Personal Data Protection Policy
1.1. Your privacy is important to us. We are committed to safeguarding and protecting your personal data in a way that complies with the Personal Data Protection Act 2012 of Singapore (“PDPA”) and to ensure the privacy of our customers.
1.2. This Personal Data Protection Policy of Kansoskin Pte Ltd (“Policy”) is intended to help you understand our policies and practices with respect to personal data that is collected, used, disclosed and/or retained by us in Singapore. It is also intended to inform you as to how you may seek access to and correction of your personal data as well as how to make an inquiry and, if necessary, make a complaint relating to our handling of that data. Unless stated otherwise, this Policy is relevant to the personal data of both our current and former customers, as well as other individuals which we may deal with.
1.3. References to “Kansoskin”, “we”, “us” or “our” in this Policy includes, individually and collectively, Kansoskin Pte Ltd and its subsidiaries that collect, use and/or disclose personal data in Singapore.
1.4. By interacting with us, submitting information to us, or signing up for any products and services offered by us, you agree and consent to us, as well as our respective representatives and/or agents collecting, using, disclosing, retaining and/or sharing amongst themselves your personal data, and disclosing such personal data to our authorised service providers and relevant third parties in the manner set forth in this Policy.
1.5. This Policy supplements but does not supersede nor replace any other consent which you may have previously provided to us in respect of your personal data and your consents herein are additional to any rights which we may have at law to collect, use, disclose and/or retain your personal data.
This Policy forms a part of the terms and conditions governing your relationship with us and should be read in conjunction with such terms and conditions (“Terms and Conditions”). In the event of any inconsistency between the provisions of this Policy and the Terms and Conditions, the provisions of the Terms and Conditions shall prevail.
2. What types of personal data do we collect, use, disclose and/or retain?
2.1. In this 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, including data in our records as may be updated from time to time.
2.2. We may collect the following data about you either directly from you, from your authorised representatives (i.e. persons you have authorised and persons who have been validly identified as being you or your authorised representatives) from third parties, or from publicly available sources. Examples of such personal data (depending on the nature of your interaction with us) may include:
(a) your name, identification number, telephone number(s), mailing address, email address and any other information relating to you which you have provided in any forms you may have submitted to use, or in other forms of interaction with you;
(b) information relating to payments, such as your bank account number or credit card information; and
(c) information about your usage of and interaction with our website(s) and/or services including computer and connection information, device capability, bandwidth, statistics on page views and traffic to and from our website(s).
3. How do we collect your personal data?
3.1 Generally, we collect personal data in the following ways:
(a) when you submit an application form or registration form, or other forms relating to any of our products and services;
(b) when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our services;
(c) when you interact with our employees, for example, via telephone calls, letters, social media platforms and emails;
(d) when you use our electronic services, or interact with us via any of our website(s) or use services on any of our website(s);
(e) when you request that we contact you or request that you be included in an email or other mailing list;
(f) when you respond to our promotions, initiatives or to any request for additional personal data;
(g) when you are contacted by, and respond to, our marketing representatives and customer service officers;
(h) when we receive references from business partners and third parties, for example, where you have been referred by them;
(i) when you fill up surveys administered by our third party surveying service providers;
(j) when we seek information from third parties about you in connection with the products and services you have applied for; and/or
(k) when you submit your personal data to us for any other reason.
3.2 When you browse our website(s), or use our application(s) and/or digital services, you generally do so anonymously but please see section 6 below on cookies. We do not, at our website(s), application(s) and digital services, automatically collect personal data unless you provide such information or login with your account credentials.
3.3 If you provide us with any personal data relating to a third party (e.g. information of your spouse, children, parents, and/or employees), by submitting such information to us, you represent and warrant to us that you have obtained the consent of the third party to provide us with their personal data for the respective purposes.
4. Purposes for which we may collect, use, disclose and/or retain your personal data.
4.1. We will collect, use, disclose and/ or retain personal data relating to you that is reasonably necessary for our business functions and activities. Typical purposes for which we may collect, use, disclose and/or retain your personal data include:
(a) to manage your package, services or products;
(b) to provide you with membership benefits and services;
(c) to provide you with employment and employability services;
(d) to provide you with training;
(e) to assist you with your enquiries, feedback, complaints and requests;
(f) to process payment for your packages or any other purchases and subscriptions;
(g) to improve membership/ customer services, such as resolving complaints and handling requests and enquiries;
(h) to conduct research, surveys and interviews;
(i) to keep you updated on our events; and social media campaigns;
(j) to redeem our marketing activities promotions and birthday voucher;
(k) to comply with applicable laws and regulations; and/or
(l) any other purpose reasonably related to the aforesaid.
4.2 Marketing/optional purposes:
From time to time, we may contact you via mail, electronic mail, telephone (call or SMS-Text) or social medial platforms, to inform you about our membership benefits, products and services that we think may be of interest to you. You can let us know at any time if you no longer wish to receive marketing materials and we will remove your details from our direct marketing database.
