- What does this Policy Cover?
This policy sets out the principles for collecting, using, disclosing, retaining and removing personal data and describes other important topics relating to an individual’s privacy, with the aim of complying with the requirements of the Personal Data Protection Act 2012 (“PDPA”) and respects your choices in respect of your personal data.
By using the PLAYe app and/or website, or by providing personal data to us, you agree to the collection, use and disclosure of your personal data in the manner described in this policy.
In addition, if you have registered your telephone number with the national Do Not Call (“DNC”) registry, we will not send you promotional and marketing messages via your telephone number unless you have provided us with the consent to do so.
- Collection, Use and Storage of Personal Data
The type of personal data that we may collect from individuals includes the following:
- name, title, address;
- personal identification and/or passport number;
- telephone number;
- email address and online passwords;
- records of communications with us (including but not limited to voice and text messages);
- credit card or debit card information;
- website usage information.
We only collect, use and disclose personal data with an individual’s consent or deemed consent or as otherwise permitted under the PDPA or other applicable laws and regulations.
Personal Data will, generally, only be collected and used for the primary purposes of:
- conducting, improving, maintaining and developing a business relationship.
- processing, servicing or enforcing transactions and sending related communications;
- identification and verification purposes in connection with any of the services or products that may be supplied to individuals;
- responding to individual’s queries;
- marketing (such as providing individuals with information about our products and promotional notices and offers); and
- improving the PLAYe website.
We take reasonable steps to ensure the individual is aware of:
- the likely use of the information;
- the means of requesting us on the provision of personal data that is in our possession;
- the means of withdrawing any consent in respect of the collection, use or disclosure of the personal data that is in our possession;
- the identity and contact details of the organisation;
- any law requiring collection of the information; and
- the main consequences of failure to provide the information.
- How will we disclose your Personal Data?
We disclose personal data:
- for the primary purpose for which it was collected; or
- for purposes that a reasonable person will consider appropriate in the circumstances; or
- where the individual has consented; or
- for direct marketing by us where consent has been given but giving individuals the opportunity to opt out of such direct marketing. We include our contact details in any direct marketing; or
- where permitted under the PDPA or other applicable law or if required by law.
We do not disclose your personal data for any secondary purposes unless your consent has been given or if so permitted or required under the PDPA or other applicable laws and regulations.
We will not sell or license any personal data that we collect from an individual.
There may be other situations where we may collect and use personal data, which are outside a person’s reasonable expectation. When this occurs, we are committed to providing the individual with an explanation for the possible use of the personal data when asking for the individual’s consent.
- Accuracy and Correction of Personal Data
We take steps to ensure information is accurate and up-to-date by updating our records whenever changes to information come to our attention. We disregard information which seems, on a reasonable basis, to be inaccurate or out of date by reason of the time which has elapsed since it was collected or by reason of any other information in our possession.
If an individual has submitted personal data to us electronically or otherwise, and would like it corrected, then an email request should be sent to firstname.lastname@example.org. We will comply with an individual’s request to correct their personal data as soon as practicable. We reserve the right to disagree with any request to correct an individual’s personal data on reasonable grounds.
- Withdrawal of Consent
An individual may withdraw his consent for the collection, use or disclosure of personal data by giving us reasonable notice by sending an email request to email@example.com. We shall inform the individual of the likely consequences of the withdrawal of the consent. We will cease to collect, use or disclose the personal data upon such withdrawal unless otherwise permitted or required by the PDPA or other applicable laws and regulations.
- Using our Website
As with most websites, when you visit the PLAYe website or use an application on the PLAYe website, we may record anonymous information such as IP address (where not used to identify a specific individual), time, date, referring URL, pages accessed and documents downloaded, type of browser and operating system.
We also use “cookies”. A cookie is a small file that stays on your computer until, depending on whether it is a sessional or persistent cookie, you turn your computer off or it expires. Cookies may collect and store your personal data. You may adjust your internet browser to disable cookies. If cookies are disabled you may still use the PLAYe website, but may be limited in the use of some of the features.
- Security of your Personal Data
We will take reasonable steps to ensure that personal data is securely stored. We protect personal data from misuse or loss by restricting access to the information in electronic format and by appropriate physical and communications security. Any data destroyed is disposed of in a manner that protects the privacy of personal data in an appropriate manner.
- Dealing with Unsolicited Information
We take all reasonable steps to ensure that all unsolicited information is destroyed immediately.
- Access to Personal Data
If an individual wishes to be provided with information regarding their Personal Data that is in our possession or under our control, or the ways in which such Personal Data has been used or disclosed by us in the year preceding such request, then that person needs to send a written request by email to firstname.lastname@example.org. We will handle such requests as soon as reasonably possible in accordance with the PDPA.
- Anonymity when dealing with us
We allow individuals the option not to identify themselves when dealing with us, where practicable, without affecting the level of service that we are able to provide to the individuals.
- Cross Border Disclosure
Any personal data provided to us may be transferred to, stored by or disclosed to an overseas recipient. For example, we may use a server hosted overseas to store data, which may include your personal data. Your personal data may also be processed by our employees operating outside of Singapore.
We will take reasonable steps, in the circumstances, before your personal data is disclosed to an overseas recipient, to ensure that the overseas recipient provide a standard of protection to personal data so transferred that is comparable to the protection under the PDPA.
- Sensitive Information
- Further Information
Updated 27 July 2015