1.1 This Policy statement provides information on the obligations and policies of the True Group in respect of an individual customer’s Personal Data. The True Group undertakes to use reasonable efforts in applying, where practicable, those principles and the processes set out herein to its operations.
1.2 The True Group’s officers, management, and members of staff shall use reasonable endeavours to respect the confidentiality of and keep safe any and all Personal Data collected and/or stored and/or disclosed and/or used for, or on behalf of, the True Group. The True Group shall use reasonable endeavours to ensure all collection and/or storage and/or disclosure and/or usage of Personal Data by the True Group shall be done in an appropriate manner and in accordance to the Act and this Policy.
1.3 For the purposes of this Policy, in line with the provisions under the Personal Data Protection Act 2012 (No. 26 of 2012) (the “Act”), “Personal Data” shall mean data, whether true or not, about an individual customer who can be identified from that data; or from that data and other information to which an organisation has or is likely to have access. Such Personal Data shall also refer to that which is already in the possession of the True Group or that which shall be collected by the True Group in the future.
2. Contacting the Data Protection Officer
2.1 Where you legitimately request access to and/or correction of Personal Data relating to you which is in the possession and control of the True Group, the True Group shall provide and/or correct that data in a reasonable time and manner in accordance with its standard procedures as stated hereinafter.
2.2 In accordance with the Act, the True Group has established a process for receiving and responding to any query or complaint that may arise with respect to the application of this Act. To ensure that the True Group receives your complaints and enquiries, please send the same via email to the Data Protection Officer (the “DPO”) of the True Group at the following email address: firstname.lastname@example.org
2.3 Should you not wish the True Group to use your Personal Data for any of the purposes listed in Clauses 3.2 to 3.4, or not to receive promotional materials from the True Group, you may opt out by sending a clearly worded email to the DPO via the email address provided in Clause 2.2. Your request shall be processed within a reasonable time.
3. Statement of Practices
Types of Personal Data Collected:
3.1 As part of its day to day activities, the True Group may collect from you, through various means, including via our websites, smart phone applications, marketing events such as road shows and any forms used by the True Group from time to time, the following Personal Data: name (first and surname); postal address; phone number (including mobile); fax number; e-mail address; bank account/credit card details; gender; Personal Data of your emergency contacts; IP addresses; and photographs and images.
Purpose of Collection of Personal Data
3.2 The above Personal Data mentioned in Clause 3.1 is collected for the purposes of processing your application and registration of your membership and to ascertain if you are eligible for discounts, privileges or benefits or other related purposes; to conduct market research and analysis; for direct marketing through voice calls; text messages; email; direct mail and facsimile messages; for payment and/or credit control purposes; to notify you of any changes to our policies or services which may affect you; to respond to queries and feedback; for identification and club access; maintaining and updating your membership details; and informing you of new developments, services, promotions of True Group and other third parties which we are associated with.
Disclosure of Personal Data
3.3 In order to carry out the functions described above, the True Group may, from time to time, disclose your Personal Data between the True Group’s companies.
3.4 Without derogating from any of the above, the True Group may also disclose your Personal Data to the following third parties, namely: regulators and law enforcement officials; lawyers; auditors; third party service providers and consultants; third party investors; credit, debit and charge card companies, banks and other entities processing payment; and any agent or subcontractor acting on the True Group’s behalf for the provision of the True Group’s services.
3.5 The True Group may disclose your Personal Data to the abovementioned parties also in the occurrence of any of the following events, namely, to the extent that the True Group is required to do so by the law; in connection with any legal proceedings or prospective legal proceedings; to establish, exercise or defend the True Group’s legal rights; to the purchaser (or prospective purchaser) of any company, business or asset which the True Group is (or is contemplating) selling; to any person and/or entity for the purpose of processing such information on the True Group’s behalf; to third parties who provide services to the True Group or on its behalf; to any third party that purchases the True Group or the True Group’s companies, business or any part of the True Group or the True Group’s business; for the purposes of disaster recovery; and any other purpose with your specific consent.
Optional Provision of Personal Data
3.6 In some instances, you may also be requested to provide certain Personal Data that may be used to further improve the True Group’s products and services and/or better tailor the type of information presented to you. In most cases, this type of data is optional although, where the requested service is a personalised service, or provision of a product or dependent on your providing all requested data, failure to provide the requested data may prevent the True Group from providing the service to you. This type of data includes, but is not limited to: your age; gender; salary range and employment details; education and profession; hobbies and leisure activities; other related products and services subscribed to; and family and household demographics.
