Privacy Policy

    HONG LEONG GROUP SPORTS & RECREATION CLUB

    PERSONAL DATA POLICY

     

    1. INTRODUCTION
      1. This policy details how the Hong Leong Group Sports & Recreation Club (herewith known as “HLGSRC”) manages members’ personal data.
      2. By interacting with the HLGSRC, accessing the HLGSRC’s app and website, submitting information to the HLGSRC (whether through our app or website or otherwise), or signing up for any events or activities, products or services offered by us, you agree and consent to the HLGSRC collecting, using, disclosing and sharing amongst ourselves your Personal Data, and disclosing such Personal Data to the HLGSRC’s authorised service providers and relevant third parties in the manner set forth in this Personal Data Policy.
      3. It is to be interpreted in conjunction with the Singapore Personal Data Protection Act (No. 26 of 2012).

     

    1. AIM
      1. This policy aims to let members of the HLGSRC know and understand the purposes for which the HLGSRC collects, uses and discloses your personal data.

     

    1. DETAILS OF POLICY
      1. Application
        1. It applies to all members of the HLGSRC.
        2. This Policy supplements but does not supersede nor replace any other consent you may have previously provided to the HLGSRC nor does it affect any rights which the HLGSRC may have at law in connection with the collection, use or disclosure of your Personal Data. The HLGSRC may from time to time update this Policy to ensure that this Policy is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of the Policy as updated from time to time on our website (www.hlgsrc.org.sg). Please check back regularly for updated information on the handling of your Personal Data.

     

