Our Policies
SG Enable's Privacy Policy
This Privacy Policy ("Policy")
describes how SG Enable Ltd ("SG Enable") and its affiliates collect,
use and disclose personal information of customers through our websites and
online services, including www.sgenable.sg, enablingvillage.sg, and other SG
Enable-owned or operated websites, social media channels, and online services
that link to this Policy (collectively, the "Sites"), through our
programmes and at our physical premises ("Services"). This Policy
does not apply to websites and services that display or link to different
privacy statements. Websites and services co-branded with other partners may
display or link to a joint privacy statement or separate privacy statements of
our partners in addition to our Policy. By accessing the Sites or utilising the
Services and by providing or making available your information, you hereby
consent to the collection and use of your information, including your personal
data, in the manner described in this Policy. Without limiting the generality
of the foregoing, you authorise SG Enable to transmit your information outside
of Singapore in the manner and for the purposes described in this Policy on the
understanding that such transfers will be in accordance with the Personal Data
Protection Act and the transfer shall only be made to countries with comparable
if not stricter personal data protection laws than Singapore. If you do not
agree, please cease use of the relevant Sites and/or Services and DO NOT
provide any personal data to us.
For avoidance of doubt, the words “you” and
“your” in this Policy shall also include third parties such as your principals
or wards, as well as such other persons whom you may represent.
1.1. What personal data is
collected
1.1 When you use our Sites,
Services or in your interaction with us, the personal data we may collect
includes:
a) Data collected directly from you. This
may be done through our Sites and social media channels, over the phone, by
email, via any correspondence, or in person when you meet or interact with our
staff, agents or representatives. Data collected may include, but is not
limited to:
i. personal particulars, e.g.
name, NRIC/FIN/passport details, address, telephone number, email address, date
of birth, education details, photographs and videos
ii. medical information, e.g.
medical conditions, records, reports, and/or history
iii.
financial information, e.g.
income, expenses, and/or banking information of you and your family
iv. employment information, e.g.
occupation, employment history, salary, and/or benefits
v. your interaction with us, e.g.
phone calls, call recordings, mobile text messages, emails, faxes, letters,
forms, and any other correspondences
vi. the schemes, services, programmes,
courses, or any other assistance rendered by SG Enable to you
vii. photographs and videos of you
captured by surveillance cameras when you visit our premises
viii. photographs and videos of you
taken by us or our representatives when you attend programmes, courses or
events hosted by us
ix.
the information you provide
when you agree to be featured in interviews or stories in print, online, or
other media channels. Such stories may be commissioned directly by SG Enable
and its affiliates, or they may be facilitated by us but commissioned by other
agencies, individuals and organisations
x. if you have contacted customer
service, the details of this contact and the contact history; and
xi. if you have sent your personal
data to us for any other reason
b) Data collected by automated means.
Various technologies may be used on our Sites and web-based applications in
order to make them more user-friendly, effective and secure. Such technologies
may lead to data being collected automatically by us or by third parties on
behalf of us. This data does not generally, but may, contain a user's personal
data. Examples of such technologies include:
i. Click-stream data. A visit to one of our
Sites results in data that is transmitted from your browser to our server being
automatically collected and stored by us or by third parties on behalf of us.
This data can include, but is not limited to, the following:
o
the visitor's IP address
o
the date and time of the visit
o
the referral URL (the site from
which the visitor has come)
o
the pages visited on our Sites
o
information about the browser
used (browser type and version, operating system, etc).
ii. Cookies. A number of places on our Sites
and web-based applications make use of cookies. These are essentially small
text files that are stored on your computer's hard drive or your user device by
your web browser. We can use cookies to identify the owner of a user account
and to store articles in a shopping basket during the purchasing process. In
other words, cookies help to make our Sites or our (mobile and web-based) applications
more user-friendly, more effective and more secure. The cookies usually used by
us are so-called "session cookies", which are automatically deleted
at the end of the visit to the relevant website. By default, web browsers
enable the use of cookies but this function can also be disabled. However, this
will result in some services not being available. It is also possible to
manually delete cookies after their use via the web browser. More information
may be available from your web browser provider.
iii.
