This Policy sets out the manner in which SAFRA collects, uses, manages and protects Personal Data (as defined below) in compliance with the provisions of the Personal Data Protection Act 2012.
This Policy applies to all Individuals (as defined below) who provide SAFRA with Personal Data or whose Personal Data is otherwise collected, used and/or disclosed by SAFRA in connection with and/or for the purposes of its operations.
This Policy supplements but does not supersede or replace any previous consent which an Individual may have provided to SAFRA, nor does it affect any rights that SAFRA may have at law in connection with the collection, use and/or disclosure of any Individual’s Personal Data. Subject to that, SAFRA will not collect any Personal Data from an Individual unless the Individual has voluntarily chosen to provide us with it.
SAFRA reserves the right to amend or update this Policy to ensure it is consistent with its future developments or business purposes or to accommodate future changes to applicable legal or regulatory requirements. All amendments or updates to this Policy will be published at www.safra.sg and appropriate notifications of any material revisions will be issued to the relevant persons (unless such persons have unsubscribed from our notification channels). Subject to an Individual’s rights at law, the prevailing terms of the Policy from time to time shall apply. By continuing their relationship with SAFRA after any amendments have been introduced and published, Individuals shall be deemed to have accepted the Policy as amended. For the avoidance of doubt, this Policy forms part of the terms and conditions, if any, governing an Individual’s specific relationship with SAFRA ("Terms and Conditions") and should be read in conjunction with such Terms and Conditions. In the event of any conflict or inconsistency between the provisions of this Policy and the Terms and Conditions, the provisions of the Terms and Conditions shall prevail to the fullest extent permissible by law.
“Alumni” means previous Members of SAFRA;
“Application” means any mobile application developed and/or operated by SAFRA from time to time;
“Data Protection Officer” means the person designated to be responsible for ensuring that SAFRA complies with the PDPA;
“DNC Registry” means the Do-Not-Call registry maintained by the Personal Data Protection Commission, pursuant to the PDPA;
“Event Participants” means persons (whether or not Members or Alumni) who participate in or attend events or programmes organised or sponsored by SAFRA from time to time;
“Individuals” means natural persons, whether living or deceased, and “Individual” means any of them;
“Members” mean the members of SAFRA from time to time;
“PDPA” means the Personal Data Protection Act 2012;
“Personal Data” means data (whether true or not) that is capable of identifying a natural person, whether on its own or in conjunction with other data that is accessible to SAFRA. Such Personal Data shall also refer to data which is already in the possession of SAFRA or that which shall be collected by SAFRA in the future;
“Personnel” shall include any person engaged under a contract of service with SAFRA, management personnel, permanent or temporary employees, as well as volunteers engaged by SAFRA from time to time;
“Platforms” mean the websites, Applications, computer systems, computer networks and any other digital platforms operated by SAFRA from time to time; and
“Potential Personnel” shall include any Individual who has submitted an application to be engaged by SAFRA as Personnel.
- Personal Data Collected by SAFRA
SAFRA will only collect, use or disclose Personal Data about an Individual which it reasonably considers necessary for the relevant purposes underlying such collection, use or disclosure. Depending on the specific nature of an Individual’s interaction with SAFRA, Personal Data which SAFRA collects, uses or discloses concerning an Individual may variously include the following:
2.1 the Individual's personal particulars such as name, gender, date of birth, occupation, photographs and marital status; and contact particulars, including telephone number(s), residential/mailing address(es) and email address;
2.2 details of the Individual's identification documents (such as NRIC or passport numbers), and applicable visa or permits (such as employment pass, work permit, permanent residency status);
2.3 details of the Individual's employment history and academic qualifications;
2.4 details of the Individual's CPF, credit card or bank account;
2.5 the name and contact particulars of the Individual's next-of-kin;
2.6 details of the Individual's personal preferences or other special requests or special conditions applicable to the Individual;
2.7 details of the Individual's hobbies or special interest areas;
2.8 the Individual’s network usage data and other data and information, submitted by the individual or gathered automatically by our Platforms, including the Individual’s computer IP address, links visited and other activities conducted online or using our Platforms;
2.9 photographs and video or CCTV recordings of the Individual; and
2.10 other information which the Individual may provide to SAFRA, from time to time, in the course of such Individual’s interaction with SAFRA.
