Privacy Policy

OVERVIEW

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, signing up for any events, performances or services offered by us, completing any of our website forms, contacting any of our staff (including but not limited to our customer experience team), interacting with our social media platforms or posts or using any of our applications, 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 Personal Data Protection Act 2012 (“PDPA”), “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/FIN number, birth certificate number 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 and in this respect may disclose, transfer or share your personal data to certain third parties without further notice to you (including SISTIC, credit, debit or charge card companies, banks or other entities processing payment instructions through SSCL’s websites, marketing agents, lawyers, professional advisers and auditors;

(c)    giving you access to possible rewards, privileges, promotions, offers, services or products offered by SSCL as well as partners, merchants or third party organizations that SSCL collaborates or partners with (collectively “member privileges”)

(d)    administering and dealing with your member benefits, sharing your personal data with SSCL to administer and deal with member benefits, contacting you through various modes of communication including via phone, voice call, text messaging, email or postal mail in any matters relating to your membership (including mailing of correspondence, statements, information, notices or invoices which could include certain personal data about you), performing internal administrative, operational and technology-related tasks for the said purposes, storage and/or backup of your personal data.

(e)    conducting market research and customer satisfaction surveys;

(f)    for marketing purposes and in this regard, we would (to the extent you have consented) be providing you marketing, advertising and promotional information, materials and/or documents relating to products productions, shows, concerts, contests, services, member benefits and/or events by the means you specify to us;

(g)    to notify you of any changes to our policies or services which may affect you;

(h)    to respond to queries and feedback;

(i)    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;

(j)    monitoring, processing and/or tracking your use of SSCL’s websites in order to facilitate your use of the websites and to assist us in improving your experience in using our websites;

(k)    conducting research, analysis and development activities (including but not limited to data analytics, surveys, product and service development and/or profiling) to improve SSCL’s products and services or to enhance your experience;

(l)    to enable us to develop, deliver and improve our services and our websites in order to better attend to your needs;

(m)    carrying out your instructions or responding to any enquiry or complaint given by you or on your behalf including responding to your enquiries and complaints, or responding to or dealing with your interactions with us or your requests, or responding to or dealing with your feedback, comments or reviews;

(n)    storing, hosting, backing up (whether for disaster recovery or otherwise) your personal data whether within or outside Singapore;

(o)    maintaining and/or developing our IT or business systems and infrastructure including testing and upgrading of these systems;

(r)    record-keeping purposes and producing statistics and research for internal and / or statutory reporting and or record-keeping requirements;

(s)    complying with any applicable law, governmental or regulatory authority in Singapore or other countries / jurisdictions, including meeting the requirements to make disclosure under the requirements of the laws of Singapore or such other countries/ jurisdictions
and

(t)    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.

MARKETING

3.1       When you register for any of the Company’s events, you may opt-in to receive marketing information via email or such other means from the Company [and other third parties]. The information will include latest news on the Company’s events as well as any promotions, contests or lucky draws.

3.2       If you opt to receive marketing information from the Company or our marketing agents:

(a)    We will use your email address to inform you about the Company events, promotions, contests or lucky draws. We may also display event-related content and advertising on our Site where we believe this may be of interest to you.

(b)    We collect your personal data in our own capacity and for our own use, and such use of your personal data by the Company shall be governed by the terms of this Privacy Policy. We may also use marketing agents and disclose your email address to our marketing agents for the purposes of carrying out the above marketing activities on our behalf.

(c)    If you change your mind at any time and wish to un-subscribe from the Company’s marketing material, you may easily do so via the unsubscribe link found on each email.

THIRD PARTIES

4.1       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. Our third party service providers currently include but are not limited to Shopify Inc. 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.

4.2       Where the Company discloses your personal data to third parties, the Company will employ reasonable measures to ensure the protection of your personal data, such as imposing suitable contractual clauses on such third parties or disclosing only to reputable organisations.

COLLECTION, USE OR DISCLOSURES EXEMPT FROM CONSENT REQUIREMENT

5.1       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 collect, use or disclose your personal data to third parties without first obtaining your consent in certain situations, including, without limitation, the following:

(a)    when the collection, use or disclosure is required or authorised based on the applicable laws and/or regulations;

(b)    when the purpose of such collection, use or disclosure is clearly in your interests, and if consent cannot be obtained in a timely way or you would not reasonably be expected to withhold consent;

(c)    the collection, use or disclosure of your personal data is in the legitimate interests of SSCL or another person and the legitimate interests of SSCL or such other person outweigh any adverse effect on you (provided that we will identify any adverse effect that the proposed collection, use or disclosure and identify will have on you and implement measures to eliminate, reduce the likelihood of or mitigate such adverse effect);

(d)    when the disclosure is necessary to respond to an emergency that threatens the life, health or safety of yourself or another individual;

(e)    where consent for the collection, use or disclosure (as the case may be) cannot be obtained in a timely way and there are reasonable grounds to believe that the health or safety of the individual or another individual will be seriously affected;

(f)    when the disclosure is necessary for any investigation or proceedings;

(g)    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;

(h)    when the disclosure is to a public agency and such disclosure is necessary in the national or public interest;

(i)    when it is necessary for the organisation to obtain legal services; and/or

(j)    where such disclosure without your consent is permitted by the PDPA or by law.

