1.1 The purpose of this policy is to inform you and provide you with an understanding of how we handle, collect, use, disclose and process personal data about you that you give us, that we receive through third parties or that is in our possession.
1.2 By interacting with us, submitting information to us, or signing up for any Products and Services offered by us, you agree and consent to us(including its related corporations and business units), as well as their respective representatives and/or agents collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to the our authorised service providers and relevant third parties in the manner set forth in this policy
2. Personal Data
2.1 “Personal Data” is hereinafter defined as data, whether true or not, about an individual who can be identified from that data or from that data and other information to which the organisation has or is likely to have access.
2.2 Personal Data that you may provide to us include but not limited to (depending on the nature of your interaction with us):
(a) your personal information such as name, NRIC, passport or other identification number or information;
(b) your contact information such as telephone number(s), mailing address, email address;
(c) your billing and payment information, including name of the credit/debit cardholder, credit/debit card number, security code and expiry date;
(d) your transaction history
(e) other information includes credit history, network data, computer network, device identifiers photographs, videos and/or audio recordings taken by us or our representatives at our events 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.
2.3 Generally, we collect your personal data when you:
(a) submit an application form or other forms relating to any of the Products and Services
(b) complete purchase orders, requests or applications for our products or services (by telephone, in person, email or electronically);
(c) sign up for a free trial of any of the Products and Services;
(d) register for an account on the Website or apps;
(e) interact with our customer service officers, for example, via telephone calls, letters, face-to-face meetings, emails or social media)
(f) purchase or obtain third party services through us
(g) enter or interact with us during promotions, competitions, contests, lucky draws or special events;
(h) subscribe to any of our membership programmes;
(i) participate in surveys and other types of research;
(j) conduct certain types of transactions such as refunds;
(k) apply for employment with us;
(l) have been referred by business partners and third parties as our references
2.4 This policy also applies to any personal data we collect via our websites. Cookies may be used on some areas of our website. “Cookies” are small text files placed on your hard drive that assist in providing a more customised website experience. If you are concerned about cookies, most browsers permit individuals to decline cookies. After termination of the visit to our site, you can always delete the cookie from your system if you wish.
2.5 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.
2.6 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.
3. Purposes for Collection, Use, Disclosure and Processing of Personal Data
3.1 personal data which we collect from you may be collected, used, disclosed and/or processed for various purposes, depending on the circumstances for which we may/will need to process your personal data, including:
(a) to communicate with you;
(b) to assess, process and provide products, services, assistant and/or facilities to you;
(c) to respond to your enquiries or complaints and resolve any issues and disputes which may arise in connection with any dealings with us;
(d) to provide you with information and/or updates on our products, services, upcoming promotions offered by us and/or events organised by us and selected third parties which may be of interest to you from time to time;
(e) for direct marketing purposes via SMS, phone call, email, fax, mail, social media and/or any other appropriate communication channels, in accordance with your consent;
(f) analysing your use of the products and services so as to help us improve, review, develop and efficiently manage the products and services offered to you
(g) to facilitate your participation in, and our administration of, any events including contests, promotions or campaigns;
(h) to conduct market research or surveys, internal marketing analysis, customer profiling activities, analysis of customer patterns and choices, planning and statistical and trend analysis in relation to our products and/or services;
(i) to share any of your personal data with our business partners to jointly develop products and/or services or launch marketing campaigns;
(j) for enabling us to perform our obligations and enforce our rights under any agreements or documents that we are a party to;
(k) to maintain and update internal record keeping (which may include data storage and processing servers located overseas);
(l) to establish your identity and background;
(m) to carry out verification and background checks as part of any recruitment and selection process in connection with your application for employment with us
(n) generating internal reports (including but not limited to annual, operational and management reports);
(o) to conduct credit reference checks and establish your creditworthiness, where necessary, when providing you with products, services and/or facilities;
(p) for administrative, audit, risk management and security purposes;
(q) to conduct investigations relating to misconduct, disputes, billing, suspected illegal or inappropriate activities or fraud
(r) to process any payments related to your commercial transactions with us;
(s) to process and issue certificates after the completion of the course(s)/certification programme(s)/qualification(s) that you have registered with us;
(t) to share any of your personal data pursuant to any agreement or document which you have duly entered with us for purposes of seeking legal and/or financial advice and/or for purposes of commencing legal action;
(u) for meeting any applicable legal or regulatory requirements and making disclosure under the requirements of any applicable law, regulation, direction, court order, by-law, guideline, circular or code applicable to us;
3.2 As the purposes for which we may/will collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose(s) at the time of obtaining your consent, unless we are permitted by the PDPA or any other applicable law to process your personal data without your consent.
