1. YOUR PERSONAL DATA
(a) your name, email address, contact number, your interest in specific products and/or services and any other information relating to you which you have provided us in any form you may have uploaded or submitted to us, or in other forms of interaction with you;
(b) information about your use of any Site, products and/or services, including cookies, information about your domain name and IP addresses; and
(c) your employment history, education background, character references, and income levels, emergency contact information.
2. COLLECTION OF PERSONAL DATA
2.1 Generally, we collect your Personal Data in the following ways:
(a) when you submit forms (online or otherwise) relating to any of our products or services, or submit any online queries (including queries for a quotation or a product and/or a service);
(b) when you enter into any agreement or provide other documentation or information in respect of your interactions with us;
(c) when you register for and/or use any of our services or surveys on any Site owned or operated by us;
(d) 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 emails;
(e) when you request that we contact you or request that you be included in an email or other mailing list;
(f) when you respond to our initiatives or to any request for additional Personal Data;
(g) when we receive references from business partners and third parties, for example, where you have been referred by them;
(h) when your images are captured by us via CCTV cameras while you are within our property and/or premises, or via photographs or videos taken by us or our representatives when you attend our events;
(i) when you are contacted by, and respond to, our marketing representatives and customer service officers;
(j) when you submit a job application; and/or
(k) when you submit your Personal Data to us for any other reason.
2.2 When you browse any Site, you generally do so anonymously but please see paragraph 7 below for information on cookies and other technologies which we have implemented on the Site. We do not, at any Site, automatically collect Personal Data unless you provide such information to us.
2.3 If you provide us with any Personal Data relating to a third party (e.g. information on your dependent, spouse, children and/or patents), by submitting such information to us, you represent and warrant that the collection, use and disclosure of that Personal Data to us, as well as the further processing of that Personal Data by us for the purposes set out below, is lawful, and you have obtained the consent of the third party to provide us with their Personal Data.
2.4 You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with products and services you have requested, or processing any requests and applications you may have made to us.
3. PURPOSES FOR THE COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
3.1 In general, we collect, use and disclose your Personal Data for the following purposes:
(a) to assist you in finding the appropriate products and/or services that you are looking for as well as informing you of other new products and/or services that we may offer;
(b) to provide you with the products and/or services that you have requested as well as the various products and/or services offered by us;
(c) to respond to, process, deal with or complete a transaction with you;
(d) to notify you of service issues;
(e) to communicate with you and respond to, handle or follow up on your queries (including queries for a quotation or a product or service), requests and complaints;
(f) for authentication, identification and verification purposes;
(g) to manage our infrastructure operations, administrative operations and business operations and to comply with internal policies and procedures;
(h) to conduct research and/or analysis for statistical, profiling or other purposes for us to design our products, understand customer locations, demographics, behaviour, preferences and market trends, and to review, develop and improve the quality of any Site, products and services;
(i) to protect and enforce our contractual and legal rights and obligations, or to comply with any contractual terms and conditions to which BBP is bound by;
(j) to prevent, detect and investigate crime, including fraud and money-laundering, and to analyse and manage other commercial risks;
(k) to manage the safety and security of our premises, products and services (including but not limited to carrying out CCTV surveillance and conducting security clearances);
(l) to monitor or record phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes;
(m) to organise, facilitate, and administer surveys and promotional events;
(n) to administer and/or manage your relationship with us and your use of our products and/or services;
(o) to commence, respond to, or act in connection with any claims, actions or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution);
(p) to match any Personal Data held which relates to you for any of the purposes listed herein;
(q) to communicate with you changes and development to our policies, terms and conditions and other administrative information;
(r) to comply with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities; and/or
(s) for any purposes which is related to or reasonably related to the aforesaid.
3.2 In addition, and without prejudice to the generality of the foregoing, if you submit an application to us as a candidate for employment, we collect, use and disclose your Personal Data for the following purposes:
(a) to process your application including to conduct any pre-recruitment checks involving your qualifications and facilitating interviews;
(b) to provide or obtain employee references or other references where relevant for background screening and/or vetting;
(c) to collect information about your suitability for the position applied for;
(d) enrolling successful candidates as our employees and facilitating human resource planning and management (including but not limited to preparing letters of employment, name cards, and building access passes);
(e) to organise training and staff development programs;
(f) to assess your performance;
(g) for our internal record-keeping purposes (including where applicable, keeping records in our internal databases);
(h) to administer benefits and payroll processing;
(i) to provide you with tools to facilitate or which are required for your to perform your job;
(j) to communicate with you any of our policies and/or processes; and
(k) for purposes which are reasonably related to the aforesaid.
3.3 Furthermore, and without prejudice to the generality of the foregoing, and where permitted under Data Protection Laws, BBP may also collect, use and disclose your Personal Data for any of the following purposes (“Additional Purposes“):
(a) providing or marketing services and benefits to you;
(b) sending you details of our products and/or services, special offers or events, either to our customers generally, or which we have identified may be of interest to you; and/or
(c) conducting research, analysis and development activities (including data analytics, surveys, product and service development and/or profiling), understanding and analysing customer behaviour, location, preferences and demographics for us to offer you products and services as well as special offers and marketing programmes which may be relevant to your preferences and profile.
3.4 If you have provided us with 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, BBP may contact you using such Singapore telephone number(s) (including via voice calls, text, fax or other means) with information about our products and/or services.
