1. MARINA CENTRE HOLDINGS PRIVATE LIMITED (Registration No. 197903339N) ("MCH"), the owner and operator of Marina Square Shopping Mall, respects shoppers’ privacy and will make reasonable efforts to protect personal data of shoppers.
- MCH understands and will at all times observe its obligations in respect of collection, use, disclosure and retention of personal data under the Personal Data Protection Act 2012 and any subsidiary legislation (the "Act") including ensuring the appropriate degree of accuracy and security in respect of the personal data under its control or within its possession.
YOUR PERSONAL DATA
- A shopper’s personal data means data about the shopper, whether true or not, (other than the shopper’s business contact information) that specifically identifies the shopper or data about the shopper which combined with other information that MCH has or is likely to have access to can be used to identify the shopper. This may include the shopper’s name, partial NRIC number, address, gender, age, credit card number, email address, any feedback provided by the shopper, information specific to the computer or electronic device that the shopper uses to access and/or use the website at https://www.marinasquare.com.sg (the "Website"), MCH's iPhone app or MCH's app on Google Play or any other app MCH may make available to the shopper (the "Apps"), photographs and video images of the shopper while the shopper is on MCH’s premises.
- An individual’s business contact information means the individual’s name, position name or title, business telephone number, business address, business email address or business fax number and any other similar information about the individual, not provided by the individual solely for his/her individual personal purposes.
- Aggregated or anonymised data that do not specifically identify an individual (e.g. number of visitors to the Website) are not considered as personal data for the purposes of this Policy.
OCCASIONS WHEN MCH MAY COLLECT YOUR PERSONAL DATA
- MCH may collect shopper's personal data when shoppers deal with or contact MCH. For example:
- when shoppers participate in lucky draws and redemption activities organised or hosted by MCH;
- if shoppers make purchases from Marina Square;
- when shoppers access and/or use the Website;
- when shoppers download, access and/or use the Apps;
- when shoppers contact MCH directly (e.g. when you speak to a Customer Service Officer);
- when shoppers interact with MCH through authorised third parties (e.g. via social media platforms or brand partners); and/or
- when shoppers are in the vicinity of MCH surveillance cameras.
PURPOSE OF COLLECTING, USING AND/OR DISCLOSING YOUR PERSONAL DATA
- Shopper's personal data may be collected, used and/or disclosed by or on behalf of MCH for the following purposes:
- for shoppers' participation in lucky draws and redemption activities;
- to facilitate shoppers’ access and/or use of the Website and/or the Apps, transactions between MCH and shoppers and activities organised by MCH which shoppers participate in;
- to offer shoppers a more individualised environment in connection with shoppers use of the Website and/or the Apps;
- to allow MCH to interact with shoppers via social media platforms;
- to refine or improve the security, use, features and functions of the Website and/or the Apps;
- to develop new features and functions of the Website and/or the Apps and to improve on the transactions between MCH and shoppers;
- to receive emails and SMSes in connection with MCH's latest promotions and/or events;
- to resolve disputes that may arise between MCH and shoppers;
- where necessary, for any investigation or proceedings;
- where necessary, for MCH to obtain legal services;
- for MCH's evaluative purposes; and
- for the specific purposes for which shoppers’ personal data were provided or any purposes exempted under the Act.
- MCH will from time to time notify shoppers of other purposes for the collection, use or disclosure of shoppers’ personal data and shoppers will be deemed to have consented to collection, use or disclosure of personal data for such other purposes by shoppers continuing to transact with MCH, shoppers continuing to participate in activities organised by MCH or shoppers continuing to access or use the Website or the Apps.
- MCH will not sell or rent shoppers’ personal data to third parties.
- MCH may disclose shoppers’ personal data to third parties for any of the purposes stated in this Policy. Such third parties include:
- Subcontractors or service providers appointed by MCH;
- Partners, affiliates or related companies of MCH; and
- Government authorities/agencies, where required.
RETENTION OF PERSONAL DATA
- MCH may retain shoppers’ 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.
- MCH will cease to retain shoppers’ personal data, or remove the means by which the data can be associated with individual shoppers, 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.
- MCH is not responsible for any third party cookies.
- If shoppers block cookies, some of the features and functions of the Website and/or Apps may not function properly and shoppers may not be able to access and/or use the Website or the Apps.
SECURITY OF SHOPPER'S PERSONAL DATA
- In addition to implementing technological safeguards (such as firewalls and password-locks), MCH will implement policies and practices to reasonably protect shoppers’ personal data in MCH's possession or control from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. Information on such policies and practices are communicated to the relevant staff of MCH and the relevant staff are required to comply with the policies and practices.
