1. YOUR PERSONAL DATA
(a) your name, national identification number (e.g. NRIC or passport number), telephone number(s), mailing address, email address, biometric information, and any other information relating to you which you have provided us in any forms you may have submitted to us, or in any other interaction with you;
(b) to the extent that we may personally identify you from such information, information about your use and/or access of our websites, software or mobile applications (each a “Platform“) and services, including computer and connection information, device capability, bandwidth, statistics on page views, click-stream data, traffic to and from our Platform(s), cookies, Internet Protocol (IP) address, account details;
(c) your payment related information, such as your bank account and/or credit card information, and your credit history;
(d) biometric information if you activate biometric sensors in your interactions with us; and
(e) your location data, such as your geographical location.
1.2 We will only retain your Personal Data for as long as we are either required or permitted to by law or as relevant for the purposes for which it was collected.
1.3 To the maximum extent permitted under applicable law, we may anonymise your Personal Data so that it no longer identifies you, in which case we shall be entitled to retain, use, disclose, and/or process such anonymised data without restriction, including for data analytics.
2. COLLECTION OF PERSONAL DATA
2.1 Generally, we may collect your Personal Data:
(a) when you submit any form to us;
(b) when you enter into any agreement or provide other documentation or information in respect of your interactions and transactions with us, or when you use any of our services;
(c) when you interact with our staff and other representatives;
(d) when you access and/or use our services (whether electronic, online and/or otherwise), or interact with us via any Platform or use any service on our Platform(s), e.g. when you register any online accounts or other profiles with us;
(e) when you purchase or obtain goods and/or services, whether from us or from third parties, through us;
(f) when you contact us to find out more about any goods and/or services, whether from us or from third parties;
(g) when you request: (i) that we contact you; and/or (ii) to be included in an email or other mailing list;
(h) when you respond to: (i) our request for additional Personal Data; and/or (ii) our promotions and/or other initiatives;
(i) when you are contacted by, and respond to, our marketing representatives and agents and other service providers;
(j) when you submit an employment application or when you provide documents or information including your resume and/or curriculum vitae in connection with any appointment as an officer, director, representative or any other position;
(k) when we seek information about you and receive your Personal Data in connection with your relationship with us, including for our goods, services, and/or job applications, for example, from business partners, public agencies, your ex-employer and regulatory authorities; and/or
(l) when you submit or otherwise make available Personal Data to us for any other reason.
2.2 If you provide us with any Personal Data relating to a third party (e.g. information of spouse, children, parents, employees and/or authorised representatives), by submitting such information to us, you represent and warrant to us that you have obtained the consent of such third party for you to provide us with the Personal Data for the third party’s purposes.
2.3 You shall 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 products and services you have requested.
3. PURPOSES FOR THE COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL DATA
3.1 Generally, we may collect, use, disclose and/or process your Personal Data for the following purposes:
(a) to provide you with goods and/or services which you have purchased or requested to receive (whether provided by us or third parties);
(b) responding to your queries and/or requests, responding to complaints, and/or providing customer support;
(c) managing the infrastructure and business operations of the CDG Group and complying with internal policies and procedures;
(d) facilitating business asset transactions (which may extend to any merger, acquisition or asset sale);
(e) matching any Personal Data held which relates to you for any of the purposes listed herein;
(f) verifying your identity;
(g) preventing, detecting and investigating crime, including fraud and money-laundering, and analyzing and managing other commercial risks;
(h) protecting and enforcing our contractual and legal rights and obligations;
(i) conducting audits, reviews and analysis of our internal processes, action planning and managing commercial risks;
(j) preventing, detecting and investigating crime and managing the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances);
(k) compliance with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities; and/or
(l) any other purpose relating to any of the above.
3.2 In addition, and without prejudice to the generality of the foregoing, if you use or download any of our Platforms, we collect, use, disclose and/or process your Personal Data for any of the following purposes:
(a) where any Platform includes subscription services, to process your application for and manage your access to these services;
(b) to verify and process your personal particulars and payments in relation to the purchase or provision of goods and/or services;
(c) to provide you with goods and/or services which you have purchased or requested to receive (whether provided by us or third parties), and to push content to you which may be relevant to you;
(d) communicating with you to inform you of changes and development to the CDG Group policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you;
(e) resolving complaints and handling requests and enquiries;
(f) conducting market research for statistical, profiling and statistical analysis for the improvement of services provided to you; and
(g) processing of your Personal Data in relation to any of the purposes stated above.
3.3 In addition, and without prejudice to the generality of the foregoing, and subject to applicable law, we may collect, use, disclose and/or process your Personal Data for any of the following purposes:
(a) providing or marketing services, products and benefits to you, including promotions, loyalty reward, and/or similar programmes, including joint marketing and/or cross promotions with third parties;
(b) matching or combining Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the development, customisation, provision or offering of products, services, marketing or promotions, whether by the CDG Group, our service providers, and/or other third parties;
(c) administering contests and competitions, and personalising your experience at the CDG Group’s touchpoints;
(d) sending you details or products, services, special offers and rewards, either to our customers generally, or which we have identified may be of interest to you;
(e) conducting market research, or analysing and/or profiling your location, preferences, demographics, purchases, transactions, and/or behaviour so as enable us, our service providers, and/or third parties to design goods and/or services, understand customer behaviour, preferences and market trends, and to review, develop and improve the quality of goods and/or services, and/or to provide you with personalised goods and/or services (e.g. special offers and marketing programmes which may be relevant to your preferences and profile);
(f) recommending, identifying and contacting you to inform you of products and services that are or may be relevant to you, including on behalf of third parties, or sharing your personal data with such third parties or their service providers for them to collect, use, disclose or process your personal data for such purposes; and
(g) collection, use, disclosure and/or processing of customer data by our business partners for data monetisation purposes.
