1.1 This Data Protection Policy (“Policy”) is designed to assist you in understanding how SSCL collects, uses, discloses and/or processes the personal data you have provided to us, as well as to assist you in making an informed decision before providing us with any of your personal data.
1.2 By interacting with us, submitting information to us, subscribing for any of our publications or literature in any format or media, or signing up for any events, performances or services offered by us, you agree and consent to SSCL collecting, using, disclosing and sharing amongst ourselves your Personal Data, and disclosing such Personal Data to SSCL’s authorised service providers and relevant third parties in the manner set forth in this Policy.
1.3 For the purposes of this Policy, in line with the provisions under the Singapore Personal Data Protection Act 2012 (No. 26 of 2012) (the “Act”), “Personal Data” shall mean data, whether true or not, about an individual who can be identified from that data; or from that data and other information which an organisation has or is likely to have access. Such Personal Data shall also include that which is already in the possession of SSCL or that which shall be collected by SSCL in future.
1.4 As part of its day-to-day activities, SSCL may collect either directly from you or your authorised representatives, and/or through our third party service providers (e.g. ticketing agents or survey companies) personal data which may include, without limitation, your statutory name, NRIC/BC/FIN and/or passport number, passport expiry date, postal address, contact numbers, email address, bank account/credit card details, IRAS and salary details, photographs, videos and images.
PURPOSE OF COLLECTION, USE, DISCLOSURE AND PROCESSING
2.1 The purposes for which SSCL may collect, use, disclose and/or process your personal data may include but are not limited to:
(a) communicating with you on your enquiries, and/or sending you marketing, advertising and promotional information and materials (through media including but not limited to electronic mail, direct mailers, short message service, telephone calls, facsimile and other mobile messaging services) relating to products; events; productions; shows; concerts; and/or services that we, our partners and/or third party organisations with whom we are collaborating, may be selling or marketing;
(b) administrative matters on your ticket purchases, managing your membership and/or processing your sign-ups/registrations for masterclasses, workshops, events, activities, or mailing lists;
(c) conducting market research and customer satisfaction surveys;
(d) to notify you of any changes to our policies or services which may affect you;
(e) to respond to queries and feedback;
(f) administering any contests, quizzes or lucky draws (whether organised solely by SSCL or in conjunction with third parties) which you participate in, including but not limited to awarding of prizes;
(g) to enable us to develop, deliver and improve our services and our websites in order to better attend to your needs; and
(h) any other purposes that we notify you of at the time of obtaining your consent,
collectively, the "Purposes".
2.2 The above list of Purposes is not exhaustive as collection, use, disclosure and/or processing of personal data depends on circumstances at hand. Accordingly, we will notify you of such other purpose at the time of obtaining your consent, unless processing of your personal data without your consent is permitted by the PDPA or by other laws.
2.3 In order to conduct our business operations more smoothly and to fulfil the above-said Purposes, we may also be disclosing the personal data you have provided to us to our third party service providers, agents and/or our affiliates or related corporations, and/or other third parties whether sited in Singapore or outside of Singapore, for one or more of the above-stated Purposes. Such third party service providers, agents and/or affiliates or related corporations and/or other third parties would be processing your personal data either on our behalf or otherwise, for one or more of the above-stated Purposes.
DISCLOSURES EXEMPT FROM CONSENT REQUIREMENT
3.1 SSCL will not disclose your personal data to third parties without first obtaining your consent permitting us to do so. However, please note that SSCL may disclose your personal data to third parties without first obtaining your consent in certain situations, including, without limitation, the following:
(a) when the disclosure is required or authorised based on the applicable laws and/or regulations;
(b) when the purpose of such disclosure is clearly in your interests, and if consent cannot be obtained in a timely way;
(c) when the disclosure is necessary to respond to an emergency that threatens the life, health or safety of yourself or another individual;
(d) when the disclosure is necessary for any investigation or proceedings;
(e) when the personal data is disclosed to any officer of a prescribed law enforcement agency, upon production of written authorisation signed by the head or director of that law enforcement agency or a person of a similar rank, certifying that the personal data is necessary for the purposes of the functions or duties of the officer;
(f) when the disclosure is to a public agency and such disclosure is necessary in the public interest;
(g) when it is necessary for the provision of legal services by the organisation to another person or for the organisation to obtain legal services; and/or
(h) where such disclosure without your consent is permitted by the PDPA or by law.
