Privacy Policy – Phoon Huat

Privacy Policy

This Privacy Policy and the Purchase Terms and Conditions of Use govern the relationship between you and Phoon Huat Pte. Ltd.

By interacting with us, submitting information to us, or purchasing or signing up for any products and services offered by us, you agree and consent to Phoon Huat Pte. Ltd. , as well as its representatives and/or agents (collectively referred to herein as “Phoon Huat“, “us“, “we” or “our“) collecting, using, disclosing and sharing amongst ourselves your Personal Data, and disclosing such Personal Data to Phoon Huat’s authorised service providers and relevant third parties in the manner set forth in this Privacy Policy.

Phoon Huat reserves the right to vary or amend the Privacy Policy and/or the Purchase Terms and Conditions of Use at any time by posting the amended policy and/or the Purchase Terms and Conditions of Use on our website at http://esales.phoonhuat.com/privacypolicy. Subject to your rights at law, you agree to be bound by the prevailing terms of this Privacy Policy as updated from time to time. Please check our website regularly for updated information on the handling of your Personal Data.

This Privacy Policy was last updated on 17/06/2016.

Unless otherwise set out in this Privacy Policy, the definitions set out in the Purchase Terms and Conditions of Use shall apply herein mutatis mutandis.

Reference to “PH Platform” in this Privacy Policy means our website www.phoonhuat.com, our eSales Portal at http://esales.phoonhuat.com, and/or any other services, information and functions made available by us through www.phoonhuat.com.

At Phoon Huat, your privacy is important to us.

1. Personal Data

1.1 In this Privacy 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.

1.2 Examples of the Personal Data which you may provide to us include (depending on the nature of your interaction with us) your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address and any other information relating to 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

2.1 Generally, we collect Personal Data in the following ways:

(a) when you submit data via the PH Platform, such as when you register as a Customer or set up an Account on the PH Platform or when you sign for any up for any of our services (including our classes) via the PH Platform;

(b) when you submit any form, including but not limited to customer inquiry forms or other forms relating to any of our products and services;

(d) when you request that we contact you or request that you be included in an email or other mailing list;

(e) when you respond to our promotions, initiatives or to any request for additional Personal Data;

(f) when your images are captured by us via CCTV cameras while you are within our premises, or via photographs or videos taken by us or our representatives when you attend our events;

(g) when you are contacted by, and respond to, our marketing representatives and customer service officers;

(h) when we seek information about you and receive your Personal Data in connection with your relationship with us, including for our products and services; and/or

(i) when you submit your Personal Data to us for any other reasons.

2.2 If you provide us with any Personal Data relating to a third party (e.g. information of your spouse or children etc), by submitting such information to us, you warrant and represent to us that you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes.

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, or delays in providing you with products and services you have requested, or processing your applications.

3. Purposes for the Collection, Use and Disclosure of Your Personal Data

3.1 Generally, Phoon Huat collects, uses and discloses your Personal Data for the following purposes (where applicable):

(a) processing payment;

(b) facilitating and processing membership applications and matters related thereto;

(d) verifying your identity;

(e) preventing, detecting and investigating crime and analysing and managing commercial risks;

(f) managing the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances);

(g) monitoring or recording phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes;

(h) such purposes in connection with the administration and maintenance your Account, including all transactions entered into in connection with your Account;

(i) recording, monitoring and processing your Orders;

(j) planning, monitoring and scheduling routes for deliveries;

(k) for all forms of communication, such as to confirm and update the status of your Orders and deliveries, and responding to, processing and handling your queries, feedback, complaints and requests;

(l) conducting market research and statistical analysis;

(m) assessing your creditworthiness;

(n) protecting the PH Platform against possible errors, frauds and other criminal activities;

(o) verifying and executing all financial transactions in relation to payments made for online purchases from the PH Platform;

(p) conducting research or performing statistical analysis of your purchasing behaviour and interest to enable Phoon Huat to better serve you;

(q) matching any Personal Data held which relates to you for any of the purposes listed herein;

(r) in connection with any claims, actions or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution), and/or protecting and enforcing our contractual and legal rights and obligations;

(s) conducting any form of investigations including but not related to those relating to disputes, billing, fraud, offences, prosecutions etc;

(t) managing and planning the administrative and business operations of Phoon Huat and complying with internal policies and procedures;

(u) facilitating business asset transactions (which may extend to any mergers, acquisitions or asset sales);

(v) meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies (including but not limited to responding to complaints and conducting audit checks, due diligence and investigations);

(w) enforcing any legal proceedings that Phoon Huat may have against you; and/or

(x) purposes which are reasonably related to the aforesaid.

