By visiting and/or ordering services and/or making reservations on this Website, you agree and where required you also consent to the collection, use and transfer of your information as set out in this policy.
INFORMATION THAT WE COLLECT FROM YOU
When you visit the Website or make an order through the Website, you may be asked to provide information about yourself including your name, contact details and payment information such as credit or debit card information. We may also collect information about your usage of the Website and information about you from the messages you post to the Website and the emails or letters you send to us.
In this Personal Data Protection Policy, “Personal Data” refers to any 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 we have or are likely to have access, including data in our records as may be updated from time to time.
Examples of such Personal Data you may provide to us include your name, NRIC, passport or other identification number, telephone numbers, mailing address, email address, network data and any other information relating to any individual which you have provided us in any form you may have submitted to us, or via other form of interaction with you.
COLLECTION OF PERSONAL DATA
Generally, East Ocean collects Personal Data, either directly from you or from your authorised representatives (i.e. persons whom you have authorised, persons who have been validly identified as being you or your authorised representative pursuant to our then-current security procedures), from third parties, from publicly available sources or through our Website (or any of our other online presence, including Facebook) in the following ways:
- when you submit a form for registering as a customer on our Website or any other forms relating to any of our Products and Services
- when you interact with us, for example, via telephone calls, letters, face-to-face meetings and emails;
- when you use some of our services, for example, websites and apps including establishing any online accounts with us;
- when you request that we contact you, be included in an email or other mailing list;
- when you respond to our promotions, initiatives or to any request for additional Personal Data;
- when you are contacted by, and respond to, our marketing representatives and customer service team;
- when we receive references from business partners and third parties, for example, where you have been referred by them; or
- when you submit your Personal Data to us for any other reasons.
If you provide us with any Personal Data relating to a third party (e.g. information of your spouse, children, parents, and/or employees), by submitting such information to us, you represent to us that you have obtained the consent of such third party to provide us with their Personal Data for the respective purposes.
You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with the Products and Services you have requested.
PURPOSES FOR THE COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
East Ocean may collect, use and disclose your Personal Data for the following purposes:
- responding to your queries and requests;
- managing the administrative and business operations of East Ocean and complying with internal policies and procedures;
- facilitating business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving any of the Companies;
- matching any Personal Data held which relates to you for any of the purposes listed herein;
- resolving complaints and handling requests and enquiries;
- preventing, detecting and investigating crime and analyzing and managing commercial risks;
- providing media announcements and responses;
- monitoring or recording phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes;
- organising promotional events;
- legal purposes (including but not limited to obtaining legal advice and dispute resolution);
- conducting investigations relating to disputes, billing or fraud;
- meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on East Ocean (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies and conducting audit checks, due diligence and investigations); and
- purposes which are reasonably related to the aforesaid.
Where permitted under the Personal Data Protection Act (the “Act”):-
- we may also collect, use and disclose your Personal Data for the following
- analytics and tracking;
- conducting market research and surveys to enable us to understand and determine customer location, preferences and demographics to develop special offers and marketing programmes in relation to East Ocean's Products and Services, and to improve our service delivery and your customer experience at our touchpoints;
- providing additional Products and Services and benefits to you, including promotions, loyalty and reward programmes from East Ocean;
- matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision, marketing or offering of Products and Services by East Ocean;
- leads generation and management for marketing East Ocean’s Products and Services;
- administering contests, competitions and marketing campaigns, and personalising your experience at East Ocean’s touchpoints;
- communicating to you advertisements involving details of our Products and Services, special offers and rewards, either to our customers generally, or of which we have identified may be of interest to you (including but not limited to upselling, cross selling and online marketing);
- organising promotional events and corporate social responsibility projects; and
- purposes which are reasonably related to the aforesaid.
- In addition, where permitted under the Act and subject to the provisions of any applicable law, your Personal Data may be disclosed, for East Ocean’s Additional Purposes, to the vendors or other third party service providers in connection with promotions, Products and Services offered by East Ocean.
- East Ocean may also collect, use and disclose your Personal Data for the following “Preferred Partners’ Additional Purposes”:
- conducting market research and surveys to enable us to understand and determine customer location, preferences and demographics to develop special offers and marketing programmes with our preferred partners;
- matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision, marketing or offering of products and services (including promotions, loyalty and reward programmes) by our preferred partners;
- leads generation and management for marketing the products and services offered by our preferred partners;
- administering contests, competitions and marketing campaigns in connection with the products and services offered by our preferred partners;
- communicating to you advertisements involving details of the products, services, special offers and rewards offered by our preferred partners, either to our customers generally, (including but not limited to upselling, cross selling and online marketing); and
- purposes which are reasonably related to the aforesaid.
