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The purpose of this document (“Privacy Statement“) is to inform you how SMRT Corporation Ltd manages Personal Data (as defined below) in accordance with the Singapore Personal Data Protection Act 2012. Please take a moment to read this Privacy Statement so that you are aware of and understand the purposes for which we collect, use and disclose your Personal Data.
By interacting with us, submitting information to us or signing up for any promotions or services offered by us, you agree and consent to SMRT Corporation Ltd and its related corporations (collectively, the “Companies“), as well as our respective representatives and/or agents (“Representatives“) (collectively referred to herein as “SMRT“, “us“, “we” or “our“) collecting, using, disclosing and sharing your Personal Data amongst ourselves, and disclosing such Personal Data to our authorised service providers and relevant third parties in the manner set forth in this Privacy Statement.
This Privacy Statement supplements but does not supersede nor replace any other consents you may have previously provided to SMRT in respect of your Personal Data, and your consents herein are cumulative and additional to any rights which we may have under applicable law to collect, use or disclose and/or otherwise process your Personal Data.
We may from time to time update this Privacy Statement to ensure that this Privacy Statement is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements, and may notify you of updates in any form we deem appropriate or, where required by applicable law, by posting a notice or reaching you via other forms of communication (e.g. sending you a SMS message or email or giving you a phone call) according to such contact particulars that we may have for you in our records from time to time. To the maximum extent permissible under applicable law, you agree to be bound by the prevailing terms of the Privacy Statement as updated from time to time on our website and/or as you may be notified. Hence, please check back regularly for updated information on the handling or processing of your Personal Data.
Use of our electronic services (including without limitation our websites, platforms, and applications) is also subject to our Terms of Use, available at http://smrt.com.sg/TermsofUse.aspx or via such other means as we may specify from time to time. For more information about our use of cookies, please refer to our Terms of Use.
1.1 In this Privacy Statement, “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.
1.2 Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us) your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address, transactional data, and any other information relating to any individuals which you have provided us (including in the form of biometric data), or via other forms of interaction with us.
2.1 Generally, we collect Personal Data in the following ways:
2.2 If you provide us with any Personal Data relating to a third party (e.g. information of spouse, minors, children, parents, employees and/or authorised persons), by submitting such information to us, you represent to us that you have obtained the consent of such third party to you providing us with their Personal Data, and for the collection, use and disclosure of their Personal Data for all purposes set out in our herein and by or for the benefit of the persons referenced herein.
2.3 You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure to do so on your part may result in our inability to provide you with the products and/or services which you have requested.
3.1 Generally, SMRT collects, uses and discloses your Personal Data for the following purposes:
3.2 In addition, SMRT collects, uses and discloses your Personal Data for the following purposes, depending on the nature of our relationship:
(iii) managing the outsourcing relationship;
(iv) facilitating training, learning and talent development;
(v) processing and payment of invoices and claims;
(vi) managing project developments and communications;
(vii) supervising operational matters; and/or
(viii) managing the security of the premises (including but not limited to conducting security screening and issuing contractor access passes);
(ii) processing your application / engagement which includes pre-recruitment / pre-engagement checks involving your qualifications and facilitating interviews;
(iii) providing or obtaining employee / customer references and for background screening;
(iv) assessing your suitability for the position or engagement applied for; and/or
(v) managing and/or processing referrals; and/or
(vi) verifying your identity and accuracy of your personal details and other information provide;
(ii) investigating any acts or defaults (or suspected acts or defaults), or contraventions of our internal or external compliance obligations;
(iii) providing you with tools and facilities to enable or facilitate the performance of your duties, and monitoring your use of such tools and facilities;
(iv) ensuring business continuity, including compiling and publishing internal directories and emergency contact lists;
(v) ensuring that our operations function in a secure, efficient and effective manner (including examining or monitoring any computer software and hardware installed by us, located in our premises, or under our control, your activities on such computer software and hardware, your internet access, your work emails and personal digital and storage devices); and/or
(vi) performing obligations under or in connection with your contract of employment or relationship with us, such as payment of remuneration and tax;
3.3 In addition, where permitted under applicable law, we 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):
(b) 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 promotions, products and services, whether by SMRT or other third parties;
(c) organising marketing and promotional events, administering contests and competitions, and personalising your experience at SMRT’s touchpoints;
(d) sending you details of promotions, services, special offers and rewards, either to our customers generally, or which we have identified may be of interest to you;
(e) conducting market research, understanding and analysing customer behaviour, location, preferences and demographics for us to offer you products and services as well as special offers and marketing programmes which may be relevant to your preferences and profile; and/or
(f) recommending, identifying and/or contacting you to inform you of products, services, special offers and rewards, either to our customers generally, or which we have identified may be of interest to you, or that are or may be relevant to you, in any case including on behalf of third parties, or sharing your Personal Data with such third parties or their service providers for them to collect, use, disclose or process your Personal Data for any of such purposes.