You may indicate your consent to the above by the following ways:
• when providing us with your personal data through our website(s) and app, or a form, indicating your consent; or
• when providing us with your personal data through the telephone, tell our customer representative that you consent; or you may opt-out from receiving marketing communications at any time, free of charge, by:
(a) following the opt-out instructions contained in the communications;
(b) writing to us at the address listed below; or
(c) updating your email subscriptions by sending us an email at firstname.lastname@example.org
Please note that we may still send you non-marketing messages such as surveys, customer-service notices and other service-related notices.
5. Disclosure and Retention of your personal data.
5.1. Any personal data provided to or collected by us is controlled primarily by us. All personal data that has been collected from you will only be stored for a limited duration that is relevant to the purpose for which it was processed and for as long as required by applicable law and we will take reasonable steps to protect your personal data against unauthorised disclosure.
5.2. We receive services from external service providers and third parties, some of which may be located outside of Singapore, and your personal data may be provided to them for this purpose. Subject to the requirements of applicable laws, your personal data may be disclosed by us for the purposes listed above in section 4 above (where applicable), to the following entities or parties:
(a) affiliated companies of Kansoskin Pte Ltd;
(b) a company subjected to a collective agreement with one of our affiliates;
(c) agents, contractors, data intermediaries or third party service providers who provide operational services, such as telecommunications, mailing, information technology, payment, payroll, data processing, training, market research, carding, storage and archival;
(d) [agents, contractors or third party service providers who provide services in connection with the courses, programmes and events organised, conducted and administered by us;
(e) our partners or collaborators in our courses, programmes and events;]
(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) involving us;
(g) external banks, financial institutions, credit card companies and their respective service providers;
(h) our professional advisers such as our consultants, auditors and lawyers;
(i) third party reward, loyalty, privileges and co-branded programme providers;
(j) business partners that provides any membership services and benefits;
(k) any person to whom we are under an obligation or otherwise required to make disclosure under the requirements of any applicable law, guidelines or guidance given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, self-regulatory or industry bodies or industry recognised bodies;
(l) any person to whom disclosure of personal data is necessary in order for us to validly effect, manage, administer and/or enforce any services requested or authorised by you;
(m) any person in connection with the purposes set forth above; and/or
(n) any other person whom you authorise us to disclose your personal data to.
6.1. We may collect or analyse anonymised information from which individuals cannot be identified (“Aggregate Information”), such as number of users and their frequency of use, the number of page views (or page impressions) that occur on our website(s) and common entry and exit points into our website(s).
6.2. 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 their frequency of use, profiles of users and their online preferences.
6.3. 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. In addition to our cookies, we may also use various third-parties cookies to report usage statistics of the services, deliver advertisements on and through the services, and so on.
6.4. Should you wish to disable the cookies associated with these technologies you may do so by changing the setting on your browser. Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.
6.5. Third-party sites:
Our website(s) may contain links to other websites operated by third parties independent of us. 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.
7. Protection of your personal data.
We maintain appropriate security safeguards and practices to protect your personal data in our possession or under our control from unauthorised access, collection, use, disclosure, copying, modification disposal or similar risks, in accordance with applicable laws.
8. Accuracy of your personal data.
We will take all reasonable steps to ensure that the personal data in our possession or under our control is accurate and up-to-date at the point of collection and at regular intervals afterwards. If there is any change in your personal data, you should inform us as soon as possible and in any event within any relevant prescribed period to enable us to update our data.
9. Withdrawal of consent.
9.1. If you wish to withdraw your consent to any use, disclosure and/or retention of your personal data as set out in this Policy, you may contact us at:
Kansoskin Pte Ltd
Email address: email@example.com
9.2. Please note that if you withdraw your consent to any or all use or disclosure of your personal data, depending on the nature of your request, we may no longer be in a position to continue to provide membership benefits and services to you. Such a withdrawal may therefore result in the termination of any membership that you may have with us.
10. Access and correction of your personal data
10.1. You have the right to request and obtain access to certain personal data that is in our possession or under our control and to have personal data relating to you which is inaccurate corrected in certain circumstances.
10.2. You can modify your personal data anytime via our application or choose to email us at firstname.lastname@example.org or directly contact Kansoskin for assistance.
11. Contacting us
If you believe that we have not complied with our obligations under the PDPA in relation to your personal data or if you have any queries with respect to our policies and practices in relation to your personal data, please contact our Personal Data Protection Officer in writing:
Email address: email@example.com
Attention: The Personal Data Protection Officer
12.1. This Policy, your browsing of our website(s), and use of our application(s) and/or digital services shall be governed in all respects by the laws of Singapore.
12.2. This Policy is based on current laws and regulations in Singapore. Currency: 5 May 2020. From time to time, we may update this Policy to ensure that this Policy is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of this Policy as updated from time to time on our website(s), application(s) and digital services. Should any revision(s) be made to this Policy, updates will be published on our public site (https://kansoskin.com/privacy/). We encourage you to check this page periodically for any changes. Your continued use of our website(s) following the posting of changes to these terms will mean you accept those changes.
12.3. This website is not intended for use by children under 13. We do not knowingly collect personal data from anyone under 13 years of age. If we become aware that we have unknowingly collected personal data from a child under the age of 13, we will make commercially reasonable efforts to delete such information from our database.