Personal Data Protection Policy

Personal Data Protection Policy

Personal Data Protection is important to us

Protection of your Personal Data is important to us. This Personal Data Protection Policy (“Policy”) outlines how we manage the Personal Data we hold.

We respect the confidentiality of Personal Data and privacy of individuals and are committed to complying with the Singapore Personal Data Protection Act (Act 26 of 2012) (“PDPA”) and other applicable data protection laws. Please read this Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data.

You agree and consent to us, collecting, using, storing and processing your Personal Data as data controllers, and disclosing such Personal Data to relevant third parties as data controllers and/or data processors as appropriate in the manner set forth in this Policy. By accessing and using the website of the Cradle n Care Pte Ltd, interacting with us, or providing your data to us, and subject to your rights at law, you accept and agree to these terms and conditions without any limitation or qualification.

This Policy supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your Personal Data, and your consents herein are additional to any rights which any member of the Cradle n Care Pte Ltd may have at law to collect, use or disclose your Personal Data. This Policy does not affect any rights which we may have at law in connection with the collection, use or disclosure of your Personal Data.

1. Your Personal Data

1.1. “Personal Data” refers to any data or information about you from which you can be identified either (a) from that data; or (b) from that data and other information to which we have or are likely to have access. Examples of such Personal Data which you may provide us include:

a) your name, NRIC number, passport number 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 form you may have submitted to us, or in other forms of interaction with you;

b) Information about your use of our websites and services, including cookies, IP addresses, subscription account details and membership details;

c) Your payment related information, such as your bank account or credit card information, and your credit history.

2. Collection of Personal Data
2.1. Generally, we collect your Personal Data in the following ways:

a) when you submit forms relating to any of our products or services, or submit any online queries;

b) when you register for or use any of our services on websites owned or operated by us or when you register as a member of websites owned and/or operated by us;

c) when you interact with our customer service officers or any of our staff, for example, via face-to- face meetings, telephone calls, letters, online forms, reservation chat, social media platforms and emails;

d) when you use or purchase our services or products;
e) when you establish any online accounts with us;
f) when you request that we contact you;
g) when you respond to our request for additional Personal Data; h) when you ask to be included in an email or other mailing list; i) when you respond to our promotions and other initiatives;

j) when you respond to our market surveys;
k) when you submit your Personal Data to us for any other reason; and l) when you browse our website.

2.2. We may monitor or record phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation, identity verification purposes, feedback, respond to your queries and requests and resolve complaints and other related purposes.

2.3. If you provide Personal Data of a third party (e.g. information of your dependent, spouse, children and/or parents) to us, you represent and warrant that the consent of that third party has been obtained for the collection, use and disclosure of the Personal Data for the purposes set out above.

3. Use and Disclosure of Personal Data

3.1. Our business is to understand and meet your needs and provide you with the products and services that you require. To do this effectively, we need to collect a range of Personal Data about you.

3.2. In general, we use and disclose your Personal Data for the following purposes: a) to provide you with the products or services that have been requested;

b) to help us review, develop, improve, manage the delivery of and enhance our products and services, including analysing future customer needs, conducting market research and data analytics;

c) to communicate with you and respond to your queries, requests and complaints;
d) to provide ongoing information about our products and services which may be of interest to you; e) to handle disputes and conduct and facilitate investigations and proceedings;

f) to protect and enforce our contractual and legal rights and obligations;

g) to prevent, detect and investigate crime, including fraud and money-laundering, and to analyze and manage other commercial risks;

h) to manage our infrastructure and business operations and to comply with internal policies and procedures; and

i) to comply with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities.

3.3. In addition, we may use and disclose your Personal Data for the following purposes, depending on the nature of our relationship with you:

a) If you have a membership account with us:

(i) to process your application for the account; (ii) to maintain your account with us;

(iii) to verify your personal particulars and process payment requests in relation to provision of the services which you may be entitled to or which you may have requested for;

(iv) to provide you with the goods and services which you have signed up for;

(v) to communicate with 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;

(vi) to resolve complaints and handle requests and enquiries;

(vii) to conduct market research for statistical, profiling and statistical analysis for the improvement of services provided to you; and

(viii) to process your Personal Data in relation to any of the purposes stated above.

b) If you download or use any of our mobile applications (apps):

(i) to process your application for subscription services if they are provided in the apps; (ii) to maintain your account with us;

(iii) to verify and process your personal particulars and process payment requests in relation to provision of goods and services connected to the app;

(iv) to provide you with the goods and services which you have signed up for;

(v) to communicate with you 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;

(vi) to resolve complaints and handling requests and enquiries;

(vii) to conduct market research for statistical, profiling and statistical analysis for the improvement of services provided to you; and

(viii) to process your Personal Data in relation to any of the purposes stated above.

3.4. The above purposes are not exhaustive, we may collect, use and disclose your Personal Data for additional purposes which you will be notified of, in accordance with applicable terms and conditions.

