PERSONAL DATA PROTECTION POLICY
Mandai Park Holdings Pte Ltd (“MPH”, “Company”, “we”, “our”, or “us), its subsidiaries, related companies and affiliates (collectively referred to as "MPH Group") recognize the importance of an individual’s privacy and personal data (as defined below).
This data protection policy ("Data Protection Policy") outlines how the MPH Group manages personal data (“Personal Data”) as defined by, and which is subject to, the Personal Data Protection Act 2012 in Singapore (the "Act").
1.1 We are aware of the revised Advisory Guidelines on the Act for NRIC and other National Identification Numbers that the Personal Data Protection Commission (“PDPC”) issued on 31 August 2018, and we are in the midst of reviewing our relevant websites, systems, platforms and policies to adhere to these guidelines.
1.2 We seek your understanding that we are continuing with the collection and use of NRIC or other National Identification Numbers (which consists of Birth Certificate numbers, Foreign Identification Numbers, Work Permit numbers, and passport numbers), while we enhance our websites, systems, platforms and policies. We expect to effect these changes within the timeframe prescribed by the PDPC.
1.3 Please be assured that we will safeguard your Personal Data under our care.
2. Personal Data
2.1 We will or may collect, use, disclose and/or process Personal Data about you. The purposes for which we will collect, use, disclose and/or process such Personal Data are set out below in paragraph 5.
2.2 Personal Data refers to any data, whether true or not, about an individual who can be identified from that data; or data and other information to which the MPH Group has or is likely to have access to including existing data in our records which you have provided us in any forms you may submitted to us or via any form of interaction with us.
2.3 If you provide the Personal Data of anyone other than yourself (including your family members), you warrant that you have informed him/her of the purposes for which you are providing their Personal Data to us (as set out in paragraph 5 or otherwise notified to you) and that he/she has consented to your disclosure of his/her Personal Data to us for those purposes.
2.4 You must ensure that all Personal Data that you provide (whether such data relates to you or to other persons) is true, accurate and complete and promptly notify us of any changes to such Personal Data.
2.5 Examples of Personal Data which you may provide us include but are not limited to the following:
b) NRIC/Passport/Other Identification Number;
c) Telephone Number;
d) Mailing address, country of residence;
e) Email address;
f) Social media account user name;
g) Profile details such as your interests;
h) Date of birth, gender;
i) Photograph; and/or
j) Credit card number/bank detail.
3. Collection of Personal Data
3.1 You can generally use and browse our website without disclosing your Personal Data to us (however, please see paragraph 5 below), except where such disclosures may be necessary to allow us to respond to your requests or in cases where you contact us directly.
3.2 MPH Group may collect Personal Data, directly or indirectly, from an individual or authorized representative of an individual in a number of ways, such as when:
a) you use our services provided through online platforms and other technology platforms (such as our membership portals, e-stores);
b) you apply for a job with us;
c) you subscribe to our alerts or newsletters;
d) you sign up as member, volunteer, ambassador or animal adopter in any of our parks;
e) you participate in our tours, events, campaigns, programmes, marketing or promotional events or in contests;
f) you share your content in any format (such as your posts, audio, photos or videos, etc,), including via photography kioks where your photos or videos are taken, etc, with us on request or when we take photos, videos or other media at locations accessible to visiting public in our parks or on our premises;
g) you participate in programmes organized by third parties for visits to our premises (eg. third party platforms such as school / education website portals for public educational programmes or camps);
h) you use our customer services at any of our parks (such as mobility aid rental service, baggage deposit services);
i) you enter or move through our premises (including through the issuance of visitor passes, conducting identification checks);
j) you participate in our public programmes such as the Zoo Explorer Camp;
k) you communicate with us in relation to any enquiry, request or feedback;
l) you participate in our interviews, market research or surveys; and/or
m) any other manner of collection reasonably related to the above.
4. Consent of Collection of Personal Data
4.1 By submitting information to us, communicating with us, or signing up for any products and services offered by any member of the MPH Group, you agree and consent to MPH Group collecting, using, disclosing and sharing amongst ourselves your Personal Data, and disclosing such Personal Data to our authorised service providers and relevant third parties in the manner set forth in this Data Protection Policy.
4.2 When you provide MPH Group with any Personal Data relating to a third party (such as information of your dependents, spouse, children and/or parents), you represent and warrant that you are authorized to do so and/or the consent of that third party has been obtained for the collection, use and disclosure of the Personal Data by us for any of the purposes listed herein.
