Data Protection Policy
This Data Protection Policy (“Policy”) applies to THE FUN EMPIRE PTE. LTD. and, where applicable, its related corporations, associated entities, affiliates and other entities that are commercially or operationally associated with the foregoing in connection with relevant activities, products and services (collectively, and solely for convenience, the “TFE Group”, which, where the context requires, may refer to one or more of these entities).
This Policy governs the collection, use, disclosure and other processing of personal data by the TFE Group and explains how we collect and handle personal data in accordance with the requirements of the Personal Data Protection Act 2012 of Singapore and its regulations (“PDPA”).
In this Policy, “personal data” shall have the meaning ascribed to it under the PDPA.
This Policy should be read together with any other notices, consent clauses or contractual provisions that we may provide in connection with the collection, use or disclosure of personal data.
1. COLLECTION OF PERSONAL DATA
We may collect personal data from clients, customers, participants, business contacts, partners, suppliers, personnel, job applicants, contractors and other individuals with whom we interact.
Depending on how you interact with us, the personal data we collect may include:
your name and contact details, such as telephone number, email address and mailing address;
your company, organisation or other information that you choose to provide to us;
information submitted through our websites, enquiry forms, registrations, bookings or other communications with us;
information relating to bookings, events, activities, products or services requested from or provided by us;
billing, payment and transaction information;
information provided for event participation, safety, indemnity or waiver purposes;
correspondence and records of communications with us;
photographs, videos or other recordings where applicable;
information provided in connection with job applications, recruitment or employment matters; and
technical information relating to your use of our websites, including information collected through cookies and similar technologies.
We may collect personal data directly from you, through our websites and online services, through telephone calls, messaging platforms, emails or other correspondence, during events or meetings, or through third parties where permitted by applicable law.
If you provide us with personal data relating to another individual, such as a colleague, participant, employee, family member or other person, you should ensure that you are authorised to provide such information to us and, where required, that the individual has been informed of and consented to our collection, use and disclosure of their personal data for the relevant purposes.
Where personal data relating to minors is provided to us by parents, guardians, schools, organisations or other persons, we expect the provider to be authorised or otherwise permitted to provide such personal data to us and, where required, to have provided the necessary notifications and obtained the necessary consents.
We will generally collect, use and disclose personal data with consent or deemed consent, where applicable, or where such collection, use or disclosure without consent is permitted or required under the PDPA or other applicable laws.
2. USE OF PERSONAL DATA
We may collect, use and disclose personal data for purposes including:
responding to enquiries, requests, applications, feedback and communications;
providing, administering and facilitating our events, activities, products and services;
processing bookings, registrations, orders, payments, invoices and other transactions;
communicating with clients, customers, participants and other relevant persons regarding bookings, events, activities, products or services;
administering event participation, indemnities, waivers, safety requirements and related operational matters;
providing customer support and handling feedback, disputes or complaints;
verifying information where reasonably necessary;
maintaining business, customer and transaction records;
managing our relationships with clients, customers, suppliers, partners and other parties;
improving our services, customer experience, websites, systems and business operations;
conducting internal analysis, reporting, audits and business administration;
preventing, detecting and investigating fraud, misuse, security incidents or unlawful activity;
complying with applicable laws, regulations, court orders and requirements of governmental, regulatory or law enforcement authorities;
establishing, exercising or defending legal rights or claims;
managing recruitment, employment and personnel matters;
carrying out marketing and promotional activities where permitted by applicable law;
- taking photographs, videos or other recordings at our events and using such photographs, videos or recordings for event documentation, publicity, marketing and promotional purposes, where permitted by applicable law and subject to any applicable consent requirements; and
other purposes reasonably related to the purposes described above or which we notify you of at or before the time the relevant personal data is collected.
Where we intend to collect, use or disclose personal data for a purpose that has not previously been notified to you, we will provide appropriate notification and obtain consent where required by applicable law.
The purposes described in this Policy may continue to apply after your relationship with us has ended where reasonably necessary for legal, regulatory, contractual, administrative or business purposes.
3. DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES
We may disclose personal data to third parties where reasonably necessary for the purposes described in this Policy or where otherwise permitted or required by applicable law.
Such parties may include:
other entities within the TFE Group;
agents, representatives, contractors, subcontractors, data intermediaries and service providers supporting our operations;
event venues, partners, suppliers and other parties involved in providing or administering an event, activity, product or service;
information technology, website hosting, cloud computing, communications, customer relationship management, payment, analytics and other technology service providers;
professional advisers such as lawyers, accountants, auditors and insurers;
governmental, regulatory, law enforcement or other authorities where required or permitted by applicable law;
parties involved in a potential or actual acquisition, sale, merger, restructuring or transfer of all or part of a relevant business or its assets; and
other persons or organisations where you have authorised the disclosure or where disclosure is otherwise permitted or required by applicable law.
Where third parties process personal data on our behalf, we take reasonable steps to require such parties to protect the personal data appropriately in accordance with applicable requirements.
4. MARKETING COMMUNICATIONS
Where permitted by applicable law, we may use your contact information to send you information about our products, services, promotions, activities, events or other matters that we believe may be relevant or of interest to you.
