5. The purposes for which we collect, use or disclose your personal data
5.1. SingPost and the SingPost Group of companies, will/may collect, use, disclose and/or process your personal data for one or more of the following purposes:
(a) processing facilitating and/or dealing with your interest in our products and/or services;
(b) considering, processing, facilitating (including carrying out risk or fraud analysis), dealing with and/or managing, your booking, reservation, request/application for, of or your purchase of, our products and/or services (the "Transaction");
(c) facilitating, processing, dealing with, administering and/or managing Transaction(s) by or with you;
(d) administering, facilitating, managing, processing and/or dealing with your relationship with us, your transaction(s) with us, your being our loyalty card member or rewards member, any transactions or activities carried out by you on the Website or at our premises/establishments or with us, your requests, including but not limited to dealing with your ad hoc queries, requests or bookings, dealing with your preferences, dealing with your membership needs, dealing with your delivery needs, processing orders and payment transactions, implementing transactions and the supply of products and/or services to you that you have requested. Without limiting the generality of the foregoing, should you make a reservation or transaction that includes third party individual(s) or on behalf of third party individual(s) or for third party individual(s), you consent to us disclosing personal data that identifies you, to the said third party individual(s) (such as but not limited to your name);
(e) administering, facilitating, processing and/or dealing in any matters relating to your use or access of the Website, including identifying you for login to the Website, our portals and other online services provided by or on behalf of us. Without limiting the generality of the foregoing, if you:
(i) gain access to or sign in to the Website, using your login credentials of a Social Networking Site, or
(ii) use any features of a Social Networking Site such as its widgets, plug-ins and browser push notifications, made available to you on our Website, it may result in information or your personal data being collected or shared between us and the third party. For example, if you use Facebook's "Like" feature, Facebook may register the fact that you "liked" a product and may post that information on Facebook. ("Social Networking Site" refers to an online or digital platform owned or operated by a third party, that is used by people to build social networks or social relations, or to interact, with other people, such as but not limited to Facebook, Instagram, Twitter). By your proceeding pursuant to (i) or (ii) above, you consent to such collection, use or disclosure of your personal data;
(f) monitoring, processing and/or tracking your use of the Website in order to provide you with a seamless experience, facilitating or administering your use of the Website, and/or to assist us in improving your experience in using the Website;
(g) administering, facilitating, processing and/or dealing in any transactions, payments, debt collection, or activities carried out by you on the Website or at our premises or with us;
(h) providing services to you as our customer, as a member of our loyalty programme(s)/ card programme(s)/ rewards programme(s) or when requested by you; dealing with or administering your participation in contests, gamification, social events organised by us;
(i) registering you as a customer of any of our products or services, and/or to deal with, process and/or administer the account that you may open with us, whether a membership account or otherwise, including to facilitate your transactions or activities at our premises, the Website, or your transactions or activities with us;
(j) carrying out your instructions or responding to any enquiry or complaint given by (or purported to be given by) you or on your behalf including responding to your enquiries and complaints; or responding to or dealing with your interactions with us or your requests; or responding to or dealing with your feedback, comments or reviews. If you have contacted us with any complaints, feedback, comments, suggestions, we will use and disclose your personal data (including your contact history) to respond to you and provide you with the best service possible. If you are the complainant and you do not want us to disclose your identity to the party you are complaining about, you must let us know immediately. However, it may not always be possible to handle your complaint on the basis of anonymity;
(k) contacting you or communicating with you via phone/voice call, text message and/or fax message, email and/or postal mail for one or more of the Purposes stated herein. You acknowledge and agree that such communication by us could be by way of the mailing of correspondence, documents or notices to you, which could involve disclosure of certain personal data about you to bring about delivery of the same as well as on the external cover of envelopes/mail packages;
(l) sharing or disclosing (at our discretion) your suggestions, comments, feedback or content (including audio, video etc.) (collectively "Feedback") that you provide through Social Networking Sites, to the Website or to us (including at our premises), with other users of the Website or with the public, for publicity and/or promotion purposes with a view to marketing or showcasing the business, products or services of any SingPost Group Company, and/or to acquiring customers, and/or for the purpose of providing the public with your Feedback which may be useful for the public's patronage decision or for the public's information or otherwise. This includes us disclosing your name together with your Feedback. Without limiting the generality of the foregoing, in the above regard, your Feedback and name may/will be published or shared by us on public media platforms such as the newspaper, the Internet, in our (including our affiliates') annual reports (if any) etc., and/or incorporated as part of SingPost Group Company's marketing collaterals/materials or corporate video to be disclosed to the public, and you hereby consent to the same. Do not provide us with Feedback if you do not wish for such Feedback to be disclosed to the public. If you wish to give us your Feedback without it being disclosed to the public, please separately contact our Customer Department at https://www.singpost.com/contact-us and head the subject of your feedback content with the word "Confidential";
(m) understanding and/or managing your interests, concerns and preferences;
