© We Are Trapeze Pte. Ltd., 2019
This Data Protection Notice (“Notice”) is effective as of 30 September 2020 and sets out the basis for which We Are Trapeze Pte. Ltd., our subsidiaries, affiliated companies and trading arms (“Trapeze”, “we”, “us”, or “our”) may collect, use, disclose and store Personal Information (as defined below) of our customers in accordance with the Personal Data Protection Act 2012, Singapore (“PDPA”), in association with any website, mobile site, mobile application, social media channel (e.g., Facebook, or Instagram), or other digital platforms owned and/or operated by us, now or in the future (individually and collectively).
This Notice applies to Personal Information in our possession or under our control, including Personal Information in the possession of organisation(s) which we have engaged to collect, use, disclose or process Personal Information for our purposes.
By accessing the Site, ordering products or services from Trapeze, or registering with Trapeze you are consenting to the Data collection and use practices described in this Policy, as modified from time to time by us in our sole discretion. We reserve the right to modify our Policy and invite you to consult this Policy from time to time in order to familiarise yourself with any changes.
Collection of Personal Information
“Personal Information” – includes but is not limited to, your name, contact number/s, email address/s, postal address/es, contact preferences, survey responses, the information you provide to us in your communications with us, whether online or offline, and in the case you make a purchase on our website, your order and transaction, and credit card information.
We collect Personal Information about you that you provide to us while browsing the www.trapeze.sg website, if you join our mailing list and information about how you use the www.trapeze.sg website, make purchases and/or bookings for any of our services. Providing your Personal Information to us is on a voluntary basis. Do note however that certain services cannot be provided if you choose not to submit your Personal Information to us—such services may require you to register or create an account in order to access certain features on the Site.
Personal Information Relating To Another Person
When making a booking on behalf of other persons, we will request for the Personal Information of such individuals. You agree that you have sought and obtained the consent of such other individuals to provide their Personal Information to us prior to doing so. Any request by such third parties to view or amend their Personal Information provided in relation to such bookings which has been made by you can only be made through your account with us.
Promotions and Surveys
We may conduct promotions and surveys from time to time and may request Personal Information from you in connection with your participation in such promotions and surveys. Participation in these promotions and surveys is voluntary and Personal Information collected for such purposes will be entered into our database for marketing purposes should you agree to such use.
Use of Personal Information
Processing of Personal Information
Personal Information collected by us will be processed in a manner necessary for the performance of the contract and services to you. Further, we process the Personal Information collected on the basis of our legitimate interests such as to improve on our services and for direct-marketing of Trapeze related promotions, products and services.
Some examples of the use of your information include but is not limited to:
- provide you with our wellness products and services;
- provide you with booking confirmation and updates;
- perform the contract and to provide you with the promotions, products or services;
- manage your account details;
- process invoice/bills;
- communicate our Terms to you;
- notify you of promotions, products and/or services which may be of interest to you;
- communicate with you in relation to your bookings, enquiries, disputes, and emergency matters;
- detect, prevent, and respond to fraud, violations of our Terms and Conditions or other misuse of our products and/or services, or violations of law;
- generate and analyse statistics about how you and others use and interact with Trapeze.
We may combine your Personal Information with other information for the purposes of improving our products, services, promotions and content provided to you.
We may provide you with direct marketing messages through email that contain information on products, services and promotions belonging or exclusively available to us which we believe are to your benefit and interests. You may withdraw your consent to us by following the steps set out in our Consent Policy section below.
Disclosure of Personal Information
Disclosure to third-parties
We may share your Personal Information with the following third-parties only if required to fulfil the provision of our products and services to you. These third-parties may be located overseas, and as a result, may require us to transfer your Personal Information overseas:
We share Data in the following ways:
- with our service providers in order to operate Trapeze, and to provide you with the products, services, and information you request. These services include but are not limited to credit card processing, business analysis, customer service, conducting surveys and promotions, marketing and digital marketing. These service providers have access to and may collect Personal Information only to the extent that such Personal Information is required to perform their services. These third-party service providers are not permitted to use or disclose such Personal Information for any other purpose;
- with our partners with whom we may jointly offer promotions, products and/or services. If you choose to receive information about these promotions, products and/or services, we may share information not limited to Personal Information about you, with such partners so that they may contact you directly by email about such products and services;
- Governmental authorities where required by applicable laws, governmental agencies or third-parties in relation to the investigation of illegal activities.
The disclosure of your Personal Information will only occur with your implied or express consent. We take all reasonable steps to ensure that such third-parties comply with the terms of the PDPA.
You have the ability to opt-in to or opt-out from receiving direct marketing emails in relation to promotions, products and/or services which we may communicate from time to time, by logging into your account to change such preferences, or emailing us at email@example.com.
Do note that removing consent may in some cases impact the availability or quality of certain products and/or services which we or our partners offer.
We have implemented commercially reasonable technical, administrative, and physical security measures to protect the information that we collect or receive.
From time to time, we will review and update our security procedures. Please be aware that, despite our ongoing efforts, no security measures are perfect or impenetrable.
Cookies and web-technologies
Such information collected by us or our authorised service providers may recognise a visitor as a unique user and may collect information such as how a visitor arrives at our sites, the type of browser a visitor is on, type of operating system a visitor is using, a visitor’s IP address, a visitor’s clickstream information and time stamp. This includes which pages a visitor has viewed, the time the pages were accessed and the time spent per web page.
We offer certain features and services on www.trapeze.sg that are available only through the use of these technologies. You are able to block, delete, or disable these technologies if your browser permits. Do note however that if you decline cookies or other similar technologies, you may not be able to access certain site features or services tools.
Display of targeted advertising on our website
We display advertisements on www.trapeze.sg served by third-party service providers. We allow these third-parties to collect information about visitors’ activities on the website through cookies and other web technologies. The collection of such information includes when you view an advertisement, how you interact with the advertisement and also extends to the collection of your interests and preferences. Such information is used to make predictions about your preferences and to display advertisements on www.trapeze.sg and other websites across the internet tailored to your interests. We do not allow these third-parties to collect your Personal Information.
Protection of Personal Data
To safeguard your Personal Information from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of Personal Information by us, and disclosing Personal Information both internally and to our authorised third party service providers and agents only on a need-to-know basis. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
Accessing and amending your Personal Data
If you wish to make:
- an access request for access to a copy of the Personal Information which we hold about you or information about the ways in which we use or disclose your Personal Information, or
- a correction request to correct or update any of your Personal Information which we hold, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
We will respond to your access request as soon as reasonably possible. Should we not be able to respond to your access request within thirty (30) days after receiving your access request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any Personal Information or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).
Please note that depending on the request that is being made, we will only need to provide you with access to the Personal Information contained in the documents requested, and not to the entire documents themselves. In those cases, it may be appropriate for us to simply provide you with confirmation of the Personal Information that our organisation has on record, if the record of your Personal Information forms a negligible part of the document.
Effective 30 September 2020