Our PDPA Policy
Dear valued February 29 customers and guests,
This Personal Data Protection Policy notice for personal data (“Notice”) is issued to all our valued customers and guests of February 29 (“[February 29]”, “us”, “we”, “our” or “ours”), pursuant to the statutory requirements of the Personal Data Protection Act 2012 (“PDPA”).
We at February 29 take our responsibilities under Singapore’s PDPA seriously. We also recognize the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data.
During your course of dealing with us, we may have, and / or will collect, use, disclose and process your personal data for purposes, including, to communicate with you, provide products and/or services to you, respond to your enquiries or complaints, provide you with information and/or updates on products, services and/or promotions offered by February 29 and selected third parties and other purposes required to operate and maintain our business as set out in our Personal Data Protection Policy (collectively referred to as “Purposes”).
In order to conduct our business operations more smoothly, we may also be disclosing the personal data you have provided to us to our third party service providers, agents and/or our affiliates or related corporations, and/or other third parties whether sited in Singapore or outside of Singapore, for one or more of the above-stated Purposes. Such third party service providers, agents and/or affiliates or related corporations and/or other third parties would be processing your personal data either on our behalf or otherwise, for one or more of the above-stated Purposes.
FOR February 29
More information on the Purposes for which we collect, use, disclose or processes your personal data and how we will protect your personal data can be found in our Personal Data Protection Policy, which is available
It is necessary for us to collect and to retain your personal data. If you do not provide us with your personal data, or do not consent with this Notice or our Personal Data Protection Policy, we will not be able to effectively provide products and/or services to you, if at all.
We are committed to ensuring that your personal data is stored securely. You have the right to request for access to, to request for a copy of and to request to update or correct your personal data held by us. You have the right at any time to request us to limit the processing and use of your personal data. (for example, requesting us to stop sending you any marketing and promotional materials or contacting you for marketing purposes).
By submitting your personal data to us, you consent to us collecting, using, disclosing and processing your personal data in accordance with this Notice. We will also take it that all personal data provided by you is accurate and complete, and that none of it is misleading or out of date. You will promptly update us in the event of any change to your personal data.
In some circumstances, you may have provided personal data relating to other individuals (such as your spouse, family members or other third party including minors). You represent and warrant that you are authorised to provide their personal data to us and you have obtained their consent to the collection, use, disclosure and processing of their Personal Data in accordance with this Notice.
We reserve the right to update and amend this Notice and our Personal Data Protection Policy from time to time. We will notify you of any amendments to this Personal Data Protection Notice or our Personal Data Protection Policy via announcements on our website or other appropriate means. If we amend this Personal Data Protection Notice or our Personal Data Protection Policy, the amendment will only apply to personal data collected after we have posted the revised Personal Data Protection Notice or Personal Data Protection Policy.
We at February 29 take our responsibilities under Singapore’s Personal Data Protection Act 2012 (the “PDPA”) seriously. We also recognise the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data.
This Data Protection Policy is designed to assist you in understanding how we collect, use, disclose and/or process the personal data you have provided to us, as well as to assist you in making an informed decision before providing us with any of your personal data.
1 INTRODUCTION TO THE PDPA
1.1 “Personal Data” is defined under the PDPA to mean data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access. Common examples of personal data could include names, identification numbers, contact information, medical records, photographs and video images.
1.2 We will collect your personal data in accordance with the PDPA. We will notify you of the purposes for which your personal data may be collected, used, disclosed and/or processed, as well as obtain your consent for the collection, use, disclosure and/or processing of your personal data for the intended purposes, unless an exception under the law permits us to collect and process your personal data without your consent.
1.2
2 COLLECTION OF YOUR PERSONAL DATA
2.1 The provision of your personal data is voluntary. But, if you do not provide your Personal Data to us, February 29 may not be able to provide the services which you require of us.
2.2 February 29 collects personal data during the course of its everyday activities, and will only collect such personal data if it is necessary for one of our functions or activities.
2.3 The Personal Data Protection Act requires us to collect personal data about you, only from you, if it is reasonable and practical to do so. Some examples of the types of information which we may collect about our stakeholders include:
3 HOW PERSONAL DATA IS COLLECTED
3.1 Some examples of how personal data can be collected:
4 PURPOSES FOR COLLECTION, USE, DISCLOSURE AND PROCESSING OF PERSONAL DATA
4.1 The personal data which we collect from you may be collected, used, disclosed and/or processed for various purposes, depending on the circumstances for which we may/will need to process your personal data, including :
5 SPECIFIC ISSUES FOR THE DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES
5.1 We respect the confidentiality of the personal data you have provided to us. February 29 does not share, sell, rent or release any personal data collected to any individuals, companies or groups. Any information we collect is used for February 29 ’s own purposes as described in this PDP policy.
