Updated as at: [5 December 2019]
PIGEON Singapore may need to collect your personal data from time to time to provide any product or service to you, or to answer any of your enquiries or respond to any of your complaints or feedback. PIGEON Singapore views data protection seriously and has taken measures to protect your personal data in compliance with the Personal Data Protection Act 2012 of Singapore (“PDPA”).
This Personal Data Protection Policy (“Policy”) contains the details of how PIGEON Singapore will collect, use, disclose, and otherwise manage your personal data. It applies to all persons to whom PIGEON Singapore provides any product and/or service (collectively referred to as “Customers” in this Policy), persons who provide personal data through PIGEON Singapore's websites and contact details, and any other person whose personal data is in our possession or under PIGEON Singapore's control.
We hope that this Policy will help you understand the kind of personal data we collect, and how we handle and use any personal data after collection.
If you require any additional information on how PIGEON Singapore handles your personal data, or if you have any complaints in relation to PIGEON Singapore’s handling of your personal data, please feel free to contact PIGEON Singapore’s data protection officer(s) who will be able to attend to your concerns on PIGEON Singapore's behalf via e-mail to firstname.lastname@example.org.
By accessing and using this site, your use indicates your agreement to the terms of this Policy. If you do not agree with this Policy, please do not use this site.
1 Personal Data We Collect
1.1 We will collect your personal data in accordance with the PDPA. We will notify you of the purposes for which your personal data may be collected, used, disclosed and/or processed, as well as obtain your consent for the collection, use, disclosure and/or processing of your personal data for the intended purposes, unless an exception under the law permits us to collect and process your personal data without your consent.
1.2 We may collect and process personal data about you such as:
(a) Personal data that you may provide when submitting or making available personal data to, this website. This includes but is not limited to any personal data provided when you contact us, open a customer account and/or use our services on this website to make an online purchase such as your name, date of , email address, billing address, phone number, shipping address, and credit card information;
(b) If you contact us for any reason, we may keep a record of that correspondence;
(c) Personal data that may be captured when you use this website, include but is not limited to the domain name and browser you use to access this website, the IP address of your device, the date and time of your visit to this website, the pages you visited, and the address of the web site you visited immediately prior to visiting this website.
1.3 We may also collect personal data of minors (individuals under 13 years of age) under your care such as your baby’s name and date of birth for the purpose of customizing content, promotions and products, including but not limited to sending complimentary gifts such as birthday vouchers and gifts. In general, we will notify you as the parent or legal guardian of the purposes for the collection, use and disclosure of personal data of minors under your care and obtain your consent for the collection, use and disclosure of the personal data unless an exception under the PDPA applies. These exceptions are set out in the Second, Third and Fourth Schedules of the PDPA respectively.
2 Notification of Purposes for the Collection, Use and Disclosure of Personal Data
2.1 PIGEON Singapore may collect, use and disclose your personal data for one or more of the following purposes, including:
(a) to observe any legal, governmental or regulatory requirements of any relevant jurisdiction (including any disclosure or notification requirements to which PIGEON Singapore is subject);
(b) to comply with PIGEON Singapore's policies and procedures and those policies and procedures of PIGEON Singapore's related companies (including without limitation any reporting and disclosure policies and procedures);
(c) to carry out due diligence, monitoring or other screening activities in accordance with PIGEON Singapore's legal or regulatory obligations or risk management procedures such as performing credit risk, know-your-customer, anti-money laundering / countering the financing of terrorism, financial and other relevant risk assessments and performing identification checks on you such as verifying your identity or age;
(d) to respond to your feedback, complaints and enquiries;
(e) to contact you in respect of defects and warranties, and repair and replacement and the provision of any spare parts in relation to products you purchased from PIGEON Singapore;
(f) to check if your Singapore telephone number is listed on the Do Not Call Register;
(g) if so consented by you, to conduct any marketing and/or advertising activities, including but not limited to organising and inviting you to any promotion events, contests and lucky draws; inviting you to join any community on social media platforms; organising and inviting you to any seminars conducted by PIGEON Singapore ; and contacting you regarding any offerings from PIGEON Singapore or PIGEON Singapore's external business partners that may be of interest to you;
