This policy statement provides information on the obligations and policies of A Higher Place Pte. Ltd., with a business address at 18B Circular Road, Singapore 049374 (the “Company”) equal to any in the world in respect of the protections they provide to an individual.
We at A higher Place (“A Higher Place Pte. Ltd.”) take our responsibilities under Singapore’s Personal Data Protection Act 2012 (the “PDPA”) seriously. We also recognize the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data.
This Data Protection Policy is designed to assist you in understanding how we collect, use, disclose and/or process the personal data you have provided to us, as well as to assist you in making an informed decision before providing us with any of your personal data.
If you, at any time, have any queries on this policy or any other queries in relation to how we may manage, protect and/or process your personal data, please do not hesitate to contact our Data Protection Officer (the “DPO”) at:
Data Protection Officer
A Higher Place Pte. Ltd.
INTRODUCTION TO THE PDPA
1.1. “Personal Data” is defined under the PDPA to mean data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access. Common examples of personal data could include names, identification numbers, contact information, medical records, photographs and video images.
1.2. We will collect your personal data in accordance with the PDPA. We will notify you of the purposes for which your personal data may be collected, used, disclosed and/or processed, as well as obtain your consent for the collection, use, disclosure and/or processing of your personal data for the intended purposes, unless an exception under the law permits us to collect and process your personal data without your consent.
1.3. Types of Personal Data Collected :
For the purpose of carrying on the Company’s business, including registration and administration of the Company’s related products and services (including relevant online services), you may be requested to provide personal data such as, but not limited to, the following, without which it may not be possible to satisfy your request:
1.3.1. Your name;
1.3.2. Correspondence address, and/or billing address;
1.3.3. Payment details, including credit card and banking information;
1.3.4. Contact details, including contact name and telephone number or email address
1.3.5. Your image taken at our premises with a web cam (or like equipment ) for visual identification
1.4. In some instances, you may also be requested to provide certain data that may be used to further improve our products and services and/or better tailor the type of information presented to you. In most cases, this type of data is optional although, where the requested service is a personalised service, or provision of a product or dependant on your providing all requested data, failure to provide the requested data may prevent us from providing the service to you. This type of data includes, but is not limited to:
1.4.1. Your age;
1.4.3. Salary range and employment details;
1.4.4. Education and Profession;
1.4.5. Hobbies and leisure activities;
1.4.6. Other related products and services subscribed to; and
1.4.7. Family and household demographics.
PURPOSES FOR COLLECTION, USE, DISCLOSURE AND PROCESSING OF PERSONAL DATA
2.1. The personal data which we collect from you may be collected, used, disclosed and/or processed for various purposes, depending on the circumstances for which we may/will need to process your personal data, including :
2.1.1. Administration of your membership, packages and enquiry
2.1.2. Marketing purposes
2.1.3. any other purposes which we notify you of at the time of obtaining your consent.
(collectively, the “Purposes”)
2.2. As the purposes for which we may/will collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of your personal data without your consent is permitted by the PDPA or by law.
2.3. In order to conduct our business operations more smoothly, we may also be disclosing the personal data you have provided to us to our third party service providers, agents and/or our affiliates or related corporations, and/or other third parties whether sited in Singapore or outside of Singapore, for one or more of the above-stated Purposes. Such third party service providers, agents and/or affiliates or related corporations and/or other third parties would be processing your personal data either on our behalf or otherwise, for one or more of the above-stated Purposes. Examples of service providers include companies that provide web hosting, data analysis, payment processing, order fulfillment, information technology and related infrastructure provision, customer service, email delivery, marketing, auditing and other services
By submitting the personal data [in this form], you undertake and warrant that;
(a) you have the authority to provide that personal information to A Higher Place;
(b) the personal data provided is accurate and true;
(c) you have informed the individual about the purposes for which his/her personal information is collected, used and disclosed as well as the parties to whom such personal information may be disclosed or transferred by A Higher Place, as set out [in this form]; and
(d) the individual has consented to the collection, use and disclosure of his/her personal information for such purposes.
