We respect the confidentiality of Personal Data and privacy of individuals and are committed to complying with the Singapore Personal Data Protection Act (Act 26 of 2012) (“PDPA”) and other applicable data protection laws. Please read this Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data.
We do not disclose your Personal Data unless prior consent has been obtained and we have administrative, physical and Information Technology (IT) security measures to protect your Personal Data.
This Policy supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your Personal Data, and your consents herein are additional to any rights which any member of MALL SG may have at law to collect, use or disclose your Personal Data. This Policy does not affect any rights which we may have at law in connection with the collection, use or disclosure of your Personal Data.
For the avoidance of doubt, to the maximum extent permitted under applicable law, nothing in this Policy establishes any joint and several liability on the part of MALL SG members.
1. Your Personal Data
1.1. “Personal Data” refers to any data or information about you from which you can be identified either (a) from that data alone; or (b) from that data combined with other information. Examples of such Personal Data which you may provide us include (depending on the nature of your interaction with us):
a) your name, gender, email address and any other information relating to you which you have provided us in any form you may have submitted to us, or in other forms of interaction with you;
b) information about your use of our websites and services, including cookies, IP addresses and membership details;
2. Collection of Personal Data
2.1. Generally, we collect your Personal Data in the following ways:
a) when you submit any online queries;
b) when you register as a member of websites owned and/or operated by us;
c) when you interact with our customer service officers or any of our staff, for example, via face-to-face meetings, telephone calls, letters, online (such as any “Contact Us” on our websites), reservation chat, social media platforms and emails;
d) when you request that we contact you;
e) when you respond to our request for additional Personal Data;
f) when you ask to be included in an email or other mailing list;
g) when you respond to any of our listings or other initiatives;
h) when we receive references from business partners and third parties, for example, where you have been referred by them;
i) when you submit your Personal Data to us for any other reason; and
We may monitor or record phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation, identity verification purposes, feedback, respond to your queries and requests and resolve complaints and other related purposes. Such monitoring or recording will be in accordance with applicable law.
2.2. If you provide Personal Data of a third party (e.g. information of your dependent, spouse, children and/or parents) to us, you represent and warrant that the collection, use and disclosure of that Personal Data to us, as well as the further processing of that Personal Data by us for the purposes set out below, is lawful.
3. Use and Disclosure of Personal Data
3.1. Our portal is to understand and meet your needs and provide you with the services that you require. To do this effectively, we need to collect a range of Personal Data about you as described in paragraph 1 above.
3.2. In general, we will, subject to applicable law, use and disclose your Personal Data for the following purposes:
a) provide you with the services that have been requested;
b) help us review, develop, improve, manage the delivery of and – to the extent this requires the use of Personal Data – enhance our services, including analysing future customer needs, conducting market research and data analytics (which does not involve automated profiling or result in automated decision-making activity which is regulated under the GDPR);
c) communicate with you and respond to your queries, requests and complaints;
d) provide ongoing information about services which may be of interest to you;
e) handle disputes and conduct and facilitate investigations and proceedings;
f) protect and enforce our contractual and legal rights and obligations;
g) manage our infrastructure and business operations and comply with internal policies and procedures;
h) comply with any applicable rules, laws and regulations, codes of practice or guidelines or assist in law enforcement and investigations by relevant authorities.
3.3. Generally, we process your Personal Data for one or more of the specific purposes identified in this Policy based on your consent obtained. Where GDPR applies, the legal basis for our processing of your Personal Data could also be that it is necessary for the legitimate interests pursued by us, or a third party which is described in paragraph 3.8 of this Policy. These legitimate interests include providing services to you where you are our client, managing the relationship between MALL SG and you and facilitating internal business purposes and administrative purposes. In some cases, the provision and processing of your Personal Data may be a statutory and/or contractual requirement, or may be necessary in order to perform any contract you have agreed with us or perform services that you have requested.
3.4. In addition, we may use and disclose your Personal Data for the following purposes, depending on the nature of our relationship with you:
a) If you have a membership account with us :
(i) process your application for the account;
(ii) maintain your account with us;
(iii) verify your personal particulars and process requests in relation to provision of the services which you may be entitled to or which you may have requested for;
(iv) provide you with the services which you have signed up for;
(v) communicate with you of changes and development to our policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to services offered to you;
(vi) resolve complaints and handle requests and enquiries;
(vii) conduct market research for statistical, profiling and statistical analysis for the improvement of services provided to you; and
(viii) process your Personal Data in relation to any of the purposes stated above.
3.5. The above purposes are not exhaustive, and depending on the nature of your relationship with us (for example, if you are a member of MALLSG), we may collect, use and disclose your Personal Data for additional purposes which you will be notified of, in accordance with applicable terms and conditions.
3.6. When you apply for or hold a co-brand product which is offered jointly by us and our co-brand partner(s), we may also collect, use and disclose your Personal Data for the purpose of sharing your Personal Data with the co-brand partners for offering, marketing and promoting to you any services, offers or events which the co-brand partner thinks may be of interest to you. We will only share your Personal Data with the co-brand partners where permitted by applicable law.
