1.1 We are committed to safeguarding the privacy of our Website visitors and/or App users; in this policy we explain how we will treat your personal information.
2.1 This document was created using a template from SEQ Legal (http://www.seqlegal.com).
3. Collecting personal information
3.1 We may collect, store and use the following kinds of personal information:
(a) Information about your computer and about your visits to and use of this website and/or Apps;
(b) Information that you provide to us when registering with our website and/or Apps;
(c) Information that you provide when completing your profile on our website and/or in our Apps;
(d) Information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters;
(e) Information that you provide to us when using the services on our website and/or in our Apps, or that is generated in the course of the use of those services;
(f) Information relating to any purchases you make of our goods and/or services or any other transactions that you enter into through our website and/or Apps;
(g) Information that you post to our website for publication on the Internet;
(h) Information contained in or relating to any communication that you send to us or send through our website; and
(i) Your facial landmark points when you use the “Face Mask” augmented reality mode in Sing-To-Talk.
(j) Any other personal information that you choose to send to us.
3.2 Before you disclose to us the personal information of another person, you must obtain that person’s consent to both the disclosure and the processing of that personal information in accordance with this policy.
4. Using personal information
4.1 Personal information submitted to us through our website and/or Apps will be used for the purposes specified in this policy or on the relevant pages of the website.
4.2 We may use your personal information to:
(a) Administer our website and business;
(b) Personalize our website and/or Apps for you;
(c) Enable your use of the services available on our website;
(d) Send you goods purchased through our website;
(e) Supply to you services purchased through our website;
(f) Send statements, invoices and payment reminders to you, and collect payments from you;
(g) Send you non-marketing commercial communications;
(h) Send you email notifications that you have specifically requested;
(i) Send you our email newsletter, if you have requested it (you can inform us at any time if you no longer require the newsletter);
(j) Send you marketing communications relating to our business which we think may be of interest to you, by post or, where you have specifically agreed to this, by email or similar technology (you can inform us at any time if you no longer require marketing communications);
(k) Provide third parties with statistical information about our users (but those third parties will not be able to identify any individual user from that information);
(l) Deal with enquiries and complaints made by or about you relating to our website and/or Apps;
(m) Keep our website secure and prevent fraud; and
(n) Verify compliance with the terms and conditions governing the use of our website.
(o) Best position the augmented reality mask on your face based on your facial landmarks.
4.3 If you submit personal information for publication on our website and/or in our Apps, we will publish and otherwise use that information in accordance with the licence you grant to us.
4.4 Your privacy settings can be used to limit the publication of your information on our website and/or in our Apps, and can be adjusted using privacy controls on the website.
4.5 We will not, without your expressed consent, supply your personal information to any third party for the purpose of their or any other third party’s direct marketing.
5. Disclosing personal information
5.1 We may disclose your personal information to any of our employees, officers, insurers, professional advisers, agents, suppliers or subcontractors insofar as reasonably necessary for the purposes set out in this policy.
5.2 We may disclose your personal information:
(a) To the extent that we are required to do so by law;
(b) In connection with any ongoing or prospective legal proceedings;
(c) In order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk);
(d) To the purchaser (or prospective purchaser) of any business or asset that we are (or are contemplating) selling; and
(e) To any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
5.3 By downloading and using Sing-To-Talk, you hereby agree to allow us to collect your facial landmarks for Face Mask’s facial recognition purposes. We do not share your facial recognition data / facial landmarks with any third parties
5.4 Except as provided in this policy, we will not provide your personal information to third parties.
6. International data transfers
6.1 Personal information that you publish on our website and/or in our Apps or submit for publication on our website and/or in our Apps may be available, via the Internet, around the world. We cannot prevent the use or misuse of such information by others.
6.2 You expressly agree to the transfers of personal information described in this Section 6.
7. Retaining personal information
7.1 This Section 7 sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal information.
7.2 Personal information that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
7.3 We do not store your facial recognition data / facial landmarks but only use them while determining the position of the masks on your face.
7.4 Notwithstanding the other provisions of this Section 7, we will retain documents (including electronic documents) containing personal data:
(a) To the extent that we are required to do so by law;
(b) If we believe that the documents may be relevant to any ongoing or prospective legal proceedings; and
(c) In order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).
8. Security of personal information
8.1 We will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
8.2 We will store all the personal information you provide on our secure (password- and firewall-protected) servers.
8.3 All electronic financial transactions entered into through our website and/or Apps will be protected by encryption technology.
8.4 You acknowledge that the transmission of information over the Internet is inherently insecure, and we cannot guarantee the security of data sent over the Internet.
