1. As used in this Policy: “member” means a member of the My Last Words, whether practicing or otherwise; “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.
2. 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, and telephone number.
3. Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context permits).
Collection, Use, and Disclosure of Personal Data
4. We generally do not collect your data unless (a) it is provided to us voluntarily by you directly or via a third party which you have duly authorized to disclose your data to us (your “authorized representative”) after (i) you (or your authorized representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorized representative) have provided written consent to the collection and usage of your 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 using your data for a purpose that has not been notified to you (except where permitted or authorized by law).
5. We may collect and use your data for any or all of the following purposes:
(a) operating our Website or its subdomains (“Website”); (b) performing our statutory functions and administering our activities; (c) communicating with our members and customers; (d) updating your personal and contact information; (e) performing obligations in the course of or in connection with our provision of the goods or services requested by you; (f) verifying your identity; (g) responding to, handling, and processing queries, requests, applications, complaints, and feedback from you; (h) managing your relationship with us; (i) processing payment or credit transactions; (j) complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental or regulatory authority; (k) statistical, analysis, planning, and reporting; (l) any other purposes for which you have provided the information; and (m) any other incidental purposes related to or in connection with the above.
6. This Policy does not apply to aggregated information that summarizes statistical information about groups of members and which does not include name, contact information, or any other information that would allow any particular individual to be identified.
7. We may disclose your data:
8. Where your use of the Website is concerned, you acknowledge and accept that certain functions, when activated or used by you, will operate to send or display information about yourself, including but not limited to, your data to certain third parties and you agree to the sharing of such information with these third parties. You acknowledge and agree that we shall not be held responsible or accountable for any loss, injury, or damage sustained by you for sharing the aforesaid information arising out of your activation or use of such features on the Website.
Withdrawing Your Consent
9. The consent you provide for the collection, use, and disclosure of your personal data will remain valid until you withdraw it in writing. You may withdraw consent and request us to stop collecting, using, or disclosing your 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.
10. 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.
11. 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 nine above.
12. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclosure without consent is permitted or required under applicable laws.
Access to and Correction of Personal Data
13. If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about how we use or disclose your data, or (b) a correction request to correct or update any of your data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
14. Please note that an access request may be charged a reasonable fee. We will inform you of the cost before processing your request.
15. We will respond to your request as soon as reasonably possible. Our response will generally be within thirty (30) business days. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we cannot provide you with any personal data or make a correction requested by you, we shall generally inform you of why we are unable to do so (except where we are not required to do so under the PDPA).
Protection of Personal Data
16. We have introduced appropriate administrative, physical, and technical measures to safeguard your data from unauthorized access, collection, use, disclosure, copying, modification, disposal, or similar risks. 17. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is entirely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
Accuracy of Personal Data
18. We generally rely on your personal data (or your authorized representative). To ensure that your information is current, complete, and accurate, please update us if there are changes to your data by informing our Data Protection Officer in writing or via email at the contact details provided below.
Retention of Personal Data
19. We may retain your data for as long as it is necessary to fulfill the purpose for which it was collected or as required or permitted by applicable laws.
20. We will cease to retain your data or remove how the data can be associated with you 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.
Transfers of Personal Data Outside of Singapore
21. We generally do transfer your data to countries outside of Singapore. It is for our data storage, security & communications purposes; by using our services, you consent to our practice. We will take steps to ensure that your data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.
23. Users of the Website are advised that if they wish to deny the use and saving of cookies from this Website onto their computers or other electronic devices, they should take the necessary steps within their internet browser's security settings to block all cookies from this Website
24. You can choose to delete the cookies at any time. However, you may lose any information that enables you to access the Website more quickly and efficiently, including but not limited to personalization settings.
Effect of Policy and Changes to Policy
26. This Policy applies to any other notices, contractual clauses, and consent clauses concerning the collection, use, and disclosure of your data by us.
27. We may revise this Policy from time to time without any prior notice. You may determine if any such revision has occurred by referring to the date on which this Policy was last updated. Your continued use of our services constitutes your acknowledgment and acceptance of such changes.
28. Should litigation, legal proceedings will take place in Singapore with existing Singapore laws.
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