- How SAFRA collects Personal Data
Generally, SAFRA may collect Personal Data about an Individual in one or more of the following ways:
3.1 from the Singapore Armed Forces, Ministry of Defence and other Singapore Governmental and/or public agencies;
3.2 through application or registration forms submitted by the Individual;
3.3 through correspondence, emails, electronic messages or otherwise submitted by the Individual to SAFRA or posted on the Platforms;
3.4 through the Individual’s verbal communications with SAFRA Personnel;
3.5 through surveys conducted with and/or feedback received from an Individual;
3.7 through recordings of the Individual at SAFRA’s premises or at any events or programmes organised by SAFRA including but not limited to instances of entry into and exit from carparks at SAFRA’s clubhouses;
3.8 through third party business partners or associates of SAFRA including but not limited to transactions carried out by Individuals at points of sale at vendors or outlets located at SAFRA’s clubhouses; and
3.9 when the Individual submits his/her Personal Data to SAFRA for any other reason related to SAFRA’s ordinary course of operations and/or to participate in a lucky draw, contest, event or competition organised by SAFRA.
- Purposes for which SAFRA may collect, use and/or disclose Personal Data
Generally, SAFRA may collect, use and/or disclose Personal Data about an Individual for one or more of the following purposes:
4.1 Members and Alumni
4.1.1 administering and managing Member and Alumni relationships with SAFRA, including the provision of services to Members and Alumni, and providing Members and Alumni with information regarding the expiry and renewal of their membership;
4.1.2 providing Members and Alumni with information about services, facilities and/or other benefits being offered or made available by SAFRA to Members and Alumni and where applicable, allowing the Members and Alumni to book, subscribe and/or purchase the same;
4.1.3 providing Members and Alumni with information about third party and/or external vendor/supplier promotions, deals and/or other services being offered or made available to Members and/or Alumni, through partnerships, associations and/or other collaborations involving such third parties or external vendors/suppliers and SAFRA;
4.1.4 organising and/or facilitating events or programmes involving Members and Alumni and/or verifying the eligibility of such Members and Alumni to participate in such events or programmes;
4.1.5 tailoring activities or services available to match Members’ and Alumni preferences and to personalise their experience; and
4.1.6 transmitting Personal Data to third parties engaged by or working in collaboration with SAFRA to facilitate any of the above-mentioned purposes.
4.2.1 administering and managing Personnel relationships with SAFRA, including the provision of services to Personnel;
4.2.2 evaluating the performance of Personnel;
4.2.3 undertaking staff training and quality assurance activities;
4.2.4 providing Personnel with information about services, facilities and/or other benefits being offered or made available by SAFRA to such Personnel as well as information about such services, facilities and benefits; and
4.2.5 transmitting Personal Data to third parties engaged by or working in collaboration with SAFRA to facilitate any of the above-mentioned purposes.
4.3 Potential Personnel
4.3.1 administering and managing SAFRA’s relationship with Potential Personnel; and
4.3.2 evaluating the suitability and eligibility of Potential Personnel to be engaged by SAFRA.
4.4 Event Participants
4.4.1 administering and managing the Event Participant’s relationship with SAFRA;
4.4.2 verifying the identity and eligibility of event participants;
4.4.3 promotional and publicity purposes, including recording videos or taking photographs of participants at events; and
4.4.4 transmitting Personal Data to third parties engaged by or working in collaboration with SAFRA to facilitate any of the above-mentioned purposes.
4.5 Visitors and users of SAFRA’s facilities
4.5.1 recording and verifying the identity of visitors to SAFRA’s premises; and
4.5.2 monitoring the activities of visitors to SAFRA’s premises.