Web beacons and tracking links. Web
beacons (also known as pixel tags and clear GIFs) involve graphics that are not
apparent to the user. Tracking links and/or similar technologies consist of a
few lines of programming code and can be embedded in our Sites. In conjunction
with cookies, these are primarily used for statistical analysis purposes. This
technology can also be used for tracking traffic patterns on websites, as well
as finding out if an e-mail has been received and opened and to see if there
has been any response.
iv. Web analytics. Web analytics is the term
given to a method for collecting and assessing the behaviour of visitors to
websites and mobile applications. This includes the analysis of traffic
patterns in order, for example, to determine the frequency of visits to certain
parts of a website or mobile application, or to find out what information and
services our visitors are most interested in. For these purposes, we primarily
make use of click-stream data and the other techniques listed above. Web
analytics are carried out by Google Analytics and/or other selected parties.
You can find out more information about the processing of web analytics data by
Google Analytics in paragraph 7 below.
c) Data from other agencies, individuals or organisations. Sources can include voluntary welfare organisations, hospitals,
schools, government ministries and agencies, employers, training providers,
and/or other agencies that approach SG Enable to render services or assistance
to you.
2. How the collected personal
data is used
2.1 We use your personal data for
the purposes of serving you. This includes, where applicable:
a) providing you with the products and services that you have
requested, including notifying you regarding the status of services or schemes
you have requested, and assessment of your eligibility for services and schemes
(for which we may use, engage with, or share your personal data with relevant
third parties);
b) ensuring that your
transactions on our Sites are safe and secure;
c) responding to queries, feedback and requests from you or people you
have authorised;
d) contacting you for feedback after a sale of a product or service;
e) investigating or resolving any problems, claims or disputes you may
encounter in relation to our services;
f) processing, providing, and/or administering schemes, services,
programmes, courses, or any other assistance to you;
g) processing claims, reimbursements, payouts, or payments for schemes,
services, programmes, courses, or any other events you have registered for;
h) facilitating referrals or connections to other organisations or
agencies that may provide relevant services or assistance to you; and
i)
informing you about SG
Enable’s schemes, services, programmes,
courses, events, or other information that may be relevant to you.
2.2 We may also use your personal
data for purposes connected or relevant to the business of the SG Enable, such
as:
a) complying with legal and regulatory obligations and requirements;
b) enforcing obligations owed to SG Enable;
c) research and developing new products and services or improving
existing products and services of SG Enable;
d) accounting, risk management, audit, compliance and record keeping
purposes;
e) carrying out research, planning, studies, statistical analysis,
evaluation, policy formulation, and reporting;
f) staff training;
g) producing materials for training, internal and/or external
communications, publicity, or other purposes deemed appropriate by us whether
in the print, online or in any other media including but not limited to
photographs, images, audio or video files;
h) for surveillance of premises; and
i)
providing your data to
organisations or agencies which administer or provide schemes, services, or
other assistance which may be of relevance to you; industry regulators and other
government organisations, as required by local laws and regulations; financial
institutions, for purposes such as facilitating payments, screenings or checks;
as well as organisations, for the purposes of data analysis, evaluation and
policy formulation, for which you will not be identified as a specific
individual.
2.3 Your personal data may also be
anonymised for use by SG Enable for other purposes.
2.4 If you have consented, your
personal data may be used by the SG Enable for the purposes of marketing products
and services offered on the Sites or other products or services offered by SG
Enable or those of its strategic partners or business affiliates, e.g.
informing you of latest activities, special offers, promotions or sending you
newsletters.
2.5 In order for us to market
products and services which are of special interest and relevance to you, we
may analyse and rely on your overall interaction with us (such as but not
limited to your contact history with our customer service, your newsletter
clicks/ opening results, your surfing behaviour (web tracking), the newsletter
types you are subscribed to, your participation in promotions or events, and
your interactions with us).
