PRIVACY POLICY
Mycarforum.com is
owned & operated by SGCM Pte Ltd (‘SGCM’). We follow the SGCM Privacy
Policy, which you can read below.
Your privacy
is important to us. The purpose of this Privacy Policy is to inform you of how
we handle or process your personal data in accordance with the Personal Data
Protection Act 2012 (“the Act”). Please take a moment to read this Privacy
Policy so that you know and understand the purposes for which we collect, use
and disclose your Personal Data.
By
interacting with us, submitting information to us or signing up for any
promotions or services offered by us, you agree and consent to SGCM Pte Ltd, its
related corporations and affiliates, and their respective successors-in-title
as well as our respective representatives (collectively referred to herein as
"SGCM", "us", "we" or "our")
collecting, using, disclosing and sharing amongst themselves your Personal
Data, and disclosing such Personal Data to SGCM’s authorised service providers
and relevant third parties in the manner and for any of the purposes set forth
in this Privacy Policy. In addition, this Privacy Policy will also provide you
with more information on the bases upon which we may lawfully collect, use
and/or disclose your Personal Data without your consent, where permitted by
applicable law.
This Privacy Policy supplements but does not supersede
nor replace any other consents you may have previously provided to SGCM nor
does it affect any rights which SGCM may have at law in connection with the
collection, use or disclosure of your Personal Data, and any consents you may
have provided in connection with this Privacy Policy are cumulative and
additional to any rights which we may have under applicable law to handle or
process your Personal Data.
We reserve the right to update or modify this Privacy
Policy from time to time, and send you notification of updates to this Privacy
Policy in any form as we may deem appropriate. While you should regularly check
this Privacy Policy, we may also inform you of how we process your Personal
Data by publishing (or amending) this Privacy Policy and, where required by
applicable law, by posting a notice, or reaching you via other forms of
communication (e.g. sending you an SMS message or email) based on the contact
particulars that we may have of you in our records from time to time. You may
also contact us in the manner disclosed in this Privacy Policy to learn about
our handling or processing of your Personal Data.
To the maximum extent permissible under applicable
law, you agree to be bound by the prevailing terms of the Privacy Policy as
updated from time to time on our websites and/or as you may be notified. Hence,
please check regularly for updated information on the handling of your Personal
Data.
For avoidance of doubt, this Privacy Policy forms a
part of the Website Terms and Conditions
(‘Website Conditions’). In the event of any conflict, inconsistency or conflict
between this Privacy Policy and the Website Conditions, the Privacy Policy
shall prevail. All defined terms contained in the Website Conditions shall
apply to this Privacy Policy unless otherwise specifically stated.
1.
Your Personal Data
1.1. In this Privacy Policy,
"Personal Data" refers to any data or information about you from
which you can be identified either (a) from that data; or (b) from that data
and other information to which we have or are likely to have access. Examples of
such Personal Data which you may provide to us include (depending on the nature
of your interaction with us:
a.
Your name, NRIC, passport or other identification number,
telephone number(s), mailing address, email address and any other information
relating to you which you have provided us in any forms you may have submitted
to us, or in other forms of interaction with you;
b.
Information about your use of SGCM Pte Ltd’s
website and services, including cookies, IP address and membership details, but
only to the extent that SGCM may identify you from such information;
c.
Your employment history, education background, and income
levels;
d.
Your payment related information, such as your bank account
or credit card information, and your credit history; and
e.
Information about your usage of and interaction with our
website and/or services including computer and connection information, device
capability, bandwidth, statistics on page views, and traffic to and from our
website.
2.
Collection of Personal
Data
2.1. Generally, SGCM collects
your Personal Data in the following ways:
a.
When you submit forms or other documents relating to any of
our products or services;
b.
When you register for or use any of our services on websites
owned or operated by us or when you register as a member of websites owned
and/or operated by us, or use services on such websites;
c.
When you interact with our customer service officers;
d.
When you use some of our services;
e.
When you establish any online accounts with us;
f.
When you request that we contact you;
g.
When you are contacted by, and respond to, our marketing
representatives, agents and other service providers;
h.
When you respond to our request for additional Personal Data
i.
When you ask to be included in an email or other mailing
list;
j.
When you respond to our promotions and other initiatives;
k.
When you submit a job application or a scholarship
application;
l.
When we receive references from business partners and third
parties, for example, where you have been referred by them;
m. When you submit your Personal
Data to us for any other reason.
2.2. When you browse our
website or Apps, you generally do so anonymously but please see the section
below on cookies and other related technologies which we have implemented on
our website. We do not, at our website, automatically collect Personal Data
unless you provide such information to us
2.3. If you provide us with any
Personal Data relating to a third party (e.g. information of spouse, children,
parents, employees and/or authorised representatives), by submitting such
information to us, you represent to us that you have obtained the consent of
the third party to you providing us with their Personal Data for the respective
purposes.
