At FiiT Pte Ltd, we are committed to ensure the appropriate handling and protection of your personal data and privacy in accordance with Singapore’s Personal Data Protection Act 2012 (the “PDPA”) seriously.
This Data protection Policy is designed to assist you in understanding the way in which we collect, use, disclose and/ or retain your Personal Data you have provided to us, as well as to assist you in making a informed decision before providing us with any of your personal data.
If you have any questions or complaints relating to the use or disclosure of your Personal Data, or if you wish to know more about how we manage, protect and/or process your Personal Data, please do not hesitate to contact our Data Protection Officer (the “DPO”) at:
Data Protection Officer
150 Orchard Road,
Orchard Plaza
#06-01
Singapore 238841
1. INTRODUCTION TO THE PDPA
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 access, including data in our records as may be updated from time to time.
1.2 Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us) your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address, network data and any other information relating to any individuals which you have provided us in any forms you may have submitted to us, or via other forms of interaction with you.
2. PURPOSES FOR COLLECTION, USE, DISCLOSURE AND PROCESSING OF PERSONAL DATA
2.1 The 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) When you submit an application form or other forms relating to any of our Services (defined below);
(b) When you interact with our sales team, for example, via telephone calls, letters, face-to-face meetings and emails;
(c) When you use some of our services, for example, websites and apps including establishing any online accounts with us;
(d) When you request that we contact you, be included in an email or other mailing list;
(e) When you respond to out promotions, initiatives or to any request for additional Personal Data;
(f) When you are contacted by, and respond to, our representatives.
(g) When we receive references from business partners and third parties, for example, where you have been referred by them;
(h) When we seek information from third parties about you in connection with the services you have applied for;
and
(i) when you submit your Personal Data to us for any other reasons.
2.2 When you browse our website, you generally do so anonymously but please see the section below on cookies. We do not at our website automatically collect Personal Data unless you provide such information or login with your account credentials.
2.3 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.
2.4 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.
3 Purposes for the Collection, Use and Disclosure of Your Personal Data
In order to conduct our business operations more smoothly, we may also be disclosing the Personal Data you have provided to us to our third party service providers or our affiliates or related corporations, and/or other third parties whether sited in Singapore or outside of Singapore, for one or more of the above-stated Purposes. Such third party service providers or our affiliates or related corporations, and/or other third parties would be processing your Personal Data either on our behalf or otherwise, for one or more of the above-stated Purposes. Without limiting the generality of the foregoing, such third parties include:
(a) FiiT’s associated or affiliated organizations or related corporations;
(b) any of FiiT’s third party service providers who process your personal data on FiiT’s behalf including but not limited to those which provide administrative or other services to FiiT such as mailing houses, telecommunication companies, information technology companies, data storage or hosting companies, data centres, disaster recovery service providers, banks;
(c) lawyers/law firms, legal process participants and their advisors;
(d) any third party in connection with any proposed or actual reorganization, merger, sale, joint venture, assignment, transfer or other disposition or all or any portion of FiiT’s business or assets and/or
(e) third parties to whom disclosure by FiiT is for one ore 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.
4 SPECIFIC ISSUES FOR THE DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES
4.1 We respect the confidentiality of the Personal Data you have provided to us.
4.2 In that regard, we will not disclose your personal data to third parties without first obtaining your consent permitting us to do so. However, please note that we may disclose your personal data to third parties without first obtaining your consent in certain situations, including, without limitation, the following:
(a) cases in which the disclosure is required or authorized based on the applicable laws and/or regulations;
(b) cases in which the purpose of such disclosure is clearly in your interests, and if consent cannot be obtained in a timely way;
(c) cases in which the disclosure is necessary to respond to an emergency that threatens the life, health or safety of yourself or another individual;
(d) cases in which the disclosure is necessary for any investigation or proceedings;
(e) cases in which the personal data is disclosed to any officer of a prescribed law enforcement agency, upon production of written authorization signed by the head or director of that law enforcement agency or a person of a similar rank, certifying that the personal data is necessary for the purposes of the functions or duties of the officer;
(f) cases in which the disclosure is to a public agency and such disclosure is necessary in the public interest; and/or
(g) where such disclosure without your consent is permitted by the PDPA or by law.
