SMRT DATA PROTECTION POLICY
The purpose of this document ("Data Protection Policy") is to inform you of how the SMRT Corporation Ltd manages personal data in accordance with the Singapore Personal Data Protection Act (No. 26 of 2012) ("the Act"). Please take a moment to read this Data Protection Policy so that you are aware of and understand the purposes for which we collect, use and disclose your personal data.
By interacting with us, submitting information to us or signing up for any promotions or services offered by us, you agree and consent to SMRT Corporation Ltd and its related corporations (collectively, the "Companies"), as well as our respective representatives and/or agents ("Representatives") (collectively referred to herein as "SMRT", "us", "we" or "our") collecting, using, disclosing and sharing amongst ourselves your Personal Data (as defined below), and disclosing such Personal Data to the Companies' authorised service providers and relevant third parties in the manner set forth in this Data Protection Policy.
This Data Protection Policy supplements but does not supersede nor replace any other consents you may have previously provided to SMRT in respect of your Personal Data, and your consents herein are additional to any rights which to any of the Companies may have at law to collect, use or disclose your Personal Data.
SMRT may from time to time update this Data Protection Policy to ensure that this Data Protection Policy is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of the Data Protection Policy as updated from time to time on our website. Please check back regularly for the updated policy on the handling of your Personal Data which may change any of the terms herein.
1. Personal Data
In this Data Protection Policy, "Personal Data" refers to any data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which we have or are likely to have access, including data in our records as may be updated from time to time.
Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us) your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address and any other information relating to any individuals which you have provided us in any forms you may have submitted to us (including in the form of biometric data), or via other forms of interaction with us and by the prevailing terms of the Data Protection Policy as updated from time to time on our website.
2. Collection of Personal Data
Generally, we collect Personal Data in the following ways:
(a) when you submit any form, including but not limited to application or declaration forms;
(b) when you interact with our staff, including our customer service officers and other representatives, for example, via telephone calls (which may be recorded), letters, fax, face-to-face meetings and email;
(c) when your images are captured by us via CCTV cameras while you are within our premises or photographs or videos taken by us or our representatives when you attend events hosted by us;
(d) when you use our services provided through online and other technology platforms, such as websites, social media platforms and mobile application software;
(e) when you request that we contact you, be included in an email or other mailing list; or when you respond to our request for additional Personal Data, our promotions and other initiatives;
(f) when you are contacted by, and respond to, our marketing representatives and agents and other service providers;
(g) when you submit an employment application or when you provide documents or information in connection with your appointment as an officer, director or other representative;
(h) when we receive your Personal Data from business partners, public agencies, your employer or other third parties;
(i) when we seek information from third parties about you in connection with your relationship with us, for example, from your ex-employer and the relevant authorities in relation to employment applications;
(j) when you submit your Personal Data to us for any other reasons.
. We do not at our website automatically collect Personal Data, including your email address unless you provide such information on our website.
If you provide us with any Personal Data relating to a third party (e.g. information of spouse, children, parents, employees and/or authorised persons), by submitting such information to us, you represent to us that you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes.
You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure to do so on your part may result in our inability to provide you with the services which you have requested.
3. Purposes for the Collection, Use and Disclosure of Your Personal Data
Generally, SMRT collects, uses and discloses your Personal Data for the following purposes:
(a) responding to, processing and handling your complaints, queries, requests, feedback and suggestions;
(b) managing the administrative and business operations of the Companies and complying with our internal policies and procedures;
(c) facilitating business asset transactions (which may extend to mergers, acquisitions, debt or asset sales) involving any of the Companies;
(d) matching any Personal Data held which relates to you for any of the purposes listed herein;
(e) verifying your identity;
(f) requesting feedback or conducting market research and/or analysis for statistical, profiling or other purposes for us to understand commuters' behaviour, preferences and market trends, and to review, develop and improve the quality of our services;
(g) facilitating and carrying out due diligence checks;
(h) preventing, detecting and investigating crime and managing the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances);
(i) conducting audits, reviews and analysis of our internal processes, action planning and managing commercial risks;
(j) project management;
(k) providing media announcements and responses;
(l) legal purposes (including but not limited to obtaining legal advice, drafting legal documents and contracts and facilitating dispute resolution);
(m) meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on SMRT (including but not limited to disclosures to regulatory bodies or conducting audit checks, surveillance, investigation, or due diligence); and/or
(n) any other purpose relating to any of the above.