2.4. You should ensure that all
Personal Data submitted to us is complete, accurate, true and correct. Failure
on your part to do so may result in our inability to provide you with products
and services you have requested, or processing any requests and applications
you may have made to us.
3. Purposes for the Collection, Use and Disclosure of Your
Personal Data
3.1. Generally, SGCM collects,
uses and discloses your Personal Data for the following purposes:
a.
Responding to, processing and handling your queries,
requests, complaints and feedback;
b.
Managing the infrastructure and business operations of SGCM
and complying with internal policies and procedures;
c.
Facilitating business asset transactions (which may extend to
any merger, acquisition or asset sale);
d.
Matching any Personal Data held which relates to you for any
of the purposes listed herein;
e.
Verifying your identity;
f.
Preventing, detecting and investigating crime, including
fraud and money-laundering, and analyzing and
managing other commercial risks;
g.
Protecting and enforcing our contractual and legal rights and
obligations;
h.
Conducting audits, reviews and analysis of our internal
processes, action planning and managing commercial risks;
i.
Preventing, detecting and investigating crime and managing
the safety and security of our premises and services (including but not limited
to carrying out CCTV surveillance and conducting security clearances);
j.
Compliance with any applicable rules, laws and regulations,
codes of practice or guidelines or to assist in law enforcement and
investigations by relevant authorities; and/or
k.
Any other purpose relating to or reasonably necessary for any
of the above.
3.2. In addition, SGCM may
collect, use and disclose your Personal Data for the following purposes,
depending on the nature of our relationship with you:
a.
If you have a subscription
or membership account with us:
i.
To process your application for the Services;
ii.
To maintain your account with us;
iii.
To verify and process your personal particulars and payments
in relation to provision of the Services to you;
iv.
To provide you with the goods and services which you have
signed up for;
v.
Communicating with you to inform you of changes and
development to SGCM policies, terms and conditions and other administrative
information, including for the purposes of servicing you in relation to
products and services offered to you;
vi.
Resolving complaints and handling requests and enquiries;
vii.
Conducting market research for statistical, profiling and
statistical analysis for the improvement of services provided to you; and
viii.
Any other purpose relating to or reasonably necessary for any
of the above;
b.
If you use download or use
any of our Apps:
i.
Where the App includes App Subscription Services, to process
your application for these services;
ii.
To maintain your account with us and to ensure your access of
the App is within the scope of your subscription;
iii.
To verify and process your personal particulars and payments
in relation to provision of goods and services connected to the App;
iv.
To provide you with the goods and services which you have
signed up for and to push articles, events and/or promotions to you which may
be relevant to you;
v.
Communicating with you to inform you of changes and
development to SGCM policies, terms and conditions and other administrative
information, including for the purposes of servicing you in relation to
products and services offered to you;
vi.
Resolving complaints and handling requests and enquiries;
vii.
Conducting market research for statistical, profiling and
statistical analysis for the improvement of services provided to you; and
viii.
Any other purpose relating to or reasonably necessary for any
of the above;
c.
If you are a prospective
tenant or a tenant:
i.
Conducting appropriate due diligence checks to ensure
suitability of tenant;
ii.
Preparation of documentation, including letters of offer,
other relevant leasing documentation and applications for any relevant licences
which may be required; and
iii.
Any other purpose relating to or reasonably necessary for any
of the above;
d.
If you submit an
application to us as a candidate for employment or an internship:
i.
Processing your application including pre-recruitment checks;
ii.
Providing or obtaining employee references or other
references where relevant for background screening/vetting;
iii.
Collecting information about your suitability for the
position applied for;
iv.
Organising training and staff development programs;
v.
Assessing your performance;
vi.
Administrating benefits and payroll processing;
vii.
Providing you with tools to facilitate or as required for you
to do your job;
viii.
Communicating with you as required by SGCM to comply with its
policies and processes, including for business continuity purposes; and
ix.
Any other purpose relating to or reasonably necessary for any
of the above; and/or
e.
If you submit an
application to us as a candidate for a scholarship:
i.
Processing your application including conducting background
checks, and obtaining references in order to determine your eligibility for the
scholarship; and
ii.
Any other purpose relating to or reasonably necessary for any
of the above.
3.3. In addition, where
permitted under the applicable laws, SGCM may also collect, use and disclose
your Personal Data, and share your Personal Data with SGCM’s business partners,
service providers and/or other third parties for the following purposes (which
we may describe in our documents and agreements as "Additional
Purposes" for the handling of Personal Data):
a.
Providing services, products and benefits to you, including
promotions, loyalty and reward programmes;
b.
