1. What does this Policy Cover?
i. sets out the principles SM follows when collecting, using, disclosing, retaining and removing personal data; and
ii. describes other important topics relating to an individual’s privacy.
By purchasing goods from SM, communicating with SM through email, by telephone, in writing or by using any of SM’s other services, including the SM website, or by providing personal data to us, you agree to the collection, use and disclosure of your personal data in the manner described in this policy.
2. Collection Use and Storage of Personal Data
The type of personal data that SM may collect from individuals will depend upon the particular transaction and the dealing. Normally the personal data collected by SM may include an individual’s:
i. name, title, address;
ii. personal identification and/or passport number;
iii. telephone number;
iv. email address and online passwords;
v. records of communications with SM;
vi. responses to market surveys and contests conducted by SM or on SM’s behalf;
vii. credit card or debit card information;
viii. camera or video footage that identifies individuals (including CCTV footage);
ix. website usage information.
SM only collects, uses and discloses personal data with an individual’s consent or deemed consent or as otherwise permitted under the PDPA or other applicable laws and regulations.
Personal Data will, generally, only be collected and used for the primary purposes of:
i. conducting, improving, maintaining and developing a business relationship.
ii. processing, servicing or enforcing transactions and sending related communications;
iii. identification and verification purposes in connection with any of the services or products that may be supplied to individuals;
iv. responding to individual’s queries;
v. administering contests or market surveys conducted by SM or on SM’s behalf
vi. marketing (such as providing individuals with information about our products and promotional notices and offers); and
vii. improving the SM’s website.
SM takes reasonable steps to ensure the individual is aware of:
i. the likely use of the information;
ii. the means of requesting SM on the provision of personal data that is in the possession of SM;
iii. the means of withdrawing any consent in respect of the collection, use or disclosure of the personal data that is in the possession of SM;
iv. the identity and contact details of the organisation;
v. any law requiring collection of the information; and
vi. the main consequences of failure to provide the information.
3. How SM will disclose your Personal Data?
SM discloses personal data:
i. for the primary purpose for which it was collected; or
ii. for purposes that a reasonable person will consider appropriate in the circumstances; or
iii. where the individual has consented; or
iv. for direct marketing by SM where consent has been given but giving individuals the opportunity to opt out of such direct marketing. SM includes its contact details in any direct marketing; or
v. where permitted under the PDPA or other applicable law or if required by law.
SM does not disclose your personal data for any secondary purposes unless your consent has been given or if so permitted or required under the PDPA or other applicable laws and regulations. SM will not sell or license any personal data that it collects from an individual.
There may be other situations where we may collect and use personal data, which are outside a person’s reasonable expectation. When this occurs, SM is committed to providing the individual with an explanation for the possible use of the personal data when asking for the individual’s consent.
4. Accuracy and Correction of Personal Data
SM takes steps to ensure information is accurate and up-to-date by updating its records whenever changes to information come to its attention. SM disregards information which seems, on a reasonable basis, be inaccurate or out of date by reason of the time which has elapsed since it was collected or by reason of any other information in its possession.
If an individual has submitted personal data to SM electronically or otherwise, and would like it corrected, then a written request should be sent by email to firstname.lastname@example.org or to the address below.
SM will comply with an individual’s request to correct their personal data as soon as practicable.
If SM disagrees with any request to correct an individual’s personal data on reasonable grounds, SM shall annotate the personal data with the correction that was requested but not made.
5. Withdrawal of Consent
An individual may withdraw his consent for the collection, use or disclosure of personal data by giving SM reasonable notice by sending a written request (a) by email to email@example.com or (b) to the address below. SM shall inform the individual of the likely consequences of the withdrawal of the consent. SM will cease to collect, use or disclose the personal data upon such withdrawal unless otherwise permitted or required by the PDPA or other applicable laws and regulations.
6. Using our Website
As with most websites, when you visit the SM website or use an application on the SM website, SM may record anonymous information such as IP address (where not used to identify a specific individual), time, date, referring URL, pages accessed and documents downloaded, type of browser and operating system.
SM also uses “cookies”. A cookie is a small file that stays on your computer until, depending on whether it is a sessional or persistent cookie, you turn your computer off or it expires. Cookies may collect and store your personal data. You may adjust your internet browser to disable cookies. If cookies are disabled you may still use the SM website, but may be limited in the use of some of the features.
7. Security of your Personal Data
SM will take reasonable steps to ensure that personal data is securely stored.
SM protects personal data from misuse or loss by restricting access to the information in electronic format and by appropriate physical and communications security.
Any data destroyed is disposed of in a manner that protects the privacy of personal data in an appropriate manner.
8. Dealing with Unsolicited Information
SM takes all reasonable steps to ensure that all unsolicited information is destroyed immediately.
9. Access to Personal Data
If an individual wishes to be provided with information regarding their Personal Data that is in the possession or under the control of SM or the ways in which such Personal Data has been used or disclosed by SM in the year preceding such request, then that person needs to send a written request by email to firstname.lastname@example.org or to the address as detailed below. SM will handle such requests as soon as reasonably possible in accordance with the PDPA.
10. Anonymity when dealing with SM
SM allows individuals the option not to identify themselves when dealing with it, where practicable.
11. Cross Border Disclosure
Any personal data provided to SM may be transferred to, stored by or disclosed to an overseas recipient. For example, SM may use a server hosted overseas to store data, which may include your personal data.
Your personal data may also be processed by employees or by other third parties operating outside of Singapore, who work for SM.
SM will take reasonable steps, in the circumstances, before your personal data is disclosed to an overseas recipient, to ensure that the overseas recipient provide a standard of protection to personal data so transferred that is comparable to the protection under the PDPA.
12. Sensitive Information
13. DNC Registry
SM complies with all provisions regarding the DNC Registry under the PDPA.
14. Other Important Information
15. 3rd Party Analytics
SM uses Google Analytics to collect data via cookies through a standard Google Analytics implementation, the data collected is used internally for performance tracking purposes only. Information collected is not shared with other 3rd parties. Users may choose to opt-out by visiting this link https://tools.google.com/dlpage/gaoptout/
16. Further Information
28 Tai Seng Street #03-01 Sakae Building Singapore 534106
Updated 25 Aug 2015