4.6 General business purposes
4.6.1 managing the administrative and business operations of SAFRA;
4.6.2 facilitating the completion of transactions with Individuals;
4.6.3 responding to complaints, queries and/or requests;
4.6.4 conducting market research for statistical profiling and other purposes in order to improve SAFRA’s services;
4.6.5 compiling data, statistics and other information, for participating in industry exercises and studies, and/or generally for data analytics initiatives to enable us to better understand and determine your preferences and demographics to develop special offers or fine tune services and to improve your service delivery and experience at our facilities;
4.6.6 safety and security purposes;
4.6.7 preventing, detecting or investigating any actual or crime, fraud, misconduct, unlawful action, breach or dispute;
4.6.8 record-keeping purposes;
4.6.9 accounting or auditing purposes;
4.6.10 participating and administering contests, lucky draws, events and competitions;
4.6.11 legal purposes (including but not limited to obtaining legal advice and dispute resolution);
4.6.12 complying with laws, regulations, codes or guidelines binding on SAFRA, including disclosures to regulatory authorities or other public bodies; and
4.6.13 transmitting Personal Data to third parties engaged by or working in collaboration with SAFRA to facilitate any of the above-mentioned purposes.
4.7 Purposes reasonably related to any of the above purposes
4.7.1 for any purposes reasonably related and/or ancillary to any of the above-mentioned purposes.
4.8 Purposes for which specific consent was obtained
4.8.1 for any purposes reasonably related and/or ancillary to any of the abovementioned purposes.
5.1 Unless otherwise authorised under the PDPA or any other applicable law, SAFRA will not collect, use or disclose an Individual’s Personal Data without his/her consent.
5.2 SAFRA will take reasonable steps to highlight the purposes relevant to an Individual, by appropriate means, at the point or time of collection of the Personal Data from such Individual, including:
5.2.1 via express provisions in contracts, application forms and/or registration forms to be signed with or submitted to SAFRA;
5.2.2 via notifications on or through the Platforms; and
5.2.3 in the course of verbal communications.
5.3 Where feasible, SAFRA will inform the Individual of purposes that are intrinsic to the relationship between SAFRA or to the provision of services to such Individual, as well as purposes that are optional.
5.4 In so far as any purpose(s) are intrinsic to the relationship or provision of services, SAFRA reserves the right to decline to engage in the relevant relationship or to provide the relevant services to the Individual if he or she does not consent to SAFRA’s collection, use or disclosure of his/her Personal Data for such purpose.
5.5 Individuals who:
5.5.1 voluntarily provide their Personal Data to SAFRA for the specified purposes;
5.5.2 use or access the Platforms;
5.5.3 enter SAFRA’s premises or using any of the facilities thereon; and/or
5.5.4 attend or participate in events or programmes organised by SAFRA
5.6 An Individual who provides SAFRA with Personal Data relating to a third party (e.g. information of his/her spouse or children) for any particular purpose, represents to SAFRA that he/she has obtained the consent of the relevant third party to SAFRA collecting, using or disclosing such Personal Data for the relevant purpose. [By providing us with any Personal Data relating to any third party (“Third Party Personal Data”), you represent and warrant that you have ensured the accuracy of such Third Party Personal Data provided and have also obtained such third party’s consent for our collection, use and disclosure of such Third Party Personal Data. You also agree to keep us indemnified from and against any and all damages, losses, costs, legal fees (on a solicitor-client basis), penalties and proceedings, imposed or charges by any regulator or authority arising out of or in connection with your acts or omission, fault or negligence which results in our breach of relevant laws.]
5.7 In so far as SAFRA collects Personal Data of an Individual from any third party(ies), such as the Singapore Armed Forces, Ministry of Defence and/or other business partners or associates of SAFRA, SAFRA will take reasonable steps to inform the relevant third party(ies) of SAFRA’s purposes for collecting the Personal Data and to verify that consent from the Individual has been obtained by the relevant third party(ies) to such disclosure for the intended purpose.
- Withdrawal of Consent
6.1 Any Individual who wishes to withdraw his/her consent to any use or disclosure of his/her Personal Data by SAFRA as set out in this Policy may do so by notifying SAFRA’s Data Protection Officer at firstname.lastname@example.org. SAFRA may require up to 2 weeks from the date of the Individual’s notification to respond and effect any change.
6.2 Depending on the extent to which an Individual withdraws consent to any or all use or disclosure of his or her Personal Data by SAFRA, such withdrawal of consent may result in SAFRA’s inability to provide services to the Individual and may be considered as a termination by the Individual of any agreement between SAFRA and the Individual. SAFRA’s legal rights and remedies are expressly reserved in such event.
