PERSONAL DATA PROTECTION POLICY

This Personal Data Policy (the “Personal Data Policy”) sets out how Jumbo Group Limited, its subsidiaries and associated companies (collectively, the “Group”) may collect, use, disclose or otherwise process your personal data (“Personal Data”) in accordance with the Personal Data Protection Act 2012 (No. 26 of 2012). This Personal Data Policy applies to Personal Data in our possession or under our control, including Personal Data in the possession of entities which we have engaged to collect, use, disclose or otherwise process Personal Data for our purposes.

Please take a moment to read this Personal Data Policy so that you know and understand the purposes for which we collect, use or disclose your Personal Data.

By interacting with us, providing information to us, signing up for any products and services offered by us or accessing and/or using our services and products, you agree and consent to the Group, as well as our representatives and/or agents (collectively, “Jumbo”, “we”, “us, “our”) collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to the Jumbo’s authorised service providers and relevant third parties in the manner set forth in this Personal Data Policy.

This Personal Data Policy supplements but does not supersede nor replace any other consents you may have previously provided to Jumbo in respect of your Personal Data. Your consents herein are additional to any rights which to Jumbo may have at law to collect, use or disclose your Personal Data.

Jumbo will take the necessary steps to ensure that our practices conform to the Singapore Personal Data Protection Act (PDPA) 2012.

PERSONAL DATA

Personal Data refers to data about an individual (whether true or not) who can be identified from data or other information that we have or likely to have access to.

Examples of Personal Data which we may collect include your name, NRIC, passport or any other identification number, telephone numbers, mailing address, email address, photograph, financial information (such as bank account or credit/debit card numbers), signature, date of birth, age, network data and any other information relating to any individuals which you have provided us in any forms you may have submitted to us, or via other forms of interaction with you.

COLLECTION OF PERSONAL DATA

Generally, the ways (whether directly or indirectly) in which we may collect your Personal Data include (but are not limited to):

1. when you submit any form, including but not limited to customer inquiry forms or other forms relating to any of our goods and/or services;
2. when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our goods and/or services;
3. when you interact with our staff, including customer service officers, for example, via telephone calls (which may be recorded), letters, fax, face-to-face meetings, social media platforms and electronic mails (“emails”);
4. when you interact with us via our websites;
5. when you browse, surf, access and/or use our websites. We may receive and record information on our servers from your browser (including your IP address and cookie information) when you browse or search on our websites. Although browser sessions may be tracked, individual users will remain anonymous;
6. when you request that we contact you or request that you be included in email, email alerts or other mailing lists;
7. when you respond to our promotions, marketing events, loyalty programs, memberships, initiatives or to any request for additional Personal Data;
8. when you purchase and make payments for any of our products and/or services including online purchases;
9. when you submit an employment application or when you provide documents or information including your resume/CVs in connection with any position as an officer, director, representative or any other position;
10. when your images are captured by us via CCTV cameras while you are within our premises, or via photographs or videos taken by us or our representatives and/or agents when you attend our events;
11. when you are contacted by, and respond to, our marketing representatives and customer service officers;
12. when we seek information about you and receive your Personal Data in connection with your relationship with us, including for our products and services or job applications, for example, during interviews with you, from business partners, public agencies, previous employer, referral intermediaries and the relevant authorities;
13. when your representatives, agents, intermediaries, and/or next-of-kin discloses your Personal Data to us on your behalf, or in connection with their own transactions, agreements or interactions with us;
14. when your employers or previous employers discloses your Personal Data to us on your behalf, or in connection with their own transactions, agreements or interactions with us;
15. when you provide your Personal Data to us at any of our restaurants, whether through leaving a copy of your business card with us or otherwise;
16. when you submit your Personal Data to us for any other reasons.

You represent and warrant to us that when you provide us with any Personal Data relating to a third party, you have obtained the necessary consent from the relevant third party for the provision of their personal data for the purpose(s) of our collection of their personal data.

PURPOSES FOR OUR COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

We may collect, use or disclose Personal Data for the following purposes:

1. performing obligations in the course of or in connection with our provision of the products and/or services to you;
2. managing your relationship with us;
3. providing customer service and support;
4. responding to and handling of your applications, feedback, queries and requests;
5. managing the administrative and business operations of Jumbo and complying with internal policies and procedures;
6. auditing, internal investigations, compliance, risk management, conflict of interest reporting and security processes;
7. processing of and the management of your payment and/or credit transactions;
8. matching any Personal Data held which relates to you for any of the purposes listed herein;
9. responding to, the handling of and the resolution of complaints;
10. providing media announcements and responses;
11. monitoring or recording phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes;
12. organising and implementation of marketing and/or promotional events;
13. providing you with marketing information about our products or services including informing you of our marketing events, initiatives and promotions, lucky draws, competitions, loyalty programs, memberships, rewards schemes and other promotions;
14. conducting market research and surveys to enable us to understand and determine customer location, preferences and demographics to develop special offers and marketing programmes in relation to Jumbo’s products and services, to improve our service delivery and your customer experience at our touchpoints;
15. providing additional products and services and benefits to you;
16. matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision, marketing or offering of products and services by Jumbo;
17. leads generation and management for marketing of Jumbo’s products and services;
18. administer, manage and execute contests, competitions and marketing campaigns, and personalising your experience at Jumbo’s touchpoints;
19. provide training to our employees;
20. administer and manage shareholder relations;
21. facilitating your use of our website;
22. creating and maintaining your Personal Data in our system database for internal records and reference;
23. communicating to you through advertisements involving details of our products and services, special offers but not limited to upselling and online marketing;
24. organising and implementation of corporate social responsibility projects;
25. conducting investigations to disputes, billing or fraud;
26. preventing, detecting and investigating crime and analysing and managing commercial risks;
27. legal proceedings;
28. managing the safety and security of our premises and/or our employees;
29. administering, processing and/or management of employment including employment applications;
30. complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
31. transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes;
32. facilitating business asset transactions including merger, acqusitions or asset sale;
33. any other purposes for which you have provided the information;
34. any other purposes for which you have been notified;
35. any other purposes a person would consider to be reasonable;
36. purposes which are incidental, in connection with and/or reasonably related to the aforesaid.

The purposes listed in the above may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).

DISCLOSURE

The Group 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 disclosed, for the purposes listed above (where applicable), to the following entities or parties, whether they are located overseas or in Singapore:

1. Amongst the Group members and affiliates (including their employees);
2. entities providing services relating to insurance to the Group;
3. agents, contractors, sub-contractors or third party service providers who provide operational services to the Group;
4. vendors or third party service providers and our marketing and business partners in connection with marketing promotions, products and services;
5. external banks, credit card companies, other financial institutions and their respective service providers;
6. our professional advisers such as consultants, auditors and lawyers;
7. relevant government ministries, regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and/or
8. any other party to whom you authorise us to disclose your Personal Data to.

In the event that your Personal Data is transferred overseas, we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.

PROTECTION OF PERSONAL DATA

The Group deploys appropriate security technologies to safeguard your personal data. However, you should be aware 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.

CONTACTING US

If you:

1. have any questions or feedback relating to your Personal Data or our Personal Data Policy;
2. would like to withdraw your consent to any use of your Personal Data as set out in this Personal Data Policy; or
3. would like to obtain access and make corrections to your Personal Data records,

Write to our Data Protection Officer at dpo@jumbogroup.com.sg

Data Protection Officer
JUMBO Group Limited
4 Kaki Bukit Avenue 1
#03-08
Singapore 6749 4955