Data Protection Policy for Customers
This Data Protection Notice (“Notice”) sets out
the basis on which BLS International Pte Ltd (“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
- 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.
- 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
name, contact information such as your address, email address or telephone
number, photographs, and other audio-visual information.
- 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
- 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 that has
not been notified to you (except where permitted or authorised by law).
- We may collect and use your
personal data for any or all of the following purposes:
a)
Performing obligations
in the course of or in connection with our provision of the goods and/or
services requested by you;
b)
verifying your identity;
c)
responding to, handling,
and processing queries, requests, applications, complaints, and feedback from
you;
d)
managing your
relationship with us;
e)
processing payment or
credit transactions;
f)
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;
g)
complying with any
applicable laws, regulations, codes of practice, guidelines, or rules, or assisting
in law enforcement and investigations conducted by any governmental and/or
regulatory authority;
h)
any other purposes for
which you have provided the information;
i)
transmitting to any
unaffiliated third parties including our third-party service providers and
agents, and relevant governmental and/or regulatory authorities, whether in
Singapore or abroad, for the purposes; and
j)
any other incidental
business purposes related to or in connection with the above.
- We may disclose your personal
data a) 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
b) to third-party service providers, agents, and other organisations that we have engaged to perform any of the functions listed in clause 5 above for us. 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). - 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 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 the purposes listed above by submitting your request by
completing the Withdrawal of Collection, Use, or Disclosure Request form
and email to our Data Protection Officer at the contact details provided
below.
- 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.
- 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 collecting, using and
disclosing personal data where such collection, use and disclosure without
consent is permitted or required under applicable laws.
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 by
completing the access and/or correction request form and 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 access
request as soon as reasonably possible. Should we not be able to respond
to your access 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 requested by you, we shall inform you
of why we are unable to do so (except where we are not required to do so
under the PDPA).
- We will respond to your
correction request as soon as reasonably possible. Should we not be able
to correct the correction request within ten (10) days after receiving
your request, we will inform you in writing of the time by which we will
be able to correct your correction request. If we are unable 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).
- We will not provide information
under the access requirement for: -
a)
opinion data kept solely
for an evaluative purpose;
b)
any examination,
examination scripts, and, prior to the release of examination results,
examination results;
c)
the personal data of the
beneficiaries of a private trust kept solely for the purpose of administering
the trust;
d)
personal data kept by an
arbitral institution or a mediation centre solely for the purposes of
arbitration or mediation proceedings administered by the arbitral institution
or mediation centre;
e)
documents related to a
prosecution if all proceedings related to the prosecution have not been
completed;
f)
personal data subject to
legal privilege;
g)
personal data which, if
disclosed, would reveal confidential commercial information that could, in the
opinion of a reasonable person, harm the competitive position of the
organisation;
h)
personal Data collected,
used, or disclosed without consent pursuant to the exemptions in the PDPA, for
the purposes of an investigation if the investigation and associated
proceedings and appeals have not been completed;
i)
the personal data was
collected or created by a mediator or arbitrator in the conduct of a mediation
or arbitration for which he was appointed to act –
o
under a collective
agreement under the Industrial Relations Act (Cap. 136) or by agreement between
the parties to the mediation or arbitration;
o
under any written law;
or
o
by a court, arbitral
institution, or mediation centre.
j)
any request: –
o
That would unreasonably
interfere with the operations of the organisation because of the repetitious or
systematic nature of the requests;
o
If the burden or expense
of providing access would be unreasonable to the organisation or
disproportionate to the individual’s interests;
o
For information that
does not exist or cannot be found;
o
For information that is
trivial; and
o
That is otherwise
frivolous or vexatious.
k)
personal data or other
information shall not be provided to an individual if the provision of that
Personal Data or information could reasonably be expected to:
o
Threaten the safety or
physical or mental health of an individual other than the individual who made
the request;
o
Cause immediate or grave
harm to the safety or to the physical or mental health of the individual who
made the request;
o
Reveal Personal Data
about another individual;
o
Reveal the identity of
an individual who has provided Personal Data about another individual and the
individual providing the Personal Data does not consent to the disclosure of
his/her identity or be contrary to the national interest.
l) If Personal Data has been disclosed to a prescribed law
enforcement agency without the consent of the individual or pursuant to the
exemptions in the PDPA, we shall not be required to inform the individual of
such disclosure.
- Correction request will not be
approved in respect of:
a)
opinion data kept solely
for an evaluative purpose;
b)
any examination
conducted by an education institution, examination scripts, and, prior to the
release of examination results, examination results;
c)
the personal data of the
beneficiaries of a private trust kept solely for the purpose of administering
the trust;
d)
personal data kept by an
arbitral institution or a mediation centre solely for the purposes of
arbitration or mediation proceedings administered by the arbitral institution
or mediation centre; or
e)
a document related to a
prosecution if all proceedings related to the prosecution have not been
completed.
Protection of Personal Data
- 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.
- 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 authorised representative). 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 via email at the contact details provided below.
Retention of Personal Data
- We may retain your personal
data for as long as it is necessary to fulfil the purpose of collecting it,
or as required or permitted by applicable laws.
- 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
- 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
- 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:
a)
Download the Withdrawal
of Consent Request form HERE
b) Email to dpo@u-win.com.sg or contact +65 6292 2398.
Effect of Notice and Changes to Notice
- 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.
- 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 acknowledgment
and acceptance of such changes.