We at Fortitudo Pte. Ltd. (“Fortitudo”, “us”, “we”, “our” or “ours”) take our responsibilities under Singapore’s Personal Data Protection Act 2012 (the “PDPA”) seriously. We also recognise the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data.
This Personal Policy is designed to assist you in understanding how we collect, use, disclose and/or process the personal data you have provided to us, as well as to assist you in making an informed decision before providing us with any of your personal data.
You can visit the Site (as defined in the Terms and Conditions) and browse without having to provide personal details. During your visit to the Site you remain anonymous and at no time can we identify you unless you have [an account on the Site and log on with your user name and password].
If you, at any time, have any queries on this policy or any other queries in relation to how we may manage, protect and/or process your personal data, please do not hesitate to contact our Data Protection Officer (the “DPO”) at
Fortitudo Pte. Ltd.
10 Anson Road
#26-04, International Plaza,
Email Address: email@example.com
1 INTRODUCTION TO THE PDPA
1.1 “Personal Data” is defined under the PDPA to mean data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access. Common examples of personal data could include names, identification numbers, contact information, medical records, photographs and video images.
1.2 We will collect your personal data in accordance with the PDPA. We will notify you of the purposes for which your personal data may be collected, used, disclosed and/or processed, as well as obtain your consent for the collection, use, disclosure and/or processing of your personal data for the intended purposes, unless an exception under the law permits us to collect and process your personal data without your consent.
2 COLLECTION OF YOUR PERSONAL DATA
2.1 The provision of your personal data is voluntary. But, if you do not provide your personal data to us, Fortitudo may not be able to provide the services which you require of us. You may access and update your personal data submitted to us at any time as described below.
If you provide personal data of any third party to us, we assume that you have obtained the required consent from the relevant third party to share and transfer his/her personal data to us.
2.2 Fortitudo collects personal data during the course of its everyday activities, and will only collect such personal data if it is necessary for one of our functions or activities.
2.3 The PDPA requires us to collect personal data about you, only from you, if it is reasonable and practical to do so. Some examples of the types of information which we may collect about you include:
- contact information such as names, addresses, telephone numbers, and email addresses;
- housing information such as household size, type of home, and living situation;
- unique information such as ID or passport number, photograph, contact preferences, and date of birth;
- transaction history; and
- if you are a candidate for employment, we may collect your resume, other information as set in our application or during our recruitment process. This data may include information relating to your employment history, working eligibility rights, and your referee details.
3 HOW PERSONAL DATA IS COLLECTED
3.1 Some examples of how personal data can be collected:
- Register your details on our Site or app;
- When you complete purchase orders, requests or applications for our products or services (by phone, in person, snail mail, or electronically);
- When you communicate with us directly via our workshops, or directly via our co-workers in relation to our products and services (in person, by email, telephone, direct mail or any other means)
- When you enter, and when you interact with us during promotions, competitions, contests, lucky draws, or special events,;
- Subscribe to any of our membership programmes;
- Participate in surveys and other types of research; or
- If you are a candidate for employment, when you complete forms in relation to the recruitment and selection process for the purpose of assessment. We may also collect information about you from your nominated referees where you have authorised us to do so.
4 PURPOSES FOR COLLECTION, USE, DISCLOSURE AND PROCESSING OF PERSONAL DATA
4.1 The personal data which we collect from you may be collected, used, disclosed and/or processed for various purposes, depending on the circumstances for which we may/will need to process your personal data, including :
- to communicate with you;
- to maintain and improve customer relationship;
- to assess, process and provide products, services and/or facilities to you;
- to administer and process any payments related to products, services and/or facilities requested by you;
- to establish your identity and background;
- to respond to your enquiries or complaints and resolve any issues and disputes which may arise in connection with any dealings with us;
- to provide you with information and/or updates on our products, services, upcoming promotions offered by us and/or events organised by us and selected third parties which may be of interest to you from time to time;
- for direct marketing purposes via SMS, whatsapp, phone call, email, fax, mail, social media and/or any other appropriate communication channels to members of our loyalty programmes, in accordance with their consent;
- to facilitate your participation in, and our administration of, any events including contests, promotions or campaigns;
- to award points in a loyalty or rewards programme;
- to maintain and update internal record keeping;
- for internal administrative purposes;
- to send you seasonal greetings messages from time to time;
- to send you invitation to join our events and promotions and product launch events;
- to monitor, review and improve our events and promotions, products and/or services;
- to conduct credit reference checks and establish your credit worthiness, where necessary, in providing you with the products, services and/or facilities;
- to process any payments related to your commercial transactions with us;
- to process and analyse your Personal Data either individually or collectively with other individuals;
- to conduct market research or surveys, internal marketing analysis, customer profiling activities, analysis of customer patterns and choices, planning and statistical and trend analysis in relation to our products and/or services;
- to share any of your Personal Data pursuant to any agreement or document which you have duly entered with us for purposes of seeking legal and/or financial advice and/or for purposes of commencing legal action;
- to share any of your Personal Data with our business partners to jointly develop products and/or services or launch marketing campaigns;
- to share any of your Personal Data with financial institutions necessary for the purpose of applying and obtaining credit facility(ies), if necessary;
- for audit, risk management and security purposes;
- for detecting, investigating and preventing fraudulent, prohibited or illegal activities;
- for enabling us to perform our obligations and enforce our rights under any agreements or documents that we are a party to;
- to transfer or assign our rights, interests and obligations under any agreements entered into with us;
- for meeting any applicable legal or regulatory requirements and making disclosure under the requirements of any applicable law, regulation, direction, court order, by-law, guideline, circular or code applicable to us;
- to enforce or defend our rights and your rights under, and to comply with, our obligations under the applicable laws, legislation and regulations; and/or
- for other purposes required to operate, maintain and better manage our business and your relationship with us, which we notify you of at the time of obtaining your consent.
