PRIVACY STATEMENT

 

This is Sambaash’s official website. Thank you for taking out time to examine our privacy statement.

 

If you are only browsing this website without logging in, we do not capture data that allows us to identify you individually. Although user sessions are tracked, the users remain anonymous.

 

If you choose to make an application or send us an email for which you provide us with personally identifiable data, we may share necessary data with our technology partners to provide you the necessary service that you are subscribed to in a most efficient and effective way, unless such sharing is prohibited by law. We will NOT share your personal data with any other entities, except where we may need to disclose personal data as required by law or court order.

 

For your convenience, we may also display to you the data you had previously supplied us. This will speed up the transaction and save you the trouble of repeating previous submissions. Should the data that you have supplied to us previously be out-of-date, please supply us with the latest data. We will retain your personal data only as necessary for the effective delivery of subscribed services to you.

 

If you sign-up for our newsletters or demo sessions, we request you to agree with the terms and conditions before sending an approval. Even as you do, as a user you have the right to “unsubscribe” from our database at any time you deem necessary. To safeguard your personal data, all electronic storage and transmission of personal data are secured with appropriate security technologies.

 

This site may contain links to other independently managed websites whose data protection and privacy practices may differ from ours. We are not responsible for the content and privacy practices of these other websites and encourage you to consult the privacy notices of those sites.

 

Governing Law

 

Your use of this website and any dispute arising out of such use of the website is subject to the laws of Singapore.

 

PERSONAL DATA PROTECTION POLICY

 

Your privacy is important to us. This Personal Data Protection Policy of Sambaash sets out how it complies with the provisions of the Personal Data Protection Act 2012 of Singapore (“PDPA”). We recognize the importance and sensitivity of any personal data which we may collect from you from time to time and are committed to protecting your privacy. We will endeavor to process your personal data in accordance with the PDPA and any other relevant legislation.

 

We also want you to understand the way in which we collect, use or disclose your Personal Data. This Personal Data Protection Policy sets out:

a.     our policies on how we manage your Personal Data;

b.     the types of Personal Data we collect, use, disclose and/ or retain;

c.     how we collect, use, disclose and/ or retain your Personal Data; and

d.     the purpose(s) for which we collect, use, disclose and/ or retain your Personal Data.

 

This Personal Data Protection Policy supplements but does not supersede nor replace any other consent which you may have previously provided to us nor does it affect any right that we may have at law in connection with the collection, use, disclosure and/ or retention of your Personal Data.

 

We may update this Personal Data Protection Policy from time to time as Sambaash deems fit. Should any revision(s) be made to this Personal Data Protection Policy, updates will be published on our public site. Subject to your legal rights in Singapore, the prevailing terms of the Personal Data Protection Policy shall apply.

 

This Personal Data Protection Policy forms a part of the terms and conditions governing your relationship with us and should be read in conjunction with such terms and conditions (“Terms of Use”). In the event of any inconsistency between the provisions of the Personal Data Protection Policy and the Terms of Use, the provisions of the Terms of Use shall prevail.

 

References in this Policy to our partners include our strategic partners, stakeholders, agents, and third-party service providers from time to time.

 

Your Personal Data

1.     In this Personal Data Protection Policy, “Personal Data” refers to any data and/or information about you from which you can be identified by, either (a) from that data; or (b) from that data and other information to which we may have legitimate access to. Examples of such Personal Data collected by Sambaash include but are not limited to:

a.     your name, other identification numbers, telephone number(s), mailing address, email address, and any other information relating to you which you have provided in any forms you may have submitted to use, or in other forms of interaction with you;

b.     your photos;

c.     your employment history, education background, and income levels;

d.   information about your usage of and interaction with our website and/ or services including computer and connection information, device capability, bandwidth, statistics on page views and traffic to and from our website

 

2. In the event that we receive personal information through this website, we will only use it to perform the specific services which you have requested.

 

3. For personal data transmitted through this website, while we take reasonable steps to ensure security, by accepting these terms and conditions, you accept that the Internet is not a totally secure medium of communication of information and that such transmission will be at your own risk.

 

4. Your personal data collected and retained by Sambaash will be kept confidential and will only be used in accordance with product and service conditions.

 

Collection of your Personal Data

1.     Generally, we may collect your Personal Data through the following ways:

a.     when you access our websites or perform an online interaction or transaction;

b.     when you interact with any of our employees or our service partner;

c.     when you submit an application (or enquiry or feedback) to us for services and benefits;

d.     when you respond to our request for additional Personal Data;

e.     when you ask to be included in an email or other mailing list;

f.     when you request that we contact you;

g.     when you respond to our initiatives or promotions; 

h.    when you complete our forms;

i.     when you sign up for our training courses;

J.    when someone refers you to us with your consent.

and

k.     when you submit your Personal Data to us for any other reason.

 

2.     When you browse our website, you generally do so anonymously, but please see the section below on “Use of cookies”.

