1. SINGLAND WEST MALL PTE. LTD. (Registration No. 199408282C) (“SLWM”), the owner and operator of West Mall, respects shoppers’ privacy and will make reasonable efforts to protect personal data of shoppers.
CORPORATE STATEMENT
2. SLWM understands and will at all times observe its obligations in respect of collection, use, disclosure and retention of personal data under the Personal Data Protection Act 2012 and any subsidiary legislation (the “Act”) including ensuring the appropriate degree of accuracy and security in respect of the personal data under its control or within its possession.
3. As part of SLWM's efforts to comply with the Act, SLWM has put in place this Privacy Policy (“this Policy”) which will govern, where applicable, how SLWM may from time to time collect, use and disclose shoppers’ personal data.
YOUR PERSONAL DATA
4. A shopper’s personal data means data about the shopper, whether true or not, (other than the shopper’s business contact information) that specifically identifies the shopper or data about the shopper which combined with other information that SLWM has or is likely to have access to can be used to identify the shopper. This may include the shopper’s name, partial NRIC number, address, gender, age, credit card number, email address, any feedback provided by the shopper, information specific to the computer or electronic device that the shopper uses to access and/or use the website at https://www.westmall.com.sg(the “Website”), SLWM's iPhone app or SLWM's app on Google Play or any other app SLWM may make available to the shopper (the “Apps”), photographs and video images of the shopper while the shopper is on SLWM's premises.
NON-PERSONAL DATA
5. An individual’s business contact information means the individual’s name, position name or title, business telephone number, business address, business email address or business fax number and any other similar information about the individual, not provided by the individual solely for his/her individual personal purposes.
6. Aggregated or anonymised data that do not specifically identify an individual (e.g. number of visitors to the Website) are not considered as personal data for the purposes of this Policy.
OCCASIONS WHEN SLWM MAY COLLECT YOUR PERSONAL DATA
7. SLWM may collect shopper’s personal data when shoppers deal with or contact SLWM. For example: a. when shoppers participate in lucky draws and redemption activities organised or hosted by SLWM; b. if shoppers make purchases from West Mall; c. when shoppers access and/or use the Website; d. when shoppers download, access and/or use the Apps; e. when shoppers contact SLWM directly (e.g. when you speak to a Customer Service Officer); f. when shoppers interact with SLWM through authorised third parties (e.g. via social media platforms or brand partners); and/or g. when shoppers are in the vicinity of SLWM surveillance cameras.
PURPOSE OF COLLECTING, USING AND/OR DISCLOSING YOUR PERSONAL DATA
8. Shopper’s personal data may be collected, used and/or disclosed by or on behalf of SLWM for the following purposes: a. for shoppers’ participation in lucky draws and redemption activities; b. to facilitate shoppers’ access and/or use of the Website and/or the Apps, transactions between SLWM and shoppers and activities organised by SLWM which shoppers participate in; c. to offer shoppers a more individualised environment in connection with shoppers use of the Website and/or the Apps; d. to allow SLWM to interact with shoppers via social media platforms; e. to refine or improve the security, use, features and functions of the Website and/or the Apps; f. to develop new features and functions of the Website and/or the Apps and to improve on the transactions between SLWM and shoppers; g. to receive emails and SMSes in connection with SLWM's latest promotions and/or events; h. to resolve disputes that may arise between SLWM and shoppers; i. where necessary, for any investigation or proceedings; j. where necessary, for SLWM to obtain legal services; k. for SLWM's evaluative purposes; and l. for the specific purposes for which shoppers’ personal data were provided or any purposes exempted under the Act.
9. SLWM will from time to time notify shoppers of other purposes for the collection, use or disclosure of shoppers’ personal data and shoppers will be deemed to have consented to collection, use or disclosure of personal data for such other purposes by shoppers continuing to transact with SLWM, shoppers continuing to participate in activities organised by SLWM or shoppers continuing to access or use the Website or the Apps.
10. SLWM will not sell or rent shoppers’ personal data to third parties.
11. SLWM may disclose shoppers’ personal data to third parties for any of the purposes stated in this Policy. Such third parties include: a. Subcontractors or service providers appointed by SLWM; b. Partners, affiliates or related companies of SLWM; and c. Government authorities/agencies, where required.
RETENTION OF PERSONAL DATA
12. SLWM may retain shoppers’ personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
13. SLWM will cease to retain shoppers’ personal data, or remove the means by which the data can be associated with individual shoppers, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.
Do Not Call Provisions
14. If you have provided us with your Singapore telephone number(s) and have indicated that you have given your clear and unambiguous consent to receiving marketing or other promotional information via your Singapore telephone number(s), then from time to time, SLWM may contact you using such Singapore telephone number(s) (including via voice calls, text, fax or other means) with information about our products, services (including discounts and special offers), and other event invitations even if these telephone number(s) are registered with the DNC Registry. You may however advise in writing should you wish not to be contacted by us at your telephone number(s) for such purposes.
