PERSONAL DATA PROTECTION POLICY

(Last updated: ……… July 2021)

1. Purpose

This Personal Data Protection Policy (“Policy”) sets out the ways in which Metta Welfare Association (“MWA”, “us”, “we” or “our”) collects, uses, discloses and retains personal data in order to carry out our activities and operations and the measures we take to protect your personal data. The Policy is designed to meet the requirements of Singapore’s personal data protection laws.

2. Application of Policy

2.1  By visiting our website, you are accepting and agreeing to the terms of this Policy as updated from time to time.

2.2  This Policy supplements but does not supersede nor replace any other consents you may have previously provided to MWA nor does it affect any rights which MWA may have at law in connection with the collection, use or disclosure of your personal data.

3. Types of Personal Data collected

3.1  “Personal Data” means data, whether true or not, about an individual who can be identified from that data or from that data and other information to which we have or are likely to have access. Common examples of personal data could include:

(a)  identification information such as your name, identity card/passport details, birth certificate number, work pass number, nationality, gender, date of birth, education details and marital status;

(b)  contact information such as your telephone number, address and email address;

(c)  photographs and audio-video information;

(d)  medical information and employment details (e.g. occupation, directorships and other positions held, employment history, salary, and/or benefits);

(e)  financial information such as your bank account details, credit/debit card details, income, expenses and your credit history;

(f)  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 website; and

(g)  any other information which you have provided to us in any forms you may have submitted to us, or in other forms of interaction with us.

4. How we collect your personal data

4.1  You can use and browse our website without having to disclose your personal data except as may be necessary to allow us to respond to your requests or in cases where you contact us directly. Generally, we collect personal data in the following ways:

(a)  when you register for any of our events, activities or services or purchase our products;

(b)  when you register for or use any of our services on websites owned or operated by us or when you register as a member of websites owned and/or operated by us, or use services on such websites;

(c)  when you establish any online accounts with us;

(d)  when you request that we contact you;

(e)  when you are contacted by, and respond to, our employees or representatives or agents;

(f)  when you respond to our request for additional personal data;

(g)  when you ask to be included in an email or other mailing list;

(h)  when you submit a job application;

(i)  when we receive references from business or charity partners or any third party, for example, where you have been referred by them;

(j)  when you make donations to us; and

(k)  when you submit your personal data to us for any other reason.

4.2  If you provide us with any personal data relating to a third party (e.g. information of spouse, children, parents, employees and/or authorized representatives), by submitting such information to us, you represent to us that you have obtained the consent of the third party to you providing us with their personal data for the respective purposes.

5. Use of Your Personal Data

5.1  All personal data and other information collected may be used by MWA individually or collectively and may be combined with other information for the following purposes:

(a) responding to and taking follow-up action on your queries, requests, applications, complaints and feedback;

(b) managing the infrastructure and business operations of MWA and complying with internal policies and procedures;

(c) 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 MWA or other third parties;

(d) verifying your identity;

(e) preventing, detecting and investigating crime, including fraud and money-laundering, and analyzing and managing other commercial risks;

(f) protecting and enforcing our contractual and legal rights and obligations;

(g) conducting audits, reviews and analysis of our internal processes, action planning and managing commercial risks;

(h) organizing seminars, events or other activities which promote MWA’s charitable causes;

(i) complying with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities;

(j) processing and evaluating your application for our products or services;

(k) performing obligations in the course of or in connection with our provision of the products or services requested by you;

(l) monitoring, evaluating and auditing of the products or services provided to you;

(m) processing your donations and tax-deduction claims;

(n) conducting market research, understanding and determining customer/donor location, preferences and demographics for us to review, develop and improve our products, services and also develop special fund-raising events, activities or programmes;

(o) maintaining your account or relationship with us;

(p) processing payment or credit transactions;

(q) communicating with you to inform you of changes and development to MWA policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you;

(r) providing or obtaining employee references or other references where relevant for background screening/vetting;

(s) improving our website’s content or layout;

(t) administering contests, competitions and conducting lucky draws, including, where necessary, in order to announce the results of these contests, competitions and lucky draws and identify and contact the winners, and in order to publicise and conduct marketing strictly related to these contests, competitions and lucky draws;

(u) sending you information about our products, services, events, activities, initiatives, beneficiaries, lucky draws, either generally or which may be of interest to you; and

(v) any other purposes relating to any of the above or for which you have provided the information.

5.2  If you have provided your Singapore telephone number(s) and have indicated that you consent to receiving information on MWA’s events or activities via your Singapore telephone number(s), then from time to time, MWA 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.

