General
Empower2Free’s Personal Data Protection Policy outlines how we manage your personal data. Your privacy is important to us and we do not take lightly any personal information that you share. All personal data is kept within our organisation and is revealed only on a needs-to-know basis. We do our best to keep the information secure. Compliance to regulatory requirements require us to spell out the details below in legalspeak.
This Personal Data Protection Policy sets out how Empower2Free (referred to herein as “Organisation”, “us”, “we” or “our”) comply with the provisions of the Personal Data Protection Act 2012 of Singapore (“PDPA”). This Notice applies to personal data in our possession or under our control. This includes personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.
You agree and consent to us, our authorised service providers and third parties to collect, use and disclose and/ or retain your Personal Data in the manner set forth in this Personal Data Protection Policy.
Empower2Free’s Personal Data Protection Policy
Empower2Free’s Personal Data Protection Policy supplements but does not supersede nor replace any other consent which you may have previously provided to us. It also does not affect any right that we may have at law in connection with the collection, use, disclosure and/ or retention of your Personal Data.
From time to time, we may update this Personal Data Protection Policy to ensure that our Policy is consistent with developments and trends and/ or any regulatory changes. Should any revision(s) be made to this Personal Data Protection Policy, updates will be published on our site. Subject to your legal rights in Singapore, the prevailing terms of the Personal Data Protection Policy shall apply.
Empower2Free’s Personal Data Protection Policy forms a part of the terms and conditions governing your relationship with us. Read this policy in conjunction with such terms and conditions (“Terms and Conditions”). In the event of any inconsistency between the provisions of the Personal Data Protection Policy and the Terms and Conditions, the provisions of the Terms and Conditions shall prevail.
Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).
Your Personal Data
In this Personal Data Protection Policy, “Personal Data” refers to any data and/or information about you from which you can be identified by, either (a) from that data; or (b) from that data and other information to which we may have legitimate access to. Examples of such Personal Data include but are not limited to:
- your name, NRIC, passport or other identification number;
- telephone number(s), mailing address, email address;
- and any other information relating to you which you have provided in any forms or in other forms of interaction;
- information about your usage of and interaction with our website and/ or services. This includes computer and connection information, device capability, bandwidth, statistics on page views and traffic to and from our website
Collection of Personal Data
Generally, we do not collect your personal data unless
- it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after
- you (or your authorised representative) have been notified of the purposes for which the data is collected, and
- you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or
- collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
Use & Disclosure of your Personal Data
We may collect and use your personal data for any or all of the following purposes:
- performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
- verifying your identity;
- responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
- managing your relationship with us;
- processing payment or credit transactions;
- sending your marketing information about our goods or services including notifying you of our marketing events, initiatives and promotions, lucky draws, membership and rewards schemes and other promotions;
- complying with any applicable laws, regulations, codes of practice, guidelines, or rules,
- assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
- any other purposes for which you have provided the information;
- transmitting to any unaffiliated third parties including our third party service providers and agents,
- transmitting to any relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
- any other incidental business purposes related to or in connection with the above.
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 or services requested by you; or
- to third party service providers, agents and other organisations we have engaged to perform any of the functions listed in clause 2 above for us.
The purposes listed in the above clauses 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).
Use of Cookies
We may collect or analyse anonymised information from which individuals cannot be identified (“Aggregate Information”). Examples include number of users and frequency of use, number of website page views / impressions and common website entry/ exit points.
We make use of “cookies” to store and track Aggregate Information about you when you enter our website(s). Such cookies are used to track information such as the number of users and frequency of use, user profiles and their online preferences.
Such Aggregate Information collected may be used to assist us in analysing the usage of our website(s) so as to improve your online experience with us.
You may wish to disable the cookies associated with these technologies by changing your browser settings. However, please note that this may affect the functionality of the website(s).
Third-Party Sites
Our website may contain links to other websites operated by third parties independent of the Organisation. We are not responsible for the privacy practices of such websites operated by third parties even though it is linked to our website(s). We encourage you to learn about the privacy policies of such third party website(s) by checking the policy of each site you visit and contact its owner or operator if you have any concerns or questions.
Withdrawing Your Consent
Consent provided for collection, use and disclosure of your personal data will remain valid until such time it is 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.
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.
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.
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.
Access to and Correction of Personal Data
You may submit your request in writing or via email to our Data Protection Officer at the contact details provided below if you wish to make
- 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
- a correction request to correct or update any of your personal data which we hold about you,
We may charge a reasonable fee 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. If we cannot respond to your request within thirty (30) days after receipt, we will notify you in writing within thirty (30) days of when we can respond. If we cannot provide your personal data or make requested corrections, we shall generally inform you why (unless not required under the PDPA).
Protection of Personal Data
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. These measures include up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us. Disclosure of personal data both internally and to our authorised third party service providers and agents are only on a need-to-know basis.
However, 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 by constantly reviewing and enhancing our information security measures.
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. This can be done by informing our Data Protection Officer via email at the contact details provided below.
Retention of Personal Data
We may retain your personal data for as long as necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
We will delete your personal data, or remove the means by which the data can be associated with you when such retention is not necessary for legal or business purposes.
Data Protection Officer
Contact our Data Protection Officer to make any request, enquiries or provide feedback on Empower2Free’s personal data protection policy via:
Contact Person: Cynthia Wong
Email Address: chatwus@empower2free.com
Effect of Notice and Changes to Notice
- This Notice applies with other relevant notices, contractual clauses and consent clauses that apply regarding the collection, use and disclosure of your personal data by us.
- We may revise this Notice from time to time without any prior notice. Check the last updated date of this Notice to see if any revisions have occurred. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.
Effective date : 05 December 2017
Last updated : 10 April 2024