3.5 In relation to particular products and/or 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.
3.6 You may withdraw your consent by contacting us using the contact details set out at paragraph 11 below.
4. DISCLOSURE OF PERSONAL DATA
(a) amongst BBP and its subsidiaries, affiliates and related corporations (including their respective staff);
(b) contractors, agents, service providers and other third parties we use to support our business. These include but are not limited to those which provide administrative or other services to us such as telecommunications, information technology, storage, payment, payroll, processing, training, market research and archival;
(c) vendors or third party service providers and our marketing and business partners in connection with any products, services and/or marketing promotions;
(d) our corporate clients;
(e) any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale);
(f) external banks, credit card companies, payment services providers and their respective service providers;
(g) our professional advisers such as consultants, auditors and lawyers;
(h) 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
(i) any other party to whom you authorise us to disclose your Personal Data to.
4.2 We may share information about you in aggregate or anonymised form, for example, information regarding service related reviews, with the abovementioned entities or parties (e.g. our business partners).
5. TRANSFER OF PERSONAL DATA OUTSIDE OF SINGAPORE AND OFFSHORE STORAGE OF PERSONAL DATA
5.1 We may transfer your Personal Data is transmitted to third-party service providers to provide services for us, such as payment processing, account management, web hosting and other services required by law. We also use third-party service providers to process personal data for service-related and administrative purposes. Such service providers are located in Singapore and other locations where BBP does business. When BBP retains another company to perform a function of this nature, such third party will be required to protect the personal data and will not be authorized to use the Personal Data for any other purpose.
5.2 The countries that we may use, disclose, process, transfer or store your Personal Data in are likely to be China, India, Indonesia, Malaysia, Philippines, Singapore, Taiwan, Thailand, and Vietnam.
6. KEEPING YOUR PERSONAL DATA ACCURATE AND UP-TO-DATE
We encourage you to contact us as soon as possible to enable us to update any Personal Data we have about you. Incomplete or outdated Personal Data may result in our inability to provide, or delays in providing you with products and/or services you have requested, or processing any requests and applications you may have made to us.
7. DEEMED CONSENT
7.1 In addition to the matters set forth above, subject to and in accordance with applicable law, you shall be deemed to have consented to BBP collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to our authorised service providers and relevant third parties:
(a) Where in response to a request for your Personal Data in connection with identified purposes, you voluntarily provide such Personal Data to us for such purpose(s) and it is reasonable that you would voluntarily provide such Personal Data;
8. OTHER BASES FOR HANDLING OR PROCESSING YOUR PERSONAL DATA
(b) For improving our existing or developing new products, services, methods, processes or business, learning and understanding customer preferences and personalising experiences and recommendations, based on your Personal Data records with us.
Cookies – Small text files (typically made up of letters and numbers) placed in the memory of your browser or device when you visit a website or view a message. Cookies allow a website to recognise a particular device or browser. We may employ cookies and other related technologies as follows:
(a) Tracking information such as the number of visitors and their frequency of use, profiles of visitors and their preferred Sites;
(b) Making the Sites and platforms easier to use. For example, cookies may be used to help speed up your future interactions with the Sites and platforms;
(c) To better tailor our products and/or services to your interests and needs. For example, cookies information may be identified and disclosed to our vendors and business partners to generate consumer insights;
(d) Collating information on a user’s search and browsing history;
(e) When you interact with us on any Site and platforms, we may automatically receive and record information on our server logs from your browser. We may collect for the purposes of analysis, statistical and site-related information including, without limitation, information relating to how a visitor arrived at the Site or platform, the browser used by a visitor, the operating system a visitor is using, a visitor’s IP address, and a visitor’s click stream information and time stamp (which may include for example, information about which pages they have viewed, the time the pages were accessed and the time spent per web page);
(f) Using such information to understand how people use the Sites and platforms, and to help us improve their structure and contents;
(g) Using cookies that are necessary in order to enable the Sites and platforms to operate, for example, cookies that enable you to log onto secure parts of the Sites and platforms; and/or
(h) Personalising the Sites and platform for you, including delivering advertisements which may be of particular interest to you and using cookie related information to allow us to understand the effectiveness of our advertisements.
Cookies can be disabled or removed by tools that are available in most commercial browsers. The preferences for each browser you use will need to be set separately and different browsers offer different functionality and options. You can also delete cookies already on your hard drive at any time.
We may use the terms “cookies” or “similar technologies” interchangeably in our policies to refer to all technologies that we may use to collect or store information in your browser or device or that collect information or assist in identifying you as a unique user in the manner described above.
9.3 Some cookies or similar technologies we use are from third party companies to provide us with web analytics and intelligence about the Sites and platforms. These companies collect information about your interaction with the Sites and platforms. We use such information to compile statistics about visitors who interact with the Sites, platforms and tools and other content on the Sites, to gauge the effectiveness of our communications, and to provide more pertinent information to our visitors.
9.4 Certain Sites’ features and services are available only through the use of these technologies. You are always free to block, delete, or disable these technologies. However, if you decline cookies or other similar technologies, you may not be able to take advantage of the Sites’ features or services tools. For more information on how you can block, delete, or disable these technologies, please review your browser settings.
10. THIRD-PARTY SITES
11. RETENTION OF PERSONAL DATA
12. CONTACTING US – WITHDRAWAL OF CONSENT, ACCESS AND CORRECTION OF YOUR PERSONAL DATA
12.2 If you:
(c) would like to obtain access and make correction to your Personal Data records,
please contact us as follows:
|Data Protection Officer, 108 Pasir Panjang Road, #04-02 Golden Agri Plaza, Singapore 118535
|Data Protection Officer [email protected]
12.3 Please note that if your Personal Data has been provided to us by a third party (e.g. your employer), you should contact that organisation or individual to make such queries, complaints, and access and correction requests to BBP on your behalf.
13. GOVERNING LAW