PRIVACY POLICY
This Data Protection Policy (“Policy”) sets out the basis which JDF Asia Pte. Ltd. (“we”, “us”, “our” or “JDF”) may collect, use, disclose or otherwise process personal data of users of website and portal operated, controlled and/owned by JDF, customers of JDF Asia package and members of the JDF Rewards Programme (each an “Individual”) in accordance with the Personal Data Protection Act and/or applicable laws governing personal data protection and personal data privacy (“PDPA”). This Policy applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.
PERSONAL DATA
- As used in this Policy:
“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 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.
- Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include name, partial date of birth, identification numbers such as partial NRIC (up to the last 4 alphanumeric characters), Passport, FIN, work permit and birth certificate, email address, nationality, gender, billing and payment information including bank account information, country, race and telephone/ mobile number. We only collect the minimum amount of personal data that is relevant and necessary to achieve the purposes set out in this Policy.
- Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context so permits).
COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
- We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal 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 before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
- We collect, process and/or use your personal data for any or all of the following purposes:
- administering, updating and processing your membership with JDF Rewards Programme;
- performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
- for the registration and/or payment for training courses, events, seminars, workshops and/or conferences;
- for your use of the online services on our websites and/or through other digital or telecommunication channels;
- for identifying and verifying your identity in connection with the use of services provided by or through our websites or the purchase of goods and services through our websites;
- for the conduct of statistical studies and analysis (including but not limited to data analytics, surveys, focus groups and/or profiling) to improve our services and facilities for your benefit, or to improve any of our programmes or events;
- to send news and event updates, and/or marketing campaigns in relation to the goods and/or services that we and/or Sellers on our websites or our business partners provide, or on our behalf. You may unsubscribe from this service at any time;
- to store, host, back up (whether for disaster recovery or otherwise) of your personal data, whether within or outside Singapore;
- responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
- managing your relationship with us;
- processing payment or credit transactions or bank transfers, offline payments;
- complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
- any other purposes for which you have provided the information;
- transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
- any other incidental business purposes related to or in connection with the above.
- We will take reasonable steps to protect your personal data against unauthorised disclosure. Subject to the provisions of any applicable law, your personal data may be disclosed, for the purposes listed above (where applicable), to the following categories of third parties:
- where such disclosure is required for performing obligations in the course of or in connection with the administration, updating and processing of your membership under the JDF Rewards Programme, your participation in the JDF Mall Programme, our provision of the goods and services requested by you, or such other services as may be provided by us or on our behalf;
- to third party service providers, agents, contractors, banks and other organisations we have engaged to perform any of the functions with reference to the above-mentioned purposes or who may provide services to us such as courier services, information technology, system operation and maintenance, legal advice, auditing, tax and accounting services;
- as may be required by governmental agencies or departments, or as permitted or required under applicable laws; or
- any other party to whom you authorise us to disclose your personal data to.
- The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, your membership agreement) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under a contract with you).
CONSENT
- If you, as a visitor, choose to log on as a member, register for courses or events, purchase products or services, apply for membership, or otherwise submit personally identifiable information, you are consenting to the collection, process, use and/or transfer of such data in accordance with this Policy by JDF and such parties mentioned in this Policy.
LINKS TO OTHER WEBSITES
- JDF website and other digital and telecommunication channels may contain links to other sites that are operated by third party companies with different privacy practices and/or policies. 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.
DATA SUBJECT RIGHTS
- You have a number of individual rights in regard to your data. It is important to be aware of these rights should you want to exercise any of them. These rights are outlined below.
WITHDRAWING YOUR CONSENT
- The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal 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.
- 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 thirty (30) business days of receiving it.
- 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 8 above.
- Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
ACCESS TO AND CORRECTION OF PERSONAL DATA
- 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 the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal 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. 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.
- Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
- We will respond to your request as soon as reasonably possible. In general, for request to access or correct personal data, once we have sufficient information from you to deal with the request, our response will 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 are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).
PROTECTION OF PERSONAL DATA
- To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption, use of privacy filters, and disclosing personal data both internally and to our authorised third-party service providers and agents only on a need-to-know basis.
- You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely 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
- We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.
RETENTION OF PERSONAL DATA
- We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
- We will cease to retain your personal data, or remove the means by which 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
- In the course of providing services to you, we may transfer your personal data to countries outside of Singapore. You agree that by continuing to use our services, you agree that you have provided your consent (whether to us, the third party or our affiliates) to the transfer of your personal data to third parties and/or our affiliates for the purposes set out in this Policy or any other terms applicable to you. Such transfers include transfers to but not limited to third parties and affiliates, which may be located inside or outside the country selected by you. We will take reasonable steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.
DATA PROTECTION OFFICER
- 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:
Name of DPO : Managing Director
Contact No. : +65 9711 6592
Email Address : jdfasia@gmail.com
EFFECT OF POLICY AND CHANGES TO POLICY
- This Policy applies in conjunction with any other policies, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
- We may revise this Policy from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Policy was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.
Effective date : 08 March 2021
Last updated : 18 October 2022