our provision of the goods and/or services requested by
you;
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verifying your identity;
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responding to, handling, and processing queries, requests,
applications, complaints, and feedback from you;
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processing payment or credit transactions;
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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;
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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;
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any other incidental business purposes related to or in
connection with the above.
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We may disclose your personal data:
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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
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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.
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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
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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.
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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.
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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 2
SAMPLE CLAUSES AND TEMPLATES FOR CUSTOMERS (published 17 October
2017) 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
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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
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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.
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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.
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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
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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.
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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
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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
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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.
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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
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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
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You may contact our Data Protection 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 following
manner,write to support@singaporedigitalnamecard.com [insert
DPO’s contact details including, where applicable, address,
email address and telephone number].
EFFECT OF NOTICE AND CHANGES TO NOTICE
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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.
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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.