This Policy applies to personal data in our possession or under our control, including personal data in the possession of organizations which we have engaged to collect, use, disclose or process personal data for our purposes.
By submitting your information to us, or signing up for any products and/or services offered by us, you agree and consent to us, collecting, using, processing and/or disclosing your personal data in the manner set out in this Policy. If you are providing us personal data of another individual, then it is deemed that you have the authority of that other individual to do so and that such other individual consents to our collection, use, processing and disclosure of such personal data in accordance with this Policy. You may choose not to provide us with any personal data but should do so with the understanding that this may affect our ability and efficiency to provide you with the required services, and also our ability to comply with legal obligations applicable to us. You acknowledge and agree that this Policy may be amended and varied by us from time to time to be consistent with developments, industry trends as well as any changes to our legal rights or obligations.
- As used in this Policy:“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.
- 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 and/or passport 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, and other personal information required to be processed in connection with the services provided by us to an individual personally.
COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
- Generally, your personal data is collected in one or more of the following ways :-
- when you submit forms or register online for or relating to or use/purchase any of our products or services;
- when you enter into agreement or provide information through any other transaction with us for any of our products or services;
- when you interact with any of our staff or officers in any manner whatsoever;
- when you respond to any of our promotions, market surveys or contests, lucky draws or events or our request for additional personal data or other initiatives;
- when your image is captured by us via CCTV cameras while you are within any of our premises or events or via photographs or videos taken by us or our representatives when you attend any of our events;
- when we receive references from any of our Third Party Providers (as defined below); and/or
- when you request us to contact you or submit your personal data to us for any other reason.
- 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;
- responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
- to communicate with you and manage your relationship with us;
- processing payment or credit information or transactions;
- sending you marketing, advertising or promotional information about our or our Third Party Providers’ goods or services including notifying you of events, initiatives and promotions, lucky draws, membership and rewards schemes and other promotions. These may be through SMS/MMS/instant messaging, email, telephone calls and/or through social media platforms from us or our Third Party Providers;
- conducting research, surveys, analysis and development activities in order to improve the products and services we offer to you, as well as to improve the overall customer experience and our marketing programmes;
- storing, hosting, backing-up of your personal data and otherwise managing and ensuring the security of our business systems;
- 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;
- to protect and enforce our contractual rights and obligations, and generally meeting our legal obligations as well as to safeguard our legal rights and interests;
- for our internal administration purposes including to manage and improve our services to, and relationship with, you and our clients;
- transmitting to any unaffiliated third parties including our Third Party Providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes;
- any other purposes for which you have provided the information; and
- any other incidental business purposes related to or in connection with the above.
- Your personal data will be protected and kept confidential. However, we work with external parties (including those who may be located outside of Singapore) to provide you with a seamless experience in relation to products and services that you purchase from us. We may be required to disclose your personal data to such external parties for one or more of the purposes stated above, in the course of and in order for us to provide services or deliver products to you. These external parties include our respective representatives (including our legal or financial advisers), agents, third party service providers, contractors and other business partners or collaborators (including without limitation our sponsors or government agencies or bodies) (together referred to as “Third Party Providers”). We will do so in accordance with the law and take steps so that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA. We may also be required to disclose your personal data in compliance with applicable laws, and we also draw your attention to the exceptions in the PDPA where personal data may be collected, used and disclosed without your consent.
- We may use data collection devices such as “cookies” on our websites. This helps us analyse and measure the promotional effectiveness of our websites, and help us provide you information that is targeted to your interests. “Cookies” are small files placed on your device that assist us in providing our services. Most are “session cookies” which will automatically be deleted from your hard drive at the end of a session. However, some are necessary cookies required for the operation of our site. If your browser permits, you may decline our cookies although this may mean that you may not be able to fully utilise certain features on our websites and you may be required to enter your passwords more frequently during your session on our websites. We are not responsible for the privacy practices of any third party sites that are or may be linked to our website. You should check the privacy policies of these third parties independently.
- 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
- 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.
- Upon receipt of your written request to withdraw your consent, we will process your request within a reasonable time (depending on the complexity of the request and its impact on our relationship with you) and notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us (if any).
- 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.
- 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.
- Where you have consented to receiving marketing information from our Third Party Providers, if you change your mind, you will have to contact and notify the relevant Third Party Provider to do so
WITHDRAWING YOUR CONSENT ACCESS TO AND CORRECTION OF PERSONAL DATA
- 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.
- 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.
- 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
- We will put in place reasonable security precautions to ensure that your personal data is adequately protected from misuse, loss, unauthorized access, modification or disclosure. However, we will not be responsible for any unauthorized use of your personal data by third parties which are attributable to reasons beyond our control.
- 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
- We generally rely on personal data provided by you (or your authorized 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 held responsible for acting on inaccurate or incorrect personal data arising from you not updating us of any changes to your personal data that had been given to us.
RETENTION OF PERSONAL DATA
- We retain personal data in accordance with our legal, regulatory, business and operations obligations. We do not keep personal data longer than is necessary and we will destroy or anonymize personal data that we no longer require for the purposes stated above.
DATA PROTECTION OFFICER
- 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, as follows :
Attention: [Tuan Hj. Ramli Bin Abdul Rahman]
TERMINAL FERI ANTARABANGSA KUKUP
[Jalan Kukup Laut, Kukup Pontian, Johor 82300, Malaysia]
Tel:- (607)-[696 9098]
Fax :- (607)-[696 9098]
Email :- [firstname.lastname@example.org]
EFFECT OF POLICY AND CHANGES TO POLICY
- This Policy 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.
- We may revise this Policy 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 Policy was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.
- This policy is governed by the laws of Malaysia
Effective date : [01/03/2020]
Last updated : [01/03/2020]