 

Purposes for the Collection, Use and Disclosure of Your Personal Data

1.     Generally, we may collect, use, disclose and/ or retain your Personal Data for the following purposes:

a.     to provide you with benefits and services that you have signed up for with us;

b.     to provide you with training;

c.     to assist you with your enquiries;

d.     to process payment for services rendered to you or any other purchases;

e.   to improve customer services, such as resolving complaints and handling requests and enquiries;

f.     to conduct research, surveys and interviews;

g.    to keep you updated on our events;

h.   to inform you about our membership benefits, services and events that we think may be of interest to you (“Marketing Materials”) via mail, electronic mail, telephone (voice or SMS-Text), facsimile or social media platforms, if you have consented to us sending you Marketing Materials; and

i.     to comply with applicable laws and regulations.

 

Marketing/ Optional Purposes 

1.     If you would like to withdraw your consent to us sending you Marketing Materials, you may withdraw your consent at any time by informing us through the unsubscribe options through applicable electronic channels. We will remove your details from our direct marketing database within one (1) month from the date of receipt of your consent withdrawal request.

 

2.     Please note that notwithstanding the withdrawal or withholding of your consent to us sending you Marketing Materials, we may still send you non-marketing messages such as surveys, customer-service notices, and other service-related notices.

 

Disclosure of your Personal Data

Please note that in accordance with the PDPA, your personal data is required to be kept confidential and not disclosed to any third parties, without your prior consent. However, subject to other relevant laws and the provision of our services and products, your personal data may be disclosed to the following parties/entities:

Our Business Partners and Technology Service Providers;

Regulatory bodies;

Our professional advisers such as our auditors;

Any other person / parties in connection with the purposes set forth above or for other purposes where you have given us your consent.

Any relevant parties that you have authorized us to disclose to.

 

Our BusIness Partners and Technology Service Partners will not be entitled to use your personal data for their own purposes. We will not share or disclose your personal data to any other third parties (whether for marketing purposes or otherwise) without your consent, save as otherwise required or permitted by law.

 

Use of Cookies 

1.     We may collect or analyse anonymised information from which individuals cannot be identified (“Aggregate Information”), such as number of users and their frequency of use, the number of page views (or page impressions) that occur on our websites and common entry and exit points into our websites.

2.     We make use of “cookies” to store and track Aggregate Information about you when you enter our website(s). Such cookies are used to track information such as the number of users and their frequency of use, profiles of users and their online preferences.

3.     Such aggregate Information collected may be used to assist us in analysing the usage of our website(s) so as to improve your online experience with us.

4.     Should you wish to disable the cookies associated with these technologies you may do so by changing the setting on your browser. However, please note that this may affect the functionality of the website(s) and the services subscribed to by you.

 

Consent

Sambaash would require your consent before we can use your personal data for a specified purpose.

 

Protection of your Personal Data

To safeguard your personal data, all electronic storage and transmission of personal data are secured with appropriate security technologies. 

 

We use industry-standard efforts to protect the confidentiality of your personal data, storage of data on secure servers, and taking other security measures to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal, or similar risks in relation to your data. We regularly review developments in relation to security and encryption technologies.

 

However, you will realize that no data transmission over the internet can be guaranteed as totally secure, and therefore, unfortunately, we cannot ensure or warrant the complete security of any information transmitted from our online products or services.

 

Accuracy of personal data

We will take reasonable efforts to ensure that your personal data is accurate and complete if it is used by us or when we disclose it to our partners or to other third parties in accordance with this Policy. Please note that, in most circumstances, we will presume that personal data directly provided by you will be accurate and complete. 

 

However, depending on the circumstances, we may decide to contact you to ensure that this is the case or to ask that you verify that the data we hold in relation to you is up to date. 

 

Access and Correction of your Personal Data

You may also request that we correct any errors or omissions with regards to your personal data and if so, we will normally ensure that this is made as soon as practicable, save where we are satisfied on reasonable grounds that such correction should not be made or where we are not required by law to do so. We reserve the right to charge a reasonable fee for processing your request for access.

 

We will respond to an access request as soon as reasonably possible from the time the access request is received. If we are unable to respond to the request within 30 calendar days after receiving the request, we shall inform the requestor in writing within 30 days of the time by which we will be able to respond to the request.

 

Before responding to an access request and/or correction request, we shall exercise due diligence and adopt appropriate measures to verify the identity of the individual's request. We may ask questions or obtain documentary evidence from the individual in order to verify his/her identity.

 

Withdrawal of Consent

You may withdraw your consent to us and/or our partners collecting, using and/or disclosing your personal data at any time by contacting our Data Protection Officer (dpo@sambaash.com). We will also inform our partners of your request and will ensure that our partners comply with your request, to the extent permitted or required by law. 

 

Please note that if you withdraw your consent to any or all use or disclosure of your Personal Data, depending on the nature of your request, we may no longer be in a position to continue to provide membership benefits and services to you.

 

Such a withdrawal may therefore result in the termination of any membership that you may have with us.

 

Retention of your personal data

We will retain your Personal Data for as long as they are required to fulfil the purposes mentioned above, or as required by applicable laws.

 

 

Third-Party Sites 

1.     This digital service may contain links to other digital services whose data protection and privacy practices may differ from ours. We are not responsible for the content and privacy practices of these other digital services and we encourage you to consult the privacy notices of those digital services.

 

2.     We encourage you to learn about the privacy policies of such third-party website(s) by checking the policy of each site you visit and contact its owner or operator if you have any concerns or questions