Privacy Policy
1. Introduction
This data protection policy applies to Defence Collective Singapore (DCS). This policy governs the collection, use and disclosure of personal data submitted to DCS, including through; job application, membership application, survey/feedback forms and indemnity forms for outdoor activities, explains how we collect and handle personal data of individuals, and comply with the requirements of the Personal Data Protection Act 2012 of Singapore and its regulation(s) (“PDPA”). In this policy, “personal data” shall have the meaning ascribed to it in the PDPA.
Protection of your personal data is important to us. We do not make available your personal information to third parties for their marketing purposes without your explicit consent. Please read this policy to learn more about how we use and protect your personal information. If you have additional questions, you may send email to our Data Protection Officer at [email protected].
2. Main Data Protection Policy
We will collect, use, or disclose personal data for reasonable business purposes only if there is consent or deemed consent from the individual and information on such purposes has been notified to the individual. We may also collect, use or disclose personal data if it is required or authorised under applicable laws.
2.1 Collection of Personal Data
We collect personal data from customers, business contacts, partners, personnel, contractors and other individuals. Such personal data may be provided to us in forms filled out by individuals, face to face meetings, email messages, telephone conversations, through our websites or provided by third parties. If any individuals contact us, we may keep a record of that contact.
We collect these personal data when it is necessary for business purposes or to meet the purposes for which the individuals have submitted the information.
We will only collect, hold, process, use, communicate and/or disclose such personal data, in accordance with this policy. If you are acting as an intermediary or otherwise on behalf of a third party individual or supplying us with information regarding a third party individual (such as a friend, a colleague, an employee etc), you undertake that you are an authorised representative or agent of such third party individual and have obtained all necessary consent from such third party individual to the collection, processing, use and disclosure of their personal data by us. As we are collecting the third-party individual’s data from you, you undertake to make the third party individual aware of all matters listed in this policy preferably by distributing a copy of this policy to them or by referring them to this policy on our website.
2.2 Use of Personal Data
We use personal data for the following purposes:
(a) to provide our services
(b) to respond to the individual’s request or for the purposes for which it was provided to us as stated at the time of the collection (or as is obvious from the context of collection)
(c) to keep customers and other contacts informed of the services we offer, seminars and other events we are holding, that may be of interest to them
(d) for general management and reporting purposes, such as invoicing and account management
(e) for recruitment
(f) all other purposes related to our business.
Any individual may choose to unsubscribe from our mailing lists, registrations, or elect not to receive further marketing information from us by contacting our Data Protection Officer. If we have contacted such individual by email, such individual may use the unsubscribe function in that email to notify us. Such requests will be processed within a month.
2.3 Disclosure of Personal Data to Third Parties
We do not disclose personal data to third parties except when required by law or when we have the individual’s consent or deemed consent or in cases where we have engaged third parties such as data intermediaries or subcontractors specifically to assist with our firm’s activities. Any such third parties whom we engage will be bound contractually to keep all information confidential.
2.4 Keeping Your Personal Data Accurate and Up-To-Date
We endeavour to ensure that all personal data we have about you is accurate and up-to-date. We understand that this information may change from time to time; we encourage you to contact us as soon as possible to enable us to update any personal data we have about you. Complete or updated data will allow us to cater to your needs more effectively.
2.5 Withdrawal of Consent
Upon reasonable notice being given by an individual of his withdrawal of any consent given or deemed to have been given in respect of our collection, use or disclosure of his personal data, we will inform the individual of the likely consequences of withdrawing his consent. We will cease to collect, use or disclose the personal data unless it is required or authorised under applicable laws.
2.6 Security and Protection of Personal Data
We have implemented generally accepted standards of technology and operational security to protect the personal data in our possession or under our control and to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. Only authorised DCS personnel are provided access to personally identifiable information and these personnel have agreed to ensure confidentiality of this information.
This digital service may contain links to non-DCS 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 websites and encourage you to consult the privacy notices of those sites.
2.7 Retention of Personal Data
We will cease to retain personal data, as soon as it is reasonable to assume that the purpose for collection of such personal data is no longer being served by such retention, and such retention is no longer necessary for legal or business purposes. Where we no longer require any personal data that we hold, that personal data would be destroyed or particulars or information which may identify individuals would be removed.
2.8 Privacy on Our Websites
This Policy also applies to any personal data we collect via our websites. Our primary purpose in collecting personal information is to provide you with a safe, smooth, efficient, and customised experience. This allows us to provide services and features that most likely meet your needs, and to customise our service to make your experience safer and easier.