SPECIFIC ISSUES FOR THE DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES
3.1. We respect the confidentiality of the personal data you have provided to us.
3.2. In that regard, we will not disclose your personal data to third parties without first obtaining your consent permitting us to do so. However, please note that we may disclose your personal data to third parties without first obtaining your consent in certain situations, including, without limitation, the following :
3.2.1. cases in which the disclosure is required or authorized based on the applicable laws and/or regulations;
3.2.2. cases in which the purpose of such disclosure is clearly in your interests, and if consent cannot be obtained in a timely way;
3.2.3. cases in which the disclosure is necessary to respond to an emergency that threatens the life, health or safety of yourself or another individual;
3.2.4. cases in which the disclosure is necessary for any investigation or proceedings;
3.2.5. cases in which the personal data is disclosed to any officer of a prescribed law enforcement agency, upon production of written authorisation signed by the head or director of that law enforcement agency or a person of a similar rank, certifying that the personal data is necessary for the purposes of the functions or duties of the officer;
3.2.6. cases in which the disclosure is to a public agency and such disclosure is necessary in the public interest; and/or
3.2.7. where such disclosure without your consent is permitted by the PDPA or by law.
3.3. The instances listed above at paragraph [3.2] are not intended to be exhaustive. For more information on the exceptions, you are encouraged to peruse the Second, Third and Fourth Schedules of the PDPA which is publicly available at http://statutes.agc.gov.sg.
3.4. Where we disclose your personal data to third parties with your consent, we will employ our best efforts to require such third parties to protect your personal data.
4.1.2. To improve your user experience on this website;
4.1.3. to remember your preferences;
4.1.4. to help us understand how this website is performing;
4.1.5. to monitor traffic to the website;
4.1.6. to enable this website to function properly;
4.1.7. (collectively the “Purposes”)
4.3. Personal data (if any) that we collect from you through cookies may be passed to our third party service providers, whether located in Singapore or elsewhere, for one or more of the Purposes, for managing and/or administering our website, or for the purpose of data hosting/storage/backup.
- Under certain circumstances, telephone calls made to our order and/or service hotlines and/or inquiry telephone numbers are recorded for the purposes of quality control, appraisal, as well as staff management and development. Unless expressly indicated at the time of calling, such recordings are NOT personal data of the caller and therefore, in respect of the caller, are not subject to the various provisions of the Ordinance and the caller has no rights and/or claims; either statutory, contractual or tortuous, over or to such data. At all times, every care is taken to protect such recordings from inadvertent and/or unauthorized access.
ACCURACY OF PERSONAL DATA
Where possible, we 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, we are able to validate the data provided against pre-existing data held by the Company. In some cases, the Company is required to see original documentation before we may use the personal data such as with Personal Identifiers and/or proof of address.
The Company will honor an individual’s request not to use his or her personal data for the purposes of direct marketing. Any such request should clearly state details of the personal data in respect of which the request is being made. Specifically, we request that you include the corresponding Company assigned account numbers which are printed on the Company’s statements/invoices. Please also state clearly the authority under which you are authorized to make such a request. Unless otherwise instructed as per the above, the Company may use any of the data collected in the normal course of its business for marketing purposes.
LINKS TO OTHER WEBSITES
A Higher Place provides links to web sites outside of the A Higher Place site. These linked sites are not under the control of A Higher Place, and A Higher Place is not responsible for the conduct of companies linked to the A Higher Place website, nor for the performance or otherwise of any content and/or software contained in such external websites.
REQUEST FOR ACCESS AND/ OR CORRECTION OF PERSONAL DATA
9.1. You may request to access and/or correct the personal data currently in our possession or control by submitting a written request to us. We will need enough information from you in order to ascertain your identity as well as the nature of your request, so as to be able to deal with your request. Hence, please submit your written request on our online enquiry forms.
9.2. For a request to access personal data, once we have sufficient information from you to deal with the request, we will seek to provide you with the relevant personal data within 30 days. Where we are unable to respond to you within the said 30 days, we will notify you of the soonest possible time within which we can provide you with the information requested. Note that the PDPA exempts certain types of personal data from being subject to your access request.
