Robin Chia PAC and RCCM Group of Companies Privacy and Data Protection Policy

1. Introduction

1.1 ROBIN CHIA PAC and RCCM Group of Companies takes its responsibilities under Singapore’s Personal Data Protection Act 2012 (the “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, and we are committed to protect the privacy of your personal data.

1.2 The purpose of this policy is to inform you and provide you with an understanding of how we handle, collect, use, disclose and process personal data about you that you give us, that we receive through third parties or that is in our possession.

1.3 By providing your personal data to us, you acknowledge and agree that you have fully read and understood this policy, and are consenting to the collection, use and disclosure of your personal data as described in this policy.

1.4 Without prejudice to any of the foregoing, if you provide the personal data of any other third party to us, you warrant and agree that such third party has fully read and understood this policy, and has consented to you disclosing his/her personal data to us for the collection, use and disclosure by us as described in this policy.

2. Types of Personal Data We Collect

2.1 The PDPA defines ‘personal data’ 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. Robin Chia PAC and RCCM Group of Companies collects information about you when you use our website(s), website/IT portal(s), forms, surveys, and/or other channels and throughout other interactions, communications and services you have with us.

2.2 Personal data which we may collect include but are not limited to :
(a) your personal information such as your name, NRIC/FIN/Passport number;

(b) your contact information such as postal addresses, email addresses, telephone, mobile phone and fax numbers;

(c) your organisation name, organisation Unique Entity Number, postal address, business telephone and fax numbers, business email addresses;

(d) your billing and payment information, including name of the credit/debit cardholder, credit/debit card number, security code, expiry date, GIRO and Cheque details.

2.3 We will collect your personal data in accordance with the PDPA.

2.4 We may collect and store certain information automatically when you visit our website(s) or use our website(s)/IT portal(s). Examples include the internet protocol (IP) address used to connect your computer or device to the Internet, connection information such as browser type and version, your operating system and platform, a unique reference number linked to the data you enter on our system, login details, the full URL clickstream to, through and from the website(s) or website/IT portal(s) (including date and time), cookie identifier and your activity on our website(s) or website/IT portal(s), including the pages you visited, the searches you made and, if relevant, the services you purchase.

2.5 We may receive information about you from third parties if you use any websites or social media platforms operated by third parties  and, if such functionality is available, you have chosen to link your profile on our website(s) or website/IT portal(s) with your profile on those other websites or social media platforms.

3. Cookies

3.1 We use cookies to identify you from other users on our website(s) or website/IT portal(s).

3.2 A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer or device.

3.3 You can block or deactivate cookies in your browser settings.

3.4 We use log-in cookies to remember you when you have logged in for a seamless experience.

3.5 We use session cookies to track your movements from page to page and in order to store your selected inputs so you are not constantly asked for the same information.

3.6 By continuing to use our website(s) or website/IT portal(s), you are agreeing to the use of cookies on the site as outlined above. However, please note that we have no control over the cookies used by third parties.

4. Purposes for which the Personal Data is Collected, Used and Disclosed

4.1 We will/may collect, use, disclose and/or process your personal data for one or more of the following purposes :

(a) For the supply of any goods and/or services which we may offer to you or that you may request, obtain or purchase from us;

(b) To deal with, process and/or administer your use of the online services at any of our website(s), website/IT portal(s) and/or through other digital or telecommunication channels;

(c) To carry out your instructions, respond to any enquiry or deal with any feedback given by (or purported to be given by) you or on your behalf, including contacting you via phone/voice call, text message and/or fax, email and/or postal mail regarding your instructions, enquiries and/or feedback;

(d) To conduct research, analysis and development activities (including but not limited to data analytics, surveys and/or profiling) to improve our services and facilities for your benefit, or to improve any of our activities, events, services or projects;

(e) To contact you or communicate with you via various modes of communication such as phone/voice call, text message and/or fax message, email and/or postal mail for the purposes of administering through ROBIN CHIA PAC and RCCM Group of Companies. You acknowledge and agree that such communication by us could be by way of the mailing of correspondence, documents or notices to you, which could involve disclosure of certain personal data about you to bring about delivery of the same as well as on the external cover of envelopes/mail packages;

(f) To carry out due diligence or other screening activities (including security and background checks) in accordance with legal or regulatory obligations or our risk management procedures that may be required by law or that may have been put in place by us;

(g) To comply with or as required by any applicable law, governmental or regulatory requirements of any jurisdiction applicable to us or our affiliates/associated companies, including meeting the requirements to make disclosure under the requirements of any law binding on us or our affiliates/associated companies, and/or for the purposes of any guidelines issued by regulatory or other authorities (whether of Singapore or elsewhere), with which we or our affiliates/associated companies are expected to comply;

(h) To comply with or as required by any request or direction of any governmental authority; or respond to requests for information from embassies, public agencies, ministries, statutory boards or other similar authorities;

(i) For marketing purpose where we send you news, information, materials and/or updates about activities, products and/or services that we and/or our business partners provide, or on our behalf. In this regard, we will be doing so by way of postal mail and/or electronic transmission to your email address(es). You may unsubscribe from this service in the manner set out in Clause 7 below;

(j) To facilitate and/or deal with payment for goods and/or services provided by us or our subsidiaries, and/or a third party on our behalf including verification of credit card details with third parties and additionally, using the personal data you provide to conduct matching procedures against databases of known fraudulent transactions (maintained by us or third parties);

(k) We wish to bring to your attention that there are surveillance cameras installed throughout the premises of ROBIN CHIA PAC and RCCM Group of Companies for security reasons and you acknowledge that your personal data will be collected by such cameras and processed by us consequently;

(l) To disclose to a third party to comply with any law, legal requirements, orders, directions or requests from any court, authority or government body of any jurisdiction, which may be within or outside Singapore;

(m) To store, host, back up of your personal data, whether within or outside Singapore.