3.7 Under certain circumstances, telephone calls made to any of the True Group companies order and/or service hotlines and/or inquiry telephone numbers are recorded for the purposes of quality control, appraisal, as well as staff management and development. In such an event, by agreeing to this Policy, you hereby give your clear and unambiguous consent for the collection, use and disclosure of such Personal Data in accordance to this Policy.
4. Transfer of Personal Data Overseas
Your Personal Data may be processed by the True Group, its affiliates, agents and third parties providing services to the True Group, in jurisdictions outside of Singapore. In this event the True Group will comply with the terms of the Act.
5. Accuracy of Personal Data
Where possible, the True Group will validate data provided using generally accepted practices and guidelines. This includes the use of check sum verification on some numeric fields such as account numbers or credit card numbers. In some instances, the True Group is able to validate the data provided against pre-existing data held by the True Group. In some cases, the True Group is required to see original documentation before we may use the Personal Data such as with Personal Identifiers and/or proof of address. To assist in ensuring the accuracy of your Personal Data in the possession of the True Group, please inform us of any updates of any parts of your Personal Data by sending a clearly worded email to the DPO at the email address earlier provided.
6. Protection of Personal Data
The True Group uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your Personal Data and will not knowingly allow access to this data to anyone outside the True Group, other than to you or as described in this Policy. However, the True Group cannot ensure or warrant the security of any information you transmit to the True Group and you do so entirely at your own risk. In particular, the True Group does not warrant that such information may not be accessed, altered, collected, copied, destroyed, disposed of disclosed or modified by breach of any of the True Group’s physical, technical, or managerial safeguards.
7. Access and Correction of Personal Data
7.1 In accordance with Clause 2.1 of this Policy, you have the right to:
a) check whether the True Group holds any Personal Data relating to you and, if so, obtain copies of such data; and
b) require the True Group to correct any Personal Data relating to you which is inaccurate for the purpose for which it is being used.
7.2 The True Group reserves the right to charge a reasonable administrative fee in order to meet your requests under Clause 7.1. Upon payment of the requisite fee, your request shall be processed within a reasonable time.
7.3 If you wish to verify the details you have submitted to the True Group or if you wish to check on the manner in which True Group uses and processes your personal data, the True Group’s security procedures mean that the True Group may request proof of identity before we reveal information. This proof of identity will take the form of full details of name, membership number and NRIC or Passport or Fin number. You must therefore keep this information safe as you will be responsible for any action which the True Group takes in response to a request from someone using your membership details. We would strongly recommend that you do not use the browser’s password memory function as that would permit other people using your terminal to access your personal information.
8. Storage and Retention of Personal Data
The True Group will delete, as reasonably possible, or otherwise anonymise any Personal Data in the event that the Personal Data is not required for any reasonable business or legal purposes of the True Group and where the Personal Data is deleted from the True Group’s electronic, manual, and other filing systems in accordance with the True Group’s internal procedures and/or other agreements.
9. Contacting you
To the extent that any of the communication means which you have provided the True Group with (which may include, your telephone number and fax number) is/will be listed on the Do Not Call Registry (the “DNC”), by agreeing to this Policy through your signing of the Membership Agreement Form or the Members’ Consent Form, or by any other means of indication, you hereby grant the True Group your clear and unambiguous consent to contact you using all of your communication means you have provided to the True Group including using SMS and MMS messages for the above purposes. This will ensure your continued enjoyment of the True Group’s promotional rates and services
10. Change Policy
The True Group reserve the right to alter any of the clauses contained herein in compliance with local legislation and/or to meet its global policy requirements, and for any other purpose deemed reasonably necessary by the True Group. You should look at these terms regularly. If you do not agree to the modified terms, you should inform us as soon as possible of the terms to which you do not consent. Pending such notice, if there is any inconsistency between these terms and the additional terms, the additional terms will prevail to the extent of the inconsistency.
11. Governing Law
This Policy is governed by and shall be construed in accordance with the laws of Singapore. You hereby submit to the non-exclusive jurisdiction of the Singapore courts.
12.1 This Policy only applies to the collection and use of Personal Data by the True Group. It does not cover third party sites to which we provide links, even if such sites are co-branded with our logo. True Group does not share your Personal Data with third party websites. The True Group is not responsible for the privacy and conduct practices of these third party websites, so you should read their own privacy policies before disclosure of any Personal Data to these websites.
12.2 The True Group will not sell your personal information to any third party without your permission, but we cannot be responsible or held liable for the actions of third party sites which you may have linked or been directed to the True Group’s website.
12.3 The True Group’s websites do not target and are not intended to attract children under the age of 18 years old. True Group does not knowingly solicit personal information from children under the age of 18 years old or send them requests for personal data.