GPL
SINGAPORE DATA PROTECTION POLICY
This Data Protection Policy
outlines how GPL Remittance Pte Ltd collects, uses, maintains and discloses
your Personal Data. GPL safeguards your Personal Data in accordance with the
Singapore Personal Data Protection Act (No. 26 of 2012) (“the Act”).
This Data Protection Policy supplements but does not supersede nor replace any
other consents which you may have previously provided to us, and your consents
herein are additional to any rights which we may have as required by our regulators
MAS to collect, use or disclose your Personal Data.
1.
Your consent is important
When you request our services, you may be required to provide us with your
Personal Data. In doing so, you agree and consent to GPL Remittance Pte Ltd and
its related corporations (collectively referred to herein as "GPL",
"us", "we" or "our") as well as our respective
agents, authorised service providers and relevant third parties collecting,
using, disclosing and/or sharing your Personal Data in accordance with this
Data Protection Policy.
Failure to provide such Personal Data or withdrawal of your consent for us to
process your Personal Data may result in GPL being unable to provide you with
effective and continuous services.
If you should withdraw your consent to the processing or handling of your
Personal Data in respect of any purpose which we may reasonably consider to be
essential in order for us to provide you with the services requested / applied
for, we may not be in a position to continue to provide our services to you or
administer any contractual relationship which may be in place between us.
Furthermore, we shall be entitled to treat such withdrawal as your termination
of any account / agreement which you may have with us, without prejudice to any
rights and remedies which we may have at law against you.
Notwithstanding the generality of the foregoing and for avoidance of doubt,
upon the termination or expiry of your contractual relationship with us, we may
still continue using or disclosing your personal data as may be necessary,
required, authorised or permitted for compliance with applicable law or as may
be requested by the relevant regulatory bodies, government agencies, statutory
boards, administrative bodies, authorities or law enforcement agencies to
comply with any laws, rules, guidelines and regulations or schemes to which we
may be subject, whether situated locally or overseas.
2.
What types of Personal Data do we
collect?
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 may 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, or via other forms of interaction with
you.
The Personal Data we collect can be either obligatory or voluntary. Obligatory
Personal Data are those that we require in order to provide you our services.
If you do not provide us with obligatory Personal Data, we would not be able to
provide you services. Voluntary Personal Data are those that are not mandatory
in order for us to provide you with our services. If you do not provide us with
voluntary Personal Data, you can still sign up for our products and services.
Obligatory and voluntary Personal Data differ for each products and services
and will be indicated in the application forms.
3.
How do we collect your Personal Data?
Generally, we obtain your Personal Data in various ways, such as:
o
when you submit application forms or other forms relating to any of
services;
o
when you use some of our services (including but not limited to
websites, apps and any online accounts established with us);
o
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;
o
when you sign up for or use one of the many services we provide or
when you register an account at any GPL websites;
o
when you contact any GPL entities through various methods such as
application forms, emails and letters, telephone calls and conversations you
have with our staff in a branch. If you contact us or we contact you using
telephone, we may monitor or record the phone call for quality assurance,
training and security purposes;
o
from our analysis of your transactions (including but not limited
to transaction history);
o
when you participate in customer surveys or when you sign up for
any of our competitions or promotions;
o
when you submit a job application;
o
when we receive references from business partners and third
parties, for example, where you have been referred by them;
o
when we seek information from third parties about you in
connection with your transaction applications or job applications, for example,
from your ex-employer and the relevant authorities; and
o
when you submit your Personal Data to us for any other reasons.
What is the purpose of processing your Personal Data?
Generally, GPL collects, uses and discloses your Personal Data for the
following purposes:
o
responding to your queries and requests;
o
verifying due diligence checks;
o
managing the administrative and business operations of GPL and
complying with internal policies and procedures;
o
matching any Personal Data held which relates to you for any of
the purposes listed herein;
o
resolving complaints and handling requests and enquiries;
o
preventing, detecting and investigating crime, including fraud and
money-laundering, and analysing and managing commercial risks;
o
maintaining security of GPL premises (including but not limited to
CCTV surveillance and issuing building access passes);
o
meeting or complying with any applicable laws, regulations,
directives, rules, codes of practice or guidelines issued by any legal or regulatory
bodies which GPL may be subject to, whether local or overseas (including but
not limited to disclosures to regulatory bodies, conducting audit checks,
surveillance and investigation);
o
legal purposes (including but not limited to obtaining legal advice
and dispute resolution); and
o
purposes which are reasonably related to the aforesaid.
In addition:
If you are
an employee of an external service provider of GPL, GPL also collects, uses and
discloses your Personal Data for the following purposes:
o
issuing building access pass and maintaining building security;
o
managing project tenders;
o
processing and payment of vendor invoices;
o
profiling in media activities; and
o any other purpose reasonably related to any of the above.
If you
submit an application to us as a candidate for an employment or representative
position, GPL also collects, uses and discloses your Personal Data for the
following purposes:
o
conducting interviews;
o
processing your application (including pre-recruitment checks
involving your qualifications);
o
providing or obtaining employee references and for background
screening;
o
evaluating and assessing your suitability for the position applied
for; and
o any other purposes reasonably related to any of the above.