5.2 So that we can provide a wide range of products and services to you, third party service providers offering services are engaged through February 29 , including the following:
6 REQUEST FOR ACCESS AND/OR CORRECTION OF PERSONAL DATA
6.1 You may request to access and/or correct the personal data currently in our possession by submitting your request at the following and using the online form set out therein. FEBRUARY 29 members may access their personal data by viewing and editing their online membership profile or through our in-store kiosks.
6.2 For a request to access personal data, we will provide you with the relevant personal data within thirty (30) days from such a request being made.
6.3 Where a request cannot be complied with within the above time frame, we will inform you of the reasonably soonest time in which we will respond.
6.4 For a request to correct personal data, we will :
(a) correct your personal data as soon as practicable after the request has been made unless we have reasonable grounds not to do so; and
(b) subject to paragraph [6.5], we will send the corrected personal data to every other organisation to which the personal data was disclosed by February 29 within a year before the date the correction was made, unless that other organisation does not need the corrected personal data for any legal or business purpose.
6.5 Notwithstanding paragraph [6.4(b)], we may, if you so consent, send the corrected personal data only to specific organisations to which the personal data was disclosed by us within a year before the date the correction was made.
6.6 Depending on the scope and nature of the work required to process your access request, we may be required to impose a fee to recover our administrative costs. This will be assessed on a case-by-case basis by our Data Protection Officer. Where such a fee is to be imposed, we will provide you with a written estimate of the fee for your consideration. Please note that we will only process your request once you have agreed to the payment of the fee. In certain cases, we may also require a deposit from you before we process the access request. You will be notified in a deposit is required in the written estimate of the fee, if any.
7 REQUEST TO WITHDRAW CONSENT
7.1 You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control by submitting your request at our contact page.
7.2 We will process your request [within a reasonable time] from such a request for withdrawal of consent being made, and will thereafter not collect, use and/or disclose your personal data in the manner stated in your request.
7.3 However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal. In this regard, depending on the extent of your withdrawal of consent for us to process your personal data, it may mean that we will not be able to continue with your existing relationship with us.
7.4 The collection of your Personal Data by us may be mandatory or voluntary in nature depending on the Purposes for which your Personal Data is collected. Where it is obligatory for you to provide us with your Personal Data, and you fail or choose not to provide us with such data, or do not consent to the above or this Policy, we will not be able to provide products and/or services or otherwise deal with you.
8 ADMINISTRATION AND MANAGEMENT OF PERSONAL DATA
8.1 We will take reasonable efforts to ensure that your personal data is accurate and complete, if your personal data is likely to be used by February 29 to make a decision that affects you, or disclosed to another organisation. However, this means that you must also update us of any changes in your personal data that you had initially provided us with. We will not be responsible for relying on inaccurate or incomplete personal data arising from your not updating us of any changes in your personal data that you had initially provided us with.
8.2 We will also put in place reasonable security arrangements to ensure that your personal data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorized access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data. However, we cannot assume responsibility for any unauthorized use of your personal data by third parties which are wholly attributable to factors beyond our control.
8.3 We will also put in place measures such that your personal data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes.
9 COMPLAINT PROCESS
9.1 If you have any complaint or grievance regarding about how we are handling your personal data or about how we are complying with the PDPA, we welcome you to contact us with your complaint or grievance through our contact page.
9.2 Where it is an email or a letter through which you are submitting a complaint, your indication at the subject header that it is a PDPA complaint would assist us in attending to your complaint speedily by passing it on to the relevant staff in our organisation to handle. For example, you could insert the subject header as “PDPA Complaint”.
9.3 We will certainly strive to deal with any complaint or grievance that you may have speedily and fairly.
10 UPDATES ON DATA PROTECTION POLICY
10.1 As part of our efforts to ensure that we properly manage, protect and process your personal data, we will be reviewing our policies, procedures and processes from time to time.
10.2 We reserve the right to amend the terms of this Data Protection Policy at our absolute discretion. Any amended Data Protection Policy will be posted on our website.
10.3 You are encouraged to visit the above website from time to time to ensure that you are well informed of our latest policies in relation to personal data protection.
