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:
2 Alexandra Rd, #06-01, Delta House, Singapore 159919
“Personal Data” means data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which the organisation has or is likely to have access. If you are using the Shuga Platform or other products in Singapore, “Personal Data” has the meaning as defined in Section 2 of the Personal Data Protection Act 2012 (No. 26 of 2012) (“PDPA”). We will collect, use, disclose and process your Personal Data in accordance with the PDPA.
The Personal Data that we may collect from you will depend on the products, services, and promotions that are used by you. Your Personal Data will be collected by us when you:
Please note that collection of your Personal Data for certain products and services may be a prior requirement, such as for access to the services or to process any voucher redemptions.
The Personal Data collected by us will depend on the nature of your interaction with us and may include information relating to the following:
We may also collect your Personal Data from third parties (such as business partners, social media providers and/or fraud prevention agencies) whom you have duly authorised to disclose your Personal Data to us and/or from publicly available sources.
We have no obligation to keep private Personal Data that you make available to other Users via the Shuga Platform. Details which relate to your use of your User Account such as duration and general patterns of use may be recorded and processed by us so as to improve your experience as a User.
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).
We may collect, use and process your Personal Data for any or all of the following purposes:
By consenting to the Terms, you also agree to receive marketing communications from us and consent that we may use Personal Data provided by you to send you information about us and the Shuga Platform, including news about product updates, promotions and special offers, to your email address, telephone number (whether by text messages, picture messages, call or otherwise), device running the Shuga Platform, home address, office address, or other types of messages directly sent to you outside or inside the Shuga Platform (“Messages”) but we will not share any Personal Data with third parties for marketing purposes without your consent. Instructions for discontinuing your receipt of such Messages from us will be provided in such Messages. Please refer to the Terms for information on how to opt out from such Messages.
For the avoidance of doubt, we will not under any circumstances rent or sell any of your Personal Data.
The data collected by us may be transferred to and stored at destinations outside Singapore. It may also be processed by personnel operating outside Singapore who work for us or for one of our service providers. By providing us with your Personal Data information, you agree to this transfer, storing, and/or processing. To protect your Personal Data, we will enter into appropriate contractual arrangements or otherwise with any companies we share data with outside Singapore to ensure the safeguarding of your Personal Data and that such parties will act at all times in compliance with applicable laws. Further, we will only transfer your Personal Data to locations outside of Singapore where we are satisfied that an adequate or comparable level of protection is in place to protect your Personal Data held in that country.
Cookies are small files placed on your computer by websites that you visit or certain emails you open. Cookies customise your use of a product or website, keep records of your access to the website or product, or store information required by you while accessing the website or product. For instance, when you log on to the Shuga Platform, we may store your User id, your IP address and time of login as a cookie on your hard drive. This cookie allows you to move from page to page without having to log on again on each page. You can disable cookies by modifying your browser settings, but doing so may affect your experience on our website.
Information to do with your use of the Shuga Platform such as billing for services provided to you by us (including those through the Shuga Platform), your User account, and details about your internet connection is uploaded to our servers. Please note that we may use software which generates and submits reports of bugs to us whenever a crash or other issue is faced in the Shuga Platform, and such bug reports may contain information which includes information about other software or hardware on your computer system. This information is not stored with your Personal Data. However, if you manually submit a bug report to us through email or through the Shuga Platform’s support services, this report will be associated and stored with your Personal Data.
We adopt adequate data collection and processing practices. Digital security measures have also been put in place to protect against intrusions, alterations and disclosures of Personal Data by individuals seeking to gain unauthorised access to system data.
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.
You should ensure that all Personal Data submitted to us is complete, accurate, true, and correct and You may correct, update or remove your Personal Data from our records. Failure on your part to ensure your Personal Data is complete, accurate, true and correct may result in the inability to provide you with the products and services that you have requested.
You may contact our Data Protection Officer in writing to access your Personal Data if you are concerned about the accuracy of the Personal Data maintained by us as set out below.
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.
We will respond to your request as soon as reasonably possible. 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). In general, we will decline requests which jeopardise the privacy of others, or which threaten the safety of others.
You may also withdraw your consent for the use of your Personal Data by submitting your request in writing to our Data Protection Officer. 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.
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 products 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 above.
Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.