5.3  In relation to particular products or services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your personal data. If so, then we will collect, use and disclose your personal data for these additional purposes as well, unless we have specifically notified you otherwise.

5.4  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 any contract with you).

6. Disclosure and Sharing of your Personal Data

6.1  MWA may from time to time disclose your personal data to any personnel of MWA or to third parties (whether located in Singapore or elsewhere) in order to carry out the purposes set out above. Please be assured that when we disclose your personal data to such parties, we require them to ensure that any personal data disclosed to them are kept confidential and secure.

6.2  Third parties whom we may disclose your personal data to include (but are not limited to):

(a) MWA affiliates;

(b) agents, contractors or third party service providers who provide operational services to MWA, such as telecommunications, information technology, payment, payroll, processing, training, market research, storage, archival or other services to MWA;

(c) vendors or any third party business or charity partners who offer goods and services or other events or activities or programs on MWA’s sites, whether in conjunction with us or not;

(d) external business and charity partners in relation to corporate promotional events;

(e) the Credit Bureau, or in the event of default or disputes, any debt collection agencies or dispute resolution centres;

(f) anyone to whom we transfer or may transfer our rights and duties;

(g) banks, credit card companies and their respective service providers;

(h) our professional advisors such as our auditors and lawyers;

(i) relevant government regulators or authority or law enforcement agency to comply with any laws or rules and regulations imposed by any governmental authority; and

(j) any other party to whom you authorize us to disclose your personal data.

6.3  MWA does not sell personal data to any third parties and we shall remain fully compliant of any duty or obligation of confidentiality imposed on us under any agreement that governs our relationship with you or any applicable law.

7. Withdrawing consent

7.1  You may withdraw consent and request us to stop 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 our Data Protection Officer at the contact details provided below.

7.2  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.

7.3  Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, MWA may not be in a position to continue providing its products or services to you or administering any contractual relationship in place, and this may also result in the termination of any agreements with MWA.

7.4  Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclosure without consent is permitted or required under any applicable law.

8. Access and Correction of your Personal Data

8.1  You may request access to a copy of the personal data which we hold about you or corrections to any of your personal data which we hold about you. You may submit your request via email to our Data Protection Officer at the contact details provided below.

8.2  MWA may charge a fee for processing your request for access. We will inform you of the fee before processing your request.

8.3  We will respond to your request as soon as reasonably possible. 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 Singapore’s personal data protection laws).

9. Protection of your Personal Data

9.1  To safeguard your personal data from unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorized third party service providers and agents only on a need-to-know basis.

9.2  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.

10. Accuracy of your personal data

10.1  We rely on you to ensure that all personal data provided by you or your authorized representative is complete, accurate, true and correct. Please update us if there are changes to your personal data by informing our Data Protection Officer via email at the contact details provided below.

11. Retention of your Personal Data

11.1   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.

11.2  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.

12. Cookies

12.1  Our website uses cookies. Cookies are small files which are placed on your computer or mobile device when you visit a website; they help the website user to navigate efficiently between pages and the website operator to track usage of the site.

12.2  We use cookies to distinguish you from other users by storing, generally non-personally identifiable, information (e.g. session information such as the number of times you visit our website and the location from which you are accessing the website). Note that some limited information is personally identifiable for the purposes of:

(a) managing and customizing your experience on the website/platform;

(b) analysing trends and improving our site for our users; and

(c) delivering content tailored to your interests and the manner in which you browse our websites and platforms.

Any other information is anonymized and/or aggregated to produce statistical reports that enable us to evaluate the use of our website; and to make improvements to and increase efficiency when you browse our website.

12.3  You have the choice to set up your web browser to disable, control or delete cookies. However, you should note that if you choose to do this, it may have an impact on the quality of your browsing experience.

13. Link to other Websites

13.1  Our websites may contain links to other websites which are not maintained by us. This Policy only applies to MWA’s  website. You should read their privacy notices when visiting other websites.

14. Changes to Policy

14.1  MWA may from time to time update this Policy to ensure that this Policy is consistent with any changes in legal requirements. You are encouraged to periodically review this Policy to be informed of how MWA is protecting your personal data.

15. Contact Information

15.1  If you have any questions or feedback relating to your personal data or this Policy, please contact us at:

(a) Email:  hqdpo@metta.org.sg

(Attention it to the ‘Data Protection Officer’)

(b) Office address: Metta Welfare Association, 32 Simei Street 1, Singapore 529950

(Attention it to the ‘Data Protection Officer’)