Data Protection Policy
This Data Protection Policy outlines how your Personal Data will be managed by Directory-SG in compliance with the Personal Data Protection Act (“PDPA”) which strives to protect personal data of individuals.
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 our Data Protection Officer at:
Email: [email protected]
1. Personal Data
1.1. “Personal Data” under the PDPA, refers to data, whether true or not, about an individual who can be identified from that data; or from that data and other information to which the organisation has or is likely to have access.
1.2. Examples of such Personal Data may include names, identification numbers, contact information, medical records, employment records, photographs and video images.
2. Collection of Personal Data
2.1. when a telco submits residential subscriber’s information, including owner’s name, telephone number(s) and mailing address to Directory-SG, prior to July 2nd 2014;
2.2. when you submit any form, including but not limited to application, registration, declaration or other forms;
2.3. when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our products and services;
2.4. when you interact with our staff, including customer service officers, for example, via telephone calls (which may be recorded), letters, face-to-face meetings, social media platforms and emails;
2.5. when you interact with us via our websites, use services on our websites or register an account via our websites;
2.6. when you subscribe to our newsletters;
2.7. when you request that we contact you or request that you be included in an email or other mailing list;
2.8. when you respond to or participate in any of our promotions, contests or surveys;
2.9. when you submit an employment application or when you provide documents or information including your resume and/or CVs in connection with any appointment as an officer, director, representative or any other position;
2.10. when your images are captured by us via CCTV cameras while you are within our premises, or via photographs or videos taken by us or our representatives when you attend events at our premises;
2.11. when you are contacted by, and respond to, our sales representatives or our marketing representatives and customer service officers;
2.12. when we seek information about you and receive your Personal Data in connection with your relationship with us, including for our products and services or job applications, for example, from business partners, public agencies, your ex-employer, referral intermediaries and the relevant authorities; and/or
2.13. when you submit your Personal Data to us for any other reason.
3. Purposes for the Collection, Use and Disclosure of Your Personal Data
3.1. Directory-SG may collect, use and disclose your Personal Data for the following purposes:
a. responding to your queries, feedback or comments;
b. managing the administrative and business operations of Directory-SG and complying with internal policies and procedures;
c. facilitating business transactions;
d. requesting feedback or participation in surveys, as well as conducting market research and/or analysis for statistical, profiling or other purposes for us to design our products, understand customer behaviour, preferences and market trends, and to review, develop and improve the quality of our products and services;
e. matching any Personal Data held which relates to you for any of the purposes listed herein;
f. analysing and managing commercial risks;
g. managing the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances);
h. monitoring or recording phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes;
i. in connection with any claims, actions or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution), and/or protecting and enforcing our contractual and legal rights and obligations;
j. conducting investigations relating to disputes, billing or other issues;
k. 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 Directory-SG (including but not limited to responding to regulatory requirements, disclosing to regulatory bodies and conducting audit checks, due diligence and investigations); and/or
l. purposes which are reasonably related to the aforesaid.
3.2. In addition, Directory-SG collects, uses and discloses your Personal Data for the following purposes depending on the nature of our relationship:
a. If you are a contact person in any of Directory-SG’s customer base:
i. processing orders for Directory-SG’s products and services;
ii. providing customer service;
iii. order reconciliation and invoicing;
iv. creating and maintaining Directory-SG’s customer profiles in our system database;
v. administering debt recovery and debt management; and/or
vi. purposes which are reasonably related to the aforesaid.
b. If you are an employee, business partner, sole proprietor, director, agent, representative or authorised signatory of an organisation that is a customer of Directory-SG;
i. processing your order for Directory-SG’s products and services;
ii. facilitating the daily operation of our products and services and providing customer service and support (including but not limited to processing payments, transactions and refunds, resolving any technical difficulties, disputes or problems that you may encounter in connection with the use of our products and services and attending to your requests for any other products and services);
iii. facilitating your appointment as an authorised signatory;
iv. administering debt recovery and debt management;
v. administering rewards and benefits; and/or
vi. purposes which are reasonably related to the aforesaid.
c. If you are an employee, officer or owner of an external service provider or vendor outsourced or prospected by Directory-SG:
i. assessing your suitability as an external service provider or vendor for Directory-SG;
ii. managing project tenders and quotations, processing orders or managing the supply of goods and services;
iii. processing and payment of vendor invoices and bills;
iv. managing business operations and product development;
v. facilities management (including but not limited to maintaining the security of our premises); and/or
vi. purposes which are reasonably related to the aforesaid.
d. If you submit an application to us as a candidate for employment:
i. conducting interviews;
ii. processing your application (including but not limited to pre-recruitment checks involving your qualifications and facilitating interviews);
iii. obtaining employee references and for background screening;
iv. assessing your suitability for the position applied for;
v. facilities management (including but not limited to maintaining the security of our premises and recording entries and exists); and/or
vi. purposes which are reasonably related to the aforesaid.
3.3. Furthermore, where permitted under the Act, Directory-SG may also collect, use and disclose your Personal Data for the following:
a. providing or marketing additional products, services and benefits to you, including but not limited to special events and promotions;
b. matching Personal Data with other data collected for other purposes and from other sources (including but not limited to third parties) in connection with the provision, marketing or offering of products and services;
c. leads generation and management for marketing products and services;
d. administering and organising contests, lucky draws, promotional events, competitions and marketing campaigns, and personalising your experience at Directory-SG’s touchpoints;
e. communicating advertisements involving details of our products and services, special offers and rewards, either to users of our products and services generally, or which we have identified may be of interest to you;
f. conducting market research and surveys to enable us to understand and determine customer 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
g. purposes which are reasonably related to the aforesaid.
4. Disclosure of Personal Data
4.1. Directory-SG 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 entities or parties:
a. companies in the Directory-SG Group;
b. partners, vendors or third party service providers in connection with products and services offered ;
c. our professional advisers such as consultants, auditors and lawyers;
d. relevant government ministries, 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/or
e. any other party to whom you authorise us to disclose your Personal Data to.
5. Use of Cookies
5.1. Our site may use “cookies” for tracking and record keeping purposes so as to enhance user experience.
5.2. Cookies are small text files stored in your computing or other electronic devices which allow us to remember you. The cookies placed by our server are readable only by us, and cookies cannot access, read or modify any other data on an electronic device. All web-browsers offer the option to refuse any cookie, and if you refuse our cookie then we do not gather any information on you.
5.3. Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser. However, this may result in some functionalities of the site being affected.
6. Contacting Us – Feedback, Withdrawal of Consent, Access and Correction of your Personal Data
6.1. If you:
a. have any questions or feedback relating to your Personal Data or our Data Protection Policy;
b. would like to withdraw your consent to any use of your Personal Data as set out in this Data Protection Policy; or
c. would like to obtain access and make corrections to your Personal Data records, you can approach us via the following channels:
- Email: [email protected]
7. Governing Law
7.1. This Data Protection Policy and your use of this website shall be governed in all respects by the laws of Singapore.
8. Updates on Data Protection Policy
8.1. 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.
8.2. 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.
8.3. You are encouraged to visit our website from time to time to ensure that you are well informed of our latest policies in relation to personal data protection.
Last updated on May 15, 2020