5.2       The instances listed above at paragraph are not intended to be exhaustive. For more information on the exceptions, you are encouraged to peruse the First and Second Schedules of the PDPA which is publicly available at https://sso.agc.gov.sg/Act/PDPA2012.

ACCESS, UPDATE, CORRECTION AND WITHDRAWAL OF PERSONAL DATA

6.1       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 [30] days. Do note that the PDPA exempts certain types of personal data from being subject to your access or correction request.

6.2       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.

6.3       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.

COOKIES

 7.       Cookies are text files that we put on your computer and they store/record information about your visit to and use of the website. SSCL uses cookies on our websites to track website visitorship and experience which can compile information about your browsing habits and can also enhance your browsing experience Most web browsers are designed to accept cookies. If you do not wish to receive any cookies, you may set your browser to refuse it.

ADMINISTRATION AND MANAGEMENT OF PERSONAL DATA

8.1       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.

8.2       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.

8.3       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.

8.4       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.

SOCIAL MEDIA

9.1       In the course of your dealing with SSCL, you may interact with SSCL’s social media websites (e.g. Facebook, Instagram, YouTube, TikTok). Please note that when you interact with SSCL’s social media sites we may collect, use, disclose, transfer and store/retain information relating to your account with such social media sites in accordance with this Privacy Policy. Such information may include your ID (YouTube ID, Facebook ID, Instagram Handle or Tiktok Handle), first name, last name, email, location, friends list and profile picture to provide certain functions on SSCL’s services, such as recommending events that your friends are interested in and sharing the events that you are interested in or attending, with certain groups of friends.

9.2       When you “like” or “follow” us on our social media sites, we may collect some information from you including your name, e-mail address, and any comments or content you post relevant to us. We likewise may collect your personal data if you submit information to us through social media sites.

9.3       SSCL”s website may contain links to social media sites (e.g. Facebook, Instagram, YouTube, TikTok). When you interact with these links, your browser will establish a direct link with the social media sites’ servers. The social media site will then receive information about your browser and activity, and may link it to your social media account. For more information about how the social media sites use data, please refer to their policies.

EUROPEAN UNION GENERAL DATA PROTECTION REGULATION ("GDPR")

10.1      This paragraph applies to the extent that the GDPR is applicable to your personal data and/or to the activities which we are carrying out in relation to your personal data. Typically, this would be where: (a) you are a European Union resident; and (b) when you are a resident in the European Union we process your personal data in relation to our offering of goods or services to you in the European Union.

10.2      In relation to the processing of your personal data by us, we are a data controller. If the GDPR applies to your personal data that is within our possession or control, you will have rights as set out in the GDPR.

10.3      We process your personal data based on one or more of the following legal basis :

(a)    you have provided us with your consent for the purposes of processing in question;

(b)    Where processing is necessary for the performance of a contract to which you are a party to or in order for us to take steps at your request prior to us entering into such a contract;

(c)    Where processing is necessary for us to comply with a legal obligation to which we are subject to;

(d)    Where processing is necessary in order to protect your vital interests or of another individual;

(e)    Where processing is necessary for the performance by us of a task carried out in the public interest or in the exercise of official authority vested in us; or

(f)    Where processing is necessary for the purposes of our legitimate interests, except where such interests are overridden by your interests or fundamental rights and freedoms.

Our legitimate interests are :

i.      responding to your queries;
ii.     providing products, services and/or information to you;
iii.    recruiting staff;
iv.    one or more of the purposes set out at paragraph 3.1 above; and/or
v.     one or more of the purposes other than the purposes referred to at (iv) above which we notify you of at the time of obtaining your consent.

We consider that the risk to your data protection rights in connection with personal data that we process on the basis of our legitimate interests is not excessive or overly intrusive. We have also put in place protection for your rights by ensuring proper retention period(s) and security controls.

UPDATE TO POLICY

 11.      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.

GOVERNING LAW

 12.      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

 13.      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 : dpo@sso.org.sg

[This Policy was last updated on 12 June 2024]

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