• 1.

  Introduction

  • 1.

    This Policy applies to personal data that is in our possession or under our control, and personal data which is collected, used, disclosed and/or processed by us in Singapore.

  • 2.

    Unless you withdraw your consent in accordance with the procedure set forth in this Policy, we may continue to share the personal data that we collect from you with our affiliates and subsidiaries. Such personal data may also, subject to the PDPA and other applicable Singapore laws, be transferred to and used by us outside of Singapore. When personal data is collected by or transferred to us, it will be treated according to the personal data protection practices set forth in this Policy.

• 2.

  Collection, Use and Disclosure of Personal Data

  • 1.

    Subject to the PDPA, we will obtain consent before collecting, using and disclosing your personal data and notify you of such purposes. In doing so, we shall make a reasonable effort to ensure your personal data collected is accurate and complete.

  • 2.

    We collect various types of personal data via the Suntec+ Platform. In this Policy, “personal data” means data, whether true or not, about an individual who can be identified: (a) from that data; or (b) from that data and other information to which we (and all our affiliates, partners, subsidiaries and all relevant third parties mentioned in this Policy) have or are likely to have access.

  • 3.

    We collect personal data about you that you knowingly and voluntarily provide in connection with certain activities or transactions with us, including but not limited to, when you access or use the Platform; sign up for our Suntec+ Membership programme; use the platform to purchase any of the goods and services offered on it; and when you report a problem with the Platform or our services; etc. The type of personal data that we collect about you depends on the nature of the activity or transaction.

  • 4.

    We may also collect your personal data from, and disclose your personal data to, our affiliates, including any relevant platforms which we may engage, related companies and independent third party sources.

  • 5.

    The types of personal data which we collect, and may collect in the future, include the following:

    • (a)

      personal particulars, such as your full name, gender, birth date;

    • (b)

      contact information, such as billing address, delivery address, email address and phone number;

    • (c)

      payment information, such as bank account number, credit card numbers, and any other payment details;

    • (d)

      account information, such as user ID and password, usage of your account, details of products or services that you have purchased or obtained through the Platform or through our affiliates;

    • (e)

      technical information, such as internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, international mobile equipment identity, device identifier, how you use and view any content on the Platform and other information and technology on the devices you use to access the Platform;

    • (f)

      communications, such as audio recordings, in-App messages or emails when you contact us through our customer support channels on the Platform;

    • (g)

      user-submitted content, such as live streams, videos, photographs and other media; and

    • (h)

      marketing and communications information, such as such as your preferences in receiving marketing from us, our affiliates and partners, and any third parties and your communication preferences.

  • 6.

    The Platform may contain links to other websites operated by other parties, such as our business affiliates, including any the websites of merchants or payment gateways. We are not responsible for the privacy practices of websites operated by these other parties. You are advised to check on the applicable data protection policies of those websites to determine how they will handle any information they collect from you.

  • 7.

    When you provide your personal data to us, you are giving us permission to use and store that information consistent with this Policy, including storage in servers outside of Singapore, subject to the requirements of the PDPA and applicable laws on cross-border data transfers.

  • 8.

    If you provide personal data of any third party to us, you represent and warrant that you have obtained the necessary consent, license and permissions from that third party to share and transfer his/her personal data to us, and for us to collect, store, use and disclose that data in accordance with this Policy.

  • 9.

    A cookie is a small text file which is placed on your device whenever you run or use the Platform. The Platform may use cookies or store other data files on your device. You hereby consent to the use of such cookies and data files. These cookies collect information (including personal data) about your use of the Platform, to automatically update the Platform and its components on your device, to add or remove functionalities, features or services. We use cookies and other technologies to facilitate your use of the Platform and to improve your experience of the Platform. You may change the settings on your device to block the use of cookies. However, if you do choose to block the cookies used on this Platform, you may not be able to use certain features and functions of the Platform.

• 3.

  Purposes for Collection, Use and Disclosure of Personal Data

  • 1.

    Depending on your relationship with us, the personal data which we collect from you (either directly or through our affiliates, related companies or any other third party) may be collected, used and disclosed for the following (non-exhaustive) purposes:

    • (a)

      to verify your identity, and to manage and administer the account that you may have set up with us. For instance, we may use your email address and phone number as unique identifiers to prevent individuals from using multiple accounts to access the Platform and our Services;

    • (b)

      to facilitate your use of the services or access to the Platform. For instance, Suntec+ members will be automatically signed in as a Suntec+ member for applicable third party platforms, to ensure a seamless experience for users;

    • (c)

      to process orders you submit through the Platform (including any payments that you make for such products);

    • (d)

      to verify and carry out financial transactions in relation to payments you make online, and to ascertain your identity for anti-money laundering, suspicious transactions reporting and fraud detection purposes;

    • (e)

      to (i) keep track of your purchase records, (ii) allocate rewards points according to your purchase records, (iii) update you periodically about relevant programs through which you may earn rewards points, (iv) redeem your rewards points and utilise your e-vouchers when you shop with participating merchants and (v) update our profiling of customer preferences so that we may be able to serve you better;

    • (f)

      to allow our affiliates to deliver any of our products that you have purchased through the Platform or our and to verify delivery of the products. We may pass your personal data on to a third party in order to make delivery of the product to you (for example to our courier or supplier);

