SMSDOME’S DATA PROTECTION POLICY
Last Updated: 6th March 2019
SmsDome Pte Ltd (‘SmsDome’, ‘we’, ‘us’, ‘our’) are committed to protecting and respecting your personal data privacy and complying with data protection principles and provisions under applicable laws, including the Singapore’s Personal Data Protection Act (“PDPA”) 2012 (No. 26 of 2012) and EU General Data Protection Regulation (“GDPR”).
This document represents a legal document that serves as our data protection policy (“Data Protection Policy”) which sets out the basis and terms upon which SmsDome collects, processes, uses and/or discloses your personal data that is obtained from you when you access our Website and/or such other product and services provided by SmsDome, our partners and affiliates and our third party services providers.
SmsDome also act as a data intermediary and processes personal data on behalf of other organisations (“Clients”) but does not include an employee in that company (“Data Intermediary”)
SmsDome will adhere to all obligations required by law to process personal data as a Data Intermediary while the Clients has the same obligations under the PDPA and/or GDPR in respect of the personal data that is processed on its behalf and for its purpose by a Data Intermediary as if the personal data were processed by the Clients themselves.
PLEASE READ THESE TERMS AND CONDITIONS OF USE CAREFULLY BEFORE ACCESSING, USING OR OBTAINING ANY MATERIALS, INFORMATION, PRODUCTS OR SERVICES.
ABOUT THESE TERMS & CONDITIONS
SmsDome’s Data Protection Policy apply to all our customers and users of our website, online store and Services, including online Services and may be changed from time to time (the “Act“).
By interacting with us, submitting information to us, or signing up for any Products and Services (as defined in Clause 3.2 below) offered by us, you agree and consent to SmsDome (including its related corporations and business units) (collectively, the “Companies“), as well as their respective representatives and/or agents collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to the Companies’ authorised service providers and relevant third parties in the manner set forth in this Data Protection Policy.
This Data Protection Policy supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your Personal Data, and your consents herein are additional to any rights which any of the Companies may have at law to collect, use or disclose your Personal Data.
We will ensure that all reasonable security arrangements are in place to prevent any unauthorized access, collection, use, disclosure, copying modification or disposal of your Personal Data. Where necessary, we will require any person to whom we provide your Personal Data to agree to comply with our Data Protection Policy. While we will use all reasonable efforts to ensure that such persons comply with our Data Protection Policy, we will not be liable to you if any person fails to do so.
1. PERSONAL DATA
1.1 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, including data in our records as may be updated from time to time (“Personal Data“).
1.2 Personal Data that you may provide to us include (depending on the nature of your interaction with us) the below items:
(iii) Passport or other identification number or information
(iv) Telephone number(s)
(v) Mailing address
(vi) Email address
(vii) Credit history
(viii) Geographical location
(ix) Network data
(x) Computer network
(xi) Device identifiers or information and
(xii) any other information relating to any individual which you have provided us in any form submitted to us, or via other forms of interaction with you.
2. COLLECTION OF PERSONAL DATA
2.1 Generally, we collect Personal Data in the following ways:-
2.1.1 when you submit a Customer Service Agreement, Purchase Agreement or other forms relating to any of the Products and Services;
2.1.2 when you participate in any contests or services run by us on behalf of our Clients;
2.1.3 when you interact with our customer service officers, for example, via telephone calls, letters, face-to-face meetings, emails or social media;
2.1.4 when we seek information from third parties about you in connection with the Products and/or Services you have applied for; and
2.1.5 when you use some of our Services, for example, websites and apps including establishing any online accounts with us;
2.1.6 when you request that we contact you, be included in an email or other mailing list;
2.1.7 when you purchase or obtain third party services through us;
2.1.8 when you respond to our promotions, initiatives or to any request for additional Personal Data;
2.1.9 when we receive references from business partners and third parties (e.g. where you have been referred by them);
2.1.10 when you are contacted by, and respond to, our marketing representatives and customer service officers;
2.1.11 when you submit your Personal Data to us for any other reasons, including when you sign up for a free trial of any of the Products and Services or when you express your interest in any of the Products and Services.