    1. COLLECTION OF PERSONAL DATA
      1. What types of Personal Data do we collect?
        1. In this Data Protection Policy, “Personal Data” refers to any data, whether true or not, about an individual 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, including data in our records as may be updated from time to time.
        2. Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us) your name, NRIC, passport or other identification number, date of birth, gender, nationality, contact number(s) (including telephone, mobile and facsimile numbers), residential and/or mailing addresses, email address and any other information relating to yourself and any individuals which you have provided us in any forms you may have submitted to us, or via other forms of interaction with you.
      2. Collection of Personal Data
        1. Generally, the HLGSRC collects your Personal Data in the following ways:
          • When you submit forms registering for any of our activities or events, or relating to any products or services which may be offered by us;
          • 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, or participate in any of our social media offerings;
          • When you interact with us, including during face-to-face meetings or by way of telephone conversations;
          • When you request that we contact you;
          • When you are contacted by, and respond to, our marketing representatives and agents;
          • When you respond to our request for additional Personal Data;
          • When you subscribe or ask to be included in our email or other mailing lists;
          • When you respond to our promotions and other initiatives;
          • When you respond to our market surveys;
          • When you submit a job application to our Group;
          • When we receive references from business partners and third parties, for example, where you have been referred by them;
          • When your photographs or videos are taken by us or our representatives when you attend events hosted by us; and
          • When you submit your Personal Data to us for any other reason.
        2. When you browse our websites, you generally do so anonymously but please see section 5 on the “Use of Cookies” and section 6 on the “IP Address”.
        3. If you provide us with any Personal Data relating to a third party (e.g. information of your spouse, children, parents, and/or employees), including where you have named them as a member of your immediate or extended family, or where you refer a third party to us for the purposes of us offering our products and/or services to that third party,  by submitting such information to us, you represent to us that you have obtained the consent of the third party for you providing us with their Personal Data for the purposes set out below.
      3. How do we use Personal Data and to whom do we disclose it?
        1. In general, the HLGSRC collects, uses and discloses your Personal Data for the following purposes:
          • to provide you with the products or services that have been requested;
          • to help us profile, review, develop, manage and enhance our products and services, including by analysing future member needs;
          • to communicate with you and respond to your queries, requests and complaints;
          • to provide ongoing information about our activities or events which may be relevant to you;
          • to protect and enforce our contractual and legal rights and obligations;
          • to comply with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities; and
          • purposes which are reasonably related to the aforesaid.
        2. In addition, the HLGSRC may collect, use and disclose your Personal Data for the following purposes, depending on the nature of our relationship with you:
          • If you have a membership account with us:
            1. to verify and process your personal particulars and payments (including but not limited to billing and process of payment instructions) in relation to provision of the services which you may be entitled to or which you may have requested for;
            2. to communicate with you to inform you of changes and development to the policies, terms and conditions, other administrative information, including for the purposes of servicing you in relation to products and services offered to you and for receiving of marketing and promotional materials sent via SMS, calls, emails, direct mailer and all the foregoing; and
            3. any other purpose directly relating to any of the above.
          • If you are a vendor, a prospective vendor or a contractor or an employee thereof:
            1. to manage the outsourcing relationship;
            2. to conduct background checks and due diligence;
            3. to contact you for emergency purposes;
            4. to process any payments of invoices and claims including payments to any accounts payable;
            5. to ensure the security of our premises; and
            6. any other purpose directly relating to any of the above.
        3. For all of the purposes mentioned above, 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.
        4. Where you have specifically provided us with additional consents, the HLGSRC may also collect, use and disclose your Personal Data for the following purposes:
          • subscribing you to our mailing list;
          • providing marketing and promotional information to you about our activities, events, services, products and benefits including offers, promotions, loyalty and reward programmes;
          • sending you regular updates on the activities, events, products and services, offers and promotions of our business partners and/or our affiliates;
          • administering contests, competition 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; and
          • sending you invitations to our activities and events, feedback sessions etc.
        5. In relation to particular activities, events, 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 additional purposes as well, unless we have specifically notified you otherwise.
        6. Your Personal Data will be protected and kept confidential, but subject to the provisions of any applicable law, this Personal Data may, depending on the activity, event, product or service concerned and for the purposes listed above (where applicable), be disclosed to the following parties:
          • other divisions or subsidiaries of the Hong Leong Group;
          • agents, contractors, third party service providers and specialist advisers to the HLGSRC who have been contracted to provide the HLGSRC with administrative, operational or other goods and services, such as telecommunications, information technology, payment, payroll, processing, training, market research, storage, or archival;
          • any third party business partners who offer goods and services or sponsor contests or other promotional programs, whether in conjunction with the HLGSRC or not;
          • insurers, credit providers, courts, tribunals and regulatory authorities as agreed or authorised by law;
          • our professional advisors such as auditors and lawyers;
          • relevant government, statutory or regulatory authority (including securities exchange) or law enforcement agency in order to comply with any laws or rules and regulations imposed by such authority or any order, notice, directive or judgment of any court, tribunal, arbitration or mediation body;
          • anyone to whom we assign or transfer or may assign or transfer any of our rights and duties; and
          • any other party as may be consented to by you, as specified by that individual or the contract.
      4. Do Not Call Provisions
