We respect the confidentiality of Personal Data and privacy of individuals and are committed to complying with the Singapore Personal Data Protection Act (Act 26 of 2012) (“PDPA”) and other applicable data protection laws, including the European Union (“EU”) General Data Protection Regulation (“GDPR”) where applicable. Please read this Policy carefully so that you know and understand the purposes for which we collect, use and disclose your Personal Data.
We adopt a pragmatic approach in collecting Personal Data. We collect Personal Data only for what is required in business, not indiscriminately without purpose. Such data will be properly destroyed once it ceases to serve any business or legal purpose. We also do not disclose your Personal Data unless prior consent has been obtained and we have the proper IT infrastructure and security measures to protect your Personal Data.
This Policy supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your Personal Data, and your consents herein are additional to any rights which we may have at law to collect, use or disclose your Personal data. This Policy does not affect any rights which we may have at law in connection with the collection, use or disclosure of your Personal Data.
1. The types of Personal Data we collect
We will collect various types of Personal Data about you for the purposes described in this Policy, including:
- Personal information that can be used to identify an individual, such as name, gender, date of birth, personal identification numbers and nationality
- Contact information such as email address, postal address, phone number and any other Personal Data that you provide by completing forms on the Website, including any subscriptions you make to enjoy our services;
- Details of any transactions made by you;
- Information about your interactions with our staff, such as details of any feedback or discussions in relation to our business and services;
- Personal data that may be contained in communications you send to us, for example to report a problem or to submit queries, concerns or comments regarding the Website or its content;
- Information from surveys that we may, from time to time, conduct on the Website for research purposes, if you choose to respond to, or participate in them;
- Credit/debit card information;
- Personal information collected from third parties, such as data that you agree to share with us on publicly accessible social networks (e.g., Facebook, Instagram, etc.) and/or that we may collect from other publicly accessible databases; and
You are under no obligation to provide any such information. Providing your Personal Data to us is necessary for supplying the services provided on the Website upon your request, or when your Personal Data is needed to fulfil obligations required by law or regulations. The refusal to provide us with any Personal Data necessary for performing the above purposes may consequently prevent us from providing any of the services provided on the Website or fulfilling obligations required by law and other regulations. Therefore, failure to provide Personal Data may constitute, in some cases, a legitimate and justified reason for not being able to provide such services as provided on the Website.
2. Special categories of information or “sensitive Personal Data”
Certain categories of Personal Data, such as information about your race, ethnicity, religion or health, are considered special categories of information, or “sensitive Personal Data” under the EU General Data Protection Regulations.
Generally, we try to limit the circumstances where we collect your sensitive Personal Data. Such information will only be collected where it is deemed necessary to authorise a service or as part of third party/ legal requirements.
3. Minimum Age
Protecting the safety and privacy of children is very important to us. We will not knowingly collect or use Personal Data from anyone under the age of sixteen (16) years, or any other age limit set out by the law of his/her country of residence. By registering on the Website, you confirm that you have reached the age of maturity in your country of residence. If you have any concerns about your child's privacy, or if you believe that your child may have entered Personal Data onto our website, please contact our Data Protection Officer at firstname.lastname@example.org. We will take steps to delete the information as soon as possible should we learn that we have collected the Personal Data of a child without first receiving verifiable parental consent.
4. How we use your Personal Data
Whenever we process your Personal Data, we do so with your consent or as otherwise permitted by local laws, and on the basis of a lawful "justification" (or legal basis). In the majority of cases, the processing of your Personal Data will be justified on one of the following bases:
- Processing is necessary to perform a contract with you or take steps that you have requested in order to enter into a contract (e.g., sale contract, process payments);
- DWG will disclose your Personal Data as necessary to law enforcement agencies, public or regulatory authorities, securities commissions, or other government organisations for us to comply with a legal or regulatory obligation, or if we have a good faith belief that disclosure would be necessarily required;
- Processing is in our legitimate interests as a business, and our interests are not overridden by your interests, fundamental rights or freedoms. Our legitimate interests may include our interest in using customer and Website user Personal Data to conduct and develop our business activities (including by carrying out standard marketing activities), personalising Website content, enhance our products and services, with current and potential customers and Website users; respond to complaints or compliments, contacting clients about updates, surveys and offers, for the purposes of undertaking targeted direct marketing and other forms of advertising, provided we have the consent of recipient and/or have provided the opportunity to opt-out (in each case where required by law), and in establishing, exercising or defending legal claims;
- DWG may use or disclose your Personal Data to persons who have been validly identified as being you or your authorised representative(s) for the purpose of the relevant transaction or enquiry, or
- Processing is based on your prior explicit consent, such as data that you agree to share with us on social networks (e.g., Facebook, Instagram, etc.) and/or that we may collect from publicly accessible databases, to correspond with you to resolve your queries or complaints, and to customise your experience with us.
