DATA PROTECTION NOTICE FOR CUSTOMERS
Last Revised: 1st June 2021
This Data Protection Notice (“Notice”) sets out the basis on which Tripwerkz Pte. Ltd. (Company Registration No.202033307M) (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of our customers in accordance with the Personal Data Protection Act 2012 (“PDPA”). This Notice applies to personal data in our possession or under our control, including personal data in the possession of third-party service providers we have engaged to collect, use, disclose or process personal data for our purposes specified herein.
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 name, identification numbers such as IC, FIN, work permit and birth certificate, residential address, email address, telephone number, nationality, gender and date of birth.
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. The provision of your personal data to us will be deemed as consent to our collection, use and disclosure of your personal data for the purposes set out in this Notice. 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:
performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
verifying your identity;
allowing you to participate in features of the website and platform and receive our services; responding to, handling and processing queries, requests, applications, complaints, and feedback from you; communicate with you by email or other chosen means to send relevant notifications about our events and services that may be of interest to you; contact you and notify you about changes to ourwebsite, platform or our services (except where you have expressly requested for us not to do so);
managing your relationship with us;
analysing how users are making use of the website and platform for our internal marketing and research purposes;
sending you important notifications that you will require in order to use the website, platform, and our services;
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;
any other purposes for which you have provided the information; and
any other incidental business purposes related to or in connection with the above.
6. By using our services, you expressly authorise and consent to us gathering, reviewing, retaining and where reasonably required, transmitting your personal data to our service providers and intermediaries for the proper and reasonable purpose of their storing and using the data responsibly and in accordance with the PDPA.We may disclose your personal datawheresuch disclosure is required for performing our obligations in the course of or in connection with our provision of the goods and services requested by you, including but not limited to the placing of order with the suppliers of the goods and services, the arranging forcredit card payments, and obtaining third party or subcontracting services for our operations.
WITHDRAWING YOUR CONSENT
7. 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 collecting, 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.
8. 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 three (3) business days of receiving it.
9. 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 7 above.
10. 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
11. 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.
12. 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.
13. We will respond to your request as soon as reasonably possible. In general, our response will be within three (3) business days. 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
14. 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 use of privacy filters.
15. 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
16.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.We will not be responsible for relying on inaccurate or incomplete data arising from your failure to notify us of any changes or inaccuracies in your personal data that was initially provided.
RETENTION OF PERSONAL DATA
17. 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.
18. 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
19. 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.
SPECIFIC PROVISIONS RELATED TO THE EUROPEAN UNION GDPR
20. We acknowledge that the General Data Protection Regulation (“GDPR”) will apply if we process or hold any personal data of individuals residing in the EU or if we offer goods or services to individuals in the EU (“EU Individuals”).
21. We understand that we may lawfully process personal data if consent is provided by the EU Individual for the processing for specific purposes, if it is necessary for the performance of a contract of if it is necessary for our compliance with a legal obligation.
22. We understand that personal data must be processed lawfully, fairly and transparently, be collected and applied only for specified, explicit and legitimate purposes, must be limited to only what is required, must be accurate, not be kept in personally identifiable form for longer than is necessary and must be secured and protected pursuant to the GDPR.
23. We acknowledge and agree that the GDPR affords EU Individuals with rights such as:
(a) The right to access and obtain a copy of the EU Individuals’ personal data, including the purposes of processing and who the personal data has been disclosed to;
(b) The right to rectify inaccurate personal data concerning the EU Individual;
(c) The right to erasure of personal data concerning the EU Individual in certain circumstances;
(d) The right to restriction of processing of personal data in certain circumstances, such as where the accuracy of the personal data is contested, or the processing is unlawful;
(e) The right to data portability by receiving personal data concerning the EU Individual or data which has been provided to us, in a structured, commonly used and machine-readable format, and the right to transmit that data to another organisation;
(f) The right to object to the processing of personal data in certain circumstances, including for the purposes of direct marketing; and
(g) The right not to be subject to automated decision-making (including profiling) where this has a legal effect on the EU Individual or significantly affects him.
24. We agree that we will act on a request from an EU Individual without undue delay (within one month). We will maintain records of how we process personal data, acknowledge the need to conduct data protection impact assessments and the need to apply careful consideration in the adoption and engagement of our data processors.
DATA PROTECTION OFFICER
25. 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 the following manner:
Contact No. : +65 6224 3006
Email Address : firstname.lastname@example.org
Address : 33 Ubi Ave 3, Vertex Tower B, #07-21, Singapore 408868
EFFECT OF NOTICE AND CHANGES TO NOTICE
26. 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.
27. 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.