5. Purpose and Use of Personal Data
5.1 Generally, MPH Group collects, uses and discloses your Personal Data for the following purposes:-
a) to communicate with you on our and/or our partners’ products and services, announcements, promotions or contests (including updates on our parks and facilities, membership programme features, etc);
b) to respond to your enquiries, requests, feedbacks or products and services improvements;
c) to process and administer your transactions with us (such as processing gift voucher purchases, handling and return of large baggage deposit services, rental and retrieval of mobility aids, handling of lost and found items notifications or return);
d) to process your application for membership, volunteer, ambassador or job;
e) to verify your identity;
f) to facilitate the running of our parks, premises and the provision of products and services to you, including to manage the administrative and business operations of our companies and comply with our internal policies and procedures;
g) to execute, administer and manage your visit to, or events you participate in at, our premises including administration and liaising with organisations which arrange for your visit (such as education executives for school visits, Zoo Explorer camps or other public programmes);
h) to facilitate business asset transactions such as asset sales, mergers or acquisitions involving any of our companies;
i) to obtain your feedback or participation in surveys, market research and/or analysis for statistical, profiling or other purposes to enable us to customize, review, improvise and develop our products and services, to understand customer preferences, behaviour and market trends;
j) to manage the safety and security of our premises and services including but not limited to conducting security clearances and carrying out CCTV surveillance, granting or refusing admission to our premises and tracking your movement on our premises;
k) to provide media announcements or responses;
l) to response to any claims, actions or proceedings and/or to safeguard and enforcing our contractual and legal rights and obligations;
m) to manage and prepare any reports regarding incidents or accidents;
n) to comply with any applicable rules, law and regulations, codes of practice or guidelines as well as to assist in investigations and law enforcement by relevant authorities; and/or
o) any other purpose reasonably related to any of the above.
5.2 For any other purpose(s) not set out herein, MPH may notify and seek your further consent in accordance with the requirements of the Act before using your Personal Data for that other purpose(s), such as when you are asked to provide your Personal Data before you participate in a contest, or when we ask you to share your photos (or media) with us for use on our websites, social media accounts, or for developing our online and public profile and community.
6. IP Addresses
6.1 When you use or access our websites, we may collect and store information about your computer (including your IP address, operating system and browser type) for the purposes of system administration.
7.2 Should you wish to disable the cookies of our websites, you may do so by changing the setting on your browser. However, you may not be able to enter certain part(s) of our websites.
8. Third Party Websites
9. Our websites may, from time to time, contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please ensure you carefully read and review the privacy policies of these websites before you submit any Personal Data to these websites.
10. Disclosure of Personal Data
10.1 MPH Group will take reasonable steps to secure your Personal Data against any unauthorized access, improper use or disclosure and ensure that access to your Personal Data is limited to persons whom we reasonably believe require access for effective delivery of our services to you for the purposes listed herein (where applicable) or any other purpose as consented by you.
10.2 Subject to the provisions of any applicable law and in order to carry out the purposes listed herein, we may share or disclose your Personal Data to the following third parties:
a) related corporations and affiliates of MPH Group;
b) agents, contractors or third party service providers (whether in Singapore or elsewhere) contracted by MPH Group to provide operational services such as courier services, insurance, telecommunications, information technology, payment, payroll, processing training, market research, storage, archival, customer support investigation services or other services;
c) organisations which arrange for your visit to our parks or premises (such as education executives organizing school visits or public programmes);
d) banks, credit card companies, secretarial agents, billing organizations and their respective service providers;
e) our business associate or partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions which may include any merger, acquisition or asset sale;
f) our professional advisors such as lawyers, auditors, accountants or consultants;
g) law enforcement agencies, relevant government ministries, regulators, statutory boards or authorities in compliance with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and/or
h) any other person to whom you authorize us to disclose your Personal Data to.
11. Withdrawal of Consent, Access and Correction of Personal Data
11.1 You may write to our Personal Data Protection Officer at the address provided below if you:
c) would like to obtain access and make correction/update to your Personal Data in our record
Data Protection Officer
Address: 80 Mandai Lake Road Singapore 729826
Email: [email protected]
11.2. Please note that for any Personal Data provided to us by a third party (e.g. your company or a recruiter or a parent), you should inform such party to write to MPH Group for any queries, feedback, complaints, and access and correction requests on your behalf.
12.1 Retention Period: Generally, MPH will retain your Personal Data up to a maximum period of seven (7) years or until retention of such data is no longer necessary for any legal or business purposes.
12.3 MPH Group reserves the right to modify and update this Data Protection Policy from time to time to ensure that this Data Protection Policy is consistent with any changes to the laws and regulations applicable to MPH Group and also the developments of our products and services. All communications, transactions and dealings with us shall be subject to the latest version of this Data Protection Policy in force at the time.
12.4 This Data Protection Policy shall be governed in all respects by the laws of Singapore.