1.1 We, Spicewharfs Private Limited, are committed to safeguarding your privacy. We treat all personal data provided by you in strict confidence, and will only use your personal data in the manner set out in this Privacy Policy. This Privacy Policy applies to all personal data that you provide to us and the personal data we hold about you.
1.2 This Privacy Policy describes how we may collect, use, disclose, process and manage your personal data when you:
1.2.1 visit http://handleowl.com (“Website”);
1.2.2 download and use our HandleOwl mobile application (“App”); and/or
1.2.3 provide us with your personal data, regardless of the medium through which such personal data is provided.
1.3 By providing us with your personal data, accessing or using the Website and/or App, you consent to our collection, use and disclosure (including transfer) of your personal data in accordance with this Privacy Policy. Please DO NOT provide any personal data to us if you do not accept this Privacy Policy.
1.3 Information provided by organisations to us for business purposes is not considered as personal data. This Privacy Policy does not apply to business contact information.
2. AMENDMENT TO THIS PRIVACY POLICY
We may amend this Privacy Policy from time to time without notice to you. The updated Privacy Policy will supersede earlier versions and will apply to personal data provided to us previously. The updated Privacy Policy will be made available upon request from us and on our Website. If you do not accept any amendment to the Privacy Policy, please contact our Data Protection Officer (see paragraph 1 below).
3. WEBSITES
3.1 Use of cookies. Cookies are small text files which are set by a website or application operator so that your browser or device may be recognised. We may make use of cookies on our Website and App to store and track information such as the number of users and their frequency of use, profiles of users and their online preferences. Cookies do not capture information which would personally identify you, but the information collected may be used to assist us in analysing the usage of our Website and App and to improve your online experience with us. You can disable the cookies by changing the setting on your browser. However, this may affect the functionality of the Website and App.
3.2 Links to other websites. Our Website and App may contain links to other websites which are not owned or maintained by us. These links are provided only for your convenience. This Privacy Policy only applies to our Website and App. When visiting these third party websites, you should read their privacy policies.
4. PERSONAL DATA
4.1 What is personal data? “Personal data” is data that can be used to identify a natural person. The personal data we may collect from you includes but is not limited to:
4.1.1 contact information (e.g. name, mailing or email address, fax and telephone number);
4.1.2 NRIC, passport or other identification number;
4.1.3 date of birth;
4.1.4 photograph;
4.1.5 video image;
4.1.6 financial information such as credit card details;
4.1.7 IP address;
4.1.8 shopping preferences;
4.1.9 transactional information based on your activities on the Website and App (such as services purchased and content generated and related to your account);
4.1.10 personal data of family members;
4.1.11 education background;
4.1.12 employment history;
4.1.13 references; and
4.1.14 any other information relating to any individuals which you have provided us in any form(s) you may have submitted to us, or via other forms of interaction with you.
4.2 Voluntary provision of personal data. Your provision of personal data to us is voluntary. However, if you choose not to provide us with the personal data we require, it may not be possible for us to contact you, or provide products or services which you need from us.
4.3 Providing personal data belonging to others. If you provide us with the personal data of anyone other than yourself, you warrant that you have informed him/her of the purposes for which we are collecting his/her personal data and that he/she has consented to your disclosure of his/her personal data to us for those purposes. You agree to indemnify and hold us harmless from and against any and all claims by such individuals relating to our collection, use and disclosure of such personal data in accordance with the terms of this Privacy Policy.
4.4 Accuracy and completeness of personal data. You must ensure that all personal data that you provide is true, accurate and complete.
5. COLLECTION OF PERSONAL DATA
5.1 Generally, we may collect your personal data when:
5.1.1 you register for a user account in order to access and use the Website and App;
5.1.2 you use our Website and App;
5.1.3 you enter information on the Website and the App;
5.1.4 you engage us to provide you with services;
5.1.5 you attend our events;
5.1.6 you participate in competitions, contests or games organised by us;
5.1.7 you contact us or interact with our employees through various communication channels, for example, through social media platforms, face-to-face meetings, telephone calls, emails, fax and letters;
5.1.8 you request that we contact you or request to be included in an email or our mailing list;
5.1.9 you respond to our request for additional personal data;
5.1.10 your images are captured via CCTV cameras while you are within our premises;
5.1.11 your images are captured via photographs or videos taken by us or our representatives when you attend events organised by us;
5.1.12 you submit an employment application or when you provide documents or information including your resume/CVs in connection with any employment application;
5.1.13 you enter into any agreement with us or provide any other documentation of information to us; and
5.1.14 you submit your personal data to use for any other purposes or reasons.
5.2 When downloading the App, the online / mobile application store may collect personal data from you. We will not be responsible for the personal data collected by the online / mobile application store.
