This Policy is designed to assist you in understanding how we collect, use and/or disclose the personal data you have provided to us, as well as to assist you in making an informed decision before providing us with any of your personal data.
This Policy applies to information we collect on www.truematchmaking.com and its sub-domains about:
i) visitors to our website (the “Site”);
ii) people who register or contact us in any form via any contact forms or contact methods as listed on our website;
If you, at any time, have any queries on this policy or any other queries in relation to how we may manage, protect and/or process your personal data, please do not hesitate to contact us at email@example.com
1. INTRODUCTION TO THE PERSONAL DATA PROTECTION ACT 2012 (“PDPA”)
1.1 “Personal Data” is defined under the PDPA to mean data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organization has or is likely to have access. Common examples of personal data could include names, identification numbers, contact information, financial records, credit card information, photographs and video images.
1.2 We will collect your personal data in accordance with the PDPA. In general, before we collect any personal data from you, we will notify you of the purposes for which your personal data may be collected, used and/or disclosed, as well as obtain your consent for the collection, use and/or disclosure of your personal data for the intended purposes.
2. INFORMATION COLLECTED FROM ALL VISITORS TO OUR WEBSITE
3.1 Cookies are text files placed on your computer to collect standard Internet log information and visitor behaviour information. The information is used to track visitor use of the Site and to compile statistical reports on Site activity. For further information about cookies visit www.aboutcookies.org or www.allaboutcookies.org. You can set your browser not to accept cookies and the above websites tell you how to remove cookies from your browser. However, in a few cases some of our Site features may not function if you remove cookies from your browser.
4. PURPOSES FOR COLLECTION, USE & DISCLOSURE OF PERSONAL DATA
4.1 The personal data which we collect from you may be collected, used and/or disclosed for any of the following purposes :
(a) considering and/or processing your membership application with us;
(b) facilitating, processing, dealing with, administering, managing and/or maintaining your membership with us, including but not limited to arranging dates for you and providing our personalised dating and consultancy services to you;
(c) carrying out your instructions or responding to any enquiry given by (or purported to be given by) you or on your behalf;
(d) contacting you or communicating with you via any kind of telecom or OTT phone/voice call, text message and/or email and/or postal mail for the purposes of administering and/or managing your membership with us such as but not limited to communicating information to you related to your membership, your appointments with us, dating tips, dates arranged for you, social events organised by us, and the personalised dating and consultancy services provided by us. You acknowledge and agree that such communication by us could be by way of the mailing of correspondence, documents or notices to you, which could involve disclosure of certain personal data about you to bring about delivery of the same as well as on the external cover of envelopes/mail packages;
(e) carrying out your instructions or responding to any enquiry given by (or purported to be given by) you or on your behalf;
(f) dealing in any matters relating to the personalised dating and consultancy services provided by us and your membership with us;
(g) carrying out due diligence or other screening in accordance with any legal or regulatory obligations or our risk management procedures that may be required by law or that may have been put in place by us;
(h) to prevent or investigate any fraud, unlawful activity or omission or misconduct, whether relating to your membership with us or any other matter arising from your membership with us, and whether or not there is any suspicion of the aforementioned;
(i) complying with or as required by any applicable law, governmental or regulatory requirements of any relevant jurisdiction, including meeting the requirements to make disclosure under the requirements of any law binding on us and/or for the purposes of any guidelines issued by regulatory or other authorities, whether in Singapore or elsewhere, with which we are expected to comply;
(j) complying with or as required by any request or direction of any governmental authority; or responding to requests for information from public agencies, ministries, statutory boards or other similar authorities. For the avoidance of doubt, this means that we may/will disclosure your personal data to the aforementioned parties upon their request or direction;
(k) conducting research, analysis and development activities (including but not limited to data analytics, surveys and/or profiling) to improve our services and facilities in order to enhance your membership with us or for your benefit, or to improve any of our services for your benefit;
(l) considering your job application with us and notifying you of any results of your job application;
(m) facilitating, dealing with and/or administering external audit(s) or internal audit(s) of our business;
(n) for marketing, if you have separately indicated that you consent to such purpose. If so, we may/will send you by email, postal mail or other modes of communication marketing and promotional information and materials relating to products and/or services (including products and/or services of third party merchants whom TRUE may collaborate or tie up with) that TRUE may be selling, marketing or promoting, whether such products or services exist now or are created in the future. In the case of the sending of marketing and promotional information and materials to you by voice call, SMS/MMS or OTT applications to your Singapore telephone number, we will not do so unless we have complied with the requirements of the PDPA in relation to use of the latter modes of communication to send you such marketing information or materials or where you have expressly consented to such mode of communication;
(o) dealing with and/or facilitating a business asset transaction or a potential business asset transaction, where such transaction involves TRUE as a participant, and where there may be other third party organisations who are participants in such transaction. “business asset transaction” means the purchase, sale, lease, merger or amalgamation or any other acquisition, disposal or financing of an organisation or a portion of an organisation or of any of the business or assets of an organisation; and/or
(p) storing, hosting, backing up (whether for disaster recovery or otherwise) of your personal data, whether within or outside Singapore.