3.4 If you have provided your Singapore telephone number(s) and you have (i) indicated that you consent to receiving marketing or promotional information via your Singapore telephone number(s), (ii) not registered with the Do Not Call Registry, or (iii) the sending of such marketing or promotional information is permissible under applicable laws and regulations, then from time to time, SMRT may contact you using such Singapore telephone number(s) (including via voice calls, text, fax or other means) with information about our promotions, products and services (including discounts and special offers). You have the right to withdraw your consent regarding the marketing or promotional information you receive at any time by contacting the appropriate Representative. Such requests will be processed within 21 days. Please note that after opting out, you may still continue to receive non-marketing messages, such as product updates and service notices as permitted under applicable laws and regulations.
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, we may collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.
4.1 SMRT 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 provided, for the purposes listed above (where applicable), to the following entities or parties, whether they are located overseas or in Singapore:
(b) companies or brokers providing services relating to insurance and/or reinsurance to SMRT;
(c) agents, contractors or third party service providers who provide operational services to SMRT, such as vehicle servicing and towing, courier services, telecommunications, information technology, advertising, payment, payroll, processing, training, market research, storage, archival, customer support investigation services or other services to SMRT;
(d) vendors or other third party service providers in connection with promotions and services offered by SMRT;
(e) any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to merger, acquisition, debt or asset sales) involving any of the Companies;
(f) banks, credit card companies, financial institutions, and their respective service providers;
(g) third party referrers;
(h) our co-brand and other business partners;
(i) our professional advisers such as our consultants, auditors and lawyers;
(j) relevant government regulators, government ministries, statutory boards or authorities and/or law enforcement agencies, whether local or overseas, including the Land Transport Authority, to comply with any directions, laws, rules, guidelines, regulations or schemes issued or administered by any of them;
(k) external business and charity partners in relation to corporate promotional events; and/or
(l) any other party to whom you authorise us to disclose your Personal Data to.
4.2 We may also share information about you in aggregate or anonymised form (such as generic aggregated demographic information regarding visitors and users) with the abovementioned parties.
5.1 In addition to the matters set forth above, subject to and in accordance with applicable law, you shall be deemed to have consented to us collecting, using, disclosing and sharing amongst ourselves your Personal Data, and disclosing such Personal Data to our authorised service providers and relevant third parties:
(b) where the collection, use and/or disclosure of your Personal Data is reasonably necessary for the conclusion and/or performance of a contract, between you and us or any other organisation entered into at your request, which may include recipients of your Personal Data not indicated in this Privacy Statement.
6.1 In addition to and without limiting the consents you have provided to our collection, use and/or disclosure of your Personal Data for the purposes set out elsewhere in this Privacy Statement, where permitted by applicable law, we may in accordance with the requirements thereof also collect, use and/or disclose your Personal Data as further detailed below including without consent, where we meet the requirements under applicable law:
7.1 If you:
(b) would like to withdraw your consent to any use of your Personal Data as set out in this Privacy Statement; or
(c) would like to obtain access or make corrections to your Personal Data records,
please contact our data protection officer as follows: dpo@smrt.com.sg
7.2 Please note that if your Personal Data has been provided to us by a third party (e.g. a recruitment agency), you should contact such party directly to make any queries, feedback, and access and correction requests to us on your behalf.
7.3 If you withdraw your consent to any or all collection, use, and/or disclosure of your Personal Data, depending on the nature of your request, we may not be in a position to continue to provide our services to you and/or administer any contractual relationship in place. Such withdrawal of consent may also result in the termination of any agreements with you, and your being in breach of your contractual obligations or undertakings. Our legal rights and remedies in such event are expressly reserved. Please also note that withdrawing consent does not affect our right to continue to process Personal Data where such processing without consent is permitted or required under applicable laws.
8.1 This Privacy Statement shall be governed in all respects by the laws of Singapore.