PDPA

Overview

This overview provides information on how Arpanam Pte Ltd manages your personal information under the Personal Data Protection Act 2012.
We are committed to treat all personal data in accordance with the relevant data protection laws of Singapore.

DATA PROTECTION POLICY

We at Arpanam take our responsibilities under Singapore's Personal Data Protection Act 2012 (the "PDPA") seriously. We also recognise the importance of the personal data you have entrusted to us and are committed to properly manage, protect and process your personal data.
This Data Protection Policy is designed to assist you in understanding how we collect, use, disclose and/or process the personal data you have provided to us, as well as to assist you in making an informed decision before providing us with any of your personal data.
If you, at any time, have any queries on this policy or how we may manage, protect and/or process your personal data, please contact our Data Protection Officer at: 

Arpanam Events & Performance Venue
Tel: +65 9017 8014 
Email: dpo@arpanam.com.sg

Office address
486A Serangoon Road, Level 2, Singapore 218151
Operating hours
8.45am to 9pm, Mondays to Fridays, excluding Public Holidays.

1. INTRODUCTION TO THE PDPA

1.1 “Personal Data” is defined under the PDPA to mean data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access. Common examples of personal data could include names, identification numbers, contact information, medical records, photographs and video images.

1.2 We will collect your personal data in accordance with the PDPA. We will notify you of the purposes for which your personal data may be collected, used, disclosed and/or processed, as well as obtain your consent for the collection, use, disclosure and/or processing of your personal data for the intended purposes, unless an exception under the law permits us to collect and process your personal data without your consent.

2. PURPOSES FOR COLLECTION, USE, DISCLOSURE AND PROCESSING OF PERSONAL DATA

2.1 The personal data which we collect from you may be collected, used, disclosed and/or processed for various purposes, depending on the circumstances for which we may/will need to process your personal data. You can see full details of the purposes of collection, use and disclosure of your personal data (collectively, the “Purposes”) on the Collection, Use and Disclosure page. As the purposes for which we may/will collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear in the Collection, Use and Disclosure page. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of your personal data without your consent is permitted by the PDPA or by law.

2.2 In order to conduct our business operations smoothly, we may also be disclosing the personal data you have provided to us to our third party service providers, agents and/or our affiliates or related corporations, and/or other third parties whether sited in Singapore or outside of Singapore, for one or more of the above-stated Purposes. Such third party service providers, agents and/or affiliates or related corporations and/or other third parties would be processing your personal data either on our behalf or otherwise, for one or more of the above-stated Purposes.

2.3 Generally all your personal data will be processed in Singapore. In certain situations, we may transfer your personal data to a country outside of Singapore for the above Purposes as may be required on a need to know basis. In such an event, we will ensure that the receiving entities are bound by laws or contractual obligations for the protection of your personal data to a standard comparable to the Singapore PDPA.

3. SPECIFIC ISSUES FOR THE DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES

3.1 We respect the confidentiality of the personal data you have provided to us.

3.2 In that regard, we will not disclose your personal data to third parties without first obtaining your consent permitting us to do so. However, please note that we may disclose your personal data to third parties without first obtaining your consent in certain situations, including, without limitation, the following:

a. cases in which the disclosure is required or authorised based on the applicable laws and/or regulations;

b. cases in which the purpose of such disclosure is clearly in your interests, and if consent cannot be obtained in a timely way;

c. cases in which the disclosure is necessary to respond to an emergency that threatens the life, health or safety of yourself or another individual;

d. cases in which the disclosure is necessary for any investigation or legal proceedings;

e. cases in which the personal data is disclosed to any officer of a prescribed law enforcement agency, upon production of written authorisation signed by the head or director of that law enforcement agency or a person of a similar rank, certifying that the personal data is necessary for the purposes of the functions or duties of the officer;

f. cases in which the disclosure is to a public agency and such disclosure is necessary in the public interest; and/or;

g. where such disclosure without your consent is permitted by the PDPA or by law.