2.6
If you have contacted us with
any complaints, feedback, comments, suggestions, we will use and disclose your
personal data (including your contact history) to respond to you and provide
you with the best service possible. If you are the complainant and you do not
want us to disclose your identity to the party you are complaining about, you must
let us know immediately. However, it may not always be possible to handle your
complaint on the basis of anonymity.
2.7 When using your personal data
to contact you for the above purposes, we may contact you via postal mail, fax,
e-mail, SMS, telephone or any other electronic means.
2.8
If we need to use your personal
data for any other purposes, we will notify you and obtain your consent
beforehand. You will be given the opportunity to withhold or withdraw your
consent for the use of your personal data for these other purposes.
3. Disclosure of information
3.1 We will not sell or transfer your
personal data to third parties or otherwise deal with your personal data in
similar manner.
3.2 We will only disclose your
personal data to third parties where you have provided us consent, and in the
situations expressly set out in in this Policy. If you have consented to
receiving marketing information from us, our strategic partners and business
associates, we will be disclosing your personal data to them.
3.3 Your personal data may be
disclosed and shared within SG Enable and its affiliates to allow us to provide
the products and services which you have requested.
3.4 We may disclose or share your
personal data with third parties who provide necessary services to us, such as:
service providers and data processors working on our behalf and providing services such as hosting and maintenance services, analysis services, e-mail messaging services, delivery services, handling of payment transactions, solvency check and address check, etc;
our consultants and professional advisers (such as accountants, lawyers, auditors)
3.5 We will also disclose your
personal data to third parties in order to comply with legal obligations or
industry requirements. This includes disclosures to legal, regulatory,
governmental, tax and law enforcement authorities.
3.6 Our Sites may have the
functionalities to allow you to share your personal data with other third
parties such as other users of our Sites. You are responsible for your
choice(s) and are deemed to have provided consent for any sharing of your
personal data in the manner provided by the Site.
3.7 You fully understand and
consent that we may transfer your personal data to any location outside of
Singapore for the purposes set out in this paragraph 3. When transferring your
personal data outside of Singapore we will protect your personal data to a
standard comparable to the protection accorded to your personal data under the
Singapore Personal Data Protection Act 2012 by ensuring that the recipient is either
in a jurisdiction which has comparable data protection laws, or ensuring that
the recipient is contractually bound to protect your personal data with such
reasonable security arrangements as required under the Singapore Personal Data
Protection Act 2012.
4. Third Parties
4.1 This Policy only applies to our
Sites and information that we collect from you. Our Sites may contain links to
other websites which are not owned or maintained by us. When visiting these
third party websites or disclosing your personal data to third parties, you
should read their privacy policies, or ask relevant questions before you
disclose your personal data. We are not responsible for the collection, use or
disclosure of your personal data by such third parties.
5. Social Networks
5.1 Our Sites and web-based
applications may provide you with social plug-ins from various social networks
(such as Facebook, Instagram, Pinterest and Twitter). If you choose to interact
with a social network, your activity on our Sites or via our web-based
applications will also be made available to these social networks.
5.2 If you are logged in on one of
the social networks during the visit of one of our Sites or web-based
applications, the social network might add this information to your profile. If
you are interacting with one of the social plug-ins, this information will be
transferred to the social network. In case you do not wish such a data
transfer, please log off on your social network before you enter one of our
Sites or web-based applications.
5.3 We cannot influence this data
collection and data transfer via the social plug-ins. Please read the privacy
policies of those social networks for detailed information about the collection
and transfer of personal data, what rights you have and how you can achieve
satisfactory privacy settings.
6. Geo-location Services
6.1 Our Sites, mobile and web-based
applications may offer location-enabled services, such as Google Maps and Bing
Maps. If you use those mobile or web-based applications, they may receive information
about your actual location (such as GPS signals sent by a mobile device) or
information that can be used to approximate a location. You are always asked if
the geo-location service can be activated and you can also object to this
geo-location service within the respective mobile or web-based application.
7. Web analytics by Google
Analytics
7.1 Our Sites, mobile and web-based
applications may contain web analytic services provided by Google Analytics.