Matching Personal Data with other data collected for other
purposes and from other sources (including third parties) in connection with
the provision or offering of products and services, whether by SGCM or other
third parties;
c.
Administering contests, competitions and conducting lucky
draws, including, where necessary, in order to announce the results of these
contests, competitions and lucky draws and identify and contact the winners,
and in order to publicise and conduct marketing strictly related to these
contests, competitions and lucky draws;
d.
Sending you details of products, services, special offers and
rewards, either to our customers generally, or of particular products and
services, special offers and rewards which may be of interest to you; and
e.
Conducting market research, data analytics, understanding and
determining customer location, preferences and demographics for us, our service
providers and/or other third parties to develop insights into the industry,
review, develop and improve our, our business partners', service providers'
and/or other third parties' products, services and also develop special offers
and marketing programmes.
3.4. If you have provided your
Singapore telephone number(s) and have indicated that you consent to receiving
marketing or promotional information via your Singapore telephone number(s),
then from time to time, SGCM may contact you using such Singapore telephone
number(s) (including via voice calls, sms, fax or
other means) with information about our products and services (including
discounts and special offers).
3.5. In relation to particular
products or services or in your interactions with us, we may also have
specifically notified you of other purposes for which we collect, use or
disclose your Personal Data. If so, then we will collect, use and disclose your
Personal Data for these purposes as well.
3.6. You may withdraw your
consent for receiving marketing or promotional materials/communication by
contacting us using the contact details below. Once we receive confirmation
that you wish to withdraw your consent for marketing or promotional
materials/communication, it may take up to 30 calendar days for your withdrawal
to be reflected in our systems. Therefore, you may still receive marketing or
promotional materials/communication during this period of time. Please note
that even if you withdraw your consent for the receipt of marketing or
promotional materials, we may still contact you for other purposes in relation
to the products and services that you have requested or purchased from SGCM.
3.7. You also consent to the
collection, use and disclosure of your Personal Data by SGCM in connection with
any transaction relating to the acquisition, divestment, securitisation,
amalgamation, listing or other transaction relating to any interest in SGCM,
the shares or assets of SGCM, and any other corporate transaction involving
SGCM, including any evaluation or due diligence relating thereto, as well as to
the collection, use and disclosure of such information by the counterpart(ies) thereto for the same purposes, and the provision of
goods and services by such counterpart(ies) following
such transaction, as may be relevant.
4.
Disclosure of Personal
Data
4.1.
SGCM will take reasonable steps to protect your Personal Data
against unauthorised disclosure. Subject to the provisions of any applicable
law, this Personal Data may be disclosed, for the purposes listed above (where
applicable), to the following third parties, whether they are located overseas
or in Singapore:
a.
SGCM affiliates;
b.
Agents, contractors or third party service providers who
provide operational services to SGCM, such as telecommunications, information
technology, payment, payroll, processing, training, market research, storage,
archival or other services to SGCM;
c.
Vendors or any third party business partners who offer goods
and services or sponsor contests or other promotional programs on SGCM sites,
whether in conjunction with us or not;
d.
External business and charity partners in relation to
corporate promotional events;
e.
The Credit Bureau, or in the event of default or disputes,
any debt collection agencies or dispute resolution centres;
f.
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);;
g.
Anyone to whom we transfer or may transfer our rights and duties;
h.
Banks, credit card companies and their respective service
providers;
i.
Our professional advisors such as our auditors and lawyers;
j.
Relevant government regulators or authority or law
enforcement agency to comply with any laws or rules and regulations imposed by
any governmental authority; and
k.
Any other party to whom you authorise us to disclose your
personal data.
5.
Deemed consent
5.1.
In addition to the matters set forth above, subject to and in
accordance with applicable law, you shall be deemed to have consented to SGCM
collecting, using, disclosing and sharing amongst ourselves your Personal Data,
and disclosing such Personal Data to SGCM’s authorised service providers and
relevant third parties:
a.
Where in response to a request for your Personal Data in connection
with identified purposes, you voluntarily provide such Personal Data to SGCM
for such purpose(s);
b.
Where the collection, use or disclosure of your Personal Data
is reasonably necessary for the conclusion and/or performance of a contract
between you and us or any other organisation entered into at your request,
which may include recipients of your Personal Data not indicated in this
Privacy Policy; or
c.
Where we have brought to your attention our intention to
collect, use or disclose your personal data for identified purposes, and you
have not taken any action to opt out within the period specified in our
notices. For this purpose, you agree that we may provide you such notices via
the SGCM website, or via other forms of communication (e.g. SMS or email) based
on the contact particulars that we may have of you in our records from time to
time.
6.
Other Bases for Handling
or Processing Your Personal Data
6.1.
