THE ACTIVATION GROUP PERSONAL DATA PROTECTION POLICY
1. The Activation Group Pte Ltd (“The Activation Group”) respects your privacy and understands that your personal data is important to you. This The Activation Group Personal Data Protection Policy sets out how The Activation Group complies with the provisions of the Personal Data Protection Act 2012 of Singapore (“the PDPA”).
2. This Personal Data Protection Policy applies to https://www.theactivationgroup.com.sg/ and websites of The Activation Group’s affiliates, unless the websites of The Activation Group’s affiliates separately provide for their own respective personal data protection policies.
3. The Activation Group will post on its website at https://www.theactivationgroup.com.sg/ any changes to this Personal Data Protection Policy with the effective date of the revised policy, so as to ensure that you are kept up to date on the way The Activation Group collects, uses and discloses your personal data.
(I) Existing Data
4. For the avoidance of doubt, The Activation Group will continue to use personal data that has been collected before the data protection provisions of the PDPA came into effect on 2 July 2014 for the purposes for which the personal data was collected, unless the individual has withdrawn consent. For personal data collected after 2 July 2014, The Activation Group will notify and obtain the individual’s consent to the collection, use and disclosure of his or her personal data.
(II) Purposes of Data Collection
5. As defined in the PDPA, “personal data” 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. This includes unique identifiers (NRIC number, passport number) as well as any set of data (e.g. name, age, address, telephone number, occupation etc.), which when taken together would be able to identify the individual.
6. The Activation Group may from time to time collect personal data from individuals for purposes which include (but not limited to) the following:
6.1. Processing enquiries – if you make a Sales Enquiry or request for certain information, your personal data may be required; and
6.2. Processing job applications – if you apply for a job at The Activation Group or any of its worldwide offices, you will have to have provide your personal data.
7. When you interact with The Activation Group’s website, we may collect information on your IP address, your web browser and device, your interactions with The Activation Group’s website as well as your location information (broadly referred to as “usage data”). The collection of such usage data is for the purpose of allowing us to analyse the usage of our website so as to improve your online experience with us. However, such usage data does not cause an individual to be identified and is therefore not “personal data” for the purposes of the PDPA.
(III) Obtaining your Consent
8. Before we collect, use or disclose your personal data, we will notify you of the purpose and obtain your consent. Such consent will be validly obtained and may be either expressly given or deemed to have been given.
9. Each time an individual uses our website’s Sales Enquiry form and voluntarily provide his or her personal data, the individual is deemed to have consented to the collection, use or disclosure of his or her personal data by The Activation Group for such purpose. The Activation Group will not share with any unaffiliated third party any personal information the individual submits through its website, unless it is necessary to respond to the individual’s Sales Enquiry or to comply with applicable laws.
10. When an individual voluntarily provides his or her personal data to The Activation Group in the form of a job application, he or she may be deemed to consent to The Activation Group collecting, using and disclosing the personal data for the purpose of his or her job application. In the event that The Activation Group wishes to use the personal data for other purposes, The Activation Group will inform the job applicant of these purposes and obtain his consent, unless relevant exceptions under the PDPA applies. After The Activation Group decides which job applicant to hire, the personal data that The Activation Group has collected from other job applicants will only be kept for as long as it is necessary for business or legal purposes.
11. On giving reasonable notice to The Activation Group, an individual may at any time withdraw any consent given or deemed to have been given, in respect of the collection, use or disclosure by The Activation Group of personal data about the individual for any purpose.
(IV) Access and Correction of Personal Data
12. Under the PDPA, individuals have the right to obtain access and request corrections to their personal data held by organisations. As such, you have the right to check whether VMSD holds your personal data and request for access to such personal data (subject to the exceptions in the PDPA).
13. An individual may also request for The Activation Group to correct an error or omission in his or her personal data, upon which Kingsmen may correct the personal data as soon as reasonably practicable.
(V) Care of Personal Data
14. In accordance with its obligations under the PDPA, The Activation Group endeavours to ensure that personal data collected is accurate and complete and shall protect personal data in its possession or under its control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. While every reasonable effort has been made to ensure that all personal data will be so protected, The Activation Group cannot be responsible for any unauthorized use of such personal data and risks which are inherent in all internet communications.
15. The Activation Group shall cease to retain personal data as soon as the purpose of collection is no longer served by the retention and when retention is no longer necessary for business or legal purposes.
(VI) Contacting Us
16. If you have any questions or feedback relating to your personal data or our Personal Data Protection Policy; or if would like to withdraw your consent to any use of your Personal Data as set out above; or if you would like to obtain access and make corrections to your Personal Data records, please contact The Activation Group’s Data Protection Officer at [email protected].com.sg
(VII) Governing Law
17. This Personal Data Protection Policy and your use of this website shall be governed in all respects by the laws of Singapore.