Where
permitted under the Act, GPL may also collect, use and disclose your Personal
Data as follows:
o
providing cross-referrals to other members of the GPL;
o
conducting analytics with regard to services which you might be
interested in;
o
administering contests, lucky draws and competitions;
o
organising promotional events and corporate social responsibility
projects (including but not limited to taking pictures and recording your
video/audio feedback and testimony in relation thereto);
o
providing services, products and benefits to you, including
promotions, loyalty and reward programmes;
o
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 services, whether by GPL or other third parties;
o
sending you details of products, services, special offers and
rewards, either to our customers generally, or which we have identified may be
of interest to you (including but not limited to cross selling and
telemarketing); and
o conducting market research, understanding and determining customer
location, preferences and demographics for us to review, develop and improve
our products, services and also 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, GPL may contact you using such Singapore
telephone number(s) (including via voice calls, text, fax or other means) with
information about our products and services (including discounts and special
offers).
In relation
to particular products 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.
You have a
choice to withdraw your consent for receiving marketing or promotional materials
/ communication. You may contact us using the contact details found below.
Please be
aware that once we receive confirmation that you wish to withdraw your consent
for marketing or promotional materials/communication, we will require some time
to process your withdrawal request. During this period of time you may still
receive marketing or promotional materials/communication. Please note that even
if you withdraw your consent for the receipt of marketing or promotional
materials, we may still contact you for other purposes in relation to the
accounts, facilities or services that you hold or have subscribed to with GPL.
5.
To whom do we disclose your Personal Data?
Your Personal Data held by us shall be kept confidential. However, in order to
provide you with effective and continuous products and services, and for the
purposes listed above (where applicable), your Personal Data may be disclosed
to the following parties:
o
entities within GPL including our head office and any of its
branches, representatives offices, subsidiaries, related corporations and
affiliates;
o
agents, contractors or third party service providers who provide
operational services to GPL, such as courier services, telecommunications,
information technology, payment, payroll, processing, training, survey, market
research, storage, archival or other services to GPL;
o
vendors and other third party service providers in connection with
promotions, online campaigns, products and services offered by GPL;
o
credit bureaus and credit reporting agencies;
o
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);
o
other financial institutions, banks and their respective service
providers;
o
our professional advisers such as financial advisors, auditors and
lawyers;
o
relevant regulatory bodies, government agencies, statutory boards,
administrative bodies, authorities or law enforcement agencies to comply with
any laws, rules, guidelines and regulations or schemes to which GPL may be
subject, whether situated locally or overseas;
o
counterparties, billing organisations and their respective banks
or our distribution agents in relation to fund transfers, and payments;
o any other party to whom you authorise us to disclose your Personal
Data to.
6.
How do we protect your data?
Employee access is only limited to authorised employees who are fully trained
in handling your information. These authorised personnel are required to ensure
the confidentiality of your information and to respect your privacy at all
times. Employees who have access to your information will be subjected to
disciplinary action should they fail to observe this Data Protection Policy and
other guidelines, codes or policies which we may issue to them from time to
time.
If we disclose any of your Personal Data to our authorised agents or service
providers, we will require them to appropriately safeguard the Personal Data
provided to them.
7.
How long may we retain your Personal Data?
We will only retain your Personal Data for as long as necessary to
fulfil the
purpose(s) for which it was collected or to comply with legal, regulatory and
internal requirements.
8.
Changes to this Data Protection
Policy
Please note that we may update this Data Protection Policy from time to time to
ensure that this Data Protection Policy is consistent with our future
developments, industry trends and/or any changes in legal or regulatory
requirements. If there are material changes to this Data Protection Policy, we
will notify you by posting a notice of such changes on our website or by sending
you a notification directly. Do periodically review this Data Protection Policy
to stay informed on how we are protecting and managing your information.
Subject to your rights at law, you agree to be bound by the prevailing terms of
the Data Protection Policy.
This Data Protection Policy was last updated in April 2015.
9.
Access and correction of your Personal Data
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 / applied for.
We are committed to ensure that the Personal Data we hold about you is
accurate, complete, and up-to-date. If there are any changes to your Personal
Data or if you believe that the Personal Data we have about you is inaccurate,
incomplete, misleading or not up-to-date, please contact us so that we may take
steps to update your Personal Data.
You have the right to access your Personal Data. If you would like to request
access to your Personal Data, please contact us. Please note that depending on
the information requested we may charge a small fee. We may also take steps to
verify your identity before fulfilling your request for access to your Personal
Data.
10.
How can you contact us?
If you need to contact us, you may visit our branch, call our Data Protection
Officer on (65)6291 2991 or (65) 6294 7081 (Overseas) or visit us
at
www.gpl.com.sg.
Alternatively, you may also write to our Data Protection Officer as
follows:
Data Protection Officer
GPL Remittance Pte Ltd
5001 Beach Road
#01-77A Golden Mile Comple
Singapore 199588
Effective date: 1 April 2015