        1. If you have provided us with your Singapore telephone number(s) and have indicated that you consent to receiving marketing or other promotional information via your Singapore telephone number(s), then from time to time, the HLGSRC may contact you using such Singapore telephone number(s) (including via voice calls, text, fax or other means) with information about our activities, events, products, services (including discounts and special offers), and other event invitations even if these telephone number(s) are registered with the DNC Registry. You may however advise in writing should you wish not to be contacted by us at your telephone number(s) for such purposes.
      5. Use of Cookies
        1. When you interact with us on our app and/or websites, we automatically receive and record information on our server logs from your browser. When you visit our app and/or websites, we may assign one or more cookies to your smartphone/computer. A cookie is a small encrypted text file placed in the 'Cookies' folder on your smartphone/computer's hard disk, and may be used to collect information and statistics relating to your access to our app/websites, including information on how you arrive at our websites, what kind of  browser you are on, what operating system you are currently using, your IP address, and your clickstream information and time stamp (for example, which pages you have viewed, the time the pages were accessed and the time spent per web page on our websites). The cookie will provide a unique identifier to your smartphone/computer and each time you visit our websites from the same smartphone/computer, our server will recognise a return visitor and allow us to increase the functionality of our websites on your computer.
        2. The cookies placed by our server are readable only by us, and cookies cannot access, read or modify any other data on your computer.
        3. Most browsers automatically accept cookies, but cookies can be enabled or disabled by modifying the settings in your browser. To find out how to do this, and for more information on cookies, please visit http://cookiepedia.co.uk/how-to-manage-cookies. If you choose not to allow us to place a cookie on your smartphone/computer, you may be restricted from some services offered on our app/website, and some of the interactive features on our app/website may be similarly restricted or be rendered inoperable.
      6. IP Address
        1. An IP address is a number that is automatically assigned to your computer when you sign up with an Internet Service Provider.
        2. When you visit our app/website, your IP address is automatically logged in our server. We use your IP address to help analyse trends, administer the website, and track users' movements. From your IP address, we may identify the general geographic area from which you are accessing our app/website. However, we will not be able to pinpoint the exact geographic location from which you are accessing our app/website. Generally we do not link your IP address to anything that can enable us to identify you unless it is required by applicable laws and regulations.
      7. Third-Party Sites
        1. Our websites may contain links to other websites operated by third parties, such as our affiliates and vendors. We have no control over, and are not responsible for the privacy practices of websites operated by third parties that are linked to our websites. We encourage you to learn about the privacy policies of such third party websites. Once you have left our website, you should check the applicable privacy policy of the third party website to determine how they will handle any information they collect from you.
      8. How to contact us
        1. If you:
          • have any questions, complaints or feedback relating to your Personal Data or our Personal Data Policy;
          • would like to withdraw your consent to any use of your Personal Data as set out in this Personal Data Policy; or
          • would like to obtain access and make corrections to your Personal Data records under our control or in our possession, please contact us as follows:
            Email: This email address is being protected from spambots. You need JavaScript enabled to view it.
            Call: 62225707
            Write in: Data Protection Officer
            Hong Leong Group Sports & Recreation Club
            16 Raffles Quay,
            #34-03, Hong Leong Building,
            Singapore 048581
          • To enable us to process your request efficiently, please include your name and email or correspondence address, together with the information you wish to be corrected or withdrawn for our processing.
          • Please note that if your Personal Data has been provided to us by a third party, you should request such third parties to make such queries, complaints, access and correction requests to the HLGSRC on your behalf.
      9. Data Transfer
        1. In the event where sharing of information about you, with and between our business corporations and associates is necessary, 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.
      10. Data Retention
        1. We may retain your Personal Data for as long as it is necessary for the purposes it has been collected, up to 7 years, unless otherwise 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.
      11. Individual Rights
        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 Data Protection Officer:
          • 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;
          • you are entitled to rectification of your Personal Data. 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 products and services you have requested;
          • in certain circumstances, you have the right to request to have your Personal Data deleted or the processing of which restricted;
          • 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;
          • 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;
          • 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
          • to lodge a complaint about the way in which your Personal Data is being used to a supervisory authority.
        2. If you withdraw your consent to any or all use of your Personal Data in our possession, depending on the nature of your request, the HLGSRC may not be in a position to continue to provide information on its activities, events, promotions, products or services to you. Your withdrawal of consent may accordingly constitute a repudiatory breach of your obligations under the agreements which you may have with the HLGSRC, which may result in the termination by the HLGSRC of the same. The HLGSRC’s legal rights and remedies in such events are expressly reserved.
        3. Where mandated under the applicable data protection laws, your exercise of the rights described or referred to above shall be free of charge. In all other situations, we may charge a fee to cover the cost of verifying the request and locating, retrieving and copying any material requested.
        4. If you want to exercise any of your rights or if you wish to raise a complaint, you may contact our Data Protection Officer at the contact details provided in section 4(h).
      12. DPO Appointment
        1. We have appointed a Data Protection Officer to oversee our management of your Personal Data in accordance with this Policy and the applicable data protections law. We train our employees who handle your Personal Data to respect the confidentiality of your Personal Data, and we regard breaches of all applicable data protection laws very seriously.
      13. Policy Review
        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. If you are unsure whether you are reading the most current version, please contact us.
        2. In the event of any inconsistencies between the English version and other translations of this Policy, the English version shall prevail.
      14. Governing Law
        1. This Personal Data Policy shall be governed in all respects by the laws of Singapore.

     

    CONCLUSION

    This policy was reviewed on 22 February 2021.

    Copyright © 2020 Hong Leong Group Sports & Recreation Club. All Rights Reserved.