We only collect personal information about you that we consider necessary for achieving this purpose. Once you give us your personal information, you are not anonymous to us. If you choose to use our services, we may require you to provide contact and identity information and other personal information as indicated on the forms throughout the site. Where possible, we indicate which fields are required and which fields are optional. You always have the option not to provide information by choosing not to use a particular service or feature. We automatically track certain information based upon your behaviour on the site. We use this information to do internal research on our users’ demographics, interests, and behaviour to understand better, protect and serve you and our community. This information may include the URL that you just came from (whether this URL is on the site or not), which URL you next go to (whether this URL is on the site or not), your computer browser information, and your IP address.
We use data collection devices such as “cookies” on certain pages of the site to help analyse our web page flow, measure promotional effectiveness, and promote trust and safety. “Cookies” are small files placed on your hard drive that assist us in providing our services. We offer certain features that are only available through the use of a “cookie”. We also use cookies to allow you to enter your password less frequently during a session. Cookies can also help us provide information that is targeted to your interests. Most cookies are “session cookies”, meaning that they are automatically deleted from your hard drive at the end of a session. You are always free to decline our cookies if your browser permits, although in that case, you may not be able to use certain features on the site and you may be required to re-enter your password more frequently during a session. After termination of the visit to our site, a visitor can always delete the cookie from his/her system if he/she so wishes.
2.9 Data Protection Officer
If an individual believes that information, we hold is incorrect or out of date, or if an individual has concerns or further queries about how we are handling his personal data, or any problem or complaint about such matters, please contact our Data Protection Officer at [email protected].
2.10 Modifications
We reserve the right to modify or amend this Policy at any time. The effective month will be displayed at the beginning of this Policy. To keep you informed, we will notify changes to this Policy by prominently identifying the alteration for a period of not less than two weeks on our home page at https://www.defencecollectivesg.com.
3. Recruitment Data Protection Policy
We believe that privacy is an important individual’s right, and this policy provides information regarding our use and disclosure of personal data collected from individuals for recruitment purpose. DCS’s information handling practices are in accordance with the current privacy and data protection legislation in Singapore.
For more general information about the privacy practices of DCS, please refer to our main Data Protection Policy.
3.1 Why do we collect personal data?
As part of our recruitment process, we collect necessary personal data about you to consider you for employment. During the course of the recruitment and selection process, we may request further information about you to assess your suitability for positions with DCS. In doing so, we only collect personal data that is necessary for recruitment decisions. The procedures used by DCS to gather further information about you might include:
(a) selection interviews;
(b) written skills tests;
(c) referee reports; and,
(d) necessary pre-employment activities.
References from your current or former employer(s) or other sources will only be obtained with your consent. Failure to provide the requested information may influence the processing and outcome of your application.
3.2 How do we use personal data?
We use the personal data for the following purposes:
(a) managing your application(s) for employment, evaluating you for open positions and managing your candidate profile;
(b) evaluating your suitability for employment with DCS (including, for example, providing your personal information to third parties to conduct background checks);
(c) sending you email notifications and other announcements, requesting additional information, or otherwise contacting you about your candidacy;
(d) relating to any other purposes for which you provided the information to DCS.
We will not collect or use your personal data in ways other than as described in this policy unless we have obtained your consent. In some cases, we may specifically request a consent form to be signed. In other cases, consent may be implied (for instance, you give us information after being fully advised of how it will be used).
3.3 Disclosure of personal data
Your personal data will be used only by staff directly involved in the recruitment process. Information will not be disclosed to third parties except when required by law, when we have your consent or in cases where the third party is a contractor or supplier whom we have engaged specifically to assist with our company’s activities. All such contractors will be bound contractually to keep all information confidential.
3.4 How is this information secured?
DCS has implemented generally accepted standards of technology and operational security to protect your personal information from loss, misuse, or destruction. In particular, DCS has put in place appropriate confidentiality obligations and technical and organisational security measures to prevent any unauthorised or unlawful disclosure or processing of such information and the accidental loss or destruction of or damage to such information.
3.5 How long will the information be kept?
As DCS needs to process your personal data to consider you for a position as part of the recruitment process and if you should revoke your consent, DCS may need to terminate your application. DCS may retain certain information related to your application for a period not longer than one year to meet applicable legal or records retention requirements. To request us to delete your personal data submitted to DCS, please send your request to [email protected].
Access to your personal data can be made by request to us unless granting access would infringe another person’s privacy. If you wish to gain access to your personal data, please send your request to [email protected].
3.6 Correction and Concerns
If you believe that the information, we hold about you is incorrect, if you have concerns about how we are handling your personal data, or if you change your mind about our usage of your data, please email us at [email protected], and we will try to resolve those concerns.
3.7 Changes to DCS’s Recruitment Data Protection Policy
DCS reserves the right to modify or amend this policy at any time and for any reason. However, DCS commits to ensure that the privacy rights of individuals are maintained.
3.8 Contact our Privacy Office
We welcome your enquiries or comments about our Recruitment Data Protection Policy and for any queries or concerns that you may have about this policy, you may email us at [email protected].