3.3 The instances listed above at paragraph [3.2] are not intended to be exhaustive. For more information on the exceptions, you are encouraged to peruse the Second, Third and Fourth Schedules of the PDPA which is publicly available at https://sso.agc.gov.sg.

3.4 Where we disclose your personal data to third parties with your consent, we will employ our best efforts to require such third parties to protect your personal data.

4. REQUEST FOR ACCESS AND/OR CORRECTION OF PERSONAL DATA

4.1 You may request to access and/or correct the personal data currently in our possession or under our control by contacting us.

4.2 For a request to access personal data, we will provide you with the relevant personal data 30 calendar days from such a request being made.

4.3 For a request to correct personal data, we will:

a. correct your personal data as soon as practicable after the request has been made unless we have reasonable grounds not to do so; and

b. subject to paragraph [4.4], we will send the corrected personal data to every other organisation to which the personal data was disclosed by Arpanam within a year before the date the correction was made, unless that other organisation does not need the corrected personal data for any legal or business purpose.


4.4 Notwithstanding paragraph [4.3(b)], we may, if you so consent, send the corrected personal data only to specific organisations to which the personal data was disclosed by us within a year before the date the correction was made.

4.5 We will also be charging you a reasonable fee for the handling and processing of your requests to access your personal data.

5. REQUEST TO WITHDRAW CONSENT

5.1 You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control by contacting us.

5.2 If you withdraw your consent for your personal data to be used for marketing purposes, we will process your request for such withdrawal of consent and will thereafter cease to use and/or disclose your personal data for marketing purposes within 30 calendar days of your request.

5.3 However, if you request to withdraw your consent for us to use your personal data for matters related to your account, this will affect our ability to provide you with the services or experiences booked with us, including preventing us from processing your booking. In this regard, it may mean that we will not be able to continue with your existing relationship with us and/or the contract you have with us will have to be terminated.

6. ADMINISTRATION AND MANAGEMENT OF PERSONAL DATA

6.1 We will take reasonable efforts to ensure that your personal data is accurate and complete, if your personal data is likely to be used by Arpanam to make a decision that affects you, or disclosed to another organisation. However, this means that you must also update us of any changes in your personal data that you had initially provided us with. We will not be responsible for relying on inaccurate or incomplete personal data if you did not update us of the changes in your personal data.

6.2 We will also put in place reasonable security arrangements to ensure that your personal data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorised access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data. However, we cannot assume responsibility for any unauthorised use of your personal data by third parties due to factors beyond our control.

6.3 We will also put in place measures such that your personal data in our possession or under our control is destroyed and/or anonymised as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes.

7. COMPLAINT PROCESS

7.1 If you have any complaint or feedback about how we are handling your personal data or complying with the PDPA, please contact our Data Protection Officer at:

Arpanam Events & Performance Venue
Tel: +65 9017 8014
Email: dpo@arpanam.com.sg 

Office address
486A Serangoon Road, Level 2, Singapore 218151
Operating hours
8.45am to 9pm, Mondays to Fridays, excluding Public Holidays.

7.2 Where it is an email or a letter through which you are submitting a complaint, your indication at the subject header that it is a PDPA complaint would assist us in attending to your complaint speedily by passing it on to the relevant staff in our organisation to handle. For example, you could insert the subject header as “PDPA Complaint”.

7.3 We will certainly strive to attend to any complaint or grievance that you may have speedily and fairly.

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 and can be viewed at https://www.Arpanam.com.sg/en/pdpa/

8.3 You are encouraged to visit the above 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 23rd August 2019

Collection, Use and Disclosure

The Personal Data Protection Act

The Personal Data Protection Act or “PDPA” governs the collection, use and disclosure of personal data by private organisations. It contains various obligations relating to the Do-Not-Call Registry (“DNC Obligations”) and the protection of personal data (“DP Obligations”). The DNC Obligations came into force on 2 January 2014 while the DP Obligations came into force on 2 July 2014.