9.3. For a request to correct personal data, once we have sufficient information from you to deal with the request, we will:
9.3.1. correct your personal data within 30 days. Where we are unable to do so within the said 30 days, we will notify you of the soonest practicable time within which we can make the correction. Note that the PDPA exempts certain types of personal data from being subject to your correction request as well as provides for situation(s) when correction need not be made by us despite your request; and
9.3.2. subject to paragraph [9.4], we will send the corrected personal data to every other organisation to which the personal data was disclosed by A Higher Place within a year before the date the correction was made, unless that other organisation does not need the corrected personal data for any legal or business purpose.
9.4. Notwithstanding paragraph [9.3(b)], we may, if you so consent send the corrected personal data only to specific organisations to which the personal data was disclosed by us within a year before the date the correction was made.
9.5. We will also be charging you a reasonable fee for the handling and processing of your requests to access your personal data. We will provide you with a written estimate of the fee we will be charging. Please note that we are not required to respond to or deal with your access request unless you have agreed to pay the fee.
REQUEST TO WITHDRAW CONSENT
You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control by submitting your request at the following webpage and using the online form set out therein.
We will process your request [within a reasonable time] from such a request for withdrawal of consent being made, and will thereafter not collect, use and/or disclose your personal data in the manner stated in your request.
However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal. In this regard, depending on the extent of your withdrawal of consent for us to process your personal data, it may mean that we will not be able to continue with your existing relationship with us .
ADMINISTRATION AND MANAGEMENT OF PERSONAL DATA
11.1. We will take reasonable efforts to ensure that your personal data is accurate and complete, if your personal data is likely to be used by A Higher Place to make a decision that affects you, or disclosed to another organisation. However, this means that you must also update us of any changes in your personal data that you had initially provided us with. We will not be responsible for relying on inaccurate or incomplete personal data arising from your not updating us of any changes in your personal data that you had initially provided us with.
11.2. We will also put in place reasonable security arrangements to ensure that your personal data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorized access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data. However, we cannot assume responsibility for any unauthorized use of your personal data by third parties which are wholly attributable to factors beyond our control.
11.3. We will also put in place measures such that your personal data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes.
11.4. Where your personal data is to be transferred out of Singapore, we will comply with the PDPA in doing so. In this regard, this includes us obtaining your consent unless an exception under the PDPA or law applies, and taking appropriate steps to ascertain that the foreign recipient organisation of the personal data is bound by legally enforceable obligations to provide to the transferred personal data a standard of protection that is at least comparable to the protection under the Act. This may include us entering into an appropriate contract with the foreign recipient organisation dealing with the personal data transfer or permitting the personal data transfer without such a contract if the PDPA or law permits us to.
12.1. If you have any complaint or grievance regarding about how we are handling your personal data or about how we are complying with the PDPA, we welcome you to contact us with your complaint or grievance.
12.2. Please contact us through one of the following methods with your complaint or grievance :
E-mail: firstname.lastname@example.org Attention it to the ‘Data Protection Officer’.
12.3. Where it is an email or a letter through which you are submitting a complaint, your indication at the subject header that it is a PDPA complaint would assist us in attending to your complaint speedily by passing it on to the relevant staff in our organisation to handle. For example, you could insert the subject header as “PDPA Complaint”.
12.4. We will certainly strive to deal with any complaint or grievance that you may have speedily and fairly.
UPDATES ON DATA PROTECTION POLICY
13.1. As part of our efforts to ensure that we properly manage, protect and process your personal data, we will be reviewing our policies, procedures and processes from time to time.
13.2. We reserve the right to amend the terms of this Data Protection Policy at our absolute discretion. Any amended Data Protection Policy will be posted on our website here.
13.3. You are encouraged to visit the above website from time to time to ensure that you are well informed of our latest policies in relation to personal data protection.
A Higher Place reserve the right to alter any of the clauses contained herein in compliance with local legislation, to meet its global policy requirements, and for any other purpose deemed necessary by the Company.