4. Specific Issues for the Disclosure of Personal Data to Third Parties
4.1 We may disclose your Personal Data to third parties without first obtaining your consent in certain situations, including, without limitation, (whether located within or outside Singapore), for one or more of the above purposes, as such third parties (includes any other party to whom you authorise us to disclose your personal data), would be processing your personal data for one or more of the above purposes. In this regard, you hereby acknowledge, agree and consent that we may/are permitted to disclose your personal data to such third parties (whether located within or outside Singapore) for one or more of the above Purposes and for the said third parties to subsequently collect, use, disclose and/or process your personal data for or more of the above purposes.
4.2 The third parties whom we conduct business are only authorized to use your information to perform the service for which they were hired. As part of our agreement with them, they are required to adhere to the PDPA and any policies that we provide, and to take reasonable measures to ensure your personal data is secure.
5. Request for Access, Correct & Withdrawal of Personal Data
You may request to access and/or correct, and withdrawn your personal data that is in our possession or under our control by writing to us as the information provide below
5.1 For a request to correct personal data, we will:
(a) correct your personal data thirty (30) days (as soon as practicable) after the written request has been made unless we have reasonable grounds not to do so; and
(b) we will send the corrected personal data to every other organisation to which the personal data was disclosed by us within thirty (30) days before the date the correction was made, unless that other organisation does not need the corrected personal data for any legal or business purpose.
(c) you understand that we are reliant on you to provide us with accurate and complete personal data and with updates if there are any changes to your personal data. We will not be responsible for relying or using any inaccurate or incomplete personal data where you have provided with such personal data and/or have failed to update us of any changes in your personal data.
5.2 For a request to access personal data, once we have sufficient information from you to deal with the request, we will seek to provide you with the relevant personal data within reasonable time:
(a) we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request.
(b) 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).
(c) depending on the request that is being made, we will only need to provide you with access to the personal data contained in the documents requested, and not to the entire documents themselves.
(d) we will need enough information from you in order to ascertain your identity as well as the nature of your request, so as to be able to deal with your request. We reserve the right, or may, charge a reasonable fee for the processing of any data access request. Where such a fee is to be imposed, we will provide you with a written estimate of the fee for your consideration. We will only process your request once you have agreed to the payment of the fee.
5.3 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 and effect your request within 30 days of receiving it.
5.4 Your withdrawal of consent may result in certain consequences. For example, it may mean that we will not be able to provide you with certain products or services that you have requested or that we will not be able to continue with your existing relationship with us. We will inform you of such consequences after we receive your request for withdrawal. However, you understand that notwithstanding your withdrawal of consent, we will still be entitled to collect, use or disclose your personal data if we are required or authorised to do so under the PDPA or any other applicable law.
6. Protection and Destruction of Personal Data
6.1 We will take reasonable security arrangements to ensure that your personal data is adequately protected and secured. In particular, reasonable security arrangements will be taken to prevent any unauthorized access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data.
6.2 We will also put in place measures to ensure that any of your personal data that is in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that:
(a) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and
(b) retention is no longer necessary for any other legal or business purposes.
7. Updates on Data Protection Policy
7.1 As part of our efforts to ensure that we properly manage, protect and process your personal data, we will be reviewing our policies, procedures and processes from time to time. No individual notice will be sent to you
7.2 You are deemed to have acknowledged and agreed to any amended version of this Personal Data Protection Policy after the changes have taken place. As such, you are strongly encouraged to check with us from time to time to ensure that you are well informed of our latest policies in relation to personal data protection.
8. Governing Law
8.1 This Data Protection Policy and your use of this website shall be governed by and construed in accordance with the Singapore Law. You have agreed to submit to the exclusive jurisdiction of Courts of Singapore in any dispute relating to this Policy.
9. Complaint and Feedback
9.1 If you have any complaint, grievance or feedback regarding about how we are handling your personal data or about how we are complying with the PDPA, we welcome you to contact us by writing or email to us.
Data Protection Officer
SJ Cosmo Future Pte Ltd
24 Sin Ming Lane , #03-92 Midview City, Singapore 57397
Email Address: email@example.com
Last Updated on 9 Oct 2021