8.5 You are responsible for keeping the password you use for accessing our website confidential; we will not ask you for your password (except when you log in to our website and/or Apps).
9.1 We may update this policy from time to time by publishing a new version on our website.
9.2 You should check this page occasionally to ensure you are happy with any changes to this policy.
9.3 We may notify you of changes to this policy by email.
10. Your rights
10.1 We may withhold personal information that you request to the extent permitted by law.
10.2 You may instruct us at any time not to process your personal information for marketing purposes.
10.3 In practice, you will usually either expressly agree in advance to our use of your personal information for marketing purposes, or we will provide you with an opportunity to opt out of the use of your personal information for marketing purposes.
11. Third party websites
11.1 Our website includes hyperlinks to, and details of, third party websites.
11.2 We have no control over, and are not responsible for, the privacy policies and practices of third parties.
12. Updating information
12.1 Please let us know if the personal information that we hold about you needs to be corrected or updated.
13. Personal Data Protection Act 2012 (PDPA)
Data Protection Notice for Customers
This Data Protection Notice (“Notice”) sets out the basis which Summer’s Therapy Services Pte. Ltd. (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of our customers in accordance with the Personal Data Protection Act (“PDPA”). This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.
13.1 As used in this Notice:
“customer” means an individual who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, entered into a contract with
us for the supply of any goods or services by us; and
“personal data” means data, whether true or not, about a customer who can be identified:
(a) from that data; or (b) from that data and other information to which we have or are likely to have access.
13.2 Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include name, residential address, email address, telephone number, gender, date of birth and photograph.
13.3 Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).
Collection, Use and Disclosure of Personal Data
13.4 We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
13.5 We may collect and use your personal data for any or all of the following purposes:
(a) Performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
(b) Verifying your identity;
(c) Responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
(d) Managing your relationship with us;
(e) Processing payment or credit transactions;
(f) Complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
(g) Any other purposes for which you have provided the information;
(h) Transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
(i) Any other incidental business purposes related to or in connection with the above.
13.6 We may disclose your personal data:
(a) Where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods and services requested by you; or
(b) To third party service providers, agents and other organisations we have engaged to perform any of the functions with reference to the above mentioned purposes.
13.7 The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under a contract with you).
Reliance on The Legitimate Interests Exception
13.8 In compliance with the PDPA, we may collect, use or disclose your personal data without your consent for the legitimate interests of Summer’s Therapy Services Pte. Ltd. or another person. In relying on the legitimate interests exception of the PDPA, Summer’s Therapy Services Pte. Ltd. will assess the likely adverse effects on the individual and determine that the legitimate interests outweigh any adverse effect.
13.9 In line with the legitimate interests’ exception, we will collect, use or disclose your personal data for the following purposes:
a. Fraud detection and prevention;
b. Detection and prevention of misuse of services; and
c. Network analysis to prevent fraud and financial crime, and perform credit analysis.
The purposes listed in the above clause may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter.
Withdrawing Your Consent
13.10 The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to the Data Protection Officer with the contact details provided below.
13.11 Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.
13.12 Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 13.8 above.
Access To and Correction of Personal Data
13.14 If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
13.15 Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
13.16 We will respond to your request as soon as reasonably possible. In general, our response will be within fourteen (14) business days. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).
Protection of Personal Data
13.17 To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as minimised collection of personal data, authentication and access controls (such as good password practices, need-to-basis for data disclosure, etc.), encryption of data, up-to-date antivirus protection, regular patching of operating system and other software, web security measures against risks, and usage of one time password(otp)/2 factor authentication (2fa)/multi-factor authentication (mfa) to secure access.
13.18 You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
Accuracy of Personal Data
13.19 We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.
Retention of Personal Data
13.20 We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
13.21 We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.
Transfers of Personal Data Outside of Singapore
13.22 With the exception of our e-commerce store (Summer’s Therapy Resources), we generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.
Data Protection Officer
13.23 You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:
Contact No. : +6597665067
Email Address : firstname.lastname@example.org
Effect of Notice and Changes to Notice
13.24 This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
13.25 We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.
PDPA Notice Effective date : 26/05/2021
PDPA Notice Last updated : 26/05/2021
14. Our details
14.1 This website and the Apps are owned and operated by Summer’s Therapy Services Pte. Ltd.
14.2 We are registered in Singapore under registration number 201612846H and our centre is at Block 128 Lor 1 Toa Payoh, #01-835, Singapore 310128.
14.3 You can contact us:
(a) By post, using the postal address given above;
(b) Using our website contact form;
(c) By telephone, on the contact number published on our website; or
(d) By email, using the email address published on our website.