PDPA DATA PROTECTION POLICY - APPLICABLE TO NON-EU SUBJECTS ONLY
PRIMA GROUP DATA PROTECTION POLICY FOR CUSTOMERS
This is a Data Protection Policy (“Policy”) issued under the Personal Data Protection Act.
In this Policy, “we”, “us”, “our” or “Prima” means Prima Group of Companies, its subsidiaries, related corporations and business units (collectively referred to as “Prima“), “you”, “your” or “yours” means the persons to whom this Policy applies.
This Policy describes how we may collect, use, disclose, process and manage your Personal Data and applies to any individual’s Personal Data which is in our possession or under our control.
As a customer of Prima, by submitting information to us or signing up for our products and services, you agree and consent for our collection, use, disclosure and sharing within and amongst the Prima Group of Companies, and disclosing such Personal Data to our authorised service providers and relevant third parties, as the case may be, where applicable, as set out herein.
This Policy supplements but does not supersede nor replace any other consents you may have previously provided to Prima in respect of your Personal Data, and your consents herein are additional to any rights which Prima may have at law to collect, use or disclose your Personal Data.
We may update this Policy from time to time to ensure that this Policy is consistent with any developments in the way Prima uses your Personal Data or any changes to the laws and regulations applicable to Prima. We will make available the updated Policy on our websites below or as notified.
- Personal Data
- 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 Prima has or is likely to have access, including without limitation data in our records as may be updated from time to time.
- Personal Data includes (depending on the type of interaction with Prima) your name, date of birth, NRIC number, passport or other identification number, telephone number(s), mailing address, email address, network data and any other information relating to you or any individuals which you have provided to Prima in any forms you may have submitted to us, or via other methods of interaction with you, as the case may be, where applicable.
- Collection of Personal Data
2.1 We will request your Personal Data:-
- a) When you submit an application or other forms relating to any Prima products and services;
- b) When you interact with our customer service officers, for example via telephone calls, face-to-face meetings, emails and other correspondences;
- c) When you use Prima services, for example via websites and apps or other electronic IT applications including any online accounts with us;
- d) When you request to be included in an email, mailing lists and other forms of updates and communications;
- e) When you respond to our promotions, initiatives or requests for additional Personal Data;
- f) When you are contacted by, and respond to, our marketing representatives and customer service officers;
- g) When we receive referrals from business partners and third parties;
- h) When we seek information from third parties about you in connection with Prima products and services you have applied for; and
- i) When you submit your Personal Data to us for any other reasons.
- 2.3 If you provide us with any Personal Data relating to a third party, for example spouse, children, parents, and/or other individuals, by submitting such information to us, you represent to us that you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes.
- 2.4 You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure to do so may result in our inability to provide you with the relevant Prima products and services you have requested.
- Purpose of Collection, Use and Disclosure of Personal Data
- 3.1 Personal Data will be collected, used and disclosed by Prima for the following purposes:-
- a) Administering, managing and executing our agreements with you;
- b) Responding to your queries and requests;
- c) Managing the administrative and business operations of Prima and complying with our internal policies and procedures;
- d) Facilitating business asset transactions involving any Prima companies;
- e) Resolving complaints and handling requests and enquiries in relation to Prima business;
- f) Preventing, detecting and investigating crime, analysing and managing commercial risks;
- g) Providing media announcements and responses;
- h) Monitoring, recording phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes;
- i) Legal purposes (including but not limited to obtaining legal advice and dispute resolution);
- j) Conducting investigations relating to disputes, billing or fraud;
- k) Delivery of notices, services or products and the marketing of such services or products whether presently or in future, to you;
- l) Maintenance and upkeep of customer records and development, marketing and client profiling activities, organising promotional events;
- m) Credit assessments, financial and background investigation, as the case may be, where applicable;
- n) Meeting any legal or regulatory requirements relating to provision of Prima services and products and to make disclosure to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority where applicable; and
- o) Sending you information by e-mail, regular postal mail, telecommunication means (telephone calls, SMS messages and other electronic format) or internet social media about products and services offered by selected third parties that we think may interest you.
- 3.2 You may at any time withdraw, in full or in part, your disclosure consent given previously, in each case subject to any applicable legal restrictions, contractual conditions and a reasonable time period in Paragraph 6.1 below.
- Disclosure of Personal Data
- 4.1 Prima will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, your Personal Data may be disclosed for the purposes listed in Paragraph 3 above, as the case may be, where applicable, to the following:-
- a) Prima to address your questions and requests in relation to you signing up for any Prima products and services;
- b) Business partners, affiliates, contractors, third party service providers who provide operational or related services or products in connection with our Prima business to facilitate your dealings with us;
- c) Vendors or third party service providers in connection with marketing promotions and services offered by Prima or its preferred partners;
- d) Commercial shops, retailers or our appointed service providers in relation to our loyalty programmes, delivery gift redemption and services or Prima business;
- e) Any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions involving Prima;
- f) Any government agencies, statutory boards or authorities or industry regulators to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority;
- g) Banks, credit card companies and their respective service providers;
- h) Our professional advisers such as auditors, consultants, lawyers, accountants or other financial or professional advisers in connection with our Prima business; and
- i) Any other party to whom you authorise us to disclose your Personal Data.
- 5.1 Prima uses “Cookies“, where a small data file is sent to your browser to store and track information about you and your preferences when you visit our websites.
- b) Enabling certain features and functions on our websites, such as remembering your user-id, browsing and other service preferences;
- c) Building up a profile of how you and other users use the websites;
- d) Improving the efficiency of our websites;
- e) Administering services to you and to advertisers; and
- f) Establishing usage statistics.
- 5.2 Most internet browsers provide you the option of turning off the processing of Cookies (please see the “help” section of your browser), but this may result in the loss of functionality, restrict your use of the websites and/or affect the way in which it operates.
- 5.3 Advertisements on our websites may be provided by third party advertisers and their agencies. These may generate Cookies to track how many people have seen a particular advertisement (or use the services of third parties to do this), and to track how many people have seen it more than once. Prima does not control these third parties and their cookie policies and if you have questions about their cookie policies, please contact Prima and we will try our best to assist by providing you information about these third party advertising agencies.
- 5.4 Prima is not responsible for the Personal Data policies (including Personal Data protection and Cookies), content or security of any third party websites linked to the Prima websites.
- Withdrawal of Consent, Access and Correction of Your Personal Data
- 6.1 You may at any time enquire or provide feedback relating to your Personal Data, this Policy, withdraw or amend, in full or in part, your consent given previously to any use of your Personal Data in our records subject to any applicable legal restrictions, contractual conditions and a reasonable time period. Please contact:-Data Protection Officer
- 6.2 Please note that if your Personal Data has been provided to us via a third party, you should contact that particular organisation or individual directly to make such queries, complaints, access and correction requests to Prima for you and on your behalf.
- 6.3 If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, Prima may not be able to continue providing our products and services to you or administer any contractual relationship, which may in turn result in the termination of any agreements between us. This may result in your being in breach of your contractual obligations or undertakings. In such an event, Prima expressly reserves all its legal rights and remedies.
- Governing Law
- 7.1 This Policy and your use of our websites shall be governed in all respects by the laws of Singapore.