8TRAORDINARY’S DATA PROTECTION POLICY

PLEASE READ THESE TERMS CAREFULLY AS THEY MAY HAVE IMPORTANT CONSEQUENCES FOR YOU.

ABOUT THESE TERMS & CONDITIONS

This is 8traordinary’s data protection policy for all the users of our website.

The purpose of this document (the “Data Protection Policy”) is to inform you of how we manage Personal Data which is subject to Singapore’s Personal Data Protection Act 2012 (No. 26 of 2012) as may be changed from time to time (the “Act”). Please read this Data Protection Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data.

By interacting with us, or submitting information to us, you agree and consent to 8traordinary, as well as our respective representatives and/or agents collecting, using, disclosing and sharing amongst ourselves your Personal Data, and disclosing such Personal Data to the Companies’ authorised service providers and relevant third parties in the manner set forth in this Data Protection Policy.

This Data Protection Policy supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your Personal Data, and your consents herein are additional to any rights which any of the Companies may have at law to collect, use or disclose your Personal Data.

We strongly believe in protecting your Personal Data. We will ensure that all reasonable security arrangements are in place to prevent any unauthorized access, collection, use, disclosure, copying modification or disposal of your Personal Data. Where necessary, we will require any person to whom we provide your Personal Data to agree to comply with our Data Protection Policy. While we will use all reasonable efforts to ensure that such persons comply with our Data Protection Policy, we will not be liable to you if any person fails to do so.

As part of our efforts to ensure that we properly manage, protect and process your Personal Data, we may from time to time update this Data Protection Policy to ensure that this Data Protection Policy is consistent with future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to any rights that you may have at law, you agree to be bound by the prevailing terms of the Data Protection Policy as updated from time to time on our website. Please ensure that you visit our website regularly to obtain updated information on the handling of your Personal Data.

PERSONAL DATA

  1. 1.1  In this Data Protection Policy, personal data refers to any data, whether true or not, about an individual 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, including data in our records as may be updated from time to time (“Personal Data”).

  2. 1.2  Personal Data that you may provide to us include (depending on the nature of your interaction with us), amongst others, your name, NRIC, passport or other identification number or information, telephone number(s), mailing address, email address, geographical location, network data, computer network, device identifiers or information and any other information relating to any individual which you have provided us in any form submitted to us, or via other forms of interaction with you.

COLLECTION OF PERSONAL DATA

2.1 Generally, we collect Personal Data in the following ways:-

  1. 2.1.1  when you submit an application form or other forms relating to any of the Products and Services;

  2. 2.1.2  when you interact with our staff, for example, via telephone calls, letters, face-to-face meetings, emails or social media;

  3. 2.1.3  when you use some of our Services, for example, websites and apps including establishing any online accounts with us;

  4. 2.1.4  when you purchase or obtain third party services through us (if any);

  5. 2.1.5  when you request that we contact you, be included in an email or other mailing list;

  6. 2.1.6  when you respond to our promotions, initiatives or to any request for additional Personal Data;

  7. 2.1.7  when you are contacted by, and respond to, our marketing representatives and customer service officers;

  8. 2.1.8  when we receive references from business partners and third parties (e.g. where you have been referred by them);

  9. 2.1.9  when we seek information from third parties about you in connection with the Products and/or Services you have applied for; and

  10. 2.1.10  when you submit your Personal Data to us for any other reasons, including when you sign up for a free trial of any of the Products and Services or when you express your interest in any of the Products and Services.

  11. 2.2  If you provide us with any Personal Data relating to a third party (e.g. information of your spouse, children, parents, and/or employees), by submitting such information to us, you represent to us that you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes set out in this Data Protection Policy.

  12. 2.3  You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with the Products and Services you have requested.


