Last updated: 19 September 2021
“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.
"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.
1. PERSONAL DATA
Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include your name and identification information such as your NRIC number, contact information such as your address, email address or telephone number, nationality, gender, date of birth, marital status, photographs and other audio-visual information, employment information and financial information such as credit card numbers, debit card numbers or bank account information.
2. PURPOSES FOR WHICH WE COLLECT, USE AND DISCLOSE YOUR PERSONAL DATA
2.1. Your personal data may be collected, used and/or disclosed for the following purposes:
a) to verify and process your personal particulars and payments;
b) performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
c) to respond and deal with enquiries, complaints and other customer-care matters or otherwise communicate with you;
d) managing your relationship with us;
e) to monitor or record phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes;
f) to manage payment, billing, account, credit checks and debt-recovery matters;
g) to send you information, promotions, updates, and marketing and advertising materials in relation to our goods and services;
h) to manage, develop and improve our business and operations to serve you better;
i) to carry out marketing promotions and campaigns, contests and lucky draws;
j) to personalise your experience at our customer touchpoints;
k) to carry out market research and customer surveys;
l) to conduct investigations or audits or carry out crime and fraud prevention and risk management activities;
m) to provide, understand, improve, and develop the AveLIVE website;
n) to provide, personalize, measure, and improve our advertising and marketing;
o) to comply with legal and regulatory requirements;
p) to enforce our legal rights and obligations;
q) to facilitate business asset transactions (which may extend to any mergers, acquisitions or asset sales);
r) for other purposes for which we have obtained your consent;
s) 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
t) for any other purposes reasonably necessary, ancillary, incidental, or related to the above specified purposes.
2.2. Your personal data may be disclosed for the purposes indicated in clause 2.1 to our officers and employees, third parties, affiliates, service providers, advisors, which include without limitation, the following persons or entities:
a) banks, credit card companies, and payment vendors;
b) debt collection agencies;
c) credit information companies;
d) logistics and courier services companies;
e) call centre services providers;
f) our business partners and authorised distributors, dealers or resellers;
g) relevant government regulators or authorities or law enforcement agencies;
h) our insurers and advisors, including consultants, auditors and lawyers;
i) data intermediaries;
j) any other party to whom you authorise us to disclose your personal data to.
2.3. The purposes listed in clause 2.1 may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) 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 any contract with you).
2.4. 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 take reasonable efforts to 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.
3. YOUR RIGHTS
You may exercise any of the rights described in this section by sending an email to our Data Protection Officer at email@example.com. Please note that we may ask you to verify your identity before taking further action on your request.
3.1. Accuracy of personal data
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.
3.2. Data Access and Correction
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 via email to our Data Protection Officer at the email provided above.
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.
We will respond to your request as soon as reasonably possible. 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 Act).
3.3. Data Retention
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.
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.
3.4. Withdrawing Consent
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 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. Please note that the withdrawal of your consent does not affect the lawfulness of any processing activities based on such consent before its withdrawal.
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 fourteen (14) business days of receiving it.
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 6 below.
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.
4. INDIVIDUALS LOCATED WITHIN THE EEA OR CALIFORNIA
4.1. Legal bases for processing for EEA users
If you are an individual in the European Economic Area (“EEA”), we collect and process information about you only where we have legal bases for doing so under applicable EU laws. Our legal basis for collecting and using your personal information will be our legitimate interest where the processing is in our, or a third party's, legitimate interests and not overridden by the individual’s data protection interests, or fundamental rights and freedoms. These interests are to provide individuals with access to the AveLIVE website and services; to send individuals information they have requested; to ensure the security of our website by trying to prevent unauthorised or malicious activities; or, to protect our legal rights and interests. In some EEA countries, we are relying on consent as a legal basis for using data for marketing purposes.
4.2. Specific rights for California residents
If you are a natural person who is resident in California, California law provides you with specific rights regarding your personal information, including the right to request, twice within a twelve-month period, that we disclose certain information to you about our collection and use of your personal information over the past 12 months; the right to request that we delete any of your personal information that we have collected from you, subject to certain exceptions; and the right to opt out of the sale of your personal information. If you wish to exercise any of these rights, please contact firstname.lastname@example.org with the subject ‘California CCPA’. You also have the right not to be discriminated against if you exercise any of your rights under California privacy law.
6. CONTACT US