DATA PROTECTION NOTICE FOR SGSTAMP REWARDS MEMBERS

This Data Protection Notice (“Notice”) sets out the basis which Singapore Philatelic Bureau  (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of our  customers in accordance with the Personal Data Protection Act (“PDPA”). This Notice applies  to personal data in our possession or under our control, including personal data in the  possession of organisations which we have engaged to collect, use, disclose or process  personal data for our purposes.  

Personal Data  

1. As used in this Notice: 

“customer” means an individual who (a) has contacted us through any means to find  out more about any goods or services we provide, or (b) may, or has, entered into a  contract with us for the supply of any goods or services by us; and 

“personal data” means data, whether true or not, about a customer who can be  identified: (a) from that data; or (b) from that data and other information to which we  have or are likely to have access.  

2. Depending on the nature of your interaction with us, some examples of personal data  which we may collect from you include name, residential address, email address,  telephone number, gender and date of birth.  

3. Other terms used in this Notice shall have the meanings given to them in the PDPA  (where the context so permits). 

Collection, Use and Disclosure of Personal Data 

4. We generally do not collect your personal data unless (a) 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 (i) you (or your  authorised representative) have been notified of the purposes for which the data is  collected, and (ii) you (or your authorised representative) have provided written  consent to the collection and usage of your personal data for those purposes, or (b)  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). 

5. We may collect and use your personal data for any or all of the following purposes: 

(a) verifying your identity; 

(b) responding to, handling, and processing queries, requests, applications,  complaints, and feedback from you; 

(c) managing your relationship with us; 

(d) processing payment or credit transactions; and 

(e) transmitting to any unaffiliated third parties including our third party service  providers and agents, and relevant governmental and/or regulatory authorities,  whether in Singapore or abroad, for the aforementioned purposes.

6. We may disclose your personal data: 

(a) to third party service providers, agents and other organisations we have  engaged to perform any of the functions with reference to the above mentioned  purposes. 

Reliance on The Legitimate Interests Exception 

7. In compliance with the PDPA, we may collect, use or disclose your personal data  without your consent for the legitimate interests of Singapore Philatelic Bureau or  another person. In relying on the legitimate interests exception of the PDPA, Singapore  Philatelic Bureau will assess the likely adverse effects on the individual and determine  that the legitimate interests outweigh any adverse effect.  

8. In line with the legitimate interests’ exception, we will collect, use or disclose your  personal data for the following purposes: 

a. Detection and prevention of misuse of services. 

The purposes listed in the above clause 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. 

Withdrawing Your Consent  

9. The consent that you provide for the collection, use and disclosure of your personal  data will remain valid until such time it is being withdrawn by you in writing. You may  withdraw consent and request us to stop collecting, 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. 

10. 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.  

11. 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 in the manner described in clause 7  above.  

12. 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 

13. If you wish to make (a) 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 (b) a correction request to correct or update any of your personal  data which we hold about you, you may submit your request in writing or via email to  our Singapore Philatelic Bureau. 

14. We will respond to your request as soon as reasonably possible. In general, our  response will be within five (5) business days. Should we not be able to respond to  your request within thirty (30) days after receiving your request, we will inform you in  writing within thirty (30) days of the time by which we will be able to respond to your  request. 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 PDPA). 

Protection of Personal Data 

15. 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 such as minimised collection of  personal data, authentication and access controls (such as good password practices,  need-to-basis for data disclosure, etc.), data anonymisation, and up-to-date antivirus  protection.  

16. You should be aware, however, that 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 and are constantly  reviewing and enhancing our information security measures. 

Accuracy of Personal Data 

17. 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 to your personal data by informing our  Customer Service Department via email to sinstamp@singpost.com. 

Retention of Personal Data  

18. We may retain your personal data for as long as it is necessary to fulfil the purpose for  which it was collected, or as required or permitted by applicable laws. 

19. We will cease to retain your personal data, or remove the means by which the data  can be associated with you, as soon as it is reasonable to assume that such retention  no longer serves the purpose for which the personal data was collected, and is no  longer necessary for legal or business purposes. 

Transfers of Personal Data Outside of Singapore 

20. We generally do not transfer your personal data to countries outside of Singapore.  However, if we do so, we will obtain your consent for the transfer to be made and we  will take steps to ensure that your personal data continues to receive a standard of  protection that is at least comparable to that provided under the PDPA.

Effect of Notice and Changes to Notice 

21. This Notice applies in conjunction with any other notices, contractual clauses and  consent clauses that apply in relation to the collection, use and disclosure of your  personal data by us. 

22. We may revise this Notice from time to time without any prior notice. You may  determine if any such revision has taken place by referring to the date on which this  Notice was last updated. Your continued use of our services constitutes your  acknowledgement and acceptance of such changes.