You may opt out of receiving marketing communications from us at any time by using the unsubscribe facility provided in our communications, where available, or by contacting us using the details set out in this Policy.
We will process marketing opt-out requests as soon as reasonably practicable and in accordance with applicable law.
Marketing activities involving Singapore telephone numbers will be conducted in accordance with the applicable provisions of the PDPA, including the Do Not Call provisions, and other applicable laws.
5. WITHDRAWAL OF CONSENT
Where our collection, use or disclosure of your personal data is based on your consent, you may withdraw your consent by contacting our Data Protection Officer using the contact details set out below.
Upon receiving a request to withdraw consent, we may require a reasonable period to process the request and may inform you of the likely consequences of the withdrawal.
Depending on the nature and scope of your withdrawal, we may not be able to continue providing certain products, services or arrangements to you. Where applicable, we will inform you of such consequences.
Following the effective withdrawal of consent, we will cease collecting, using or disclosing the relevant personal data for the purposes to which the withdrawal applies unless such collection, use or disclosure is permitted or required under applicable law.
Withdrawal of consent does not affect the lawfulness of our collection, use or disclosure of personal data before the withdrawal takes effect.
6. ACCESS TO AND CORRECTION OF PERSONAL DATA
Subject to the PDPA and applicable exceptions, you may request:
access to personal data about you that is in our possession or under our control, as well as information regarding the ways in which such personal data has been used or disclosed as provided under the PDPA; or
correction of an error or omission in personal data about you that is in our possession or under our control.
Requests should be submitted to our Data Protection Officer using the contact details below.
We will respond to access and correction requests as soon as reasonably possible and in accordance with the PDPA and other applicable laws.
Where permitted by applicable law, we may charge a reasonable fee for processing an access request. If a fee is applicable, we will inform you of the amount before processing the request.
There may be circumstances under the PDPA in which we are not required or permitted to provide access to, or make a requested correction to, certain personal data.
7. ACCURACY OF PERSONAL DATA
We will make reasonable efforts to ensure that personal data collected by us or on our behalf is accurate and complete where the personal data is likely to be used by us to make a decision that affects you or is likely to be disclosed to another organisation.
We generally rely on personal data provided by you or your authorised representative. You should inform us if there are material changes to your personal data so that our records may be updated where appropriate.
8. PROTECTION AND SECURITY OF PERSONAL DATA
We take reasonable administrative, physical and technical measures to protect personal data in our possession or under our control against unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks.
However, no method of transmission over the Internet or method of electronic storage is completely secure. While we take reasonable measures to protect personal data, we cannot guarantee absolute security.
9. RETENTION OF PERSONAL DATA
We retain personal data for as long as it is reasonably necessary to fulfil the purposes for which it was collected or for legal or business purposes.
We will cease retaining personal data, or remove the means by which the personal data can be associated with particular individuals, when it is reasonable to assume that retention no longer serves the purpose for which the personal data was collected and is no longer necessary for legal or business purposes.
Nothing in this Policy requires us to delete personal data where its continued retention is permitted or required by applicable law or is reasonably necessary for legal or business purposes.
10. TRANSFERS OF PERSONAL DATA OUTSIDE SINGAPORE
Some of our service providers, systems or business operations may involve the transfer, storage or processing of personal data outside Singapore.
Where personal data is transferred outside Singapore, we will take appropriate steps in accordance with applicable law to ensure that the transferred personal data receives a standard of protection that is comparable to the protection required under the PDPA.
11. PERSONAL DATA BREACHES
In the event of a personal data breach, we will assess and respond to the breach in accordance with applicable law.
Where a personal data breach is notifiable under the PDPA, we will notify the Personal Data Protection Commission and/or affected individuals as required under applicable law.
12. COOKIES AND SIMILAR TECHNOLOGIES
Our websites may use cookies and similar technologies to enable website functionality, improve user experience, understand how our websites are used and support our business and marketing activities.
Cookies are small files that may be stored on your device when you visit a website.
Information collected through cookies and similar technologies may include information such as your IP address, browser or device information, pages visited, referring websites and information regarding your interactions with our websites.
Depending on your browser or device settings, you may be able to block, disable or delete cookies. Disabling certain cookies may affect the functionality or performance of our websites.
13. THIRD-PARTY WEBSITES AND SERVICES
Our websites may contain links to third-party websites, applications or services.
We are not responsible for the privacy practices, security or content of third-party websites or services that are not operated by us.
We encourage you to review the applicable privacy policies of those third parties before providing them with personal data.
14. DATA PROTECTION OFFICER
If you have any questions, feedback or complaints regarding this Policy or the handling of your personal data, or if you wish to make a request relating to your personal data, you may contact our Data Protection Officer at:
Data Protection Officer
FunEmpire
Email: dpo@funempire.com
15. MODIFICATIONS TO THIS POLICY
We may revise this Policy from time to time to reflect changes to our business practices, operations, technologies or applicable legal and regulatory requirements.
The latest version of this Policy will be published at:
www.funempire.com/data-protection-policy/
Where required by applicable law, we will provide appropriate notification of material changes and obtain consent where necessary.