Useful Links
PDPC website
DNC Registry website 

If you are an individual and you book or have booked an event or experience with Arpanam Pte Ltd, your personal data will be collected, used and/or disclosed in the course of your dealing with Arpanam. Please see the section on Purposes of Use of Personal Data for related information.

If you are a corporation and you book or have a booking / experience with Arpanam, you may be collecting and passing individual’s personal data to/from Arpanam. Please see the section on PERSONAL DATA PROTECTION COMPLIANCE UNDERTAKINGS (BY CORPORATE PROSPECT/ACCOUNT) for related information. 

PURPOSES OF USE OF PERSONAL DATA

Marketing
If you consent to marketing, Arpanam may contact you to inform you about Arpanam or Arpanam related events, services, special offers or other information which may be of interest to you.
You can change your mind on the consent anytime. If you subsequently decide that you do not wish to receive marketing materials from us, all you need to do is to contact us.
Alternatively, if you decide that you would like to receive the above marketing materials, you can also contact us to do so.

Administration and Servicing
In order to carry out our business, process, administer and/or manage your relationship, and/or account with Arpanam Pte Ltd, we will have to collect, use and disclose your personal data.
1. Personal Data
Such personal data may include information or data provided by you or other parties in the application forms, other forms or from other sources, including existing data in our record and/or to be collected in the future.
2. Purposes
Such personal data will be collected, used, disclosed and/or processed by Arpanam for the purpose(s) of:
a. processing event / experience related bookings and to recommend events / services / experiences based on your interests and choices, where applicable;

b. processing restaurant / bar reservations

c. processing feedback in which contact information is solicited
      i. carrying out your instructions or responding to any enquiries by you
      ii. assessing and processing your feedback

d. administration of your account which may include but is not limited to:
      i. maintenance of your account
      ii. performing or updating transactions on your account
      iii. carrying out your instructions or responding to any enquiries by you

e. dealing in any matters relating to your bookings with us (including the mailing of correspondence and other documents to you which may disclose certain personal data about you on the envelopes/mail packages);

f. managing your relationship with Arpanam;

g. compiling statistics or conducting research for company or industry exercises and studies, to design, review or improve our services and experiences;

h. compliance monitoring and audit reviews; due diligence checks, other screening activities and/or risk management procedures put in place by Arpanam and/or the industry;

i. complying with applicable laws, regulations, rules, guidelines, schemes or directions imposed by any regulator, government body, statutory body, law enforcement agency or dispute resolution body;

j. providing general information on service enhancements, which are relevant to your requests or choices;

k. investigating fraud, misconduct, any unlawful action or omission, whether relating to your policy, your claims or any other matter relating to your policy, and whether or not there is any suspicion of the aforementioned; and

l. archiving, backing-up or destroying personal data.

Some of these purposes may apply or continue to apply after your relationship, policy and/or account with Arpanam has ended or is no longer in force or active.

3. Disclosure
Such personal data of yours will be disclosed by:

a. Arpanam to other Arpanam assets in Singapore and elsewhere in the world and between each of them; and/or

b. Arpanam (or Arpanam assets) to third party service providers, suppliers, agents, reinsurers, fund managers or intermediaries, as and when relevant or necessary for the purposes as described above.

Without limiting the generality of the foregoing, Arpanam may also disclose such personal data of yours to the following parties for the following purposes:

      i. To third party vendors engaged by Arpanam to perform processes required for the administration of your account / booking (e.g. data entry, printing and despatch of documents, administration etc.), for data analytics or to perform processes required to send marketing material or messages to you, where applicable;

      ii. To related companies or third-party vendors engaged by Arpanam to store and maintain our data and documents (including storage for business recovery purposes);

      iii. To any regulatory, government and statutory body to comply with applicable laws or regulation or upon their valid request; and

      iv. To related company or regional office or head office to comply with company policies and procedures or upon their valid request.