(n) carrying out due diligence, statutorily required activities or other screening activities (including background checks, anti-money laundering checks, know your client checks) in accordance with legal or regulatory obligations applicable to us or any SingPost Group Company, the requirements or guidelines of governmental authorities which we determine are applicable to us (whether Singapore or other countries) or any SingPost Group Company and/or our risk management procedures that may be required by law (whether Singapore or other countries) or that may have been put in place by us or our affiliates/associated companies;
(o) to prevent or investigate any fraud, unlawful activity or omission or misconduct, whether or not there is any suspicion of the aforementioned; dealing with conflict of interests; or dealing with and/or investigating complaints;
(p) complying with or as required by any applicable law, governmental or regulatory requirements of any jurisdiction applicable to us or our affiliates/associated companies, including meeting the requirements to make disclosure under the requirements of any law binding on us or our affiliates/associated companies, and/or for the purposes of any guidelines issued by regulatory or other authorities (whether of Singapore or other countries), with which we or our affiliates/associated companies are expected to comply;
(q) complying with or as required by any request or direction of any governmental authority (whether Singapore or other countries) which we or any SingPost Group Company are expected to comply with; or responding to requests for information from public agencies, ministries, statutory boards or other similar authorities. For the avoidance of doubt, this means that we may/will disclose your personal data to the aforementioned parties upon their request or direction;
(r) conducting research, (including customer research), surveys, market surveys, analysis and development activities (including but not limited to data analytics, and/or profiling), obtaining your feedback to our products, services or facilities, to:
(i) improve or develop our products, services and/or facilities in order to enhance any continued interaction between yourself and us connected or in relation to your relationship with us, the Website, or your Transaction(s);
(ii) improve any of our products or services or facilities, whether now or in the future; or
(iii) improve our understanding of your interests, concerns and preferences.
Without limiting the generality of the foregoing, we may/will in this regard send you surveys or request a face to face interview survey or request your feedback, by way of email or postal mail.
In order for us to market products and services which are of special interest and relevance to you, we may analyse and rely on your overall interaction with us (such as but not limited to your shopping behaviour in e-shops, your use of loyalty programmes, your ratings and reviews of products, your contact history with our customer service, your newsletter clicks/ opening results, your surfing behaviour (web tracking), the newsletter types you are subscribed to, your participation in promotions or events, your interactions with us and your use of (mobile) applications);
(s) the conduct of training or training purpose, so as to develop or improve our products or services and/or our staff's and agents' services and/or service quality. Without limiting the generality of the foregoing, such training may involve collection, use, disclosure or processing of your personal data including your feedback or comments or reviews;
(t) to facilitate and/or ensure the safety and security of our premises, our customers, our staff and/or visitors to our premises; to deal with, handle and/or conduct disciplinary, security, crime prevention and/or quality assurance processes, matters and/or arrangements. Without prejudice to the generality of the aforesaid, we wish to bring to your attention that there are surveillance cameras installed throughout our premises and/or our offices, for security, crime prevention, safety and training reasons and you acknowledge that your personal data will be collected by such cameras and processed by us consequently;
(u) for marketing purpose where you have provided your consent to us for the same, and with such consent, we may/would be providing you with marketing, advertising and promotional information, materials and/or documents relating to products, services and/or events (including products, services and/or events of third party organisations with which we may collaborate with) that we or such third party organisations may be selling, marketing, offering, organizing, involved in or promoting, whether such products, services and/or events exist now or are created in the future;
(v) storing, hosting, backing up (whether for disaster recovery or otherwise) of your personal data, whether within or outside Singapore;
(w) maintaining and/or developing our IT or business systems and infrastructure including testing and upgrading of these systems;
(x) creating reports with respect to your Transaction(s) and/or transactions that we have with our customers;
(y) facilitating, dealing with and/or administering external audit(s) or internal audit(s) of the business of SingPost and/or of the SingPost Group, Transaction(s), and/or our transactions with our customers;
(z) anonymisation of your personal data. In this regard, you acknowledge that personal data that has been anonymised is no longer personal data and the requirements of Applicable Data Protection Law would no longer apply to such anonymised data;
(aa) dealing with and/or facilitating a business asset transaction or a potential business asset transaction, where such transaction involves SingPost as a participant or involves only a related corporation or affiliated company of SingPost as a participant or involves SingPost and/or any one or more of SingPost's related corporations or affiliated companies as participant(s), and there may be other third party organisations who are participants in such transaction. "business asset transaction" means the purchase, sale, lease, merger or amalgamation or any other acquisition, disposal or financing of an organisation or a portion of an organisation or of any of the business or assets of an organisation;
(bb) record-keeping purposes and producing statistics and research for internal and/or statutory reporting and/or record-keeping requirements, of any SingPost Group Company;
(cc) Any SingPost Group Company's reporting purposes including but not limited to reporting on the SingPost Group Company's business performance; and
(dd) to deal with the or as part of a bankruptcy, winding up, reorganisation, restructuring, insolvency, receivership or an assignment for the benefit of creditors, of any SingPost Group Company.