6. PURPOSES FOR COLLECTION, USE OR DISCLOSURE OF YOUR PERSONAL DATA
6.1 General purposes. Generally, we collect, use or disclose your personal data for the following purposes:
6.1.1 managing your relationship with us;
6.1.2 authenticating, operating and maintaining your user account;
6.1.3 facilitating your use of the Website and App;
6.1.4 managing your user account;
6.1.5 providing you with the services that you have requested for;
6.1.6 to provide you with personalised services based on your past usage of the Website and App;
6.1.7 allow interaction between you and other users of the Website and App (depending on your profile setting);
6.1.8 to keep you updated on our programmes and events;
6.1.9 to invite you to our events;
6.1.10 assessing your performance in any competitions, contests or games organised by us;
6.1.11 processing your job application and assessing your suitability for the position applied for;
6.1.12 resolving disputes;
6.1.13 to assist you with your enquiries, and respond to your feedback, complaints and requests;
6.1.14 managing the safety and security of our premises and event premises (including but not limited to carrying out CCTV surveillance and conducting security clearances); and
6.1.15 any other reasonable purposes related to the aforesaid.
6.2 Business purposes. We may also use your personal data for purposes connected or relevant to our business, such as:
6.2.1 complying with our legal obligations and requirements;
6.2.2 enforcing obligations owed to us, and contractual terms and conditions;
6.2.3 accounting, risk management and record keeping;
6.2.4 carrying out research, planning and statistical analysis;
6.2.5 staff training; and
6.2.6 any other reasonable purposes related to the aforesaid.
6.3 Additional purposes. If you have consented, we may use your personal data, from time to time, for additional purposes such as:
6.3.1 to inform you of the latest activities, special offers and promotions offered by our strategic business partners and associates; and
6.3.2 to use your photographs on the Website, App and/or in publicity materials.
6.4 Contacting you. When using your personal data to contact you for the above purposes, we may contact you via regular mail, fax, e-mail, SMS, telephone or any other means.
7 DISCLOSURE OF INFORMATION
7.1 We will not sell, rent or trade your personal data to third parties.
7.2 Consent for disclosure to others. If you have consented to our disclosure of your personal data to our related entities, strategic business partners and associates, we may disclose your personal data to them. They will use your personal data only for the purposes you have consented to.
7.3 Disclosure to service providers. You agree that we may disclose or share your personal data with third parties such as:
7.3.1 service providers and data processors working on our behalf and providing services to us such as accounting, hosting and maintenance services, analysis services, e-mail message services, delivery services, handling of payment transactions, marketing etc; and
7.3.2 our consultants and professional advisors (such as accountants, lawyers, auditors).
7.4 Other permitted disclosure. We may also disclose your personal data as required or permitted by law. We may disclose your personal data to regulatory authorities, statutory bodies or public agencies for the purposes of complying with their respective requirements, policies and directives.
7.5 The Website and App may have the functionalities to allow you to share your personal data with third parties such as other users of the Website and App. You are responsible for your choice(s) and are deemed to have provided consent for any sharing of your personal data in the manner provided by the Website and App.
8. TRANSFER OF PERSONAL DATA OUT OF SINGAPORE
8.1 Transfer outside Singapore. You fully understand and unambiguously consent that we may transfer your personal data to any location outside of Singapore for the purposes set out above.
8.2 Protection of your personal data. If we transfer your personal data to a country or territory outside of Singapore, we will ensure that the recipient of the personal data provides a standard of protection that is comparable to the protection which your personal data enjoys under the laws of Singapore. Where these countries or territories do not have personal data protection laws which are comparable to that in Singapore, we will enter into legally enforceable agreements with the recipients to ensure that they protect your personal data to the same standard as required under the laws of Singapore.
9. PROTECTION OF PERSONAL DATA
9.1 We will take reasonable precautions to safeguard your personal data. While reasonable precautions will be taken to ensure that the information you provide is protected against unauthorised or unintended access, we cannot be held responsible for unauthorised or unintended access that is beyond our control.
10. RETENTION OF PERSONAL DATA
10.1 We will keep your personal data for so long as we need the personal data for our business and legal purposes.
11. YOUR RIGHTS
11.1 Contact Data Protection Officer. If you wish to withdraw any consent you have given us at any time, or if you wish to correct or have access to your personal data held by us, or if you do not accept any amendment to this Privacy Policy, please contact our Data Protection Officer:
Name : Edwin Cheng
Telephone : +65 8599 9958
Email : edwin@spicewharfs.com
11.2 Fee for access. We may charge you a fee for responding to your request for access to your personal data held by us, or for information about the ways in which we have (or may have) used your personal data in the one-year period preceding your request. If a fee is to be charged, we will inform you of the amount beforehand and respond to your request after payment is received. We will endeavour to respond to your request within thirty (30) days, and if that is not possible, we will inform you of the time by which we will respond to you.
11.3 Effect of withdrawal of consent. In many circumstances, we need to use your personal data in order for us to provide you with products or services which you require. If you do not provide us with the required personal data, or if you withdraw your consent to our use and/or disclosure of your personal data for these purposes, it may not be possible for us to continue to serve you or provide you with the products and services that you require.
12. GOVERNING LAW
12.1 This Privacy Policy is governed by the laws of the Republic of Singapore. You agree to submit to the exclusive jurisdiction of the Courts of the Republic of Singapore in any dispute relating to this Privacy Policy.
