[Last updated on 4 Feb 2016]
For avoidance of doubt, the words “you” and “your” in this Policy shall also include third parties such as your principals or wards, as well as such other persons whom you may represent.
1. What personal data is collected
1.1 When you use our Sites, Services or in your interaction with us, the personal data we may collect includes:
a) Data collected directly from you. This may be done through our Sites and social media channels, over the phone, by email, via any correspondence, or in person when you meet or interact with our staff, agents or representatives. Data collected may include, but is not limited to:
- personal particulars, e.g. name, NRIC/FIN/passport details, address, telephone number, email address, date of birth, education details, photographs and videos
- medical information, e.g. medical conditions, records, reports, and/or history
- financial information, e.g. income, expenses, and/or banking information of you and your family
- employment information, e.g. occupation, employment history, salary, and/or benefits
- your interaction with us, e.g. phone calls, call recordings, mobile text messages, emails, faxes, letters, forms, and any other correspondences
- the schemes, services, programmes, courses, or any other assistance rendered by SG Enable to you
- photographs and videos of you captured by surveillance cameras when you visit our premises
- photographs and videos of you taken by us or our representatives when you attend programmes, courses or events hosted by us
- the information you provide when you agree to be featured in interviews or stories in print, online, or other media channels. Such stories may be commissioned directly by SG Enable and its affiliates, or they may be facilitated by us but commissioned by other agencies, individuals and organisations
- if you have contacted customer service, the details of this contact and the contact history; and
- If you have sent your personal data to us for any other reason
b) Data collected by automated means. Various technologies may be used on our Sites and web-based applications in order to make them more user-friendly, effective and secure. Such technologies may lead to data being collected automatically by us or by third parties on behalf of us. This data does not generally, but may, contain a user’s personal data. Examples of such technologies include:
- Click-stream data. A visit to one of our Sites results in data that is transmitted from your browser to our server being automatically collected and stored by us or by third parties on behalf of us. This data can include, but is not limited to, the following:
- the visitor’s IP address
- the date and time of the visit
- the referral URL (the site from which the visitor has come)
- the pages visited on our Sites
- information about the browser used (browser type and version, operating system, etc).
- Web beacons and tracking links. Web beacons (also known as pixel tags and clear GIFs) involve graphics that are not apparent to the user. Tracking links and/or similar technologies consist of a few lines of programming code and can be embedded in our Sites. In conjunction with cookies, these are primarily used for statistical analysis purposes. This technology can also be used for tracking traffic patterns on websites, as well as finding out if an e-mail has been received and opened and to see if there has been any response.
- Web analytics. Web analytics is the term given to a method for collecting and assessing the behaviour of visitors to websites and mobile applications. This includes the analysis of traffic patterns in order, for example, to determine the frequency of visits to certain parts of a website or mobile application, or to find out what information and services our visitors are most interested in. For these purposes, we primarily make use of click-stream data and the other techniques listed above. Web analytics are carried out by Google Analytics and/or other selected parties. You can find out more information about the processing of web analytics data by Google Analytics in paragraph 7 below.
- Data from other agencies, individuals or organisations.Sources can include voluntary welfare organisations, hospitals, schools, government ministries and agencies, employers, training providers, and/or other agencies that approach SG Enable to render services or assistance to you.
2. How the collected personal data is used
2.1 We use your personal data for the purposes of serving you. This includes, where applicable:
- providing you with the products and services that you have requested, including notifying you regarding the status of services or schemes you have requested, and assessment of your eligibility for services and schemes (for which we may use, engage with, or share your personal data with relevant third parties);
- ensuring that your transactions on our Sites are safe and secure;
- responding to queries, feedback and requests from you or people you have authorised;
- contacting you for feedback after a sale of a product or service;
- investigating or resolving any problems, claims or disputes you may encounter in relation to our services;
- processing, providing, and/or administering schemes, services, programmes, courses, or any other assistance to you;
- processing claims, reimbursements, payouts, or payments for schemes, services, programmes, courses, or any other events you have registered for;
- facilitating referrals or connections to other organisations or agencies that may provide relevant services or assistance to you; and
- informing you about SG Enable’s schemes, services, programmes, courses, events, or other information that may be relevant to you.