(The purposes set out in this paragraph 5.1 above shall be collectively referred to as the "Purposes").
5.2. You may withdraw your consent for us to process your personal data for marketing purpose mentioned at paragraph 5.1(u) above at any time via one the following relevant methods:
(a) clicking the Unsubscribe button located at the bottom of our emailers; or
(b) contacting us or our Data Protection Officer through the contact details below.
5.3. We may/will need to disclose your personal data to third parties, whether located within or outside Your Jurisdiction, for one or more of the above Purposes, as such third parties, 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 Your Jurisdiction) 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 one or more of the above Purposes. Without limiting the generality of the foregoing or of paragraph 5.1, such third parties include:
(a) our associated or affiliated organisations or related corporations, or any SingPost Group Company;
(b) any of our agents, contractors or third party service providers that process or will be processing your personal data on our behalf including but not limited to those which provide administrative or other services to us such as mailing houses, telecommunication companies, information technology companies, data centres, hosting and maintenance service providers, analysis services service providers, e-mail messaging services service providers, delivery service provider, handling of payment transactions service providers, marketing service providers, delivery services, handling of payment transactions and debt collection, solvency check and address check;
(c) our professional advisers, for example, our auditors and lawyers, as well as our insurers;
(d) third parties to whom disclosure by us is for one or more of the Purposes and such third parties would in turn be collecting and processing your personal data for one or more of the Purposes. Without limiting the generality of the foregoing, such third parties to which we may/will disclose your personal data include payment, debt collection, finance companies or banks including credit card companies; and
(e) any actual or proposed assignee or transferee of the business of any SingPost Group Company, or a merged entity in the event any SingPost Group Company is merged to create the said merged entity.
5.4. We may share your information with any SingPost Group Company, which may be based in territories outside Your Jurisdiction, from time to time for one or more of the Purposes.
5.5. Should you provide us with personal data of your child or children, you confirm, declare and agree that you are the parent and/or legal guardian of such child/children, and that we may collect, use and/or disclose your child's or children's personal data for the Purposes set out at paragraph 5.1 above and in the manner as set out at paragraphs 5.1 to 5.4 above.
5.6. You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control by submitting your withdrawal request at www.singpost.com/contact-us/data-protection. We will process your request within a reasonable time from such a request for withdrawal of consent being made, and will thereafter not collect, use and/or disclose your personal data in the manner stated in your request, unless an exception under the law or a provision in the law permits us to. However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal, including us being unable to perform the transactions requested by you or the termination of your relationship with us (depending on the extent of your withdrawal), as the case may be.
5.7. We may collect, use, disclose or process your personal data for other purposes that do not appear above. We will do so in compliance with Applicable Data Protection Law.
5.8. To the extent permitted by applicable law, we may/will also be collecting from sources other than yourself, personal data about you, for one or more of the above Purposes, and thereafter using, disclosing and/or processing such personal data for one or more of the above Purposes. We may combine information we receive from other sources with information you give to us and information we collect about you. We may use this information and the combined information for the Purposes set out above (depending on the types of information we receive).
5.9. Our Website may have the functionalities to allow you to share your personal data with other third parties such as other users of our website. You are responsible for your choice(s) and are deemed to have provided consent for any sharing of your personal data in the manner provided by the Website.
5.10. We take reasonable steps to ensure that any personal data we collect, disclose and use is accurate and complete, if your personal data is likely to be used by us to make a decision that affects you, or disclosed to another organisation. However, it is important that you advise us of any changes to your personal data or if there are any errors in the personal data we hold about you. We will not be responsible for relying on inaccurate or incomplete personal data arising from you not updating us of any changes in your personal data that you had initially provided us with.