You have the right to withdraw your consent at any time by contacting us at email@example.com.
5. Disclosure of your Personal Data
We may disclose your Personal Data to any of our affiliate companies, or to our service providers who assist us in providing the services we offer, processing transactions, fulfilling requests for information, receiving and sending communications, updating marketing lists, analysing data, providing support services or in performing other tasks, from time to time.
Your Personal Data will be accessible by authorized personnel of DWG and affiliated companies, and service providers acting on our behalf on a need-to-know basis. Transfer of your Personal Data from your country of residence to other countries (notably to countries where we operate) will be involved, and some of these countries are subject to a data protection adequacy decision of the European Commission, whereas others are not. Your Personal Data will only be transferred to locations outside of Singapore where we are satisfied that comparable levels of protection equivalent to those in Singapore are in place to protect any Personal Data held in that location.
We may also share your Personal Data with potential acquirers and their professional advisers in connection with potential or actual sale or restructuring of our company or any of our assets, or those of any associated company, in which case Personal Data held by us about our users may be one of the transferred assets.
We may disclose your Personal Data to protect the rights, property, health or safety of our company and its affiliates, our users, a third party or the public as required or permitted by law (including exchanging Personal Data with other companies and organisations to investigate suspected unlawful activities including but not limited to fraud protection, intellectual property infringements, privacy and credit risk reduction).
We will also respond to requests for Personal Data where required by or permitted to do so by law, or when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, request from a regulator or any other legal process served on us, in each case anywhere in the world.
In addition, DWG may disclose Personal Data to our legal advisors for establishing, exercising or defending our legal rights, to our other professional advisors, or as otherwise authorised or required by law.
6. Transfer of information overseas
The DWG head office is based in Singapore. Customer’s Personal Data may be transmitted to data storage/ office systems of DWG’s offices and appointed agents, including affiliated partners, in Singapore and around the world in connection with DWG’s performance of the contract with you.
This means that Personal Data will be transferred to, and stored at a destination outside of your country and outside the European Economic Area (“EEA”). The Personal Data is transferred outside the EEA on the basis that it is necessary for the performance of the contract/ services between you and DWG.
We place great importance on the security of all Personal Data associated with our users. We have adopted security measures to protect Personal Data against accidental or unlawful destruction, accidental loss, alteration, unauthorized disclosure or access. For the best possible protection of your Personal Data outside the limits of our control, your device should be protected (such as by updated antivirus systems) and your internet service provider should take appropriate measures for the security of network data transmission (such as, for example, firewalls and anti-spam filtering).
While we take all reasonable steps to protect your Personal Data, we cannot guarantee that the Personal Data you disclose to us will be 100% secure, or that any data breach will not occur.
You accept the inherent security implications of dealing online over the Internet and will not hold DWG or their processors responsible for any data breach unless it is due to our negligence.
8. Retention of your Personal Data
Our general approach is to retain your Personal Data only for as long as required to fulfil the purposes for which it was collected. However, in some circumstances we may retain Personal Data for longer periods of time, for instance where we are required to do so in accordance with legal, tax and accounting requirements.
In specific circumstances we may also retain your Personal Data for longer periods of time corresponding to the applicable statute of limitations so that we have an accurate record of your dealings with us in the event of any complaints or challenges.
9. Non-EU Personal Data rights
If you are not a resident of EU, you may have certain rights in relation to the Personal Data we hold about you.
You have the right to know whether we process Personal Data about you, and if we do, to access Personal Data we hold about you and certain information about how we use it and who we share it with.
Where permitted by law, DWG reserves the right to charge a reasonable administrative fee for this service. In exceptional circumstances, DWG reserves the right to deny you access to your Personal Data and may provide an explanation as required by applicable laws.
Exceptional circumstances include (to the extent allowable under applicable laws) where:
- An investigating authority or government institution objects to DWG complying with the client’s request;
- The information may, in the exercise of DWG’s reasonable discretion and/ or assessment, affect the life or security of an individual; and
- Data is collected in connection with an investigation of a breach of contract, suspicion of fraudulent activities or contravention of laws.