USE OF COOKIES
15. SLWM may use cookies to facilitate shoppers’ access and/or use of the Website and/or the Apps. Cookies may be used to identify shoppers when they access the Website or the Apps.
16. SLWM is not responsible for any third party cookies.
17. If shoppers block cookies, some of the features and functions of the Website and/or Apps may not function properly and shoppers may not be able to access and/or use the Website or the Apps.
SECURITY OF SHOPPER’S PERSONAL DATA
18. In addition to implementing technological safeguards (such as firewalls and password-locks), SLWM will implement policies and practices to reasonably protect shoppers’ personal data in SLWM's possession or control from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. Information on such policies and practices are communicated to the relevant staff of SLWM and the relevant staff are required to comply with the policies and practices.
19. While SLWM will endeavour to protect shoppers’ personal data by making reasonable security arrangements, there is no absolute security in transmission of data over the internet. Shoppers should exercise care in protecting their personal data.
20. Shoppers may access third party websites which are linked to the Website or the Apps. SLWM is not responsible for shoppers’ personal data collected, used or disclosed by the third party websites and the data protection policies and practices of third parties, if any, are not found in and are not intended to be covered by this Policy.
21. Third party contractors with access to shoppers’ personal data are subject to a clause in SLWM contract that they have to comply with PDPA regulations.
ACCESS TO AND ACCURACY OF YOUR PERSONAL DATA
22. As part of SLWM's efforts to ensure the accuracy of shoppers’ personal data, SLWM may adopt verification practices or processes such as asking shoppers questions relating to their identity, checking against existing data held by SLWM or requesting that shoppers furnish photo identification.
23. SLWM has appointed a Data Protection Officer to oversee SLWM's compliance with the Act and to facilitate shoppers’ dealings with SLWM in respect of their personal data.
24. If shoppers’ wish to make (a) a request for access to a copy of the personal data which SLWM holds about them or information about the ways in which SLWM uses or discloses their personal data, or (b) a request to correct or update any of the shoppers’ personal data which SLWM holds about them, shoppers may by send a request to us at http:www.westmall.com.sg/contact-westmall/feedback or via email to SLWM's Data Protection Officer at dpo@westmall.com.sg.
25. Please note that a reasonable fee may be charged for a data access request by any shopper. If so, SLWM will inform the shopper of the fee before processing the request.
26. SLWM will respond to the shopper’s data access request as soon as reasonably possible. Should SLWM not be able to respond to the shopper’s request within thirty (30) days after receiving the request, SLWM will inform the shopper in writing within thirty (30) days of the time by which SLWM will be able to respond to the shopper’s request. If SLWM is unable to provide the shopper with some of the personal data as requested by the shopper, SLWM will generally inform the shopper of the reasons why SLWM is unable to do so (including exceptions to data access request provided for under the PDPA).
27. SLWM has the right to reject, among others, frivolous or vexatious requests or requests for trivial information.
28. If shoppers believe their personal data contain an error or omission, they should inform SLWM immediately. SLWM will make the correction as soon as practicable, within thirty (30) days after receiving the request, unless it is satisfied on reasonable grounds that the correction should not be made (including exceptions to data correction request provided for under the PDPA).
TRANSFER OF YOUR PERSONAL DATA TO ANOTHER COUNTRY
29. Consistent with the purposes for which shoppers’ personal data were collected, shoppers’ personal data may be transferred outside of Singapore.
30. Shoppers’ personal data will not be transferred to a third party outside of Singapore unless the third party is able or undertakes to provide a standard of protection to shoppers’ personal data that is comparable to the standard of protection under the Act.
COMPLAINTS
31. All shoppers’ requests, complaints and queries relating to their personal data are to be forwarded to SLWM's Data Protection Officer at dpo@westmall.com.sg. SLWM will respond to shoppers’ complaints within a reasonable period of time depending on the nature of the complaint.
WITHDRAWAL OF CONSENT TO RECEIVE MARKETING INFORMATION
32. If shoppers wish to stop receiving information with marketing information from SLWM, they should send an email to SLWM's Data Protection Officer at dpo@westmall.com.sg stating their name, address and email address. For emails, shoppers may click on the unsubscribe link in the latest email received from SLWM. SLWM will process and effect such withdrawal within 30 working days.
33. If shoppers wish to withdraw their consent in relation to other purposes, they are to contact SLWM's Data Protection Officer at dpo@westmall.com.sg and where applicable, SLWM will inform shoppers of the likely consequences of withdrawing their consent. If shoppers have given their consent for multiple purposes, shoppers’ personal data may still be collected, disclosed and used for purposes for which no withdrawal of consent was made. Even if shoppers withdraw consent from SLWM, and SLWM ceases to use their personal data, SLWM may still retain their personal data that is necessary for legal or business purposes according to its data retention policy.
VARIATION OF THIS POLICY
34. SLWM reserves the right to modify this Policy from time to time by posting the modifications on the Website. Individuals should check the pages regularly for any modifications. Such modifications will be effective immediately and incorporated into the Website.