In addition, SMRT collects, uses and discloses your Personal Data for the following purposes depending on the nature of our relationship:
(a)If you are customer of SMRT (for example, if you are a passenger on our trains, buses or taxis):
(i) processing taxi bookings;
(ii) providing customer service and administering benefits (including but not limited to fare ticketing and providing rewards, rebates and other promotions);
(iii) managing and preparing reports on incidents, offences and accidents;
(iv) investigating and processing compensation claims; and/or
(v) any other purpose relating to any of the above.
(b) If you are an employee, business partner, director or representative of an organisation that is a corporate customer, business partner or otherwise has a corporate relationship with SMRT:
(i) conducting background screenings and due diligence checks;
(ii) facilitating the bidding of tenders; and/or
(iii) any other purpose relating to any of the above.
(c) If you are a taxi partner with SMRT:
(i) administration in relation to the leasing of taxis (including but not limited to processing taxi licenses and rental payments);
(ii) facilitating the continuation or termination of the leasing relationship (including but not limited to maintenance of records, processing lease renewals and providing regular updates and communications);
(iii) administering programmes and benefits;
(iv) facilitating the advertising of our taxi services;
(v) processing claims;
(vi) management of vehicle servicing;
(vii) facilitating training, learning and talent development;
(viii) facilitating the enforcement of repayment obligations and approval of bad debts;
(ix) enabling us to respond to emergencies; and/or
(x) any other purpose relating to any of the above.
(d) If you are a tenant at our retail premises:
(i) facilitating the leasing of properties;
(ii) administration in relation to the leasing of properties (including but not limited to handing and taking over of properties and processing payments);
(iii) facilitating the continuation or termination of the leasing relationship (including but not limited to maintenance of tenant records, processing tenancy renewals and providing regular updates and communications); and/or
(iv) any other purpose relating to any of the above.
(e) If you are an existing or prospective external service provider, vendor, contractor, subcontractor or consultant or an employee thereof (where applicable) of SMRT:
(i) providing information on upcoming tenders;
(ii) procuring, awarding and managing project tenders (including but not limited to procuring approval from relevant government regulators, government ministries, statutory boards or authorities);
(iii) managing the outsourcing relationship;
(iv) facilitating training, learning and talent development;
(v) processing and payment of invoices and claims;
(vi) managing project developments and communications;
(vii) supervising operational matters;
(viii) managing the security of the premises (including but not limited to conducting security screening and issuing contractor access passes); and/or
(ix) any other purpose relating to any of the above.
(f) If you submit an application to us as a candidate for employment:
(i) conducting interviews;
(ii) processing your application which includes pre-recruitment checks involving your qualifications and facilitating interviews;
(iii) obtaining employee references and for background screening;
(iv) assessing your suitability for the position applied for;
(v) managing referrals; and/or
(vi) any other purposes relating to any of the above.
(g) If you are an SMRT shareholder:
(i) maintaining statutory registers and managing the publication of shareholder statistics on annual reports and circulars;
(ii) facilitating shareholder analysis (including but not limited to profiling shareholders, identifying investors and scheduling shareholder meetings); and/or
(iii) any other purpose relating to any of the above.
(h) If you sit on the SMRT Board of Directors:
(i) facilitating appointment to the Board (including but not limited to managing the publication of directors' statistics on annual reports and circulars);
(ii) facilitating the execution of duties and administrative matters (including but not limited to maintaining statutory registers, delivering meeting agendas, processing both local and overseas tax filing and organising corporate events); and/or
(iii) purposes which are reasonably related to the aforesaid.