2.2 We may also use your personal data for purposes connected or relevant to the business of the SG Enable, such as:
- complying with legal and regulatory obligations and requirements;
- enforcing obligations owed to SG Enable;
- research and developing new products and services or improving existing products and services of SG Enable;
- accounting, risk management, audit, compliance and record keeping purposes;
- carrying out research, planning, studies, statistical analysis, evaluation, policy formulation, and reporting;
- staff training;
- producing materials for training, internal and/or external communications, publicity, or other purposes deemed appropriate by us whether in the print, online or in any other media including but not limited to photographs, images, audio or video files;
- for surveillance of premises; and
- providing your data to organisations or agencies which administer or provide schemes, services, or other assistance which may be of relevance to you; industry regulators and other government organisations, as required by local laws and regulations; financial institutions, for purposes such as facilitating payments, screenings or checks; as well as organisations, for the purposes of data analysis, evaluation and policy formulation, for which you will not be identified as a specific individual.
2.3 Your personal data may also be anonymised for use by SG Enable for other purposes.
2.4 If you have consented, your personal data may be used by the SG Enable for the purposes of marketing products and services offered on the Sites or other products or services offered by SG Enable or those of its strategic partners or business affiliates, e.g. informing you of latest activities, special offers, promotions or sending you newsletters.
2.5 In order for us to market products and services which are of special interest and relevance to you, we may analyse and rely on your overall interaction with us (such as but not limited to your contact history with our customer service, your newsletter clicks/ opening results, your surfing behaviour (web tracking), the newsletter types you are subscribed to, your participation in promotions or events, and your interactions with us).
2.6 If you have contacted us with any complaints, feedback, comments, suggestions, we will use and disclose your personal data (including your contact history) to respond to you and provide you with the best service possible. If you are the complainant and you do not want us to disclose your identity to the party you are complaining about, you must let us know immediately. However, it may not always be possible to handle your complaint on the basis of anonymity.
2.7 When using your personal data to contact you for the above purposes, we may contact you via postal mail, fax, e-mail, SMS, telephone or any other electronic means.
2.8 If we need to use your personal data for any other purposes, we will notify you and obtain your consent beforehand. You will be given the opportunity to withhold or withdraw your consent for the use of your personal data for these other purposes.
3. Disclosure of information
3.1 We will not sell or transfer your personal data to third parties or otherwise deal with your personal data in similar manner.
3.2 We will only disclose your personal data to third parties where you have provided us consent, and in the situations expressly set out in in this Policy. If you have consented to receiving marketing information from us, our strategic partners and business associates, we will be disclosing your personal data to them.
3.3 Your personal data may be disclosed and shared within SG Enable and its affiliates to allow us to provide the products and services which you have requested.
3.4 We may disclose or share your personal data with third parties who provide necessary services to us, such as:
- service providers and data processors working on our behalf and providing services such as hosting and maintenance services, analysis services, e-mail messaging services, delivery services, handling of payment transactions, solvency check and address check, etc; and
- our consultants and professional advisers (such as accountants, lawyers, auditors).
3.5 We will also disclose your personal data to third parties in order to comply with legal obligations or industry requirements. This includes disclosures to legal, regulatory, governmental, tax and law enforcement authorities.
3.6 Our Sites may have the functionalities to allow you to share your personal data with other third parties such as other users of our Sites. You are responsible for your choice(s) and are deemed to have provided consent for any sharing of your personal data in the manner provided by the Site.
3.7 You fully understand and consent that we may transfer your personal data to any location outside of Singapore for the purposes set out in this paragraph 3. When transferring your personal data outside of Singapore we will protect your personal data to a standard comparable to the protection accorded to your personal data under the Singapore Personal Data Protection Act 2012 by ensuring that the recipient is either in a jurisdiction which has comparable data protection laws, or ensuring that the recipient is contractually bound to protect your personal data with such reasonable security arrangements as required under the Singapore Personal Data Protection Act 2012.