In addition to and without limiting the consents you have
provided to our collection, use and disclosure of your Personal Data for the
purposes set out elsewhere in this Privacy Policy, where permitted by
applicable law, SGCM may also in accordance with the requirements thereof also
collect, use and/or disclose your Personal Data as further detailed below
including without your further consent, where we meet the requirements of
applicable law:
a.
For our legitimate interests or the legitimate interests of
any other person, including but not limited to the purposes expressly set forth
in this Privacy Policy; or
b.
For improving our products, services, processes or business,
understanding customer preferences and personalising experiences and
recommendations, based on your Personal Data records with any SGCM Companies
(regardless whether you are an existing or prospective customer of any SGCM
Companies).
7.
Use of Cookies and Related
Technologies
7.1. When you interact with us
on our websites, applications or services, we may collect or analyse anonymised
information from which individuals cannot be identified ("Aggregate
Information"), such as number of users and their frequency of use, the
number of page views (or page impressions) that occur on the website and common
entry and exit points into website.
7.2. SGCM uses cookies, and
other related technologies which have different functions. They are either
necessary for the functioning of our services, help us improve our performance,
or serve to provide you with extra functionalities.
Cookies – Small data file which is
sent to your browser to store and track Aggregate Information about you when
you enter our websites. The cookie is used to track information such as the
number of users and their frequency of use, profiles of users and their
preferred sites.
Cookies can be disabled or removed by tools that are available in most
commercial browsers. The preferences for each browser you use will need to be
set separately and different browsers offer different functionality and
options.
Web beacons - Small graphic images
(also known as "pixel tags" or "clear GIFs") that are not
apparent to the user. Tracking links and/or similar technologies consist of a
few lines of programming code and can be embedded in our websites or platforms.
Web beacons are usually used in conjunction with cookies and primarily used for
statistical analysis purposes. This technology can also be used for tracking
traffic patterns on websites and platforms, as well as finding out if an e-mail
has been received and opened and to see if there has been any response.
7.3. We may use the terms
"cookies" or "related technologies" interchangeably in our
policies to refer to all technologies that we may use to collect or store
information in your browser or device or that collect information or assist in
identifying you as a unique user in the manner described above
7.4. SGCM may use an
independent company (the "Third Party Market Research Company") to
measure and analyse the Internet usage across SGCM websites. SGCM uses the
Third Party Market Research Company's services to collect the following core information
on the usage of our websites, including:
a.
The number of page views (or page impressions) that occur on
SGCM websites;
b.
The number of unique visitors to SGCM websites;
c.
How long these unique visitors (on average) spend on SGCM
websites when they do visit; and
d.
Common entry and exit points into SGCM websites.
7.5. This information is
aggregated by the Third Party Market Research Company and provided to SGCM to
assist in analysing the usage of SGCM websites. Such data is also accessible by
media organizations and research companies, for the purpose of conducting
industry comparisons with other Internet portals.
7.6. Pages on SGCM websites may
be coded with software which enables the Third Party Market Research Company to
track visitors to our websites.
7.7. For more information about
the cookies and other related technologies we use, please see our Cookie
Policy. Should you wish to disable the cookies associated with these
technologies, you may do so by changing the setting on your browser. However,
you may not be able to enter certain part(s) of our websites.
8.
Third-Party Sites
8.1. Our website may contain
links to other websites operated by third parties, such as our business
partners. We are not responsible for the privacy practices of websites operated
by third parties that are linked to our website. We encourage you to learn
about the privacy policies of such third party websites. Some of these third
party websites may be co-branded with our logo or trademark, even though they
are not operated or maintained by us. Once you have left our website, you
should check the applicable terms, conditions and policies of the third party
website to determine how they will handle any information they collect from
you.
9.
Withdrawal, Access and
Correction of your Personal Data
9.1. Should you wish to withdraw consent to use of your Personal Data or obtain access to or make corrections to or request for deletion of your Personal Data records, please log in to the relevant account through which the Personal Data was provided, if any, failing which please contact the relevant Personal Data Protection Officer, in writing or via email at the contact details provided below.
9.2. Please note that if your
Personal Data has been provided to us by a third party, you should contact such
third party directly to make any queries, feedback, and access and/or
correction requests to SGCM on your behalf.
9.3. Please note that if you
withdraw your consent to any or all use of your Personal Data, depending on the
nature of your request, SGCM may not be in a position to continue to provide
its products or services to you or administer any contractual relationship in
place, and this may also result in the termination of any agreements with SGCM
and your being in breach of your contractual obligations or undertakings, and
SGCM’s legal rights and remedies in such event are expressly reserved.
10. Governing Law
10.1.
This Privacy Policy shall be governed in all respects by the
laws of Singapore.
11. Data Protection Officer
11.1.
You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:
Email: [email protected]
Contact number: 6744 1514
(Updated as of 28 February
2022)