    • (g)

      to communicate with you and to process and respond to your queries, feedback, claims or disputes, whether directly or through any outsourced customer service vendors. For instance, in order for a customer service representative respond to your questions or concerns and to communicate with you so that we answer your questions as completely and thoroughly as possible, we may need personal data like your name, email and telephone number for verification purpose;

    • (h)

      to facilitate any events that we may hold. For instance, when you participate in a contest, we ask for personal data in order for us to identify and verify the winner of our contest;

    • (i)

      to update you on any of the products and services of APM and our affiliates as well as any latest developments;

    • (j)

      to improve our Platform or to improve the services provided;

    • (k)

      to carry out market research on our users demographics, advertising or purchasing preferences, and other behaviour;

    • (l)

      to provide you with information we think you may find useful or which you have requested from us, including information about our or affiliates’ products and services, provided you have indicated that you have not objected to being contacted for these purposes, if applicable;

    • (m)

      to comply with a court order or other legal process or other statutory and/or regulatory requirements of any governmental and/or regulatory authorities; and

    • (n)

      any other purpose permitted by the applicable laws of Singapore, or as may be described to you from time to time at the point of collection of your personal data

    • (collectively, "the Purposes".)

• 4.

  Sharing of Personal Data

  • 1.

    We may share your personal data with third parties, related companies and our affiliates for any of the Purposes.

  • 2.

    In sharing your personal data with external parties, we endeavour to ensure that the third parties and our affiliates and related companies keep your personal data secure from unauthorised access, collection, use, disclosure, processing or similar risks and retain your personal data only for as long as they need your personal data to achieve the abovementioned Purposes.

• 5.

  Accuracy of Personal Data

  • 1.

    It is important that the personal data you provide to us is accurate and complete. You are responsible for informing us of changes to your personal data, or in the event you believe that the personal data we have about you is inaccurate, incomplete, misleading or out of date.

  • 2.

    You will be able to update your personal data at any time by through the “Profile” page. Alternatively, if you are unable to do so, you may contact our Data Protection Officer as indicated below.

  • 3.

    We may take steps to share the updates to your personal data with third parties and our affiliates with whom we have shared your personal data if your personal data is still necessary for the above Purposes.

• 6.

  Transfers of Personal Data Outside Singapore

  • 1.

    By providing us with your personal data, you understand and agree that your personal data may be transferred to servers located outside Singapore for processing by us, our affiliates and/or any other organisation which we may choose, in accordance with this Policy.

  • 2.

    In situations where we transfer your personal data overseas, we shall take steps to ensure that appropriate levels of protection necessary to maintain the security and integrity of your personal data are in place. We shall ensure that the recipient organisation is able to provide the transferred personal data with a standard of protection comparable to that under the PDPA.

• 7.

  Withdrawal of Consent

  • 1.

    You may, at any time, communicate the withdrawal of your consent to the continued use, disclosure, storing and/or processing of your personal data for any of the Purposes as stated above by contacting our Data Protection Officer as indicated below.

  • 2.

    Please note that if you withdraw your consent to our use, disclosure, storing or processing of your personal data for the Purposes as stated above, we may not be able to continue to provide the services to you or perform on any contract we have with you, and we will not be liable in the event that we do not continue to provide the services to, or perform our contract with you.

  • 3.

    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 and effect your request within ten (10) business days of receiving it.

  • 4.

    Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclosure without consent is permitted or required under applicable laws.

• 8.

  Access to and Correction of Personal Data

  • 1.

    You may, at any time, request to access your personal data in our possession, or enquire about the ways in which your personal data may have been used, disclosed, stored or processed by us for the past year. You may also, at any time, request to correct any error or omission in your personal data records.

  • 2.

    In order to facilitate the processing of your access or correction request, it may be necessary for us to request further information relating to your request. Please also note that an administrative fee may be payable on access requests made.

  • 3.

    If you wish to access, or correct an error or omission in, your personal data records, please contact our Data Protection Officer as indicated below. 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 from the date of your request, we will inform you in writing.

  • 4.

    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 applicable data protection laws).

  • 5.

    Please note that depending on the request that is being made, we will only need to provide you with access to the personal data contained in the documents requested, and not to the entire documents themselves. In those cases, it may be appropriate for us to simply provide you with confirmation of the personal data that we have on record, if the record of your personal data forms a negligible part of the document.

• 9.

  Retention of Personal Data

  • 1.

    We may retain your personal data for as long as the purpose for which the personal data was collected continues, or if the retention is necessary for our legal or business purposes, even in circumstances where you have closed your account with us. We will cease to retain personal data once we have no reason for doing so.

• 10.

  Security of Personal Data

  • 1.

    The security of your personal data is important to us. We have implemented technical, procedural and other measures to protect your personal data from unauthorised access, improper use or disclosure, unauthorised modification, unlawful destruction or accidental loss.

• 11.

  Contact Us

  • 1.

    If you have any questions on this Policy or if you have any other queries in relation to how we may manage, protect and/or process your personal data, please contact our Data Protection Officer at DPO@apmasia.com.sg.

This Policy is accurate as of 7 February 2023