In addition, where permitted under the Act and subject to the provisions of any applicable law, your Personal Data may be disclosed, for Preferred Partners' Additional Purposes, to the vendors or other third party service providers in connection with promotions and services offered by East Ocean’s preferred partners.
If you have provided your Singapore telephone numbers, we may contact you using such Singapore telephone numbers (including via voice calls, SMSes, fax or other means) with information about our Products and Services or those products and services offered by our preferred partners (including discounts, flash sales and special offers).
In relation to particular Products and 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, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.
DISCLOSURE OF PERSONAL DATA
East Ocean will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, your Personal Data may be disclosed, for the purposes listed above (where applicable), to the following:
- East Ocean’s related corporations and employees who provide content, Products and Services to you, address your questions and requests in relation to your customer accounts, subscription and billing or order arrangements with us as well as our Products and Services, to activate, deactivate, install, maintain and operate our systems and/or services;
- companies who provide insurance and consultancy services to East Ocean;
- agents, contractors or third party service providers who provide operational services to us, such as courier services, telecommunications, information technology, payment, printing, billing, payroll, processing, technical services, training, market research, call centre, security or other services to East Ocean;
- vendors or third party service providers who provide marketing promotions and services offered by East Ocean or our preferred partners;
- our professional advisers such as auditors and lawyers;
- relevant government regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and
- any other party to whom you authorise us to disclose your Personal Data to.
WITHDRAWAL OF CONSENT
Should you wish to withdraw your consent for us to send you sales, marketing or promotional information via a specific mode, please inform us in the following manner:
- to withdraw consent from receiving SMS promotions, please unsubscribe by following the steps provided in the promotional SMS;
- to withdraw consent from promotional emails, please click on the “Unsubscribe” link we provide in promotional emails; and
- to withdraw consent from receiving promotional material by mail, please email us with the words “PERSONAL DATA” in the subject line, to our email address - email@example.com.
Please be aware that once we receive confirmation that you wish to withdraw your consent for marketing or promotional materials/communication, it may take up to 90 days for your withdrawal to be reflected in our systems. Therefore, you may still receive marketing or promotional materials/communication during this period of time. Please note that even if you withdraw your consent for the receipt of marketing or promotional materials through a specific mode, we may still contact you for other purposes in relation to the Products and Services that you have requested from or subscribed with East Ocean.
Otherwise than stated above, if you wish to withdraw any consent given in respect of the collection, use or disclosure of your Personal Data, please contact our Data Protection Officer (“DPO”) at firstname.lastname@example.org. Please note that such withdrawal of consent may affect our ability to provide our Products and Services you have requested or may request in the future.
ACCESS AND CORRECTION OF PERSONAL DATA
If you wish to request for access to and/or correction of your Personal Data we have in possession or control over, please contact our DPO at the following email address: email@example.com. Our DPO may require you to fill up a form for such requests.
Unless prohibited by law, we will provide access or make the correction to your Personal Data as soon as reasonably possible.
Please note that East Ocean reserves the right to charge a reasonable fee in order to meet your requests.
If our business enters into a joint venture with, purchases or is sold to or merged with another business entity, your information may be disclosed or transferred to the target company, our new business partners or owners or their advisors.
CHANGES TO THIS POLICY
THIRD PARTY WEBSITES
SECURITY AND PRIVACY
We have the right, but not the obligation, to monitor any activity and content associated with the Website. We may investigate any reported violation of these Terms or complaints and take any action that we deem appropriate (which may include, but is not limited to, issuing warnings, suspending, terminating or attaching conditions to your access and/or removing any materials on the Website).
If any part of the Terms shall be deemed unlawful, void or for any reason unenforceable, then that part shall be deemed to be severable from these Terms and shall not affect the validity and enforceability of any of the remaining parts of the Terms.
No waiver by us shall be construed as a waiver of any proceeding or succeeding breach of any part of the Terms.
Except insofar as the Terms expressly provide that a third party may in his own right enforce a term of the Terms, a person who is not a party to this Agreement has no right under the Contracts (Rights of Third Parties) Act (Cap. 53B) to rely upon or enforce any term of the Terms but this does not affect any right or remedy of a third party which exists or is available apart from under that Act.
This Personal Data Protection Policy, the Terms and your use of this Website shall be governed by and construed in all respects in accordance with the laws of the Republic of Singapore. Disputes arising in connection with the Terms shall be subject to the non-exclusive jurisdiction of the courts of Singapore.
CONTACTING OUR DPO
You may contact our DPO at the following email address: firstname.lastname@example.org, if you wish to:
- request for more information on our policies and practices in protecting your Personal Data;
- make a complaint with respect to our obligations under the Act.