In addition, where permitted under the Act, SMRT may also collect, use and disclose your Personal Data for the following purposes (which we may describe in our documents and agreements as "Additional Purposes" for the handling of Personal Data):
(a) providing promotions, services and benefits to you, including promotions, loyalty and reward programmes;
(b) matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision or offering of promotions, products and services, whether by SMRT or other third parties;
(c) administering contests and competitions, and personalising your experience at SMRT's touchpoints;
(d) organising marketing and promotional events or marketing our services to you;
(e) sending you details of promotions, services, special offers and rewards, either to our customers generally, or which we have identified may be of interest to you; and/or
(f) conducting market research, understanding and analysing customer behaviour, location, preferences and demographics for us to develop special offers and marketing programmes.
If you have provided your Singapore telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your Singapore telephone number(s), then from time to time, SMRT may contact you using such Singapore telephone number(s) (including via voice calls, text , fax or other means) with information about our promotions and services (including discounts and special offers).
In relation to particular services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.
4. Disclosure of Personal Data
SMRT will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, your Personal Data may be provided, for the purposes listed above (where applicable), to the following entities or parties, whether they are located overseas or in Singapore.
(a) SMRT's related corporations;
(b) companies or brokers providing services relating to insurance and/or reinsurance to SMRT;
(c) agents, contractors or third party service providers who provide operational services to SMRT, such as vehicle servicing and towing, courier services, telecommunications, information technology, advertising, payment, payroll, processing, training, market research, storage, archival, customer support investigation services or other services to SMRT;
(d) vendors or other third party service providers in connection with promotions and services offered by SMRT;
(e) any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to merger, acquisition, debt or asset sales) involving any of the Companies;
(f) external banks, credit card companies and their respective service providers;
(g) third party referrals;
(h) our co-brand and other business partners;
(i) our professional advisers such as our consultants, auditors and lawyers;
(j) relevant government regulators, government ministries, statutory boards or authorities and/or law enforcement agencies, whether local or overseas, including the Land Transport Authority, to comply with any directions, laws, rules, guidelines, regulations or schemes issued or administered by any of them;
(k) external business and charity partners in relation to corporate promotional events; and/or
(l) any other party to whom you authorise us to disclose your Personal Data to.
5. Contacting Us - Withdrawal of Consent, Access and Correction of your Personal Data
(a) have any questions or feedback relating to your Personal Data or our Data Protection Policy;
(b) would like to withdraw your consent to any use of your Personal Data as set out in this Data Protection Policy; or
(c) would like to obtain access or make corrections to your Personal Data records,
please contact SMRT as follows: firstname.lastname@example.org
Please note that if your Personal Data has been provided to us by a third party (e.g. a recruitment agency), you should contact such party directly to make any queries, feedback, and access and correction requests to SMRT on your behalf.
If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, SMRT may not be in a position to continue to provide our services to you, administer any contractual relationship in place, may also result in the termination of any agreements with you, and your being in breach of your contractual obligations or undertakings, and SMRT's legal rights and remedies in such event are expressly reserved.
6. Location Data
6.1 Collecting Location Data
If you opt in to share your location with us, we automatically receive data about your current location whenever you use the features of the WINK+ app (e.g., scanning WINK+ QR codes, checking WINK+ GATES nearby). Moreover, if you opt in and consent to enable background location, we will collect data about your location while the WINK+ app is in the background (as permitted by your device settings).
If you have opted-in to sharing your background location with us in the WINK+ app, you may remove your permission at any time by going into your device settings and toggling off background location sharing.
6.2 Purpose of Collecting Location Data
We collect information about your location when you use the features of the WINK+ app to help us provide location-based rewards (e.g., rewarding points to our users, enabling users to participate in ongoing campaigns). To ensure that our users are rewarded accordingly, location data is also used to verify incentivised user actions which include scanning of WINK+ QR codes and travelling through WINK+ GATES, when they are travelling on public transport or driving.
6.3 Sharing Location Data
This Data Protection Policy shall be governed in all respects by the laws of Singapore.