3.7. In relation to particular products or services or in your interactions with us, we may also notify or have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.
3.8. Your Personal Data will be protected and kept confidential, but subject to the provisions of any applicable law, your Personal Data may, depending on the products or services concerned, be disclosed to third parties set out below. Such disclosure may be subject to additional legal requirements under applicable law, depending on the nature of such transfer to third parties. Your Personal Data will, in each case, only be disclosed to the extent necessary and proportionate.
The third parties are:
a) other divisions or entities within MALL SG directors, officers and/or employees;
b) our joint venture/ alliance partners;
c) our agents, contractors, third party service providers and specialist advisers who have been contracted to provide us with administrative, financial, research, operational or other services in pursuance of the purposes set out in this Policy, such as telecommunications, information technology, payment, payroll, processing, training, market research, storage and archival;
d) any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving the MALL SG;
e) our professional advisors such as our auditors and lawyers;
f) relevant government regulators or authority or law enforcement agency to comply with any laws or rules and regulations imposed by any governmental authority;
g) anyone to whom we transfer or may transfer our rights and obligations, including, for example, where we obtain the services of a third party organisation to handle any aspect of the processing of your Personal Data for the purposes notified to you in accordance with this Policy;
h) any other party as may be consented to by you, as specified by you or as may be notified to you by us in subsequent notices. In the event that your Personal Data is shared with a third party that acts with a member of MALL SG as joint controllers under GDPR, we will, to the extent required by law, provide you with additional information on the responsibilities of each joint controller, any particular means by which you can enforce your rights and the primary contact person for such requests in relation to your rights.
3.9 We require that organisations outside MALL SG which handle or obtain Personal Data as service providers to us acknowledge the confidentiality of this data, undertake to respect any individual’s right to privacy and comply with the PDPA, the GDPR and any other applicable data protection laws. As a requirement under these laws, we may be required to have specific agreements in place with such third parties to regulate and safeguard your data protection rights. We also require that these organisations use this information only for our purposes and follow our directions with respect to this information.
4. Transfer of Personal Data
4.1 Your Personal Data may be stored in external servers. In addition, as described above, in carrying out our business, it may be necessary to share information about you with and between our related corporations and third party service providers, some of which may be located in countries outside your country of residence. Such countries may not afford a standard of protection similar to those in your country of residence. However, we will take reasonable steps to ensure that your Personal Data transmitted outside of your country of residence is adequately protected. In addition, we will ensure that such transfers comply with the requirements of the applicable data protection laws.
5. Retention of Personal Data
5.1 We may retain your Personal Data for as long as it is permitted by applicable law or in order to defend legal claims. Where we no longer require your Personal Data for those purposes, we will cease to retain such Personal Data.
6.1 You have the following rights, under applicable data protection laws (except where the exercise of these are restricted under applicable laws – for example, due to judicial proceedings or the carrying out of investigations), which can be exercised by contacting the relevant MALL SG employees.
a) you have the right to obtain from us confirmation as to whether or not your Personal Data is being processed and to request a copy of your information. Where legally required, we can provide your information in an easily accessible format and assist in transferring some of this information to third parties;
b) you are entitled to rectification of your Personal Data. We endeavour to ensure that all Personal Data we have about you is accurate and up-to-date. We understand that this information changes frequently with changes of address and other personal circumstances. We encourage you to contact us as soon as possible to enable us to update any Personal Data we have about you. Incomplete or outdated Personal Data may result in our inability to provide you with services you have requested;
c) in certain circumstances, you have the right to request to have your Personal Data deleted or the processing of which restricted;
d) if we process your information based on our legitimate interests explained above, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is necessary for legal reasons. Where we use your data for direct marketing purposes, you can always object by contacting us directly;
e) to prevent any processing of Personal Data that is causing or is likely to cause unwarranted and substantial damage or distress to you or another individual;
f) to be informed about any use of your Personal Data to make automated decisions about you where such decisions produce legal effects or have similarly significant effects on you, and to obtain meaningful information about the logic involved, as well as the significance and the envisaged consequences of this processing; and
g) to lodge a complaint about the way in which your Personal Data is being used to a supervisory authority.
6.2 Where we rely on your consent to use your Personal Data, you have the right to withdraw that consent at any time. If you withdraw your consent to any or all purposes and depending on the nature of your request, we may not be in a position to continue to provide our services to you.
7. Third-Party Sites
8. Third Party Modules
9. Governing Law
9.1 This Policy and your use of this website shall be governed in all respects by the laws of Singapore.
9.2 For the avoidance of doubt, the applicable data protection laws will apply to the processing of your Personal Data.
10. Review of this Policy
10.1 This Policy will be reviewed from time to time by us. We may also from time to time update this Policy to take account of new laws and technology, changes to our operations and practices and the changing business environment.