This Data Protection Policy states how your Personal Data will be managed in accordance with the Personal Data Protection Act (“PDPA”) which aims to protect personal data of individuals. This Data Protection Policy will give you an understanding of the purposes for which we may collect, use and/or disclose Personal Data. You agree and consent to ABR Holdings Ltd (“ABR”) and our group companies, affiliates, associated entities, branches, subsidiaries and offices (collectively referred to herein as “ABR”, “us”, “we” or “our”) as well as our respective agents, authorized service providers and relevant third parties collecting, using, disclosing and/or sharing your Personal Data in the manner set forth in this Data Protection Policy. This Data Protection Policy supplements but does not supersede nor replace any other consent which you may have previously provided to us nor does it affect any rights that we may have at law in connection with the collection, use and/or disclosure of your Personal Data. We may from time to time update this Data Protection Policy to ensure that this Data Protection Policy is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. If any material revision is made to this Data Protection Policy, updates will be published at our official websites. Subject to your rights at law, the prevailing terms of the Data Protection Policy shall apply.
Your Personal Data
In this Data Protection Policy, “Personal Data” refers to any data or information about you from which you can be identified either (i) from that data; or (ii) from that data and other information to which we have or are likely to have access. Examples of such Personal Data include:
- your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address and any other information relating to you which you have provided us in any forms you may have submitted to us, or in other forms of interaction with you;
- information about your use of ABR’s website and services, including cookies, IP address, policy and claims history information;
- your employment history, education background, and income levels;
- your transaction related information, such as your credit card information; and
- information about your usage of and interaction with our website and/or services including computer and connection information, device capability, bandwidth, statistics on page views, and traffic to and from our websites.
Collection of Personal Data
Generally, ABR may collect your Personal Data in the following ways:
- when you register with us for an account and membership;
- when you access our website or perform an online transaction;
- when you interact with any of our employees (including customer service officers and front line service staff);
- when you submit an application to us to purchase our products or use our services;
- when you respond to our request for additional Personal Data;
- when you ask to be included in an email or other mailing list;
- when you request that we contact you;
- when you respond to our promotions; and
- when you submit your Personal Data to us for any other reason.
Purposes for the Collection, Use and Disclosure of Your Personal Data
ABR may collect, use and/or disclose your Personal Data for the following business purposes:
- evaluating and providing advice and/or recommendations to you regarding the type of products and services suited to your needs; b
- assessing and processing any applications or requests made by you for products and services offered by ABR;
- communicating with you to inform you of changes and updates to our policies, terms and conditions and other administrative information, including without limitation for the purposes of servicing you in relation to products and services offered to you;
- administering, maintaining, managing and operating the products and services offered to you;
- processing and administering benefits or entitlements in connection with our services or your membership which you have applied for, including the administration of loyalty and rewards programmes;
- verification of your identity for the purpose of providing you with our services;
- responding to your queries and requests and handling complaints;
- providing you with personalised service, including at our customer service touch points;
- conducting market research for statistical profiling and other purposes to understand and determine customer preferences and demographics in order for us to review, develop and improve the products and services which we are providing to you (including without limitation to ensure that the products and services offered are relevant to you);
- managing our infrastructure and business operations and complying with internal policies and procedures;
- archival of documents and records in both electronic and physical form for record keeping purposes;
- maintaining records of customer instructions, whether through hard copy documents, soft copy documents or instructions given via electronic or other means;
- compliance with any applicable statute, rule, law, regulation, judgment, decree, directive, code of practice, guideline, administrative requirement, sanctions regime, court order, agreement between any ABR group company and an Authority, agreement or treaty between Authorities, internal policies or procedures, which may apply to any ABR group company or which any such company is subject to, or to assist in or with law enforcement and investigations by any Authority or to comply with any request from an Authority.
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 products and services you have requested. Where personal data is submitted by you on behalf of another individual or concerns another individual other than yourself (eg. in the case of a guardian applying for a Kid’s Club Membership for a child), 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 Data Protection Policy) have been obtained from the relevant individuals and that you have retained proof of these consents, such proof to be provided to us upon our request.
ABR may collect, use and/or disclose your Personal Data for the purposes, in accordance with the PDPA, for which we have specifically obtained your consent and for the purposes for which you have provided your Personal Data to us.
Marketing / Optional Purposes
Where you have specifically provided us with additional consents, ABR may also collect, use and/or disclose your Personal Data for the following purposes:
- providing benefits to you, including without limitation promotions, loyalty and reward programmes and sending you details of products, services, special offers and rewards, either to our customers generally, or which may be of interest to you;
- matching your Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision or offering of products and services, whether by any ABR group company, or other third parties;
- administering contests and competitions;
- participation in ABR’s marketing initiatives;
- participation in ABR’s branding activities (including without limitation written or video/audio recordings of your quotes and testimony for media pitching, press releases and ABR’s internal publications and broadcasts );
- invitations to participate in ABR’s corporate sustainability activities, and the video/audio recording of your feedback and testimony in relation thereto; and
- developing special offers and marketing programmes.
If you have provided your Singapore telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your Singapore telephone number(s), then from time to time, we may contact you using such Singapore telephone number(s) (including via voice calls, SMS, fax or other means) with information about our products and services (including discounts and special offers).
Disclosure of Personal Data
Personal Data will be protected and kept confidential but, subject to the provisions of any applicable law, may be disclosed for the purposes listed above (where applicable) to the following parties:
- ABR group companies;
- agents, contractors or third party service providers who provide services, such as telecommunications, call centre, mailing, information technology, payment, payroll, data processing, training, market research, storage and archival, to ABR;
- banks, financial institutions, credit card companies and their respective service providers;
- our professional advisers such as our auditors and lawyers;
- any judicial, administrative or regulatory body, any government or public or government agency, or any agents thereof, having jurisdiction over any ABR group company (collectively referred to as “Authorities” and each an “Authority”);
- third party reward, loyalty, privileges and co-branding programme providers;
- any other person in connection with the purposes set forth above.
We may collect or analyse anonymised information from which individuals cannot be identified (“Aggregate Information”), such as number of users and their frequency of use, the number of page views (or page impressions) that occur on our websites and common entry and exit points into our websites.
We use “cookies”, where a small data file is sent to your browser to store and track Aggregate Information about you when you enter our websites. The cookie is used to track information such as the number of users and their frequency of use, profiles of users and their preferred sites.
The Aggregate Information collected is used to assist us in analysing the usage of our websites and improving our websites.
Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser. However, you may not be able to enter certain part(s) of our websites.
Our website may contain links to other websites operated by third parties. 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 our website, you should check the applicable data protection policy of the third party to determine how they will handle any information they collect from you.
Withdrawal of Consent
If you wish to withdraw your consent to any use or disclosure of your Personal Data as set out in this Data Protection Policy, you may contact us via the “contact us/feedback” webpage in this website. 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. Such withdrawal may also result in the termination of any loyalty program membership you may have with us.
Access and Correction of your Personal Data
You may request access to or make corrections to your Personal Data records. If you are a loyal program member, you may do so via our membership portal in this website or contact our membership department via the “contact us/feedback” webpage in this website.
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 us via the “contact us/feedback” webpage in this website.