(collectively, the “Purposes”)
4.2 In order to conduct our business operations more smoothly, we may also be disclosing the personal data you have provided to us to our third party service providers, agents, public agencies, including but not limited to the Social Development Network [and/or our affiliates or related corporations], which may be sited outside of Singapore, for one or more of the above-stated Purposes. This is because such third party service providers, agents and/or affiliates or related corporations would be processing your personal data on our behalf for one or more of the above-stated Purposes.
5. SPECIFIC ISSUES FOR THE DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES
5.1 We respect the confidentiality of the personal data you have provided to us.
5.2 In that regard, we will not disclose, sell, trade or otherwise transfer any of your personal data to any third parties without first obtaining your express consent permitting us to do so. However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.
5.3 We may also disclose your personal data to third parties without first obtaining your consent in certain situations, including, without limitation, the following :
(a) cases in which the disclosure is required based on the applicable laws and/or regulations;
(b) cases in which the purpose of such disclosure is clearly in your interests, and if consent cannot be obtained in a timely way;
(c) cases in which the disclosure is necessary to respond to an emergency that threatens the life, health or safety of yourself or another individual;
(d) cases in which there are reasonable grounds to believe that the health or safety of yourself or another individual will be seriously affected and consent for the disclosure of the data cannot be obtained in a timely way, provided that we shall, as soon as may be practicable, notify you of the disclosure and the purposes of the disclosure;
(e) cases in which the disclosure is necessary for any investigation or proceedings;
(f) cases in which the personal data is disclosed to any officer of a prescribed law enforcement agency, upon production of written authorisation signed by the head or director of that law enforcement agency or a person of a similar rank, certifying that the personal data is necessary for the purposes of the functions or duties of the officer; and/or
(g) cases in which the disclosure is to a public agency and such disclosure is necessary in the public interest.
5.4 The instances listed above at paragraph 5.3 are not intended to be exhaustive. For an exhaustive list of exceptions, you are encouraged to peruse the Second, Third and Fourth Schedules of the PDPA which is publicly available at http://statutes.agc.gov.sg.
5.5 In all other instances of disclosure of personal data to third parties with your express consent, we will endeavor to provide adequate supervision over the handling and administration of your personal data by such third parties, as well as to provide for adequate forms of protection over such personal data.
5.6 Where personal data is transferred by us to any third parties outside of Singapore, we will ensure that such transfers are compliant with the requirements under the PDPA. In this regard, we will take such necessary measures to ensure that such overseas recipients are bound by legally enforceable obligations to ensure that these overseas recipients provide a standard of protection to the personal data so transferred that is comparable to the protection under the PDPA.
6. REQUEST FOR ACCESS AND/OR CORRECTION OF PERSONAL DATA
6.1 Subject to the exceptions referred to in section 21(2) of the PDPA, you have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please send an email to firstname.lastname@example.org.
6.2 We want to ensure that your personal information is accurate and up to date. If any of the information that you have provided to TRUE changes, for example if you change your email address, name or payment details, or if you wish to cancel your registration, please let us know the correct details by sending an email to enquiry@truematchmaking. You may ask us, or we may ask you, to correct information you or we think is inaccurate, and you may also ask us to remove information which is inaccurate.
7. REQUEST TO WITHDRAW CONSENT
7.1 You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control at any time by submitting your request to the contact details listed below at paragraph 10.2.
7.2 We will process your request within a reasonable time from such a request for withdrawal of consent being made, and will thereafter refrain from collecting, using and/or disclosing your personal data in the manner stated in your request.
8. ADMINISTRATION AND MANAGEMENT OF PERSONAL DATA
8.1 We will take appropriate measures to keep your personal data accurate, complete and updated.
8.2 We will also take commercially reasonable efforts to take appropriate precautions and preventive measures to ensure that your personal data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorized access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data. However, we cannot assume responsibility for any unauthorized use of your personal data by third parties which are wholly attributable to factors beyond our control.
8.3 We will also take commercially reasonable efforts to ensure that the personal data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes.
9. LINKS TO OTHER WEBSITES
10. COMPLAINT PROCESS
10.1 If you have any complaint or grievance regarding about how we are handling your personal data or about how we are complying with the PDPA, we welcome you to contact us with your complaint or grievance.
10.2 Please contact us through the following method with your complaint or grievance :
E-mail: [email@example.com]. Attention it to the ‘Data Protection Officer’.
10.3 Where it is an email or a letter through which you are submitting a complaint, your indication at the subject header that it is a PDPA complaint would assist us in attending to your complaint speedily by passing it on to the relevant staff in TRUE to handle. For example, you could insert the subject header as “PDPA Complaint”.
10.4 We will certainly strive to deal with any complaint or grievance that you may have speedily and fairly.
11. UPDATES ON DATA PROTECTION POLICY
11.1 As part of our efforts to ensure that we properly manage, protect and process your personal data, we will be reviewing our policies, procedures and processes from time to time.
11.2 We reserve the right to amend the terms of this Data Protection Policy at our absolute discretion. Any amended Data Protection Policy will be posted on our website and can be viewed at [https://truematchmaking.com/privacy/].
11.3 You are encouraged and it is also fully your duty alone to always visit the above website from time to time to ensure that you are well informed of our latest policies in relation to personal data protection.