4. Marketing Data Protection Policy
DCS believes that privacy is an important individual’s right and this policy provides information regarding our use and disclosure of personal data collected from individuals including via our websites for marketing purposes. DCS’s information handling practices are in accordance with the current privacy and data protection legislation in Singapore.
For more general information about the privacy practices of DCS, please refer to our main Data Protection Policy.
4.1 Why do we collect personal data and how do we use it?
Our business is to understand and meet your needs and provide you with the products and services that you require. To do this effectively, we need to collect a range of personal data about you.
In general, DCS collects, uses and discloses your personal data for the following purposes:
(a) to provide you with the products or services that have been requested;
(b) to help us manage the delivery of and enhance our products and services, including analysing customers’ needs and identifying potential customers’ needs;
(c) to communicate with you and respond to your queries, requests and feedback;
(d) to provide ongoing information about our products and services which may be of interest to you;
(e) to handle disputes; conduct and facilitate investigations and proceedings;
(f) to protect and enforce our contractual and legal rights and obligations;
(g) 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.
(h) If you have a membership account with us:
(1) to process your application for the account;
to maintain your account with us;
(2) to verify your personal particulars and process payment requests in relation to the provision of services which you may be entitled to or which you may have requested for;
(3) to communicate with you on changes and development of DCS and policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you;
(4) to manage feedback and handle requests and enquiries; and
(5) to conduct market research for profiling and statistical analysis for the improvement of services provided to you.
4.2 Retention of Personal Data
Personal data which is kept by DCS will be destroyed no longer than 6 months from the time when it becomes outdated or is no longer required for the purpose for which it was collected or when we receive your request to delete it.
4.3 How is this personal data secured?
The personal data submitted to DCS is stored in our contacts database or similar system and is available to only authorised DCS’s staff and contractors.
4.4 Access to and Correction of Personal Data
If you wish to access, delete or correct your personal data provided to us or if you have any concerns about how we handle information about you, please send your request to our Data Protection Officer at [email protected].
Upon request, we will provide the individual with access to their personal data or other appropriate information on their personal data in accordance with the requirements of the PDPA.
Upon request, we will correct an error or omission in the individual’s personal data that is in our possession or control in accordance with the requirements of the PDPA.
4.5 Withdrawal of Consent
Upon reasonable notice being given by an individual of his withdrawal of any consent given or deemed to have been given in respect of our collection, use or disclosure of his personal data, we will inform the individual of the likely consequences of withdrawing his consent. We will cease (and cause any of our data intermediaries and agents to cease) collecting, using or disclosing the personal data unless it is required or authorised under applicable laws.
4.6 Disclosure of Data to Third Parties
The personal data submitted will not be disclosed to third parties except when required by law, when we have your explicit consent or in cases where the third party is a contractor or supplier whom we have engaged specifically to assist with the company’s activities. All such contractors will be bound contractually to keep all information confidential.
As a matter of policy, we do not sell or rent any of your personal information to third parties for their marketing purposes without your explicit consent. However, the following describes some of the ways that your personal information may be disclosed in the normal scope of business to provide our services.
Advertisers. We aggregate (gather up data across all user accounts) personal information and disclose such information in a non-personally identifiable manner to advertisers and other third parties for their marketing and promotional purposes. However, in these situations, we do not disclose to these entities any information that could be used to identify you personally. Certain information, such as your name, email address, password, credit card number, and bank account number, will not be disclosed to these third parties in a personally identifiable manner without your explicit consent.
Internal Service Providers for Our Operations. We may use third parties that we refer to as internal service providers to facilitate or outsource one or more aspects of the business, product and service operations that we provide to you (e.g., search technology, discussion boards, bill collection, affiliate and rewards programs, co-branded credit cards) and therefore we may provide some of your personal information directly to these internal service providers. These internal service providers are subject to confidentiality agreements with us and other legal restrictions that prohibit their use of the information we provide them for any other purpose except to facilitate the specific outsourced DCS related operation unless you have explicitly agreed or given your prior permission to them for additional uses. In some instances, the internal service provider may collect information directly from you. In these cases, you will be notified of the involvement of the internal service provider, and all additional information you provide them, and their additional uses will be strictly up to you. If you provide additional information to an internal service provider directly, then their use of your personal information is governed by their applicable privacy policy.
Other Corporate Entities. DCS will share some or all of your personal information with another business entity should we plan to merge with or be acquired by that business entity. Should such a combination occur, we will require that the new combined entity follow this policy concerning your personal information.
4.7 Contact our Data Protection Officer
If an individual believes that information, we hold is incorrect or out of date, or if an individual has concerns or further queries about how we are handling his personal data, or any problem or feedback about such matters, please contact our Data Protection Officer at [email protected]. We will get back to you within 7 working days.