2.2 If you provide us with any Personal Data relating to a third party (e.g. information of your spouse, children, parents, and/or employees), by submitting such information to us, you represent to us that you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes set out in this Data Protection Policy.
2.3 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 the Products and Services you have requested.
3. PURPOSES FOR THE COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL DATA
This Clause describes the purposes for which we collect, use and disclose your Personal Data.
3.1 Generally, we collect, use and disclose your Personal Data for the following purposes:-
3.1.1 to resolve complaints and handle requests and enquiries;
3.1.2 to manage our administrative and business operations and complying with internal policies and procedures;
3.1.3 to respond to your queries and requests;
3.1.4 to monitor or record phone calls and customer-facing interactions for quality assurance, employee training, performance evaluation and identity verification purposes;
3.1.5 legal purposes (including but not limited to obtaining legal advice and dispute resolution);
3.1.6 to match any Personal Data held which relates to you for any of the purposes listed in this Data Protection Policy;
3.1.7 to prevent, detect and investigate crime and analyse and manage any commercial risks;
3.1.8 to conduct investigations relating to disputes, billing, suspected illegal activities or fraud;
3.1.9 to meet or comply with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on us (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies and conducting audit checks, due diligence and investigations); and
3.1.10 purposes which are reasonably related to any of the above purposes in this Clause 3.1 or for any other purpose which we may notify you at the time of obtaining your consent.
3.2 In addition, if you are a customer or an employee of our Clients or an organisation which share a close business relationship with us in areas such as marketing collaborations and co-branding (“Strategic Partners”), including but not limited to the purchase, subscription or use of our products and services of Strategic Partners (collectively, the “Products and Services”), we collect, use and disclose your Personal Data for the following purposes:-
3.2.1 facilitating third party services if purchased, obtained, administered or processed through us;
3.2.2 opening or continuation of accounts and establishing or providing you with the Products and Services you subscribe to (including but not limited to service activation, service operations, service delivery and order processing);
3.2.3 facilitating the daily operation of the Products and Services (including but not limited to billing, customer service, customer verification, technical support, network maintenance and troubleshooting);
3.2.4 processing of payment instructions, GIRO, direct debit facilities and/or credit facilities requested by you;
3.2.5 facilitating the continuation or termination of your subscription to the Products and Services (including but not limited to administering subscription arrangements, account maintenance, account closure, processing renewal of contracts and customer relationship management);
3.2.7 managing and executing our service-level agreements with you if any;
3.2.8 credit and internal risk management (including but not limited to performing credit checks and disclosures to law enforcement agencies);
3.2.9 generating internal reports (including but not limited to annual, operational and management reports);
3.2.10 analysing your use of the Products and Services so as to help us improve, review, develop and efficiently manage the Products and Services offered to you; and
3.2.11 purposes which are reasonably related to any of the above purposes in this Clause 3.2 or for any other purpose which we may notify you at the time of obtaining your consent.
3.3 In relation to particular Products and 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, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.
3.4 If you have provided your Singapore telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your Singapore telephone number(s), We may, from time to time, contact you using such Singapore telephone number(s) (including via voice calls, text, fax or other means) with information about our Products and Services or those products and services offered by our Strategic Partners (including discounts and special offers).
3.5 You have a choice to withdraw your consent for receiving marketing or promotional materials/communication. To do so, you may contact us using the contact details in Clause 6 below.
4. DISCLOSURE OF PERSONAL DATA
This Clause describes how your Personal Data may be disclosed by us.
4.1 Subject to Clause 4.2 below, we may share aggregated, non-personally identifiable information with the public and with our partners, such as our vendors, advertisers and other service providers.
