Privacy Policy
This Privacy Policy (“Policy”) is designed to assist you in understanding how The TENG Ensemble Ltd (“we, “us” or “our”) may collect, use, disclose or otherwise process your personal data in accordance with the Personal Data Protection Act (“PDPA”).
This Policy supplements but does not supersede nor replace any other consents which you may have previously provided to us. We may from time to time update this Policy to ensure that it is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements.
1. Your Personal Data
1.1 As used in this Policy:
“Personal Data” means data, whether true or not, about you from which you 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.
1.2 Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include:
Your name, identification number such as NRIC, passport or other identification number, contact information such as residential address, email address or telephone number, nationality
Photos, films, portraits and/or video recordings of you
Your employment information, education background and financial information such as credit card numbers, debit card numbers or bank account information
Information about your usage of and interaction with our website, and/or services including computer and connection information, bandwidth, statistics on page views, and traffic to and from our website
1.3 Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context so permits).
2. Collection, Use and Disclosure of Personal Data
2.1 We generally do not collect your personal data unless:
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:
you (or your authorised representative) have been notified of the purposes for which the data is collected
you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purpose
Collection and use of personal data without consent is permitted or required by the PDPA or other laws
2.2 We may collect, use and disclose your Personal Data for the purposes for which we have specifically obtained your consent and the purposes for which you have provided your Personal Data to us. Some of the purposes are listed below and not limited to:
· Verifying your identity to provide the services requested by you or your authorised representative
· Processing your reservations and ticket purchases to our event or activities
· Processing your donations and your tax-deduction claims
· Processing your purchases of merchandises
· Processing and evaluating your application for employment and your suitability to volunteer
· Informing you of our upcoming events or activities, or other information which may be of interest to you. We may also invite you to participate in our events and activities.
· Responding to, handling, and processing your queries, applications, feedback and complaints
· Compiling statistics for us and/or industry exercises and studies, to design and improve our products and services for you
· Monitoring, evaluating and/or auditing of services provided. This may include an assessment of the quality of the services provided
· Complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority
· Any other purposes for which you have provided the information
· 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
· Any other incidental purposes related to or in connection with the above
2.3 We may disclose your personal data:
· Where such disclosure is required for, or in connection with, the provision of the services requested by you or your authorised representative
· To third party service providers, agents and other organisations we have engaged to perform any of the purposes listed in clause 2.3 above for us
· To comply with any applicable laws, regulations, codes of practice, guidelines, rules or requests by public agencies, or to assist in law enforcement and investigations
· Any other party to whom you authorised us to disclose your personal data to, or where necessary to undertake any action requested by you
2.4 The purposes listed in the above clauses may continue to apply even in situations where your relationship with us has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under a contract with you).
3. Withdrawing Your Consent
3.1 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 or your authorised representative in writing. You or your authorised representative 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 via email to our Data Protection Officer at the contact details provided clause 9.1. If you are unable to submit your request in writing or if you require any assistance with the submission of your request, you can ask to speak to our Data Protection Officer.
3.2 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 thirty (30) business days of receiving it.
3.3 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 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 the manner described in clause 3.1 above.
3.4. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
4. Access to and Correction of Personal Data
4.1 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 via email to our Data Protection Officer at the contact details provided clause 9.1. If you require assistance with the submission of your request, you can ask to speak to our Data Protection Officer.
4.2 Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
4.3 We will respond to your request as soon as reasonably possible. In general, our response will be within thirty (30) 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).
5. Protection of Personal Data
5.1 To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have put in place appropriate administrative, physical and technical measures.
5.2 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.
6. Accuracy of Personal Data
6.1 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 Data Protection Officer at the contact details provided in clause 9.1.
7. Retention of Personal Data
7.1 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.
7.2 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.
8. Use of Cookies and Web Analytics
8.1 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 and common entry and exit points into our website.
8.2 We use “cookies” where a small data file is sent to your browser to store and track Aggregate Information about you when you enter our website. The cookie is used to track information such as the number of users, their frequency of use, profiles of users, and their preferred sites.
8.3 The Aggregate Information collected, together with the use of web analytics, help us to analyse our web page flow and measure promotional effectiveness.
8.4 You are always free to decline our cookies (if your browser permits you to do so), although in that case you may not be able to use certain features on the website and you may be required to enter your personal data more frequently during a session on the website.
9. Transfers of Personal Data Outside of Singapore
9.1 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.
10. Data Protection Officer
10.1 You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:
Email Address: dpo@thetengcompany.com
11. Updates on Privacy
11.1 This policy 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.
11.2 We reserve the right to amend this policy at any time and will place any amended policy here.