4.3 The instances listed above at paragraph [4.2] are not intended to be exhaustive. For more information on the exceptions, you are encouraged to peruse the Second, Third and Fourth Schedules of the PDPA which is publicly available at http://statutes.agc.gov.sg.
4.4 Where we disclose your personal data to third parties with your consent, we will employ our best efforts to require such third parties to protect your personal data.
5 REQUEST FOR ACCESS AND/OR CORRECTION OF PERSONAL DATA
5.1 You may request to access and/or correct the personal data currently in our possession by submitting your request to Data Protection Officer at
Data Protection Officer
150 Orchard Road,
Orchard Plaza
#06-01
Singapore 238841
5.2 For a request to access personal data, we will provide you with the relevant personal data within a reasonable time from such a request being made.
5.3 For a request to correct personal data, we will:
(a) correct your personal data as soon as practicable after the request has been made unless we have reasonable grounds not to do so; and
(b) subject to paragraph [5.4], we will send the corrected personal data to every other organization to which the personal data was disclosed by FiiT Pte Ltd within a year before the date the correction was made, unless that other organization does not need the corrected personal data for any legal or business purpose.
5.4 Not withstanding paragraph [5.3(b)], we may, if you so consent, send the corrected personal data only to specific organizations to which the personal data was disclosed by us within a year before the date the correction was made.
5.5 We will also be charging you a reasonable fee for the handling and processing of your requests to access and/or correct your personal data.
6. REQUEST TO WITHDRAW CONSENT
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 request to DPO at Data Protection Officer at
150 Orchard Road,
Orchard Plaza
#06-01
Singapore 238841
6.1 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.
6.2 However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal. In this regard, depending on the extent of your withdrawal of consent for us to process your personal data, it may mean that we will not be able to continue with your existing relationship with us.
7. ADMINISTRATION AND MANAGEMENT OF PERSONAL DATA
7.1 We will take reasonable efforts to ensure that your personal data is accurate and complete, if your personal data is likely to be used by FiiT Pte Ltd to make a decision that affects you, or disclosed to another organization. However, this means that you must also update us of any changes in your personal data that you had initially provided us with. We will not be responsible for relying on inaccurate or incomplete personal data arising from your not updating us of any changes in your personal data that you had initially provided us with.
7.2 We will also put in place reasonable security arrangements to ensure that your personal data is adequately protected and secured. Appropriate 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. However, we cannot assume responsibility for any unauthorized use of your personal data by third parties which are wholly attributable to factors beyond our control.
7.3 We will also put in place measures such that your personal data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes.
8. COMPLAINT PROCESS
8.1 If you have any complaint or grievance regarding about how we are handling your personal data or about how we are complying with the PDPA, we welcome you to contact us with your complaint or grievance.
8.2 Please write in to us with your complaint or grievance at:
(a)
150 Orchard Road,
Orchard Plaza
#06-01
Singapore 238841
Attention it to the Data Protection Officer
8.3 Where it is an email or a letter through which you are submitting a complaint, your indication at the subject header that it is a PDPA complaint would assist us in attending to your complaint speedily by passing it on to the relevant staff in our organization to handle. For example, you could insert the subject header as “PDPA Complaint”.
8.4 We will certainly strive to deal with any complaint or grievance that you may have speedily and fairly.
9. UPDATES ON DATA PROTECTION POLICY
9.1 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.
9.2 We reserve the right to amend the terms of this Data Protection Policy at our absolute discretion. Any amended Data Protection Policy will be posted on our website and can be viewed at http://fiit.sg/data-protection-policy/
9.3 You are encouraged to visit the above website from time to time to ensure that you are well informed of our latest policies in relation to personal data protection.
