Privacy Policy of CommGate (S) Pte Ltd

  1. Introduction

    1. The following Privacy Policy:
      1. is to be read in conjunction with CommGate (S) Pte Ltd’s Personal Data Corporate Policy which is hereby incorporated into and will form part of this Privacy Policy (collectively, the “Policy”). A copy of the Personal Data Corporate Policy can be downloaded at [web-link]
      2. forms part of the Terms of Use (“Terms”) which govern your access to, and use of, the CommGate (S) Pte Ltd website (the “Site”), both on your desktop (web version) as well as mobile device (mobile version), owned and operated by CommGate (S) Pte Ltd.
      3. forms part of (and should be read in conjunction with) the terms and conditions governing your contractual and commercial relationship with us and under which we supply goods and services to you.
    2. By creating an account or by accessing and browsing through our website, or otherwise purchasing our products and services:
      1. you agree to be bound by the Policy and any of the related policies or guidelines, including any subsequent changes or modifications to them;
      2. you agree and consent to CommGate (S) Pte Ltd as well as our respective agents, authorised service providers and relevant third parties collecting, using, disclosing and/or sharing your Personal Data (as defined below) in the manner set forth in this Policy.
    3. This Policy supplements but does not supersede nor replace any other consents which you may have previously provided to us.
    4. We may from time to time update this Policy to ensure that this Policy is updated to take into account changes in the corporate and business environment and/or any changes in legal or regulatory requirements. If any material revision is made to this Policy, updates will be published at http://www.commgate.net/privacy-policy/.
    5. If you have any queries about the Policy, please get in touch with us using the contact details set out at [insert link] and we will do our best to answer your questions.
  2. Personal Data collected

    1. In the course of providing you with products and services, we may collect the following personal data from you:
      1. name, a username, gender, date of birth, NRIC/passport number, photograph;
      2. email address, postal address, telephone number, mobile number;
      3. employment details
      4. your interests;
      5. credit card number and expiry date;
      6. credit and transaction history;
      7. Others(collectively, “Personal Data”)
    2. Although it is not compulsory to give us the above information, if you do not then we may not be able to provide you with the full range of services that CommGate (S) Pte Ltd has to offer.
    3. In particular, certain Personal Data are essential to our ability to provide you with our products and services as well as provide customer support for these products and services.
    4. If you do not permit us to collect, use and disclose the Essential Personal Data, we will not be able to provide you with all our products and services (including customer support services).
    5. This Policy outlines how your Personal Data will be managed in accordance with the Personal Data Protection Act 2012 (“PDPA”). Please read this Policy carefully so that you know and understand the purposes for which we may collect, use and/or disclose your Personal Data.
  3. Use of Personal Data

    1. We will use and you consent to our usage of the Personal Data in order to:
      1. administer your accounts with us;
      2. process orders or applications submitted by you;
      3. send you information about our products and services;
      4. send you information about products which are related to and/or complementary to our products and services;
      5. providing benefits to you, including without limitation promotions, loyalty and reward programmes and sending you details of products, services, special offers and rewards, or materials which may be of interest to you;
      6. verify your identity;
      7. carry out marketing analysis and make general improvements to our website;
      8. processing and administering benefits or entitlements in connection with our services which you have applied for, including the administration of loyalty and rewards programmes;
      9. conducting market research for statistical profiling and other purposes to understand and determine customer preferences and demographics;
      10. compliance with any applicable local or foreign statute, rule, law, regulation, judgment, decree, directive, code of practice, guideline and/or administrative requirement;
      11. obtain your views or comments on the services we provide;
      12. contact the winners of our competitions and to help us plan other promotional activity.
    2. You agree and warrant 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 products and services you have requested.
    3. You consent to receiving information about our products, promotions and offers through voice calls, SMS, fax or other means.
    4. If you are submitting Personal Data on behalf of another individual or concerns another individual other than yourself, you represent and warrant to us that all the necessary consents (procured in accordance with all applicable data protection legislation, including without limitation the PDPA, for such purposes stated in the relevant sections of this Policy) have been obtained from the relevant individuals and that you have proof of these consents.
  4. Use and Disclosure of Personal Data

    1. Certain services available on the Site and/or through our offices are offered in conjunction with the our business partners.
    2. In order for those services to be provided we provide some necessary details about you to them. We will tell you about this at the point we collect that information on the Site and through other means. Please note that certain services may be unavailable if you do not want to disclose the Personal Data you are asked for.
    3. We may transfer your Personal Data to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation, but we will take steps with the aim of ensuring that your privacy rights continue to be protected.
    4. In addition we may pass your information onto one of our carefully selected business partners or to other carefully selected third parties to enable them to send you information which may be of interest to you but only if you have given us permission to do so. You can tell us to stop this at any time by sending an email to pdp@commgate.net.
    5. Other than as set out above, we will not disclose any of your Personal Data without your permission unless we are required by law to do so (for example, if required to do so by a court order or for the purposes of prevention of fraud or other crime).
  5. Information automatically collected from your computer