3.2 Where Phoon Huat enters into any business asset transactions (which may extend to mergers, acquisitions, disposals or asset sales), you consent and authorise Phoon Huat to disclose your Personal Data to any business partner, investor, assignee or transferee (actual or prospective) for the purposes of facilitating the business asset transaction and the ongoing conduct of the business thereafter, including for the purposes set out in this Privacy Policy.

3.3 Where permitted under applicable law, Phoon Huat may also collect, use and disclose your Personal Data in order to update you of Phoon Huat’s promotions, offers, surveys, events, products and services, and purposes which are reasonably related to the aforesaid.

3.4 In relation to particular products and services or in your interactions with us, we may also from time to time notify 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.

4. Disclosure of Personal Data

4.1 Phoon Huat 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 entities or parties, whether they are located overseas or in Singapore:

(a) Phoon Huat’s related corporations and affiliates;

(b) agents, contractors, sub-contractors or third party service providers who provide operational services to Phoon Huat, such as courier services, telecommunications, information technology, payment, printing, billing, processing, technical services, transportation, training, market research, call centre, security, or other services to Phoon Huat;

(c) vendors or third party service providers and our marketing and business partners in connection with marketing promotions, products and services;

(d) 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);

(e) external banks, credit card companies, other financial institutions and their respective service providers;

(f) our professional advisers such as consultants, auditors and lawyers;

(g) relevant government ministries, 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/or

(h) any other party to whom you authorise us to disclose your Personal Data.

5. Confidentiality of Personal Data

5.1 Personal Data provided to Phoon Huat by you will be kept confidential and will only be disclosed for the purposes stated in this Privacy Policy You acknowledge and consent to Phoon Huat disclosing such Personal Data to its employees and third parties contracted by Phoon Huat to perform tasks relating to the provision of the Products and services to you. All such third parties, if any, are required by Phoon Huat to use the Personal Data strictly to provide the Products and services, and are required to maintain the confidentiality of the Personal Data.

5.2 Any questions, comments, suggestions or information (other than Personal Data) sent or posted to the PH Platform by you will be deemed voluntarily provided to Phoon Huat on a non-confidential and non-proprietary basis. Phoon Huat may use, reproduce, disclose, transmit, publish, broadcast or post elsewhere such information in connection with the development, manufacture and marketing of the Products and services.

5.3 Phoon Huat is not responsible for the privacy practices or policies of other websites accessible via the PH Platform. By activating a link (eg, by clicking on the banner of an advertiser or pop-out by other third parties), you will leave the PH Platform and Phoon Huat does not have control over any Personal Data or any other information you give to any other person or entity.

6. Collection of Computer Data through the PH Platform

6.1 The PH Platform may use cookies, web beacons, and other similar technologies for storing information to help provide you with a better, faster, safer and personalized experience when you use the services and/or access the PH Platform. When you visit the PH Platform, Phoon Huat’s servers will automatically record information that your browser sends whenever you visit a website. This data may include:

your computer’s IP address;
browser type;
the Webpage you were visiting before you came to the PH Platform;
the pages within the PH Platform which you visit;
the time spent on those pages, items and information searched on the PH Platform, access times and dates, and other statistics.

Such information is collected for analysis and evaluation in order to help Phoon Huat improve the PH Platform, and the Products and services it provides and you consent to the same.

6.2 The PH Platform may pass a “cookie” (a string of information that is sent by a website to reside in your computer’s hard drive and/or temporarily in your computer’s memory). The purpose of a cookie is to tell the web server that you have returned to a particular page, to retain log-in information or to remember preferences and enhance your experience on the PH Platform. Phoon Huat may allow third parties to set cookies through the PH Platform in order to help Phoon Huat manage and analyse the performance of the PH Platform. You may set your browser to decline cookies. If you do so, you may not be able to fully experience some interactive features of the PH Platform.

7. Personal Data Security

7.1 Personal data collected by Phoon Huat will be securely stored and disposed when no longer required by Phoon Huat for business or legal purposes.

7.2 If you have an Account with us on the PH Platform, you agree that your Personal Data may be retained by Phoon Huat even after your Account is terminated and that Phoon Huat may, where permitted under applicable law, continue to contact you with marketing information until you notify Phoon Huat otherwise.

8. Contact Us

8.1 If you wish to withdraw your consent to Phoon Huat’s use of your Personal Data, request to access or correct your Personal Data, have any queries, comments or concerns, or require any other assistance, kindly contact Phoon Huat’s designated Data Protection Officer at: dpo@phoonhuat.com

8.2 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 calendar days for your withdrawal to be reflected in our systems. Therefore, you may still receive marketing or promotional materials/communication during this period of time.

9. Governing Law

9.1 This Privacy Policy shall be governed in all respects by the laws of Singapore.

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