This means that when you visit our Sites or use any mobile or web-based
applications, a cookie will be stored on your computer or mobile device, except
when your browser settings do not allow for such cookies.
7.2 This further means that when
you visit our Sites or use any mobile or web-based applications, the personal
data described above in paragraph 1.1 - including the "click-stream
data", the data from "web beacons and tracking links" and
information stored in Google Analytics' cookies - will be sent to Google
Analytics for analysis for and on behalf of us.
7.3 Google Analytics acts only as
our agent and we alone determine the purposes for which the data is being used
and which will be consistent with purposes and provisions stated herein. You
can find out more about the relationships between Google Analytics and us in
the Google Analytics' privacy policy.
7.4 If you do not wish information
about your behaviour at our Sites or any web-based applications being collected
and assessed by Google Analytics, you can install the Google Analytics opt-out
browser add-on. This add-on instructs the Google Analytics JavaScript (ga.js,
analytics.js, and dc.js) to not send your site visit information to Google
Analytics. The browser add-on is available for most modern browsers. The Google
Analytics opt-out browser add-on does not prevent information from being sent
to the website itself or in other ways to web analytics services.
8. Retargeting Technologies
8.1
Our Sites and web-based
applications may use retargeting technologies within the internet. This enables
us to show our visitors, who were already interested in our services,
advertisements from us on partner websites.
8.2 We also work with other
companies who use tracking technologies to serve advertisements on our behalf
across the Internet. These companies may collect non-personally identifiable
information about your visits to our Sites or web-based applications and your
interaction with our communications, including advertising.
8.3
Retargeting technologies
analyse your cookies and display advertisement based on your past surfing
behaviour. For further information on cookies, please refer to paragraph 1 of
this Policy.
8.4 We do not store any personal
data about you with this technology.
9. Security
9.1
The security of your
information is important to us. We have in place reasonable and appropriate
safeguards required by law to protect the information stored with us. We endeavour to take precautions to ensure that the
information you have provided is protected against unauthorised or unintended
use, access or disclosure. However, we cannot be held responsible for
unauthorised or unintended use, access or disclosure that is beyond our
control.
10. Disclaimer
10.1
To the maximum extent permitted
by law, we shall not be liable in any event for any special, exemplary,
punitive, indirect, incidental or consequential damages of any kind or for any
loss of reputation or goodwill, whether based in contract, tort (including
negligence), equity, strict liability, statute or otherwise, suffered as a
result of unauthorised or unintended use, access or disclosure of your personal
data.
11. Changes to this Policy
11.1 We may amend this Policy from
time to time. The amended Policy will be publicised on our Sites. All communications, transactions
and dealings with us shall be subject to the latest version of this Policy in
force at the time.
12. Withdrawal of Consent
12.1
You may withdraw your consent
given, or deemed to have been given, for any or all purposes set out in this Privacy Policy, by emailing to
PDPA@sgenable.sg.
12.2 Do note that if you withdraw your
consent to any or all of the purposes, SG Enable and its affiliates may not be
in a position to continue to provide our services to you.
13. How to Contact Us
13.1 To contact us on any queries or
on any aspect of this policy or your personal data or to provide any feedback,
you may contact us at PDPA@sgenable.sg.
14. Governing Law
14.1 This Policy is governed by the
laws of Singapore. You agree to submit to the exclusive jurisdiction of the Courts of Singapore in any dispute relating to
this Policy.
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SG Enable does not tolerate any malpractice, impropriety, statutory non-compliance or wrongdoing involving staff in the course of our work.
Below provides an avenue for staff, suppliers, contractors and other parties to step forward and disclose, in good faith, their concerns on
wrongdoings.
Reports can be made to whistleblow@sgenable.sg.
In order to effectively evaluate and investigate a concern, the report made should provide as much specific details as possible. The following
information should be included:
Name of whistleblower
Name(s) of person(s)/partner(s)/vendor(s) involved
Date, time and location of incident
Description of the concern
Frequency of occurrence
Evidence, if any
Any other information that may substantiate the concern
We will hold all reports and the identities of the whistleblowers in strictest confidence.
