1. PERSONAL DATA
- Personal Data refers to data, whether true or not, about an individual who can be identified from that data, or from that data in combination with other information to which the organisation may have access and includes the meaning otherwise as defined in the Act as amended from time to time.
2. COLLECTION OF YOUR PERSONAL DATA
- Fenlyn collects your Personal Data either directly from you or from your authorised representatives (i.e. persons whom who may have authorised, who have been validly identified as being you or your authorised representative pursuant to our then-current security procedures), from third parties, or from publicly available sources or through our website including, but not limited to, the following ways:
- when you order or purchase products or services from us;
- when you post a feedback or interact with our customer service officers, eg. via letters, posts, messages on our social media pages, meetings, emails or telephone calls (which may be recorded for training, quality control, business and/or other lawful purposes);
- when you use some of our services including establishing any online accounts with us;
- when you request that we contact you, be included in an email or other mailing list;
- when you respond to our promotions, campaigns or other initiatives or attend our events;
- when we receive references from business partners and third parties, for example, where you have been referred by them;
- when you visit our websites;
- when you take part in any contest, survey or promotion conducted by us and/or our business partners;
- during CCTV recordings when you visit our premises or photo taking or video recording at events;
- when we receive information about you from third party social networking services when you choose to connect with those services;
- when you provide or contemplate providing security to us for a transaction;
- when you submit your Personal Data to us for any other reasons; and/or
- when we collect your Personal Data by other lawful means.
- Unless permitted by applicable laws, we will not collect Personal Data without your consent.
- 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.
- You should take due care to ensure that all Personal Data submitted to us are complete, accurate, true and correct at the date of submission. Failure on your part to do so many result in our inability to provide you with the Products and/or Services you have requested.
- You shall consult your parent or guardian before giving us your Personal Data if you are under the age of eighteen.
3. PURPOSES FOR THE COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
- 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 deem fit to process your personal data. This is including, but not limited to:
- to verify and process your personal particulars and payments;
- to provide goods and services to you;
- to respond and deal with enquiries, complaints and other customer-care matters or otherwise communicate with you;
- to monitor or record phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes;
- to manage payment, billing, account, credit checks and debt-recovery matters;
- to send you information, promotions, updates, and marketing and advertising materials in relation to our goods and services and that of our group companies;
- to communicate advertisements involving Fenlyn products, special offers, rewards, either to our customers generally, or which we have identified may be of interest to you (including, but not limited to, upselling, cross selling and online marketing);
- to manage, develop and improve our business and operations to serve you better;
- to carry out marketing promotions and campaigns, contests, lucky draws and corporate social responsibility projects, and personalising your experience at our customer touchpoints;
- to carry out market research and customer surveys;
- to conduct investigations or audits or carry out crime and fraud prevention and risk management activities;
- to comply with legal and regulatory requirements;
- to enforce our legal rights and obligations;
- to facilitate business asset transactions (which may extend to any mergers, acquisitions or asset sales);
- to conduct analytics & tracking;
- to conduct market research and surveys to enable us to understand and serve our Fenlyn customers better, including, but not limited to, understanding preferences, demographics to improve our service delivery and customer experience at our touch points;
- to match Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision, marketing or offering of products by Fenlyn ;
- for other purposes for which we have obtained your consent; and
- for any other purposes reasonably necessary, ancillary or related to the above specified purposes.
- Your Personal Data may be disclosed for the purposes indicated above to our officers and employees, third parties, affiliates, service providers, advisors, which include without limitation, the following persons or entities:
- banks, credit card companies, and payment vendors;
- debt collection agencies;
- credit information companies;
- logistics and courier services companies;
- call centre services providers;
- our business partners and authorised distributors, dealers or resellers;
- relevant government regulators or authorities or law enforcement agencies;
- our insurers and advisors, including consultants, auditors and lawyers;
- data intermediaries; and
- any other party to whom you authorise us to disclose your Personal Data to.
Save for relevant government regulators and authorities or law enforcement agencies, we will ensure that such parties receiving your Personal Data (i) are under duty of confidentiality to us with respect to the use, holding, processing, retention and/or transfer of your Personal Data; and (ii) have the need to know or handle such Personal Data.
- These examples are not exhaustive and you are encouraged to peruse the Second, Third and Fourth Schedules of the PDPA that is publicly available at sso.agc.gov.sg/Act/PDPA2012.
