Privacy policy

This Data Protection Notice (“Notice”) sets out the basis which JE Schmear Pte Ltd (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of our customers in accordance with the Personal Data Protection Act (“PDPA”) and other relevant regulation. This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.

PERSONAL DATA

1. As used in this Notice:

“customer” means an individual who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us; and

“personal data” means data, whether true or not, about a customer 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.

2. Depending on the nature of your interaction with us, the type of Personal Data collected may vary based on how it was gathered, and may include:

“Identity Data” such as name, marital status, title, date of birth and gender;

“Contact Data” such as your home/work/billing address, e-mail address and telephone number;

“Professional Background Data” such educational and professional history;

“Transaction Data” such as details about payments to and from you and other details of services you have subscribed from us;

“Marketing Data” such as your preferences in receiving marketing from us and our third parties and your communication preferences. If you correspond with us by email or messaging through the Services, we may retain the content of such messages and our responses;

“Online Presence Data” such as links to your public account pages at social media websites and other online materials related to you;

“Behavioral Data” such as inferred or assumed information relating to your behavior and interests, based on your online activity. This is most often collated and grouped into "segments";

“Technical Data” such as Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Site or use our Services;

“Content Data” such as content you post to the Services not already included in another category, including your profiles, questions, preference settings, answers, messages, comments, and other contributions on the Services, and metadata about them (such as when you posted them) (collectively, "Content").

We may also collect certain Personal Data from third party sources, for example, from social media sites, our affiliates, analytics providers, advertisers, data brokers, and identity verification and compliance service providers.

When you interact with us through this Site, or other means of communication, we may receive and store certain personally non-identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. We may store such information itself or such information may be included in databases owned and maintained by our affiliates, agents or service providers. This Site may use such information and pool it with other information to track, for example, the total number of visitors to this Site, the number of visitors to each page of this Site, the domain names of our visitors' Internet service providers, and how our users use and interact with our Services. Also, in an ongoing effort to better understand and serve the users of our Services, we often conduct research on our customer demographics, interests and behavior based on Personal Data and other information provided to us. This research may be compiled and analyzed on an aggregate basis. We may share such non-identifiable and aggregate data with our affiliates, agents and business partners, but this type of non-identifiable and aggregate information does not identify you personally. We may also disclose aggregated user statistics in order to describe our Services to current and prospective business partners, and to other third parties for other lawful purposes. However, if we combine or connect such non-identifiable or aggregated data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy.

We do not knowingly or willingly collect any "Special Categories of Personal Data" about you. This includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. Nor do we collect any information about criminal convictions and offences.

3. Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).

COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

4. We may collect and use your personal data for any or all of the following purposes:

(a) performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;

(b) verifying your identity;

managing your relationship with us;

(d) processing payment or credit transactions;

(e) complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;

(f) marketing of our products and services which may be of interest to you based on your interactions with us;

any other purposes for which you have provided the information;

(g) transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and

(h) any other incidental business purposes related to or in connection with the above.

(i) transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and

(j) any other incidental business purposes related to or in connection with the above.

5. We may disclose your personal data:

where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods and services requested by you; or

to third party service providers, agents and other organisations we have engaged to perform any of the functions with reference to the above mentioned purposes.

6. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to your employment contract should you be hired) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under a contract with you).

WITHDRAWING YOUR CONSENT

7. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.

8. 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 your request within ten (10) business days of receiving it.

9. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in Clause 8 above.

10. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

11. If you request that we remove your Personal Data in exercise of your rights, we will convey that request to any third-party with whom we have shared your data. We are not, however, responsible for revising or removing your Personal Data obtained by any third party who has previously been provided your information by us in accordance with this Policy or any third party to whom you have provided such information (whether by sharing your login and password, or otherwise).

ACCESS TO AND CORRECTION OF PERSONAL DATA

12. If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.

13. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.

14. We will respond to your request as soon as reasonably possible. In general, our response will be within thirty (30) business days. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. 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).

PROTECTION OF PERSONAL DATA

15. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis.

16. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

ACCURACY OF PERSONAL DATA

17. We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.

RETENTION OF PERSONAL DATA

18. We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.

19. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.

TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE

20. Recipients of your Personal Data may be located outside Singapore. You agree that we may transfer your Personal Data to our affiliates, subsidiaries and/or other authorised third parties located outside of Singapore, as long as the Personal Data is handled in accordance with this Policy and all applicable laws. We will ensure recipients of your Personal Data are legally bound to provide a standard of protection for your personal data comparable to the protection afforded under the PDPA, GDPR and/or the data protection laws of the relevant jurisdiction.

DATA PROTECTION OFFICER

21. You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:

Email: info@welcomehome.sg

Post: DPO Request, 212 Ocean Dr, #05-16, Singapore 098624

EFFECT OF NOTICE AND CHANGES TO NOTICE

22. This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.

23. We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.

GENERAL DATA PROTECTION REGUATION (GDPR) FOR THE EU

24. You have the following rights under this Policy, and by law if you are within the European Union (“EU”), to:

Request access to your Personal Data. If you are within the EU, this enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.

Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.

Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right, if you are within the EU, to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below).

Object to processing of your Personal Data. This right exists where we are relying on a legitimate interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to processing of your Personal Data on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.

Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.

Request the transfer of your Personal Data. If you are within the EU, we will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent. This right only exists where we are relying on consent to process your Personal Data ("Consent Withdrawal"). If you withdraw your consent, we may not be able to provide you with access to the certain specific functionalities of our Site. We will advise you if this is the case at the time you withdraw your consent.

Please note that certain rights provided in the above clause 23 are available to you if you are within the EU in accordance with the GDPR. If the GDPR is not applicable to you, your rights will be governed by this Policy to the extent of complying with the PDPA.

25. If you wish to exercise the rights under Clause 24 above, please:

Put your request in writing via the DPO Contact;

Provide us with sufficient information, or we may request for further information, for us to Verify your identity as our security measures to ensure that Personal Data is not disclosed to any person who has no right to receive it; and

Specify the right which you wish to exercise and identify the relevant Personal Data for this purpose.

We will endeavor to respond to all legitimate requests within thirty (30) days unless your request is particularly complex or you have made multiple requests. In this regard, we will notify you and keep you posted. Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if your request is clearly unfounded, repetitive or excessive, we may refuse to comply with your request in these circumstances.

If you wish to stop receiving marketing communications from us or modify your email preferences, you may follow the opt-out links on our marketing communications sent to you, or contact us to do so via the contact details provided below. Where you opt out of receiving these marketing communications, it does not mean that it will apply to Personal Data provided to us as a result of emails relating to existing or pending Services from us or consent to direct marketing communications which you may have given earlier.

You may submit a complaint to us via the DPO Contact in in relation to this Privacy or our practices in relation to your Personal Data. If you are in the EU and feel that your complaint has not been adequately resolved, you the right under the GDPR to contact your local data protection supervisory authority.

26. If you are an individual in the EU who is less than 16 years old, please do not send us any information or your Personal Data. We do not knowingly collect nor do we wish to collect and personally identifiable information or other user information from children under the age of 16. In the event that we learn we have collected any personal information from a child under the age of 16, we will delete the information from our database and terminate the corresponding account, if any.

Jurisdiction

27. Irrespective of the country from which you access or use this Site or our Services, to the extent permitted by law, this Policy shall be governed in accordance with the laws of Singapore without regard to choice or conflicts of law principles, and you hereby agree to submit to the exclusive jurisdiction of the courts of Singapore to resolve any claims or disputes which may arise in connection with this Policy.

Effective date : 18/06/2020
Last updated : 18/06/2020