3.5. When you apply for or hold a co-brand product which is offered jointly by us and our co-brand partner(s), we may also collect, use and disclose your Personal Data for the purpose of sharing your Personal Data with the co-brand partners for offering, marketing and promoting to you any products, services, offers or events which the co-brand partner thinks may be of interest to you.

3.6. Where you have provided us with specific consents, we may also use and disclose your Personal Data for the following purposes:

a) providing services and extending benefits to you, including promotions, loyalty and reward programs, and other information on our products, services, offers or promotions which may be of interest to you;

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 products and services, whether by us or third parties;

c) administering contests, competitions and conducting lucky draws, including, where necessary, announcing the results of these contests, competitions and lucky draws and identifying and contacting the winners; and

d) conducting market research to understand and determine customer locations, preferences and demographics for us to develop special offers, promotional and/or marketing programs.

3.7. In relation to particular products or services or in your interactions with us, we may also notify or 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.

3.8. Your Personal Data will be protected and kept confidential, but subject to the provisions of any applicable law, your Personal Data may, depending on the products or services concerned, be disclosed to the following third parties:

a) our joint venture/ alliance partners;

b) our agents, contractors, third party service providers and specialist advisers who have been contracted to provide us with administrative, financial, research, operational or other services, such as telecommunications, information technology, payment, payroll, processing, training, market research, storage and archival;

c) any third party business partners who offer goods and services or sponsor contests or other promotional programs, whether in conjunction with us or not;

d) insurers or insurance investigators and credit providers;

e) the Credit Bureau, or in the event of default or disputes, any debt collection agencies or dispute resolution centres;

f) 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) involving the Cradle n Care Pte Ltd;

g) our professional advisors such as our auditors and lawyers;

h) relevant government regulators or authority or law enforcement agency to comply with any laws or rules and regulations imposed by any governmental authority;

i) anyone to whom we transfer or may transfer our rights and obligations; j) banks, credit card companies and their respective service providers; and

k) any other party as may be consented to by you, as specified by that individual or in the applicable contract.

We require that organisations outside the Cradle n Care Pte Ltd which handle or obtain Personal Data as service providers to us acknowledge the confidentiality of this data, undertake to respect any individual’s right to privacy and comply with the PDPA. We also require that these organisations use this information only for our purposes and follow our reasonable directions with respect to this information.

4. Keeping Your Personal Data Accurate and Up-To-Date

4.1. We endeavour to ensure that all Personal Data we have about you is accurate and up-to-date. We understand that this information changes frequently with changes of address and other personal circumstances. We encourage you to contact us as soon as possible to enable us to update any Personal Data we have about you. Incomplete or outdated Personal Data may result in our inability to provide you with products and services you have requested.

5. Telemarketing Policy

5.1. Our Telemarketing Policy relates only to individual users of Singapore telephone numbers and was developed to comply with the Do Not Call (“DNC”) provisions under the PDPA.

5.2. We aim to comply with the DNC provisions and your choices to receive promotional and marketing messages:

a) If you have registered your Singapore telephone number with the relevant Singapore DNC registers, we will not send you promotional and marketing messages via SMS, fax, calls and other means (as applicable) to your telephone number.

b) However, if you have previously consented to our sending you such messages to your Singapore telephone number(s), we will continue to do so until you withdraw such consent, regardless of your DNC nominations.

c) Also, if you currently have an existing, ongoing relationship with us, depending on the nature of that relationship, we may continue to send you promotional or marketing messages via SMS or fax

about products and services which are related to that ongoing relationship notwithstanding your registration with the DNC Registry, unless you opt-out of receiving such messages.

7. Third-Party Sites

7.1. Our website may contain links to other websites operated by third parties, such as our business partners. We are not responsible for the privacy practices of websites operated by third parties that are linked to our website. We encourage you to learn about the privacy policies of such third party websites. Once you have left our website, you should check the applicable privacy policy of the third-party website to determine how they will handle any information they collect from you.

8. Withdrawal of Consent

8.1. You may withdraw your consent given for any or all purposes set out in this Policy in writing by contacting us via email. If you withdraw your consent to any or all purposes and depending on the nature of your request, we may not be in a position to continue to provide our products or services to you. Without prejudice to the foregoing, you agree and acknowledge any withdrawal of your consents in accordance with the terms set out in this Policy will not affect any consent which you may have provided to us in respect of the use of your Singapore telephone number(s) for the receiving of marketing or promotional information.

9. Governing Law

9.1. This Privacy Policy and your use of this website shall be governed in all respects by the laws of Singapore.

10. Review of the Policy

10.1. This Policy will be reviewed from time to time by us. We may also from time to time update this Policy to take account of new laws and technology, changes to our operations and practices and the changing business environment. If you are unsure whether you are reading the most current version, please contact us.

10.1. In the event of any inconsistencies between the English version and other translations of this Policy, the English version shall prevail