4.2 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 in Clause 3 above or for any purpose allowed under any applicable law or regulations, to the following parties:-
4.2.1 vendors or third party service providers in connection with marketing promotions and services offered by us or our Strategic Partners;
4.2.2 our related corporations and employees to provide Content, Products and Services to you, address your questions and requests in relation to your customer accounts, subscription and billing arrangements with us as well as our Products and Services and to activate, deactivate, install, maintain and operate our systems and/or services;
4.2.3 agents, contractors or third party service providers who provide operational services to us, such as courier services, telecommunications, information technology, payment, printing, billing, payroll, processing, technical services, training, market research, call centre, security or any other services;
4.2.4 any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving any of the Companies;
4.2.5 our professional advisers such as auditors and lawyers;
4.2.6 other telecommunications, content or other service providers to facilitate their provision of content or services, or for interconnection, interoperability, system operation and maintenance and billing between service providers;
4.2.7 collection and repossession agencies in relation to the enforcement of repayment obligations for debts;
4.2.8 companies providing services relating to insurance and consultancy to us;
4.2.9 relevant government regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and
4.2.10 any other party to whom you authorise us to disclose your Personal Data to.
4.3 You understand that the transmission of information via the internet is not completely secure. Although we will do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our websites, online Services and apps; any transmission is at your own risk. Additionally, we cannot assume responsibility for any unauthorised use of your Personal Data by third parties which are wholly attributable to factors beyond our control.
5.1.1 to improve the efficiency of our websites;
5.1.2 to build up a profile of how you and other users use our websites;
5.1.3 to enable you to share our content easily on social networks.
5.1.4 to establish usage statistics;
5.1.5 to enable certain features and functions on our websites (e.g. remembering your user-id, favourite channel selections, browsing and other service preferences);
5.1.6 to administer Services to you and to advertisers;
5.1.7 to enable authentication cookies to identify you when you perform online transactions with us; and
5.2 Most internet browsers provide you the option of turning off the processing of cookies, but this may result in the loss of functionality, restrict your use of our websites and/or delay or affect the way in which our websites operate.
5.3 Advertisements on our websites may be provided by third party advertisers and their agencies. These may generate cookies to track how many people have seen a particular advertisement (or use the services of third parties to view a particular advertisement), and to track how many people have seen it more than once. We do not control these third parties and their cookie policies and if you have questions about their cookie policies, please contact us and we will endeavour to assist you by providing you information about these third party advertising agencies.
5.4 SmsDome is not responsible for the Personal Data policies (including Personal Data protection and cookies), content or security of any third party websites linked to our websites.
6. WITHDRAWAL OF CONSENT, ACCESS AND CORRECTION OF YOUR PERSONAL DATA
This Clause describes how you can withdraw your consent or obtain access and make corrections to the Personal Data that you have provided us.
6.1 If you would like to withdraw your consent to any use of your Personal Data as set out in this Data Protection Policy, please email us at firstname.lastname@example.org
6.2 Please be aware that once we receive confirmation that you wish to withdraw your consent for marketing or promotional materials/communication, it may take up to 30 working days for your withdrawal to be reflected in our systems. In the meantime, you may still receive marketing or promotional materials/communication from us. Please note that even if you withdraw your consent for the receipt of marketing or promotional materials, we may still contact you for other purposes in relation to the Products and Services that you hold or have subscribed to with us.
6.3 If you would like to obtain access and make corrections to your Personal Data records, please contact us in writing as follows:-
Data Protection Officer
SmsDome Pte Ltd
47 Jalan Pemimpin, Halcyon 2 #03-01
or through email at email@example.com
6.4 Please note that if your Personal Data has been provided to us by our Clients or a third party (e.g. a referrer), you should contact that organisation or individual to make such queries, complaints, and access and correction requests to us on your behalf.
6.5 If you withdraw your consent to any or all use of your Personal Data, depending on the
nature of your request, we may not be in a position to continue to provide the Products and Services to you or administer any contractual relationship that is already in place, which in turn may result in the termination of any agreements that you have with us, resulting in you being in breach of your contractual obligations or undertakings. SmsDome’s legal rights and remedies in such event are expressly reserved.
7. GOVERNING LAW
This Data Protection Policy and your use of our website is governed by Singapore law.