Neither Arpanam nor any of its officials shall be liable for any loss or damage suffered by you or any user as a result of any disclosure of any personal data which you have consented to Arpanam and/or any of its officials disclosing.

4. Consent
By booking an event or experience with Arpanam, you consent to Arpanam and/or Arpanam group of companies:

a. collecting, using, disclosing and/or processing the personal data mentioned above for the purposes as described above; and

b. transferring the personal data mentioned above to other Arpanam assets, its third party service providers, suppliers, agents, or intermediaries where such third party service providers, suppliers, agents, or intermediaries are sited (whether in Singapore or outside of Singapore), for the purposes as described above.

5. Consequence of withdrawing consent to the collection, use and disclosure of personal data for administration and servicing

      You may withdraw your consent for Arpanam to collect, use or disclose your personal data by giving Arpanam reasonable notice so long as there are no legal or contractual restrictions preventing you from doing so. For example, you may withdraw your consent for your personal data to be used for marketing purposes. This withdrawal will not affect Arpanam’s ability to provide you with the services or experiences that you asked for or have with Arpanam.

      However, if you withdraw your consent for Arpanam to collect, use or disclose your personal data, Arpanam will be unable to process, administer and/or manage your relationship and/or account with us. To proceed with such withdrawal, you will be required to surrender or terminate all your accounts with Arpanam.  

PERSONAL DATA PROTECTION COMPLIANCE UNDERTAKINGS (BY CORPORATE PROSPECT/ACCOUNT)

1. The Company hereby represents, undertakes and warrants to Arpanam Pte Ltd (“Arpanam”) that:

a. for any personal data of individuals that the Company will be or is disclosing to Arpanam, whether directly or through an intermediary, that the Company would have prior to disclosing such personal data to Arpanam obtained the appropriate consent from the individuals whose personal data are being disclosed, to:

      i. permit the Company to collect, use and/or disclose the individuals’ personal data to Arpanam for the purpose of booking the Company’s event or experience with Arpanam, including the processing of the individuals’ personal data for administrative purposes, and for statistical, compliance, audit and regulatory purposes;

      ii. permit Arpanam and Arpanam assets (in Singapore and/or elsewhere) to collect, use, disclose and/or process the individuals’ personal data for the purpose of administration of the Company’s booking / experience and/or account(s) with Arpanam, including but not limited to the processing of the individuals’ personal data for administrative purposes, and for statistical, compliance, audit and regulatory purposes; and

      iii. permit Arpanam to disclose the individuals’ personal data to Arpanam assets, third party service providers, suppliers, reinsurers or intermediaries, whether located in Singapore and/or elsewhere, for the purposes as described above;

b. any personal data of individuals that the Company will be or is disclosing to Arpanam are accurate. Further, the Company shall give Arpanam notice in writing as soon as reasonably practicable should it be aware that any such personal data has been updated and/or changed after such disclosure;

c. it shall give Arpanam notice in writing as soon as reasonably practicable should it be aware that any individual above has withdrawn such consent as set out at sub-clause (a); and

d. it shall otherwise assist Arpanam to comply with the Personal Data Protection Act 2012 and all subsidiary legislation related thereto.

2. Notwithstanding anything to the contrary, the Company undertakes to indemnify and at all times hereafter to keep Arpanam and Arpanam group of companies (together with their respective officers, employees and agents) (each an “Injured Party”) indemnified against any and all losses, damages, actions, proceedings, costs, claims, demands, liabilities (including full legal costs on a solicitor and own client basis) which may be suffered or incurred by the Injured Party or asserted against the Injured Party by any person or entity (including Company, his/her agents) whatsoever, in respect of any matter or event whatsoever arising out of, in the course of, by reason of or in respect of:

a. any breach of any of the provisions in this clause; and/or

b. any action or omission by the Company, that causes Arpanam and/or any of Arpanam group of companies to be in breach of the PDPA. 

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