- If you have provided your Singapore telephone numbers, Fenlyn may contact you using such Singapore telephone numbers (including via voice calls, sms, fax or other means) with information about our products or those product and services offered by our preferred partners (including discounts, flash sales and special offers).
- Your Personal Data may be transferred, stored and/or processed in a country or territory outside Singapore and you consent to any such transfer, storage and/or processing of your Personal Data outside Singapore. We will however ensure that any party to whom we transfer your Personal Data outside Singapore provides to such Personal Data a standard of protection at least comparable to the protection under the Act. This includes without limitation ensuring that any party coming into contact with the Personal Data outside Singapore:
- takes all appropriate measures to ensure such compliance by implementing such Data Handling Principles as notified by us to them from time to time and appropriate technical and organisational measures and providing a standard of protection for the Personal Data that is comparable to the protection under the Act; and
- protects the Personal Data by making reasonable security arrangements to prevent unauthorised access, use, disclosure or modification.
4. WITHDRAWAL OF CONSENT & ACCESS
- You may withdraw your consent to our continued use and disclosure of your Personal Data or seek access to your Personal Data (to a reasonable extent and as permitted by the Act) at any time by writing to firstname.lastname@example.org . You may also withdraw your consent for specific forms of communication and on specific communications via the unsubscribe options as stated on our email or other marketing messages.
- In withdrawing your consent, you acknowledge that we may not be able to provide or continue providing certain goods and/or services to you and that we may cease such provision accordingly without any liability.
- 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 thirty (30) days for your withdrawal to be reflected in our systems. Therefore, you may still receive marketing or promotional materials/communication during this period of time. Please note that even if you withdraw your consent for the receipt of marketing or promotional materials through a specific mode, we may still contact you for other purposes in relation to the Products and Services that you hold or have subscribed to with Fenlyn.
5. ACCURACY & CORRECTION
- We will endeavour to ensure that your Personal Data we use is sufficiently accurate and complete in making any decision that impacts you.
- To help us maintain the accuracy of your Personal Data, we encourage you to inform us of any changes to your Personal Data which you have provided us by
- writing to email@example.com . We will correct or complete your Personal Data as soon as reasonably practicable.
6. PROTECTION, POLICIES & PROCEDURES
- We will endeavour to protect your Personal Data in our possession or control against risks of unauthorised access, collection, use, disclosure, copying, modification, disposal or destruction, through reasonable and appropriate security measures. We strive to ensure that our systems are secure and that they meet industry standards. To prevent unauthorized access, maintain data accuracy and ensure the correct use of information, we have put in place appropriate physical, electronic, and managerial procedures to safeguard and secure the Personal Data we collect. Notwithstanding our security measures for protecting your Personal Data, you acknowledge that no data transmission over the Internet is completely secure and by providing your Personal Data, you are transmitting information at your own risk.
7. RETENTION OF DATA
- We will retain your Personal Data for as long as you use our products or services and it is necessarily required or relevant for business or legal purposes.
- We gather Information on our website activity, such as data on the number of visitors, the pages they visit, the duration of their stay, etc. Such information is collected on an aggregate, anonymous basis, which means no Personal Data is associated with this data and gathered through the use of web server logs and cookies. We do not at our website automatically collect Personal Data unless you provide such information or login with your account credentials.
- Enabling certain features and functions on our websites, e.g. remembering your details, browsing and other services preferences;
- Building up a profile of how you and other users use the website;
- Improving the efficiency of our website;
- Administering services to you and to advertisers; and
- Establishing usage statistics
- Most internet browsers provide you the option of turning off the processing of cookies, but this may result in the loss of functionality, restrict your use of the website and/or delay or affect the way in which it operates.
- By accessing and using our website and services, you consent to the storage of cookies, other local storage technologies, beacons and other information on your devices. You also consent to the access of such cookies, local storage technologies, beacons and information by us or our representatives or agents.
9. THIRD-PARTY LINKS & PRODUCTS ON OUR SERVICES
- Advertisements on the Fenlyn website 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 do this), and to track how many people have seen it more than once. Fenlyn does not control these third parties and their cookie policies and if you have questions about their cookie policies, please contact Fenlyn and we will try our best to assist you by providing information about these third-party advertising agencies.
10. GOVERNING LAW
- The Personal Data Protection Policy and your use of this website shall be governed in all respects by the laws of Singapore.
11. CONTACT US
© Fenlyn. All rights reserved.
Updated as at Nov 2018.