DATA PROTECTION NOTICE
This Data Protection Notice (“Notice”) sets out the basis on which Gushcloud (“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”) on behalf of the Seller (“Registered seller with gclive.co”). This Notice applies to personal data in our possession or under our control, including personal data in the possession of organizations which we have engaged to collect, use, disclose or process personal data for our purposes.
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.
2. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include your name and identification information such as your identifiable name, contact information such as your address, email address or telephone number, gender, date of birth, marital status, photographs, and other audio-visual information, and financial information such as credit card numbers, debit card numbers or bank account information to facilitate payment of goods and services.
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
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 authorized by you to disclose your personal data to us (your “authorized representative”) after (i) you (or your authorized representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorized 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 that has not been notified to you (except where permitted or authorized by law).
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) sending your marketing information about our goods or services including notifying you of our marketing events, initiatives and promotions, lucky draws, membership and rewards schemes, and other promotions; (g) 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; (h) any other purposes for which you have provided the information; (i) 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 (j) any other incidental business purposes related to or in connection with the above.
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 or services requested by you; or
(b) to third-party service providers, agents, and other organizations we have engaged to perform any of the functions listed in clause 5 above for us.
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 any contract with you).
WITHDRAWING YOUR CONSENT
8. 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 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.
9. 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.
10. 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 8 above.
11. 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 applicable laws.
ACCESS TO AND CORRECTION OF PERSONAL DATA
12. 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. 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.
14. 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).
PROTECTION OF PERSONAL DATA
15. 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.
16. 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
17. We generally rely on personal data provided by you (or your authorized 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
18. We may retain your personal data, which could include:
- Provided names
- Facebook user IDs to recognize unique customers and provide customer support on the Facebook messaging platform
- Facebook access-token to provide customer support on the Facebook messaging platform
- Emails for the communication of orders
- Telephone numbers for the communication of the delivery of goods
- Business addresses (applicable for business sellers only)
- Bank details for payment processing (applicable for business sellers only)
- Residential addresses for the purpose of the delivery of goods for as long as it is necessary to fulfill the purpose for which it was collected, or as required or permitted by applicable laws.
19. 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
20. 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.
DELETION OF PERSONAL DATA
21. Deletion of user data is processed via a programming script that would identify the user's personal data via a user id in our database. It would permanently delete all records of the user's personal data that is identifiable. Information of the user that may be linked to a business transaction would still be kept to maintain the records of the business as required for business operations.
DATA PROTECTION OFFICER
22. You may contact our Data Protection Officer if you have any inquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner: Tan Hong Zhou, firstname.lastname@example.org.
EFFECT OF NOTICE AND CHANGES TO NOTICE
23. 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.
24. 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 acknowledgment and acceptance of such changes.
Effective date: 19 Jan 2021
Last updated: 19 Jan 2021
ACKNOWLEDGEMENT AND CONSENT
By proceeding to register with our service on the website, I acknowledge that I have read and understood the above Data Protection Notice, and consent to the collection, use, and disclosure of my personal data by Gushcloud for the purposes set out in the Notice, including to receive information about the goods and services which may be provided by Gushcloud, including (but not limited to) offers, promotions, and information about new goods and services, via the following channels: □ newsletter □ email □ text message □ telephone call.