- Verification of Personal Data & Notification of Changes
7.1 Where feasible (and without prejudice to clause 5.6 of this Policy), SAFRA will take reasonable steps to verify the accuracy of Personal Data received at the point of collection but Individuals remain primarily responsible and liable to ensure that all Personal Data submitted by them to SAFRA is complete and accurate. Information voluntarily by an Individual to SAFRA shall prima facie be deemed complete and accurate.
7.2 SAFRA will also take reasonable steps to periodically verify Personal Data in its possession, taking into account the exigencies of its operations, but Individuals are nonetheless required to notify SAFRA, from time to time, of any applicable changes to such Personal Data.
7.3 SAFRA shall not be held liable for any inability on its part to provide services to an Individual who fails to ensure that his/her Personal Data submitted to SAFRA is complete and accurate or who fails to notify SAFRA of any relevant changes to such Personal Data. In this regard, you should ensure that the Personal Data provided by you to SAFRA is at all times correct, accurate and complete; and you agree to update SAFRA in a timely manner of all changes to your Personal Data.
- Policy on telephone numbers registered with the DNC Registry
8.1 SAFRA is prohibited from sending unsolicited telemarketing messages (“specified messages”) to Singapore telephone numbers through voice calls, text or fax messages registered on the DNC Registry unless SAFRA has obtained the relevant Individual’s clear and unambiguous consent in written or other accessible forms.
8.2 In compliance with the PDPA, SAFRA will not send specified messages to telephone numbers that appear on the DNC Registry unless the relevant Individual has given SAFRA clear and unambiguous consent to do so.
8.3 SAFRA will continue to contact Individuals at the telephone numbers provided to SAFRA in the limited circumstances allowed under the DNC Registry even if these telephone number(s) are registered with the DNC Registry. Individuals who do not wish to receive such messages may notify SAFRA’s Data Protection Officer at email@example.com.
- Activities undertaken prior to 2 July 2014
9.1 SAFRA may use Personal Data of an Individual that was collected before 2 July 2014 for purposes for which the Personal Data was collected unless consent is withdrawn by that Individual.
9.2 SAFRA will continue to use Personal Data of its Alumni and current Members, which had been collected before 2 July 2014, for its general business purposes and purposes relating to members and alumni. Members and Alumni who wish to withdraw their consent to SAFRA’s use of their Personal Data may contact SAFRA’s Data Protection Officer at firstname.lastname@example.org.
- Protection of Personal Data
10.1 SAFRA shall make reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks to Personal Data in its possession.
10.2 If SAFRA transfers Personal Data outside Singapore, SAFRA will take reasonable steps to ensure that such Personal Data transferred receives a standard of protection comparable to the protection received under the PDPA.
10.3 SAFRA will ensure that third parties who receive Personal Data from SAFRA protect such Personal Data in a manner consistent with this Policy and not use such Personal Data for any purposes other than those specified by SAFRA, by incorporating appropriate contractual terms in its written agreements with these third parties.
10.4 SAFRA is not responsible in any way for the security and/or management of Personal Data shared by Individuals with third party websites or links accessible via the Platforms.
- Contacting SAFRA — Access to and/or Correction of Personal Data
11.1 Any Individual who:
11.1.1 has questions or feedback relating to this Policy;
11.1.2 would like to obtain access to his/her Personal Data held by SAFRA;
11.1.3 would like to information about the ways in which his/her Personal Data held by SAFRA has been or may have been used or disclosed by SAFRA in the year preceding the request; and/or
11.1.4 would like to update or make corrections to his/her Personal Data held by SAFRA should contact SAFRA's Data Protection Officer at email@example.com.
11.2 Individuals should note that SAFRA is not required, under the PDPA, to provide access and correction to Personal Data in certain situations.
11.3 The PDPA allows and SAFRA reserves the right to charge a reasonable fee for the handling and/or processing of access requests by an Individual pursuant to clauses 11.2.1 or 11.3.1 above.
11.4 SAFRA may require up to 3 weeks from the date of the Individual’s request to respond and effect any change.
- Governing Law
12.1 This Policy shall be governed by and construed in accordance with the laws of Singapore.
12.2 Any dispute arising out of or in connection with this Policy including any question regarding its existence, validity or termination, shall be referred to and finally resolved by the Courts of Singapore.