(collectively, the “Purposes”)
As the purposes for which we may/will collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of your personal data without your consent is permitted by the PDPA or by law.
4.2 In order to conduct our business operations more smoothly, we may also be disclosing the personal data you have provided to us to our third party service providers, agents and/or our affiliates or related corporations, and/or other third parties whether sited in Singapore or outside of Singapore, for one or more of the above-stated Purposes. Such third party service providers, agents and/or affiliates or related corporations and/or other third parties would be processing your personal data either on our behalf or otherwise, for one or more of the above-stated Purposes. In sharing your personal data with them, we endeavor to ensure that the third parties and our affiliates keep your personal data secure from unauthorised access, collection, use, disclosure, or similar risks and retain your personal data only for as long as they need your personal data to achieve the abovementioned purposes. Third parties, with the exception of Government bodies and other public agencies, are subject to data protection obligations and may only use your personal data to perform the necessary functions.
Fortitudo does not share, sell, rent or release any personal data collected to any individuals, companies or groups. Any information we collect is used for the purposes as described in this Personal Policy.
As a general policy, we will not disclose your personal data to third parties without first obtaining your consent permitting us to do so. However, in exceptional circumstances Fortitudo may be required to disclose personal information, such as when there are grounds to believe that the disclosure is necessary to prevent a threat to life or health, or for law enforcement purposes, or for fulfillment of legal and regulatory requirements and requests.
6 REQUEST FOR ACCESS AND/OR CORRECTION OF PERSONAL DATA
6.1 You may request to access and/or correct your personal data currently in our possession by emailing your request to firstname.lastname@example.org.
6.2 For a request to access personal data, we will provide you with the relevant personal data within thirty (30) days from such a request being made.
6.3 Where a request cannot be complied with within the above time frame, we will inform you of the reasonably soonest time in which we will respond.
6.4 For a request to correct personal data, we will :
(a) correct your personal data as soon as practicable after the request has been made unless we have reasonable grounds not to do so; and
(b) subject to paragraph [6.5], we will send the corrected personal data to every other organisation to which the personal data was disclosed by Fortitudo within a year before the date the correction was made, unless that other organisation does not need the corrected personal data for any legal or business purpose.
6.5 Notwithstanding paragraph [6.4(b)], we may, if you so consent, send the corrected personal data only to specific organisations to which the personal data was disclosed by us within a year before the date the correction was made.
6.6 Depending on the scope and nature of the work required to process your access request, we may be required to impose a reasonable fee to recover our administrative costs. This will be assessed on a case-by-case basis by our Data Protection Officer. Where such a fee is to be imposed, we will provide you with a written estimate of the fee for your consideration. Please note that we will only process your request once you have agreed to the payment of the fee. In certain cases, we may also require a deposit from you before we process the access request. You will be notified if a deposit is required in the written estimate of the fee, if any.
7 REQUEST TO WITHDRAW CONSENT
7.1 You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control by submitting your request to email@example.com.
7.2 We will process your request within a reasonable time from such a request for withdrawal of consent being made, and will thereafter not collect, use and/or disclose your personal data in the manner stated in your request.
7.3 However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal. In this regard, depending on the extent of your withdrawal of consent for us to process your personal data, it may mean that we will not be able to continue with your existing relationship with us, and we may not be in a position to continue to provide our products or services to you or perform on any contract we have with you. Our legal rights and remedies are expressly reserved in such event.
8 ADMINISTRATION AND MANAGEMENT OF PERSONAL DATA
8.1 We will take reasonable efforts to ensure that your personal data is accurate and complete, if your personal data is likely to be used by Fortitudo to make a decision that affects you, or disclosed to another organisation. However, this means that you must also update us of any changes in your personal data that you had initially provided us with. We will not be responsible for relying on inaccurate or incomplete personal data arising from your not updating us of any changes in your personal data that you had initially provided us with.
8.2 We will also put in place reasonable security arrangements to ensure that your personal data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorized access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data. However, we cannot assume responsibility for any unauthorized use of your personal data by third parties which are attributable to factors beyond our control.
8.3 We will also put in place measures such that your personal data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes.
9 COMPLAINT PROCESS
9.1 If you have any complaint or query regarding about how we are handling your personal data or about how we are complying with the PDPA, we welcome you to contact us with your complaint or query at firstname.lastname@example.org.
9.2 You may also contact us through one of the following methods with your complaint or grievance :
Data Protection Officer
Fortitudo Pte. Ltd.
10 Anson Road
#26-04, International Plaza,
Email Address: email@example.com
9.3 Where it is an email or a letter through which you are submitting a complaint, your indication at the subject header that it is a PDPA complaint would assist us in attending to your complaint speedily by passing it on to the relevant staff in our organisation to handle. For example, you could insert the subject header as “PDPA Complaint”.
9.4 We will certainly strive to deal with any complaint or query that you may have speedily and fairly.
10.1 As part of our efforts to ensure that we properly manage, protect and process your personal data, we will be reviewing our policies, procedures and processes from time to time.
10.3 You are encouraged to visit our Site from time to time to ensure that you are well informed of our latest policies in relation to personal data protection.
Last Updated on 1 January 2017