    1. Log files/IP addresses: When you visit the Site our web server automatically records your IP address. We use IP addresses to help us administer the Site and to collect demographic information for aggregation purposes.
    2. We may also gather other non-Personal Data (from which we cannot identify you) such as the type of your internet browser which we use to provide you with a more effective service.
  6. Cookies

    1. When you visit the Site we may store some information (commonly known as a “cookie”) on your computer. Cookies are pieces of information that a website transfers to your hard drive to store and sometimes track information about you. Cookies are specific to the server that created them and cannot be accessed by other servers, which means that they cannot be used to track your movements around the web. Passwords and credit card numbers are not stored in cookies. A cookie helps you get the best out of the Site and helps us to provide you with a more customised service. We use cookies [so that you will not have to re-enter your details each time you visit the Site] [and] [to track how our Site is used and to improve and update our content].
    2. You can block or erase cookies from your computer if you want to (your browser’s help screen or manual should tell you how to do this), but certain parts of the Site are reliant on the use of cookies to operate correctly and may not work correctly if you set your browser not to accept cookies.
  7. Information about other products and services

    1. From time to time we may send you information about our products and services that we think may be of interest to you.
    2. You can tell us to stop this at any time by sending an email to pdp@commgate.net.
    3. Also, as mentioned above, we may pass your information onto one of our business partners or to other selected third parties to enable them to send you information which may be of interest to you but only if you have given us permission to do so. You can tell us to stop this at any time by sending an email to pdp@commgate.net.
  8. Use of forums or chat rooms

    • The Site may from time to time include chat rooms, forums, message boards, and/ or news groups on which you can post information. Any information that you post in these areas becomes public information and you should always be careful when deciding to disclose your personal details as part of that information.
  9. Security

    • We have implemented technology and policies to safeguard your privacy from unauthorised access and improper use.
  10. Linking to third-party websites

    1. We cannot be responsible for the privacy policies and practices of other sites even if you access them using links from our Site and recommend that you check the policy of each site you visit and contact its owner or operator if you have any concerns or questions.
    2. In addition, if you linked to this Site from a third-party site, we cannot be responsible for the privacy policies and practices of the owners or operators of that third-party site and recommend that you check the policy of that third party site and contact its owner or operator if you have any concerns or questions.
  11. Transferring your information outside of Singapore

    1. As part of the services offered to you through the Site, the information you provide to us may be transferred to countries outside Singapore. By way of example, this may happen if any of our servers are located in a country outside Singapore or one of our service providers is located in a country outside Singapore. We also share information between our group companies, which are located in countries worldwide. These countries may not have similar data protection laws to Singapore. If we transfer your information outside Singapore in this way, we will take steps with the aim of ensuring that your Personal Data continue to be protected to a standard that is comparable to that under the PDPA.
    2. If you use our services while you are outside Singapore, your Personal Data may be transferred outside Singapore in order to provide you with those services.
  12. Contact us

    • Access or Changes to your Personal Data
      1. We aim to keep our information about you as accurate as possible. If you would like to access, review or change the details you have supplied us with, you may contact our Data Protection Officer at:Address: 71 Ubi Road 1, Oxley Bizhub 1 #07-38/39 Singapore 408732Email: pdp@commgate.net
    • Withdrawal of Consent
      1. If you wish to withdraw your consent to any use or disclosure of your Personal Data as set out in this Policy, you may contact our Data Protection Officer at:Address: 71 Ubi Road 1, Oxley Bizhub 1 #07-38/39 Singapore 408732Email: pdp@commgate.net
      2. Please note that if you withdraw your consent to any or all use or disclosure of your Personal Data, depending on the nature of your request, we may not be in a position to continue to provide our products or services to you or administer any contractual relationship in place where the continuation of such products/services/contractual relationship would reasonably require your Personal Data. Such withdrawal may also result in the termination of any agreement you may have with us. [Name of Company]’s legal rights and remedies are expressly reserved in such event.
    • Other Queries
      • If you have any questions or complaints relating to the use or disclosure of your Personal Data, or if you wish to know more about our data protection policies and practices, please contact our Data Protection Officer at :Address: 71 Ubi Road 1, Oxley Bizhub 1 #07-38/39 Singapore 408732Email: pdp@commgate.net