1.         Introduction

1.1.         In line with its aim to comply with the requirements of the Personal Data Protection Act 2017 (“PDPA”) and to maintain the highest standards of confidentiality with respect to the personal data of our guests, visitors, members, customers or affiliates, this document sets out the Personal Data Policy of the SEASOFT (the “Club”).

1.2.         The purpose of the PDPA is to govern the collection, use and disclosure of personal data by organisations in a manner that recognises both the right of individuals to protect their personal data and the need for organisations to collect, use or disclose personal data for purposes that a reasonable person would consider appropriate in the circumstances.

1.3.         This Personal Data Policy applies to all information collected by the SEASOFT from our guests, visitors, members, customers or affiliates.

1.4.         Nothing in this Personal Data Policy is intended to derogate from any contract that you have entered into with the SEASOFT. 

1.5.         For the purpose of this policy, the terms “we”, “us” or “our” shall, unless otherwise indicated, refer to the SEASOFT.  

 2.         What is personal data?  

2.1.         Personal data is personal information, whether true or not and whether in electronic or other form, about an individual who can be identified :

2.1.1.     from that data; or

2.1.2.     from that data and other information to which we have access to or are likely to have access to.

2.2.         Examples of personal data are your name, address, NRIC number or FIN number, photograph or video image, telephone number and email address.

2.3.         We will do our best to ensure that your personal data that we collect is accurate. However, we do encourage you to provide us with an update of any change in your personal particulars as soon as possible. 

 3.         When is personal data collected from you?  

3.1.         When you visit the SEASOFT and attend our events or respond to our marketing campaigns.

3.2.         When you provide feedback or interact with the SEASOFT's customer service officers e.g. via meetings or emails.  

3.3.         When you agree that we contact you.

3.4.         When you agree to be included in a mailing list.

3.5.         When you take part in any of the SEASOFT’s contests, surveys or promotions.

3.6.         In certain situations and with your consent, we may also obtain your personal data from third parties.

3.7.         When you access our website.

3.8.         When you provide the personal data of your family members or friends for purposes connected with your custom of, visit to or employment with the SEASOFT. 

4.         What is the information collected or used for?  

4.1.         To maintain a register of our members.

4.2.         To facilitate the use of our facilities and services and participation in our activities.

4.3.         To respond to your requests and queries.

4.4.         To communicate with you.

4.5.         To enforce our rules and regulations, contractual and legal rights and obligations.

4.6.         To send you information, promotions, updates and marketing and advertising material in relation to the facilities, services and activities offered by the SEASOFT and our affiliates.

4.7.         To publicise events and activities of the SEASOFT in our publications.

4.8.         From time to time, to conduct contests, surveys or promotions.

4.9.         To maintain an appropriate level of security in the SEASOFT and its premises.

4.10.      To comply with the law, any requests from law enforcement and regulatory officials, or orders of court.

4.11.      Towards any other purpose of use for which we have obtained your consent, express or implied.

5.         Is your consent required and can it be withdrawn? 

5.1.         We will endeavour to obtain your consent to collect, use and disclose your personal data prior to or at the time we collect it. However, in certain situations you will be deemed to have consented to the provision of your personal data, e.g. where you provide your personal data voluntarily.

5.2.         You may at any time give us reasonable written notice of the withdrawal of your consent to collect, use or disclose your personal data. Within a reasonable time after we receive the notice of withdrawal of your consent, we will inform you of the consequences of your withdrawal of consent and when it will take effect. 

6.         Can I get access to or correct my personal data? 

6.1.         Your right to view your personal data is limited to your personal data only. We are not permitted to reveal any personal data about any other individual to you. We reserve the right to refuse access to your personal data if it will reveal or lead to the revelation of another individual’s personal data, cause harm to you or another individual or is contrary to the national interest.

6.2.         You can submit a update to correct your personal data which we have collected and stored. 

7.         Is my personal data secure? 

    7.1.         The SEASOFT makes every effort to maintain the highest standards of confidentiality and security of your personal data. To this end, we have internal policies and procedures in place to ensure that your personal data is kept secure. These include the following:  

    Restricting access to your personal data;

    7.2.         Conducting regular briefings and trainings for our staff in relation to our data protection policies;

    7.3.         Imposing confidentiality obligations on our staff;

    7.4.         Conducting regular audits of our data protection policies; and 

    7.5.         Devising procedures that will be implemented in the event of a breach of security.

    8.         How long do you retain my personal data?

    8.1.         The SEASOFT will retain your personal data for as long as the purpose for which your personal data was collected is still being served and as long as it is necessary for legal or business purposes.