Privacy Policy

This Policy, together with our Terms of Use and any other documents referred to in it, sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.

1. INFORMATION COLLECTION

(a) To provide our Services to you, we may collect and process the following:

(i) information that you provide, including information provided at the time of registering to use our site, subscribing to our Services, posting material or requesting further services. We may also require additional information at other times, for example in connection with a promotion or when you report a problem with our site;

(ii) we may keep a record of every correspondence between us and you;

(iii) we may require you to complete surveys that we use for research purposes, although you may choose whether or not to respond to them;

(iv) details of transactions you carry out through our site and of the fulfilment of your requests/actions;

(v) details of your visits to our site and the resources that you access.

(b) We retain personal data for so long as it is necessary. Data may be archived as long as the purpose for which the data was used still exists, even after termination of your account or use of our Services.

2. USE OF INFORMATION DECLARED, SUBMITTED AND OBTAINED

(a) Information may be used by us in and outside Singapore for:

(i) ensuring that content of our Services is presented in an effective manner for you and for your computer;

(ii) providing you with alerts, news, education materials and/or information that you requested or signed up to/for;

(iii) carrying out our obligations arising from any Agreements entered into between you and us;

(iv) allowing you to participate in interactive features of our Services;

(v) designing and conducting surveys/questionnaires for client profiling/segmentation, analysis, and improving our Services;

(vi) complying with laws and regulations applicable to us or any of our affiliates;

(vii) legal proceedings;

(viii) researching, designing and launching of new or related services or products;

(ix) promoting and marketing current, new or related services and products subject to your exercise of the opt-out right (please see further details in clause 8 below); or

(x) all other purposes directly related or incidental to the above.

(b) Your data may be used in direct marketing and we require your consent (which includes an indication of no objection) for that purpose. Therefore, please note that:

(i) your name, contact details (including address, contact number, email address), products and services information, transaction patterns and behaviour, background and demographic data held by us from time to time may be used by us in direct marketing;

(ii) the following classes of services, products and subjects may be marketed in direct marketing:

(iii) services and products related to our site and/or our affiliates (including marketing affiliates programs we are a part of);

(iv) reward, loyalty or privileges programmes, promotional offers and related services; and

(v) invitations to events such as seminars/webinars/tele-seminars, conferences, live programs or events.

(c) We may conduct direct marketing via fax, email, direct mail, telephone and other means of communication or send e-newsletters to you. You may choose not to receive promotional materials, by simply telling us (see below for contact details), and we will cease to do so, without charge.

3. DISCLOSING OF INFORMATION

(a) Personal data will be held confidential but may be used to provide information to:

(i) personnel, agents, advisers, auditors, contractors, financial institutions, and service providers in connection with our Services;

(ii) our overseas offices, affiliates, business partners and counterparts (if any);

(iii) persons under a duty of confidentiality to us;

(iv) persons to whom we are required to make disclosure under applicable laws and regulations in or outside Singapore; and/or

(v) actual or proposed transferees or participants of our services in or outside Singapore.

4. USE OF COOKIES

(a) A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.

(b) Our website uses cookies to distinguish you from other users. This provide you with a good experience when you browse our website and allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies.

(c) We use the following cookies:

(i) Necessary cookies. These are cookies that are required for the smooth operation of our website. They include cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.

(ii) Analytical cookies. These are cookies that allow us to recognise and count the number of visitors and their usage patterns on website. This helps us to improve our website.

(iii) Third parties (including advertising networks and providers of external services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.

(d) Our website uses Google Analytics, a web traffic analysis service provided by Google Inc. (“Google”). Please refer to http://www.google.com/policies/privacy/partners to find out more about how Google uses data when you use our website and how to control the information sent to Google.

(e) You may use your browser settings to block all cookies (including essential cookies) but doing so may result in you not being able to access all or parts of our site.

5. SECURITY

(a) All information you provide to us is stored on our secure servers. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential.

(b) In reality, the transmission of information via the internet is not completely secure and while we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site. Any transmission is at your own risk.

6. AMENDMENTS

Any amendments to this Policy will be posted on our website.

7. DATA TRANSFER

We may hold your data on servers in Singapore and any other territories as we see fit from time to time. We may also transfer your data to our overseas offices or to any third party listed at clause 3 above, who may be located in or outside of Singapore.

8. CONSENT AND RIGHTS

(a) By using our service, making an application or visiting our website, you consent to the collection and use of your information and other activities as outlined herein.

(b) Under the Personal Data Protection Act (the “PDPA“), individuals have the right:

(i) to check whether we hold personal data about you and to access such data;

(ii) to require us to correct as soon as reasonably practicable any inaccurate data relating to you;

(iii) to ascertain our policies and practices in relation to personal data and the kind of personal data held by us; and

(iv) to object to the use of your personal data for marketing purposes and we shall not use your personal data for marketing purposes after you communicate your objection to us.

(c) You may exercise your opt-out right by notifying us if you wish to object to the use of your personal data for direct marketing purposes. Please send requests for such objections, access to data, correction of data, information regarding policies and practices and kinds of data held, questions or complaints to:

ask@rafflestreat.sg

(d) In accordance with the terms of the PDPA, we have the right to and may charge a minimum fee for processing any data access request.

9. JURISDICTION

Nothing in this Policy shall limit the rights of the data subject under the PDPA. This Policy shall be governed by the laws of the Republic of Singapore and you agree to submit to the exclusive jurisdiction of the Singapore courts.