Version 1 dated 2 July 2014 (this "Policy")

This Policy is to inform you of how the Prima Group of Companies, its subsidiaries, related corporations and business units (collectively referred to as "Prima") manage Personal Data pursuant to the Personal Data Protection Act 2012 (No. 26 of 2012) (the "Act"), which comes into full effect on 2nd July 2014.

As a customer of Prima, by signing up for Prima products and services, you agree and consent to submitting your Personal Data to Prima for Prima's collection, use, disclosure and sharing within and amongst the Prima Group of Companies, and disclosing such Personal Data to Prima's authorised service providers and relevant third parties, as the case may be, where applicable, as set out herein.

This Policy supplements but does not supersede nor replace any other consents you may have previously provided to Prima in respect of your Personal Data, and your consents herein are additional to any rights which Prima may have at law to collect, use or disclose your Personal Data.

Prima may from time to time update this Policy in line with legal, regulatory requirements and under the Act. Subject to your rights at law, you agree to be bound by the prevailing terms of this Policy as updated from time to time on our websites:- or as notified.

  1. Personal Data
    1. Personal Data means 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 Prima has or is likely to have access, including data in Prima's records as may be updated from time to time.
    2. Personal Data include (depending on the type of interaction with Prima) your name, date of birth, NRIC number, passport or other identification number, telephone number(s), mailing address, email address, network data and any other information relating to you or any individuals which you have provided to Prima in any forms you may have submitted to us, or via other methods of interaction with you, as the case may be, where applicable.
  2. Collection of Personal Data
    1. We will request your Personal Data:-
      1. when you submit an application form or other forms relating to any Prima products and services;
      2. when you interact with our customer service officers, among other things, via telephone calls, face-to-face meetings, emails and other correspondences;
      3. when you use Prima services, for example, websites and apps or other electronic IT applications including establishing any online accounts with us;
      4. when you request to be included in an email, mailing lists and other forms of updates and communication;
      5. when you respond to our promotions, initiatives or requests for additional Personal Data;
      6. when you are contacted by, and respond to, our marketing representatives and customer service officers;
      7. when we receive references from business partners and third parties, as referred to us;
      8. when we seek information from third parties about you in connection with Prima products and services you have applied for; and
      9. when you submit your Personal Data to us for any other reasons.
    2. When you browse our websites, you generally do so anonymously (refer to Section 5 below on Use of Cookies). Our websites do not automatically collect Personal Data unless you provide such information or login with your account credentials.
    3. If you provide us with any Personal Data relating to a third party (in relation to your spouse, children, parents, and/or other individuals), by submitting such information to us, you represent to us that you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes.
    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 the Prima products and services you have requested.
  3. Purpose of Collection, Use and Disclosure of Personal Data
    1. Personal Data will be collected, used and disclosed by Prima for the following purposes:-
      1. administering, managing and executing our agreements with you;
      2. responding to your queries and requests;
      3. managing the administrative and business operations of Prima and complying with our internal policies and procedures;
      4. facilitating business asset transactions involving any Prima companies;
      5. resolving complaints and handling requests and enquiries in relation to Prima business;
      6. preventing, detecting and investigating crime, analysing and managing commercial risks;
      7. providing media announcements and responses;
      8. monitoring, recording phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes;
      9. legal purposes (including but not limited to obtaining legal advice and dispute resolution);
      10. conducting investigations relating to disputes, billing or fraud;
      11. delivery of notices, services or products and the marketing of such services or products whether presently or in future, to you;
      12. maintenance and upkeep of customer records and development, marketing and client profiling activities, organising promotional events;
      13. credit assessments, financial and background investigation, as the case may be, where applicable;
      14. meeting any legal or regulatory requirements relating to provision of Prima services and products and to make disclosure to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority where applicable; and
      15. sending you information by e-mail, regular postal mail, telecommunication means (telephone calls, SMS messages and other electronic format) or internet social media about products and services offered by selected third parties that we think may interest you.
    2. You may at any time withdraw, in full or in part, your disclosure consent given previously, in each case subject to any applicable legal restrictions, contractual conditions and a reasonable time period in Section 6.1 below.
  4. Disclosure of Personal Data
    Prima will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, your Personal Data may be disclosed for the purposes listed in Section 3 above, as the case may be, where applicable, to the following:-
    1. Prima to address your questions and requests in relation to you signing up for any Prima products and services;
    2. business partners, affiliates, contractors, third party service providers who provide operational or related services or products in connection with our Prima business to facilitate your dealings with us;
    3. vendors or third party service providers in connection with marketing promotions and services offered by Prima or its preferred partners;
    4. commercial shops, retailers or our appointed service providers in relation to our loyalty programmes, delivery gift redemption and services or Prima business;
    5. any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions involving Prima;
    6. any government agencies, statutory boards or authorities or industry regulators to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority;
    7. banks, credit card companies and their respective service providers;
    8. our professional advisers such as auditors, consultants, lawyers, accountants or other financial or professional advisers in connection with our Prima business; and
    9. any other party to whom you authorise us to disclose your Personal Data.
  5. Use of Cookies
    1. Prima uses "cookies", where a small data file is sent to your browser to store and track information about you and your preferences when you visit our websites.
    2. Prima uses cookies on its websites for the following purposes:-
      1. enabling certain features and functions on our websites, such as remembering your user-id, browsing and other service preferences;
      2. building up a profile of how you and other users use the websites;
      3. improving the efficiency of our websites;
      4. administering services to you and to advertisers; and
      5. establishing usage statistics.
    3. Most internet browsers provide you the option of turning off the processing of cookies (please see the "help" section of your browser), but this may result in the loss of functionality, restrict your use of the websites and/or delay or affect the way in which it operates.
    4. Advertisements on our websites may be provided by third party advertisers and their agencies. These may generate cookies to track how many people have seen a particular advertisement (or use the services of third parties to do this), and to track how many people have seen it more than once. Prima does not control these third parties and their cookie policies and if you have questions about their cookie policies, please contact Prima and we will try our best to assist by providing you information about these third party advertising agencies.
    5. Prima is not responsible for the Personal Data policies (including Personal Data protection and cookies), content or security of any third party websites linked to the Prima websites.
  6. Withdrawal of Consent, Access and Correction of Your Personal Data
    1. You may at any time raise any questions or provide feedback relating to your Personal Data or this Policy, or would like to withdraw or amend, in full or in part, your consent given previously to any use of your Personal Data in Prima's records, in each case subject to any applicable legal restrictions, contractual conditions and a reasonable time period. Please contact:-
      Data Protection Officer
    2. Please note that if your Personal Data has been provided to us via a third party, you should contact that particular organisation or individual directly to make such queries, complaints, access and correction requests to Prima for you and on your behalf.
    3. If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, Prima may not be in a position to continue to provide Prima's products and services to you, administer any contractual relationship in place, which in turn may also result in the termination of any agreements with Prima, and your being in breach of your contractual obligations or undertakings. In such an event, Prima expressly reserves all its legal rights and remedies.
  7. Governing Law
    This Policy and your use of our websites shall be governed in all respects by the laws of Singapore.
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