3.2 The instances listed above at paragraph are not intended to be exhaustive. For more information on the exceptions, you are encouraged to peruse the Second, Third and Fourth Schedules of the PDPA which is publicly available at http://statutes.agc.gov.sg.
Access, Update, Correction and Withdrawal of Personal Data
4.1 You have the right to request access to, update and/or correct your personal data held by us. If you wish to do so, please contact our Data Protection Officer at SSCL (details below) and provide details of your access, update and/or correction request. SSCL reserves the right to charge a reasonable administrative fee in order to meet your requests. Upon payment of the requisite fee and/or receipt of your request, your request shall be processed within  days. Do note that the PDPA exempts certain types of personal data from being subject to your access or correction request.
4.2 You may withdraw your consent given, whether in part or as a whole. Should you wish to withdraw your consent in part or whole, please send an email to our Data Protection Officer and provide details of your withdrawal request. We will process your request within a reasonable time from such a request for withdrawal of consent being made, and will thereafter not collect, use and/or disclose your personal data in the manner stated in your request. However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal including (to the extent of withdrawal) not being able to continue with your existing relationship with us
4.3 If you wish to verify the details you have submitted to SSCL or if you wish to check on the manner in which SSCL uses and processes your personal data, SSCL’s security procedures mean that SSCL may request proof of identity before we reveal information. This proof of identity may take the form of full details of name, login details and NRIC/BC/FIN or Passport number. You must therefore keep this information safe as you will be responsible for any action, which SSCL takes in response to a request from someone using your login details. We would strongly recommend that when you login to your online account in our websites / portals that you do not use the browser’s password memory function as that would permit other people using your terminal to access your personal information.
ADMINISTRATION AND MANAGEMENT OF PERSONAL DATA
6.1 SSCL will take reasonable efforts to ensure that your personal data is accurate and complete but you must also update us of any changes in your personal data that you had initially provided us with. We will not be responsible for relying on inaccurate or incomplete personal data arising from you not updating us of any changes in your personal data that you had initially provided us with.
6.2 SSCL will also put in place reasonable security arrangements to ensure that your personal data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorised access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data. However, SSCL cannot assume responsibility for any unauthorised use of your personal data by third parties which are wholly attributable to factors beyond our control.
6.3 SSCL will also put in place measures such that your personal data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that: (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes.
6.4 Where your personal data is to be transferred out of Singapore, SSCL will comply with the PDPA in doing so. In this regard, this includes us obtaining your consent and taking appropriate steps to ascertain that the foreign recipient organisation of the personal data is bound by legally enforceable obligations to provide to the transferred personal data a standard of protection that is at least comparable to the protection under the PDPA.
UPDATE TO POLICY
7. SSCL reserves the right to update this Policy in compliance with changes in relevant laws or in accordance with the needs of SSCL. If there is any inconsistency between these terms and the updated terms, the updated terms will prevail to the extent of any inconsistency. You are encouraged to visit this website frequently to ensure that you are well informed of our latest policies in relation to personal data protection.
8. This Policy is governed by and shall be construed in accordance with the laws of Singapore. You hereby submit to the non-exclusive jurisdiction of the Singapore courts.
FEEDBACK AND COMPLAINTS
9. If you have any questions about this Policy or any complaint of grievance in relation to this Policy, please contact us at the following:
SSG PDPA Officer
E-mail : firstname.lastname@example.org
[This Policy was last updated on 1 November 2017]