3.4 If you have provided us with your Singapore telephone number(s), and if required by law, have indicated that you consent to receiving marketing or promotional information via your Singapore telephone number(s), then from time to time, we may contact you using such Singapore telephone number(s) (including via voice calls, SMS, text, fax or other means) with information about our products and services (including discounts and special offers).
3.5 In relation to particular products or services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use, disclose and/or process your Personal Data. If so, subject to applicable law, we shall have the right to collect, use, disclose and/or process your Personal Data for such additional purposes as well unless we have specifically notified you otherwise.
4. DISCLOSURE OF PERSONAL DATA
(a) any of the CDG Group’s affiliates;
(b) any agent, contractor or third party service provider who provide services to the CDG Group, including Market Research Companies (as defined in Clause 5 below);
(c) any vendor or third party business partner, including any vendor who offers goods and services or sponsor contests or other promotional programs on any Platform (whether in conjunction with us or not), advertisers and/or marketplace aggregators;
(d) any external business and charity partner in relation to corporate promotional events;
(e) the Credit Bureau Singapore, and/or in the event of default or disputes, any debt collection agencies or dispute resolution centres;
(f) any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale);
(g) any person to whom we transfer or may transfer our rights and duties;
(h) banks, credit card companies and their respective service providers;
(i) our professional advisors such as our auditors and lawyers;
(j) relevant government regulators or authority or law enforcement agency to comply with any laws or rules and regulations imposed by any governmental authority;
(k) analytics, search engine providers or other third party service providers that assist us in delivering any of our products, services, and/or Platforms as well as improving and optimising the same; and/or
(l) any other party to whom we are authorised by you or by law to disclose your Personal Data.
4.2 In addition, we may also share aggregated, non-personally identifiable information with the public and our partners, such as our vendors, advertisers, marketplace aggregators, and/or other service providers.
5. COOKIES, WEB BEACONS AND OTHER TECHNOLOGIES
5.1 Our Platform(s) may include technologies that automate the collection, use, disclosure, and/or processing of data (including your Personal Data). Such technologies may include cookies, web beacons and other web analytics. If you do not wish to have your data collected through such technologies you should disable the operation of these technologies on your devices (where possible), or refrain from using our Platform(s).
5.3 The CDG Group may also use independent companies and service providers (“Market Research Companies“), and our Platform(s) may be coded with software or other technologies to assist the Market Research Companies in measuring and analyzing the user behaviour across any of our Platforms, and to track visitors. For example, we may use the Market Research Companies’ services to collect the following information on the usage of our Platform(s), including without limitation: (a) the number of page views or page impressions that occur on our Platform(s); (b) the number of unique visitors to our Platform(s); (c) how long these unique visitors (on average) spend on our Platform(s) when they do visit; (d) common entry and exit points into our Platform(s); (e) user travel patterns; (f) location data (including geographical location); (g) time spent at a particular location, (h) quantity and value of transactions for purchases on our Platform(s); (i) user spending behavior; (j) user’s choice of goods and/or services purchased or used on our Platform(s); and (k) “dwell time” information. Such information is provided by the Market Research Companies to the CDG Group to assist the CDG Group in analysing the usage of our Platform(s).
6. DATA SECURITY
6.1 We will take reasonable efforts to protect your Personal Data in our possession or control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. However, we cannot completely guarantee the security of any of your Personal Data, or that no harmful code (for example viruses, bugs, trojan horses, spyware or adware) will enter any Platform. You should be aware of the risks associated with using any Platform.
7. THIRD-PARTY SITES
7.1 The CDG Group is not responsible for the Personal Data policies (including Personal Data protection and cookies), content or security of any third party websites linked to any Platform.
8. WITHDRAWAL, ACCESS AND CORRECTION OF YOUR PERSONAL DATA
8.1 If you:
(a) have any questions or feedback relating to your Personal Data or this Policy;
(b) would like to withdraw your consent to any collection, use or disclosure and/or processing of your Personal Data by us; and/or
(c) would like to obtain access or make corrections to your Personal Data records,
you may write to our Data Protection Officer as follows:
Data Protection Officer
CDG Zig Pte. Ltd.
Data Protection Officer, [email protected]
8.2 If your Personal Data has been provided to us by a third party, you should request such third party directly to make any queries, feedback, and access and correction requests to the CDG Group on your behalf.
8.3 If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, we may not be in a position to continue to provide our products or services to you or administer any contractual relationship in place, and this may also result in the termination of any agreements with us and your being in breach of your contractual obligations or undertakings, and our legal rights and remedies in such event are expressly reserved.
8.4 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 purposes for which the Personal Data was collected, and is no longer necessary for any legal or business purpose.
9.1 For the avoidance of doubt, in the event that applicable personal data protection law permits the CDG Group to collect, use or disclose Personal Data without your consent, such permission granted by the law shall continue to apply.
Last updated: 07/06/2021