You have the right to correct any Personal Data held about you that is inaccurate.
If you have any feedback, concerns or complaints about the use and/or sharing of your Personal Data, please write to our Data Protection Officer at firstname.lastname@example.org.
10. EU Personal Data rights
If you are a resident of EU, you may have certain rights in relation to the Personal Data we hold about you.
Please note that we will require you to provide us with proof of identity before responding to any requests to exercise your rights. We must respond to a request by you to exercise those rights without undue delay and at least within one month (although this may be extended by a further 2 months in certain circumstances). To exercise any of your rights, please write to the Data Protection Officer at email@example.com.
- Right of access
You have the right to know whether we process Personal Data about you, and if we do, to access the Personal Data we hold about you and certain information about how we use it and who we share it with. If you require more than one copy of the Personal Data we hold about you, we may charge an administration fee. We may not provide you with certain Personal Data if providing it would interfere with another’s rights or where another exemption applies.
- Right of data portability
You have the right to receive Personal Data which you have provided to us in a structured, commonly used and machine-readable format, and also to require us to transmit it to another controller where this is technically feasible. We are not responsible for the security of the Personal Data or its processing once received by the third party. We may also not provide you with certain Personal Data we hold about you which may reveal information about another person.
- Right to correction
You have the right to correct any Personal Data held about you that is inaccurate.
- Right to erasure
You may request that we erase your Personal Data in the following circumstances:
- You believe that it is no longer necessary for us to hold the Personal Data we hold about you;
- We are processing the Personal Data we hold about you on the basis of your consent, and you wish to withdraw your consent and there is no other ground under which we can process your Personal Data;
- We are processing your Personal Data on the basis of our legitimate interest and you object to such processing. You may provide us with details as to your reasoning so that we can assess whether there is an overriding interest for us to retain such Personal Data;
- You no longer want us to use your Personal Data in order to send you promotions, special offers, marketing materials and lucky draws; or
- You believe the Personal Data we hold about you is being unlawfully processed by us.
Please provide us as much details as possible on your reasons for the request to assist us in determining whether you have a valid basis for erasure. However, we may retain the Personal Data if there are valid grounds under the law for us to do so (eg. For the defence of legal claims or freedom of expression) but we will let you know if that is the case.
Please note that after deleting your Personal Data, we may not be able to provide the same level of servicing as we will not be aware of your preferences.
For further information regarding your rights, to exercise any of your rights, or if you have any complaints or questions regarding the processing of your Personal Data, please contact our Data Protection Officer at firstname.lastname@example.org.
11. Restriction of processing to storage only
You have the right to require us to stop processing your Personal Data other than for storage purposes in certain circumstances. However, please note that if we stop processing your Personal Data, we may use it again if there are valid grounds under data protection law for us to do so (eg. to defend legal claims).
You may request we stop processing and just store the Personal Data we hold about you where:
- You believe the Personal Data is not accurate, for the period it takes for us to verify whether the Personal Data is accurate;
- We wish to erase the Personal Data but you want us to just store it instead;
- We wish to erase the Customer Data as it is no longer necessary for our purposes but you require it to be stored for the establishment, exercise or defence of legal claims; or
- You have objected to us processing your Personal Data on the basis of our legitimate interest and you wish us to stop processing your Personal Data whilst we determine whether there is an overriding interest in us retaining such Personal Data.
At any time, you have the right to object to our processing of your Personal Data about you in order to send you promotions, special offers, marketing messages, and we will stop processing your Personal Data for that purpose.
You may also object where we are processing your Personal Data on the basis of our legitimate interest and you object to such processing.
Please provide us with details of your reasoning so that we can assess whether there is a compelling overriding interest in us continuing to process such data or we need to process it in relation to legal claims.
DWG needs your assistance to ensure that your Personal Data is current, complete and accurate. As such, please inform DWG of changes to your Personal Data by contacting DWG and submitting your updated particulars to DWG in writing. DWG may also request Personal Data updates from you from time to time.
13. Links to other websites
14. Changes to this Policy
We may occasionally change this Policy, for example, to comply with new requirements imposed by the applicable laws or technical requirements. We will post the updated Policy on the Website. We may also notify you in case of material changes and seek your consent to those changes, where required by applicable law. We will seek your consent if your personal information may be processed for a new purpose not described in this Policy. You are also encouraged to periodically review this page.
Updated: 25 June 2018