1 Your Personal Data
- your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address and any other information relating to you which you have provided us in any forms you may have submitted to us, or in other forms of interaction with you;
- information about your use of GUESTSTAR’s website and services, including cookies, IP address, subscription account details and membership details, but only to the extent that GUESTSTAR may identify you from such information;
- your payment related information, such as your bank account or credit card information, and your credit history; and
- 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.
2 Collection of Personal Data
2.1 Generally, GUESTSTAR collects your Personal Data in the following ways:
- when you submit forms relating to any of our products or services;
- when you register for or use any of our services on websites or mobile applications 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;
- when you interact with our customer service officers;
- when you use some of our services;
- when you establish any online accounts with us;
- when you request that we contact you;
- when you are contacted by, and respond to, our marketing representatives and agents;
- when you respond to our request for additional Personal Data
- when you ask to be included in an email or other mailing list;
- when you respond to our promotions and other initiatives;
- when we receive references from business partners and third parties, for example, where you have been referred by them when you submit your Personal Data to us for any other reason.
2.2 When you browse our website, you generally do so anonymously, but please see the section below on cookies in Clause 5, below.
2.3 If you provide us with any Personal Data relating to a third party (e.g. information of spouse, children, parents, employees and/or authorised 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.
2.4 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 products and services you have requested.
3 Purposes for the Collection, Use and Disclosure of Your Personal Data
3.1 Generally, GUESTSTAR collects, uses and discloses your Personal Data for the following purposes:
- responding to your queries and requests and responding to complaints;
- managing the infrastructure and business operations of GUESTSTAR and complying with internal policies and procedures;
- facilitating business asset transactions (which may extend to any merger, acquisition or asset sale;
- matching any Personal Data held which relates to you for any of the purposes listed herein;
- verifying your identity;
- preventing, detecting and investigating crime, including fraud and money-laundering, and analyzing and managing other commercial risks protecting and enforcing our contractual and legal rights and obligations;
- managing commercial risks, conducting audits, reviews and analysis of our internal processes, action planning and;
- compliance with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities; and/or any other purpose relating to any of the above.
3.2 In addition, GUESTSTAR may collect, use and disclose your Personal Data for the following purposes, depending on the nature of our relationship with you:
(a) If you have an account with us:
(i) to process your application for an account;
(ii) to maintain your account with us;
(iii) to verify and process your personal particulars and payments in relation to provision of services to you;
(iv) communicating with you to inform you of changes and development to our policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you;
(v) resolving complaints and handling requests and enquiries;
(vi) conducting market research for statistical, profiling and statistical analysis for the improvement of services provided to you; and
(vii) the processing of your Personal Data in relation to any of the purposes stated above.
(b) If you use download or use any part of our Service (including the Site; any Third Party Sites; or any app):
(i) where the app includes app subscription services, to process your application for these services;
(ii) to maintain your account with us and to ensure your access of the app is within the scope of your subscription;
(iii) to verify and process your personal particulars and payments in relation to provision of goods and services to you;
(iv) to provide you with the goods and services which you have signed up for and to push messages to you which may be relevant to you;
(v) communicating with you to inform you of changes and development to GUESTSTAR policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you;
(vi) resolving complaints and handling requests and enquiries;
(vii) conducting market research for statistical, profiling and statistical analysis for the improvement of services provided to you; and
(viii) the processing of your Personal Data in relation to any of the purposes stated above.
3.3 In addition, where permitted under the Act, GUESTSTAR may also collect, use and disclose your Personal Data for the following purposes (which we may describe in our documents and agreements as “Additional Purposes” for the handling of Personal Data):
- providing services, products and benefits to you, including promotions, loyalty and reward programmes;
- matching 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 GUESTSTAR or other third parties;
- 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;
- sending you details of products, services, special offers and rewards, either to our customers generally, or of particular products and services which may be of interest to you; and
- conducting market research, understanding and determining customer location, preferences and demographics for us to review, develop and improve our products, services and also develop special offers and marketing programmes.
3.4 If you have provided your telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your telephone number(s), then from time to time, GUESTSTAR may contact you using such telephone number(s) (including via voice calls, sms, fax or other means) with information about our products and services (including discounts and special offers).
3.5 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.
3.6 You also consent to the collection, use and disclosure of your Personal Data by GUESTSTAR in connection with any transaction relating to the acquisition, divestment, securisation, amalgamation, listing or other transaction relating to any interest in GUESTSTAR, the shares or assets of GUESTSTAR, and any other corporate transaction involving GUESTSTAR, including any evaluation or due diligence relating thereto, as well as to the collection, use and disclosure of such information by the counterpart(ies) thereto for the same purposes, and the provision of goods and services by such counterpart(ies) following such transaction, as may be relevant.