PURPOSES FOR THE COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL DATA

This Clause describes the purposes for which we collect, use and disclose your Personal Data. 3.1 Generally, we collect, use and disclose your Personal Data for the following purposes:-

  1. 3.1.1  to respond to your queries and requests;

  2. 3.1.2  to manage our administrative and business operations and complying with internal policies and procedures;

  3. 3.1.3  to facilitate business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving any of the Companies;

  4. 3.1.4  to match any Personal Data held which relates to you for any of the purposes listed in this Data Protection Policy;

  5. 3.1.5  to resolve complaints and handle requests and enquiries;

  6. 3.1.6  to prevent, detect and investigate crime and analyse and manage any commercial risks;

  7. 3.1.7  to provide media announcements and responses;

  8. 3.1.8  legal purposes (including but not limited to obtaining legal advice and dispute resolution);

  9. 3.1.9  to conduct investigations relating to disputes, billing, suspected illegal activities or fraud;

  10. 3.1.10  to meet or comply with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on us (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies and conducting audit checks, due diligence and investigations); and

    3.1.11 purposes which are reasonably related to any of the above purposes in this Clause 3.1 or for any other purpose which we may notify you at the time of obtaining your consent.

DISCLOSURE OF PERSONAL DATA

This Clause describes how your Personal Data may be disclosed by us.

  1. 4.1 You understand that the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our websites, online Services and apps; any transmission is at your own risk. Additionally, we cannot assume responsibility for any unauthorised use of your Personal Data by third parties which are wholly attributable to factors beyond our control.

If such disclosure involves transfer of your Personal Data outside Singapore, a standard of protection that is comparable to that under this Data Protection Policy shall be provided.

USE OF COOKIES

This Clause describes the use of cookies on our websites.

We use cookies3 on our websites for the following purposes:-

4.1.1 to enable certain features and functions on our websites (e.g. browsing preferences);

4.1.2 to build up a profile of how you and other users use our websites and/or other third party websites;

4.1.3 to improve the efficiency of our websites;

4.1.4 to administer Services to you;

4.1.5 to establish usage statistics;

4.1.6 to enable authentication cookies to identify you when you perform online interactions with us; and

4.1.7 to enable you to share our content easily on social networks.

Most internet browsers provide you the option of turning off the processing of cookies (please see the “help” section of your browser), but this may result in the loss of functionality, restrict your use of our websites and/or delay or affect the way in which our websites operate.

If there are advertisements on our websites, they may be provided by third party advertisers and their agencies. These may generate cookies to track how many people have seen a particular advertisement (or use the services of third parties to view a particular advertisement), and to track how many people have seen it more than once.

8traordinary is not responsible for the Personal Data policies (including Personal Data protection and cookies), content or security of any third party websites linked to our websites.

WITHDRAWAL OF CONSENT, ACCESS AND CORRECTION OF YOUR PERSONAL DATA

This Clause describes how you can withdraw your consent or obtain access and make corrections to the Personal Data that you have provided us.

  1. 5.1  If you would like to withdraw your consent to any use of your Personal Data as set out in this Data Protection Policy, you may email us to do so.

    5.2  Please be aware that once we receive confirmation that you wish to withdraw your consent for marketing or promotional materials/communication, it may take up to 14 working days for your withdrawal to be reflected in our systems. In the meantime, you may still receive marketing or promotional materials/communication from us. Please note that even if you withdraw your consent for the receipt of marketing or promotional materials, we may still contact you for other purposes in relation to the Products and Services that you hold or have subscribed to with us.

  2. 5.3  If you would like to obtain access and make corrections to your Personal Data records, please contact us in writing as follows:-

    Data Protection Officer

    8traordinary Pte Ltd
    2 Eu Tong Sen Street, Soho 2 @ Central, #06-165, Singapore 059819

    or through email at [email protected]

  3. 5.4  Please note that if your Personal Data has been provided to us by a third party (e.g. a referrer), you should contact that organisation or individual to make such queries, complaints, and access and correction requests to us on your behalf.

     

GOVERNING LAW

This Data Protection Policy and your use of this website is governed by Singapore law.