DATA PROTECTION NOTICE FOR CUSTOMERS
This Data Protection Notice (“Notice”) sets out the basis which Smoofy (“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
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.
- 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, nationality, gender, date of birth, photograph, employment
information and financial information.
- 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
- 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).
- We may collect and use your personal data for any or all of the following purposes:
(a) performing obligations in the course of or in connection with our provision of
the goods and/or services requested by you;
(b) verifying your identity;
(c) responding to, handling, and processing queries, requests, applications,
complaints, and feedback from you;
(d) managing your relationship with us;
(e) processing payment or credit transactions;
(f) 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;
(g) any other purposes for which you have provided the information;
(h) 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; and
(i) any other incidental business purposes related to or in connection with the
above.
- We may disclose your personal data:
(a) where such disclosure is required for performing obligations in the course of or
in connection with our provision of the goods and services requested by you;
or
(b) 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.
- The purposes listed in the above clauses 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 (including, where
applicable, a period to enable us to enforce our rights under a contract with you).
RELIANCE ON THE LEGITIMATE INTERESTS EXCEPTION
- In compliance with the PDPA, we may collect, use or disclose your personal data
without your consent for the legitimate interests of Smoofy or another person. In relying
on the legitimate interests exception of the PDPA, Smoofy will assess the likely
adverse effects on the individual and determine that the legitimate interests outweigh
any adverse effect.
- In line with the legitimate interests’ exception, we will collect, use or disclose your
personal data for the following purposes:
a. Fraud detection and prevention;
b. Detection and prevention of misuse of services;
c. Network analysis to prevent fraud and financial crime, and perform credit analysis;
and
d. Collection and use of personal data on company-issued devices to prevent data
loss.
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
- 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.
- 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.
- 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 8
above.