4 Disclosure of Personal Data
4.1 GUESTSTAR will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, this Personal Data may be disclosed, for the purposes listed above (where applicable), to the following third parties, whether they are located overseas or in Singapore:
- GUESTSTAR affiliates;
- agents, contractors or third party service providers who provide operational services to GUESTSTAR, such as telecommunications, information technology, payment, payroll, processing, training, market research, newspaper vendor services, newspaper delivery services, storage, archival or other services to GUESTSTAR;
- vendors or any third party business partners who offer goods and services or sponsor contests or other promotional programs on GUESTSTAR sites, whether in conjunction with us or not;
- external business and charity partners in relation to corporate promotional events;
- the Credit Bureau, or in the event of default or disputes, any debt collection agencies or dispute resolution centres;
- any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale;
- anyone to whom we transfer or may transfer our rights and duties;
- banks, credit card companies and their respective service providers;
- our professional advisors such as our auditors and lawyers;
- relevant government regulators or authority or law enforcement agency to comply with any laws or rules and regulations imposed by any governmental authority; and
- any other party to whom you authorise us to disclose your personal data
5.1 When you interact with us on our websites, we may collect or analyse anonymised information from which individuals cannot be identified (“Aggregate Information”), such as number of users and their frequency of use, the number of page views (or page impressions) that occur on the website and common entry and exit points into website.
5.2 GUESTSTAR uses “cookies”, where a small data file is sent to your browser to store and track Aggregate Information about you when you enter our websites. The cookie is used to track information such as the number of users and their frequency of use, profiles of users and their preferred sites.
5.3 GUESTSTAR may use an independent company (the “Third Party Market Research Company”) to measure and analyse the Internet usage across GUESTSTAR websites. GUESTSTAR uses the Third Party Market Research Company’s services to collect the following core information on the usage of our web sites, including:
- The number of page views (or page impressions) that occur on GUESTSTAR websites;
- The number of unique visitors to GUESTSTAR websites;
- How long these unique visitors (on average) spend on GUESTSTAR websites when they do visit; and
- Common entry and exit points into GUESTSTAR websites.
6 Third-Party Sites
Our Website or any products/services being rendered to you may contain links to other websites that are not operated by Us and whose privacy practices may differ from Us. If you click on a third-party link, you may be directed to the third-party website. Any submission of your Personal Data to any of those third-party websites will be governed by the relevant third-parties’ privacy policies. We have no control and shall not assume any responsibilities howsoever arising thereof and We strongly advise you to carefully read the privacy policies prior to the disclosure of any information.
7 Withdrawal, Access and Correction of your Personal Data
7.1 Should you wish to withdraw consent to use of your Personal Data or obtain access to or make corrections to your Personal Data records, please log in to the relevant account through which the Personal Data was provided, if any, failing which please contact the relevant Personal Data Protection Officer, contact details of which are found in the Personal Data Protection Statement or similar document elsewhere on the relevant GUESTSTAR website.
7.2 Please note that if your Personal Data has been provided to us by a third party, you should contact such party directly to make any queries, feedback, and access and correction requests to GUESTSTAR on your behalf.
7.3 Please note that if you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, GUESTSTAR may not be in a position to continue to provide its products or services to you or administer any contractual relationship in place, and this may also result in the termination of any agreements with GUESTSTAR and your being in breach of your contractual obligations or undertakings, and GUESTSTAR’s legal rights and remedies in such event are expressly reserved.
8 Governing Law
9 Retention of your Personal Data
9.1 Data is retained as long as necessary for the performance of the services provided by the Website and to comply with legal obligations (including, auditing or taxation purposes), to meet regulatory requirements, resolve disputes, maintain security, and/or to prevent frauds and abuse.
9.2 In relation to Personal Data of your profile, We will retain the same as long as your account with Us is still active. If you choose to close the account or if your account is closed, We will take all reasonable steps to ensure that all personal data is destroyed or permanently deleted if it is no longer required for the purpose for which it was to be processed. This is without prejudice to Our right to retain the information (such as username and transaction details) to comply with legal obligations, prevent frauds and protect Our legal interest.
9.3 We treat the security of all information submitted or provided by you to Us seriously and is of importance to Us. We will take reasonable steps to protect or secure this data, including Personal Data. Accordingly, We may require Our employees or third-party service providers to assist Us in implementing or applying appropriate securities measures (such as firewalls, penetration testing etc). You are also advised not to disclose and secure your own username and password.
9.4 You have the right to obtain from Us confirmation whether your Personal Data are being processed by Us, and, in said circumstances, you have the right to request access to and rectification or erasure of the same or restriction of processing, on payment of a prescribed fee, and to object to the processing at any time, as well as under certain circumstances the right to data portability. With respect to the data portability, you have the right to receive your Personal Data in a structured, commonly used and machine-readable format and to request the transmission of said data.
10 How to contact us
Our DPO’s contact details