PRIVACY POLICY
Your personal data is important to us and we are committed to complying with the Personal Data Protection Act 2012 (No. 26 of 2012) (the “PDPA”). This personal data protection policy (“Policy”) sets out how we collect, use and disclose your personal data and applies to Capen Marketing Pte Ltd and its subsidiaries (collectively, the Kele Roll Cakes).
This Policy supplements but does not supersede nor replace any other consents you may have previously provided to the Kele Roll Cakes in respect of your personal data, and your consents herein are additional to any rights which the Kele Roll Cakes may have at law to collect, use or disclose your personal data.
PERSONAL DATA
‘Personal data’ is defined under the PDPA to mean data about an individual who can be identified from that data; or from that data and other information to which the organisation has or is likely to have access.
Personal data may include your name, NRIC number, passport number, employment pass number, nationality, gender, photograph, telephone numbers, mailing address, email address, age, date of birth, marital status, signature, job title/profession, financial information (such as bank account or credit/debit card numbers) 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.
COLLECTION OF PERSONAL DATA
The ways in which we may collect your personal data include (but are not limited to) collecting your personal data directly or indirectly from you or your authorised representatives in the course of:
We may also collect personal data about you from third parties including (but not limited to):
If you provide us with any personal data relating to a third party (e.g. information of your next-of-kin, spouse, children, parents, dependants, and/or employees), you represent and warrant to us that you have obtained the necessary consent from the relevant third party to provide us with their personal data for the relevant purpose(s) for which we are collecting their personal data.
USE AND DISCLOSURE OF PERSONAL DATA
We use the personal data that we collect from you for the following purposes:
We may transfer or share your personal data with:
Kele Roll Cakes is a listed entity on the Singapore Exchange Securities Trading Limited with international presence. As such, the personal data you submit to us in one country may be transferred, used and accessed in one or more additional countries. You fully understand and unambiguously consent that we may transfer your personal data to any location outside of Singapore for the purposes set out above. When transferring your personal data outside of Singapore, we will ensure that your personal data will be protected to a standard comparable to the protection accorded to your personal data under the PDPA by ensuring that the recipient is either in a jurisdiction which has comparable data protection laws, or is contractually bound to protect your personal data.
Notwithstanding the above, we may process your personal data without your consent if it is permitted under the PDPA or any other relevant legislation.
SECURITY AND STORAGE OF PERSONAL DATA
We will take reasonable efforts to protect your personal data in our possession or control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks (“Risks”). However, we shall not be held responsible for Risks occurring in relation to your personal data that are beyond our control, such as Risks resulting from cyber-attacks.
Security arrangements which we undertake to protect your personal data may include the following:
While we strive to protect your personal data, we cannot ensure the security of the information you transmit to us via the Internet or through the use of our electronic services, and we urge you to take every precaution to protect your personal data when you use such platforms. If applicable, you undertake to use a combination of uppercase and lowercase letters, numbers and symbols for your password, change your password often, use a secure browser when accessing our website(s), keep your username and password secure and confidential and not disclose or permit it to be disclosed to any unauthorised person, and to inform us as soon as reasonably practicable if you know or suspect that someone else knows your username and password or believe the confidentiality of your username and password has been lost, stolen or compromised in any way or that actual or possible unauthorised transactions have taken place.
RETENTION OF PERSONAL DATA
We will cease to retain your personal data when we no longer require such personal data for any of the purposes for which it was collected or for any business or legal needs.
ACCURACY OF PERSONAL DATA
We will take reasonable efforts to ensure that your personal data in our records is accurate and complete, if your personal data is likely to be used by us to make a decision that affects you, or disclosed to another organisation. However, you must also update us of any changes in your personal data that you have initially provided us with. We will not be responsible for relying on inaccurate or incomplete personal data arising from you not updating us of any changes in your personal data that you have initially provided us with.
You must also ensure that all personal data submitted by you to us is complete, accurate, true and correct.
COOKIES
When you interact with us on our website(s), we automatically receive and record information (such as your server address, domain name, the date and time of visit and the pages viewed) on our server logs from your browser. We may employ cookies in order for our server to recognise a return visitor as a unique user including, without limitation, monitoring information relating to how a visitor arrives at the website, what kind of browser a visitor is on, what operating system a visitor is using, a visitor’s IP address, and a visitor’s click stream information and time stamp (for example, which pages they have viewed, the time the pages were accessed and the time spent per web page).
Cookies are small text files placed in your computer hard drive or mobile devices when you visit our website(s) and allow us to remember you. The cookies placed by our server are readable only by us, and cookies cannot access, read or modify any other data on a computer.
Should you wish to disable the cookies associated with these technologies, you may do so by changing your browser settings accordingly. However, you may not be able to enter certain part(s) of our website(s), and some of the functions and services may not be able to function without cookies. This may also impact your user experience while on our website(s).
THIRD-PARTY SITES
Our website may contain links to other websites operated by third parties, such as our business partners. We are not responsible for the privacy practices of websites operated by third parties that are linked to our website. We encourage you to learn about the privacy policies of such third party websites. Some of these third party websites may be co-branded with our logo or trademark, even though they are not operated or maintained by us. Once you have left your website, you should check the applicable privacy policy of the third party website to determine how they will handle any information they collect from you.
CONTACTING US
If you:
If you make a request to obtain access to your personal data records with us, we may charge a reasonable fee for verifying the authenticity of the request and locating, retrieving and copying any material requested. If a fee is to be charged, we will inform you of the amount beforehand and respond to your request after payment is received.
Please note that if your personal data had been provided to us by a third party, you should contact that organisation or individual to make such queries, complaints, and access and correction requests to us on your behalf.
Please also note that we are not required, under the PDPA, to provide access and correction to your personal data in certain exempted situations as set out in the PDPA.
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 our products and services to you, or administer any contractual relationships in place, which in turn may also result in termination of any agreements you have entered into with us, and your being in breach of your contractual obligations or undertakings. Our legal rights and remedies in such event are expressly reserved.
GOVERNING LAW
This Policy shall be governed by and construed in accordance with the laws of Singapore. 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.
CONTRACT (RIGHTS OF THIRD PARTIES) ACT
A person who is not a party to this Policy shall have no right under the Contracts (Rights of Third Parties) Act (Chapter 53B) to enforce any of its terms.
UPDATES TO THIS POLICY
We reserve the right to periodically review and amend this Policy from time to time to take account of new laws and technology, changes to our operations and practices and the changing business environment. The updated Policy will be made available on http://www.kelerollcakes.com.sg/privacy-policy and date stamped so that you are aware of when the Policy was last updated.
You are encouraged to visit the above website on a regular basis to ensure that you are well informed of our latest policies in relation to personal data protection.