4. Third Parties
4.1 This Policy only applies to our Sites and information that we collect from you. Our Sites may contain links to other websites which are not owned or maintained by us. When visiting these third party websites or disclosing your personal data to third parties, you should read their privacy policies, or ask relevant questions before you disclose your personal data. We are not responsible for the collection, use or disclosure of your personal data by such third parties.
5. Social Networks
5.1 Our Sites and web-based applications may provide you with social plug-ins from various social networks (such as Facebook, Instagram, Pinterest and Twitter). If you choose to interact with a social network, your activity on our Sites or via our web-based applications will also be made available to these social networks.
5.2 If you are logged in on one of the social networks during the visit of one of our Sites or web-based applications, the social network might add this information to your profile. If you are interacting with one of the social plug-ins, this information will be transferred to the social network. In case you do not wish such a data transfer, please log off on your social network before you enter one of our Sites or web-based applications.
5.3 We cannot influence this data collection and data transfer via the social plug-ins. Please read the privacy policies of those social networks for detailed information about the collection and transfer of personal data, what rights you have and how you can achieve satisfactory privacy settings.
6. Geo-location Services
6.1 Our Sites, mobile and web-based applications may offer location-enabled services, such as Google Maps and Bing Maps. If you use those mobile or web-based applications, they may receive information about your actual location (such as GPS signals sent by a mobile device) or information that can be used to approximate a location. You are always asked if the geo-location service can be activated and you can also object to this geo-location service within the respective mobile or web-based application.
7. Web analytics by Google Analytics
7.1 Our Sites, mobile and web-based applications may contain web analytic services provided by Google Analytics. This means that when you visit our Sites or use any mobile or web-based applications, a cookie will be stored on your computer or mobile device, except when your browser settings do not allow for such cookies.
7.2 This further means that when you visit our Sites or use any mobile or web-based applications, the personal data described above in paragraph 1.1 – including the “click-stream data”, the data from “web beacons and tracking links” and information stored in Google Analytics’ cookies – will be sent to Google Analytics for analysis for and on behalf of us.
8. Retargeting Technologies
8.1 Our Sites and web-based applications may use retargeting technologies within the internet. This enables us to show our visitors, who were already interested in our services, advertisements from us on partner websites.
8.2 We also work with other companies who use tracking technologies to serve advertisements on our behalf across the Internet. These companies may collect non-personally identifiable information about your visits to our Sites or web-based applications and your interaction with our communications, including advertising.
8.3 Retargeting technologies analyse your cookies and display advertisement based on your past surfing behaviour. For further information on cookies, please refer to paragraph 1 of this Policy.
8.4 We do not store any personal data about you with this technology.
9.1 The security of your information is important to us. We have in place reasonable and appropriate safeguards required by law to protect the information stored with us. We endeavour to take precautions to ensure that the information you have provided is protected against unauthorised or unintended use, access or disclosure. However, we cannot be held responsible for unauthorised or unintended use, access or disclosure that is beyond our control.
10.1 To the maximum extent permitted by law, we shall not be liable in any event for any special, exemplary, punitive, indirect, incidental or consequential damages of any kind or for any loss of reputation or goodwill, whether based in contract, tort (including negligence), equity, strict liability, statute or otherwise, suffered as a result of unauthorised or unintended use, access or disclosure of your personal data.
11. Changes to this Policy
11.1 We may amend this Policy from time to time. The amended Policy will be publicised on our Sites. All communications, transactions and dealings with us shall be subject to the latest version of this Policy in force at the time.
12. Withdrawal of Consent
12.2 Do note that if you withdraw your consent to any or all of the purposes, SG Enable and its affiliates may not be in a position to continue to provide our services to you.
13. How to Contact Us
13.1 To contact us on any queries or on any aspect of this policy or your personal data or to provide any feedback, you may contact us at PDPA@sgenable.sg.
14. Governing Law
14.1 This Policy is governed by the laws of Singapore. You agree to submit to the exclusive jurisdiction of the Courts of Singapore in any dispute relating to this Policy.