(collectively, referred to as the “Purposes”)

4.2 We may/will need to disclose your personal data to third parties, including to banks, payment service providers and/or other payment gateways, whether located within or outside Singapore, for one or more of the above Purposes, as such third parties, would be processing your personal data for one or more of the above Purposes. In this regard, you hereby acknowledge, agree and consent that we may/are permitted to disclose your personal data to such third parties (whether located within or outside Singapore) for one or more of the above Purposes and for the said third parties to subsequently collect, use, disclose and/or process your personal data for or more of the above Purposes. Without limiting the generality of the foregoing, such third parties include :

(a) our associated/affiliated organisations or related corporations;

(b) any of our agents, contractors or third party service providers that process or will be processing your personal data on our behalf including but not limited to those which provide administrative or other services to us such as mailing houses, telecommunication companies, information technology companies and data centres; and

(c) third parties to whom disclosure by ROBIN CHIA PAC and RCCM Group of Companies is for one or more of the Purposes and such third parties would in turn be collecting and processing your personal data for one or more of the Purposes.

4.3 You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control by contacting our Data Protection Officer. However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal, including us being unable to perform the transactions requested by you on our website(s) or website/IT portal(s). Do note that your withdrawal of consent will not affect our ability to collect, use or disclose your personal data for a specific purpose without your consent, if the PDPA or a provision in applicable law permits us to.

4.4 We may collect, use, disclose or process your personal data for other purposes that do not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of your personal data without your consent is permitted by the PDPA or by law.

4.5 We may/will also be collecting from sources other than yourself, personal data about you, for one or more of the above Purposes, and thereafter using, disclosing and/or processing such personal data for one or more of the above Purposes. We may combine information we receive from other sources with information you give to us and information we collect about you. We may use this information and the combined information for the Purposes set out above (depending on the types of information we receive).

5. Storage of Personal Data

5.1 Security of your personal data is important to us. We take appropriate action to protect personal data from loss, misuse, unauthorised access or disclosure, alteration or destruction using the same safeguards as we use for our own proprietary information. All information you provide to us is stored on secure servers and any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website(s) or website/IT portal(s), you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

5.2 We will 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 (a) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (b) retention is no longer necessary for any other legal or business purposes.

6. Link to other websites

6.1 ROBIN CHIA PAC and RCCM Group of Companies website(s), website/IT portal(s) and other digital and telecommunication channels may contain links to other sites that are operated by third party companies with different privacy practices. You should remain alert and read the privacy statements of other sites. We have no control over personal data that you submit to or receive from these third parties.

7. Withdrawal of Consent for Marketing Purposes

7.1 You have the right to ask us not to use your personal data for marketing purpose. If you no longer wish to receive marketing messages from us, please contact:

The Data Protection Officer
Robin Chia PAC
60 Tessensohn Road
#02-01A, Club CSC @ Tessensohn
Singapore 217664
Email : dpo@rccmgroup.com

8. Data Access and Correction

8.1 You have the right to access and/or correct any personal data that we hold about you, subject to the requirements of the PDPA. If you would like to have a copy of your personal data being held by us, or to update and/or correct the personal data which you have previously provided to us, please contact:

The Data Protection Officer
Robin Chia PAC
60 Tessensohn Road
#02-01A, Club CSC @ Tessensohn
Singapore 217664
Email : dpo@rccmgroup.com

8.2 We will need enough information from you in order to ascertain your identity as well as the nature of your request, so as to be able to deal with your request. We reserve the right, or may, charge a reasonable fee for the processing of any data access request.

8.3 For a request to access personal data, once we have sufficient information from you to deal with the request, we will seek to provide you with the relevant personal data within 30 days. Where we are unable to respond to you within the said 30 days, we will notify you of the soonest possible time within which we can provide you with the information requested.

8.4 For a request to correct personal data, once we have sufficient information from you to deal with the request, we will correct your personal data within 30 days. Where we are unable to do so within the said 30 days, we will notify you of the soonest practicable time within which we can make the correction. Note that the PDPA exempts certain types of personal data from being subject to your correction request as well as provides for situation(s) when correction need not be made by us despite your request. We will send the corrected personal data to every other organisation to which the personal data was disclosed by us 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.

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 as follows:

The Data Protection Officer
Robin Chia PAC
60 Tessensohn Road
#02-01A, Club CSC @ Tessensohn
Singapore 217664
Email : dpo@rccmgroup.com

9.2 Where you are sending an email in 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. General

10.1 Your consent that is given pursuant to this Privacy Policy is additional to and does not supersede any other consents that you had provided to ROBIN CHIA PAC and RCCM Group of Companies with regard to processing of your personal data.

10.2 For the avoidance of doubt, in the event that Singapore personal data protection law permits an organisation such as us to collect, use or disclose your personal data without your consent, such permission granted by the law shall continue to apply.

11. Enquiries

11.1 For any enquiries on our privacy policy, please write to:

The Data Protection Officer
Robin Chia PAC
60 Tessensohn Road
#02-01A, Club CSC @ Tessensohn
Singapore 217664
Email : dpo@rccmgroup.com

ROBIN CHIA PAC reserves the right to change this policy with or without notice so please check back frequently.