- While MCH will endeavour to protect shoppers’ personal data by making reasonable security arrangements, there is no absolute security in transmission of data over the internet. Shoppers should exercise care in protecting their personal data.
- Shoppers may access third party websites which are linked to the Website or the Apps. MCH is not responsible for shoppers’ personal data collected, used or disclosed by the third party websites and the data protection policies and practices of third parties, if any, are not found in and are not intended to be covered by this Policy.
- Third party contractors with access to shoppers’ personal data are subject to a clause in MCH contract that they have to comply with PDPA regulations.
ACCESS TO AND ACCURACY OF YOUR PERSONAL DATA
- As part of MCH's efforts to ensure the accuracy of shoppers’ personal data, MCH may adopt verification practices or processes such as asking shoppers questions relating to their identity, checking against existing data held by MCH or requesting that shoppers furnish photo identification.
- MCH has appointed a Data Protection Officer to oversee MCH's compliance with the Act and to facilitate shoppers’ dealings with MCH in respect of their personal data.
- If shoppers’ wish to make (a) a request for access to a copy of the personal data which MCH holds about them or information about the ways in which MCH uses or discloses their personal data, or (b) a request to correct or update any of the shoppers’ personal data which MCH holds about them, shoppers may submit their request in writing or via email to MCH’s Data Protection Officer at firstname.lastname@example.org.
- Please note that a reasonable fee may be charged for a data access request by any shopper. If so, MCH will inform the shopper of the fee before processing the request.
- MCH will respond to the shopper’s data access request as soon as reasonably possible. In general, MCH’s response will be within twenty-one (21) business days. Should MCH not be able to respond to the shopper’s request within thirty (30) days after receiving the request, MCH will inform the shopper in writing within thirty (30) days of the time by which MCH will be able to respond to the shopper’s request. If MCH is unable to provide the shopper with some of the personal data as requested by the shopper, MCH will generally inform the shopper of the reasons why MCH is unable to do so (including exceptions to data access request provided for under the PDPA).
- MCH has the right to reject, among others, frivolous or vexatious requests or requests for trivial information.
- If shoppers believe their personal data contain an error or omission, they should inform MCH immediately. MCH will make the correction as soon as practicable, within thirty (30) days after receiving the request, unless it is satisfied on reasonable grounds that the correction should not be made (including exceptions to data correction request provided for under the PDPA).
TRANSFER OF YOUR PERSONAL DATA TO ANOTHER COUNTRY
- Consistent with the purposes for which shoppers’ personal data were collected, shoppers’ personal data may be transferred outside of Singapore.
- Shoppers’ personal data will not be transferred to a third party outside of Singapore unless the third party is able or undertakes to provide a standard of protection to shoppers’ personal data that is comparable to the standard of protection under the Act.
- All shoppers’ requests, complaints and queries relating to their personal data are to be forwarded to MCH's Data Protection Officer at email@example.com. MCH will respond to shoppers’ complaints within a reasonable period of time depending on the nature of the complaint.
WITHDRAWAL OF CONSENT TO RECEIVE MARKETING INFORMATION
- If shoppers wish to stop receiving information with marketing information from MCH, they should send an email to MCH's Data Protection Officer at firstname.lastname@example.org stating their name, address and email address. For emails, shoppers may click on the unsubscribe link in the latest email received from MCH. MCH will process and effect such withdrawal within 30 working days.
- If shoppers wish to withdraw their consent in relation to other purposes, they are to contact MCH's Data Protection officer at email@example.com and where applicable, MCH will inform shoppers of the likely consequences of withdrawing their consent. If shoppers have given their consent for multiple purposes, shoppers’ personal data may still be collected, disclosed and used for purposes for which no withdrawal of consent was made. Even if shoppers withdraw consent from MCH, and MCH ceases to use their personal data, MCH may still retain their personal data that is necessary for legal or business purposes according to its data retention policy.
Do Not Call Provisions
33. If you have provided us with your Singapore telephone number(s) and have indicated that you have given your clear and unambiguous consent to receiving marketing or other promotional information via your Singapore telephone number(s), then from time to time, MCH may contact you using such Singapore telephone number(s) (including via voice calls, text, fax or other means) with information about our products, services (including discounts and special offers), and other event invitations even if these telephone number(s) are registered with the DNC Registry. You may however advise in writing should you wish not to be cont`acted by us at your telephone number(s) for such purposes.
VARIATION OF THIS POLICY
34. MCH reserves the right to modify this Policy from time to time by posting the modifications on the Website. Individuals should check the pages regularly for any modifications. Such modifications will be effective immediately and incorporated into the Website.