- This Policy statement provides information on the obligations and policies of Pratique in respect of an individual customer’s Personal Data. Pratique undertakes to use reasonable efforts in applying, where practicable, those principles and the processes set out herein to its operations.
- Pratique’s management and members of staff shall use reasonable endeavors to respect the confidentiality of and keep safe any and all Personal Data collected and/or stored and/or disclosed and/or used for, or on behalf of, Pratique. Pratique shall use reasonable endeavors to ensure all collection and/or storage and/or disclosure and/or usage of Personal Data by Pratique shall be done in an appropriate manner and in accordance to the Personal Data Protection Act (“Act”) and this Policy.
2. Contacting the Data Protection Officer
- Where you legitimately request access to and/or correction of Personal Data relating to you which is in the possession and control of Pratique, Pratique shall provide and/or correct that data in a reasonable time and manner in accordance with its standard procedures as stated hereinafter.
- In accordance with the Act, Pratique has established a process for receiving and responding to any query or complaint that may arise with respect to the application of the Act. To ensure that Pratique receives your complaints and enquiries, please send the same via email to email@example.com.
- Should you not wish Pratique to use your Personal Data for any of the purposes listed in Clauses 3.2 to 3.4, or not to receive promotional materials from Pratique, you may opt out by sending a clearly worded email to firstname.lastname@example.org. Your request shall be processed within a reasonable time.
3. Statement of Practices
3.1 Types of Personal Data Collected
As part of its day to day activities, Pratique may collect from you, through various means, including via our website, from time to time, the following Personal Data: name (first and surname); postal address; phone number (including mobile); fax number; e-mail address; gender; Personal Data of your emergency contacts; photographs and images.
3.2 Purpose of Collection of Personal Data
The above Personal Data mentioned in Clause 3.1 is collected for the purposes of processing your application and registration of your participation and/or membership and to ascertain if you are eligible for discounts, privileges or benefits or other related purposes; to conduct market research and analysis; for direct marketing through voice calls; text messages; email; direct mail and facsimile messages; to notify you of any changes to our policies or services which may affect you; to respond to queries and feedback; for identification and access; maintaining and updating your personal details; and informing you of new developments, services, promotions of Pratique and other third parties which we may be associated with.
3.3 Disclosure of Personal Data
Pratique will not, in any way, disclose your Personal Data unless they are for regulators and law enforcement officials; lawyers; auditors; third party service providers and consultants; third party investors; credit, debit and charge card companies, banks and other entities processing payment; and any agent or subcontractor acting on Pratique’s behalf for the provision of Pratique’s services.
4. Transfer of Personal Data Overseas
Your Personal Data may be processed by Pratique in jurisdictions outside of Singapore. In this event Pratique will comply with the terms of the Act.
5. Accuracy of Personal Data
Where possible, Pratique will validate data provided using generally accepted practices and guidelines. This includes the use of check sum verification on some numeric fields such as account numbers or credit card numbers. In some instances, Pratique is able to validate the data provided against pre-existing data held by Pratique. In some cases, Pratique is required to see original documentation before we may use the Personal Data such as with Personal Identifiers and/or proof of address. To assist in ensuring the accuracy of your Personal Data in the possession of Pratique, please inform us of any updates of any parts of your Personal Data by sending a clearly worded email to the DPO at email@example.com.
6. Protection of Personal Data
Pratique uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your Personal Data and will not knowingly allow access to this data to anyone outside Pratique, other than to you or as described in this Policy. However, Pratique cannot ensure or warrant the security of any information you transmit to Pratique and you do so entirely at your own risk. In particular, Pratique does not warrant that such information may not be accessed, altered, collected, copied, destroyed, disposed of disclosed or modified by breach of any of Pratique’s physical, technical, or managerial safeguards.
7. Access and Correction of Personal Data
7.1 In accordance with Clause 2.1 of this Policy, you have the right to:
- check whether Pratique holds any Personal Data relating to you and, if so, obtain copies of such data; and
- require Pratique to correct any Personal Data relating to you which is inaccurate for the purpose for which it is being used.
7.2 Pratique reserves the rights to charge a reasonable administrative fee in order to meet your requests under Clause 7.1. Upon payment of the requisite fee, your request shall be processed within a reasonable time.
7.3 If you wish to verify the details you have submitted to Pratique or if you wish to check on the manner in which Pratique uses and processes your Personal Data, Pratique’s security procedures mean that Pratique may request proof of identity before we reveal any information. This proof of identity will take the form of full details of name, membership number and NRIC or Passport or FIN number, amongst others. You must therefore keep this information safe as you will be responsible for any action which Pratique takes in response to a request from someone using your personal information. We would strongly recommend that you do not use the browser’s password memory function as that would permit other people using your terminal to access your personal information.
8. Storage and Retention of Personal Data
Pratique will delete, as reasonably possible, or otherwise anonymise any Personal Data in the event that the Personal Data is not required for any reasonable business or legal purposes of Pratique and where the Personal Data is deleted from Pratique’s electronic, manual, and other filing systems in accordance with Pratique’s internal procedures and/or other agreements.
9. Change Policy
Pratique reserves the right to alter any of the clauses contained herein in compliance with legislation and/or policy requirements, and for any other purpose deemed reasonably necessary by Pratique. You should look at these terms regularly. If you do not agree to the modified terms, you should inform us as soon as possible of the terms to which you do not consent. Pending such notice, if there is any inconsistency between these terms and the additional terms, the additional terms will prevail to the extent of the inconsistency.
10. Governing Law
This Policy is governed by and shall be construed in accordance with the laws of Singapore. You hereby submit to the non-exclusive jurisdiction of the Singapore courts.
11.1 This Policy only applies to the collection and use of Personal Data by Pratique. It does not cover third party sites to which we provide links, even if such sites are co-branded with our logo. Pratique does not share your Personal Data with third party websites. Pratique is not responsible for the privacy and conduct practices of these third party websites, so you should read their own privacy policies before disclosure of any Personal Data to these websites.
11.2 Pratique will not sell your personal information to any third party without your permission, but we cannot be responsible or held liable for the actions of third party sites which you may have linked or been directed to Pratique’s website.
11.3 Pratique’s websites do not target and are not intended to attract children under the age of 18 years old. Pratique does not knowingly solicit personal information from children under the age of 18 years old or send them requests for personal data.