(h) to conduct any market research activities, including but not limited to contacting you to request your completion of surveys to understand your opinion of current services or products offered, or potential new services or products that may be offered, by PIGEON Singapore;
(i) to facilitate and/or process your transaction with us including but not limited to processing your payment for the order and delivering the products you purchased;
(j) to contact you as may from time to time be necessary in connection with your use of our website and/or the services made available on it;
(k) to process, administer and/or manage your customer account with us;
(l) to enroll you in contests, lucky draws and similar promotions, and administering these activities. Some of these activities have additional terms and conditions, which could contain additional information about how we use and disclose your personal data, so we suggests that you read these additional terms and conditions carefully;
(m) to collect information relating to your online interactions with us (including, for example, your IP address and the pages you view) so that we can offer you a more consistent and personalised experience in your relationship with us and better serve your needs by customising the content that we share with you;
(n) to store, host and/or keep a back up (whether for disaster recovery or otherwise) of your personal data, whether within or outside Singapore;
(o) to perform internal and statutory reporting and/or record-keeping purposes;
(a) to protect the rights, property or safety of any person (including for the purposes of fraud detection and prevention);
(b) to prevent or investigate any fraud, unlawful activity, omission or misconduct, whether relating to your use of our website or any other matter arising from your relationship with us, and whether or not there is any suspicion of the aforementioned; and
(c) any other purposes which we notify you of at the time of obtaining your consent.
(collectively, the “Purposes”)
2.2 For the avoidance of doubt, PIGEON Singapore will not require Customers to give consent to the collection, use and/or disclosure of their personal data as a condition for providing Customers with a product or service, except where to require such consent is reasonable for the purposes of PIGEON Singapore providing the Customers with the product or service.
3 Disclosure of Personal Data to Third Parties
3.1 In order to conduct our business operations more smoothly, your personal data may be used, disclosed, maintained, accessed, processed and/or transferred to the following third parties, whether sited in Singapore or outside of Singapore for one or more of the above-stated Purposes:
(a) our affiliates, related corporations and/or agents;
(b) third party service providers who help with our business operations or who provide certain services to you on our behalf, for example, third party service providers which have been engaged by us to: (i) to provide and maintain any IT equipment used to store and access your personal information; (ii) to host and maintain our website; or (iii) to provide logistics and product transportation services;
(c) our auditors and legal advisors;
(d) public and governmental/regulatory authorities, statutory boards, industry associations; and /or
(e) courts and other alternative dispute forums.
4 Specific Issues for the Disclosure of Personal Data to Third Parties
4.1 We respect the confidentiality of the personal data you have provided to us.
4.2 In that regard, we will not disclose any of your personal data to any third parties without first obtaining your express consent permitting us to do so. However, please note that we may disclose your personal data to third parties without first obtaining your consent in certain situations, including, without limitation, the following:
(a) cases in which the disclosure is required based on the applicable laws and/or regulations;
(b) cases in which the purpose of such disclosure is clearly in your interests, and if consent cannot be obtained in a timely way;
(c) cases in which the disclosure is necessary to respond to an emergency that threatens the life, health or safety of yourself or another individual;
(d) cases in which there are reasonable grounds to believe that the health or safety of yourself or another individual will be seriously affected and consent for the disclosure of the data cannot be obtained in a timely way, provided that we shall, as soon as may be practicable, notify you of the disclosure and the purposes of the disclosure;
(e) cases in which the disclosure is necessary for any investigation or proceedings;
(f) cases in which 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; and/or
(g) cases in which the disclosure is to a public agency and such disclosure is necessary in the public interest.
4.3 The instances listed above at paragraph 4.2 are not intended to be exhaustive. For an exhaustive list of exceptions, you are encouraged to peruse the Second, Third and Fourth Schedules of the PDPA which is publicly available at https://sso.agc.gov.sg/
4.4 In all other instances of disclosure of personal data to third parties with your express consent, we will endeavor to provide adequate supervision over the handling and administration of your personal data by such third parties, as well as to provide for adequate forms of protection over such personal data.
4.5 Where personal data is transferred by us to any third parties outside of Singapore, we will ensure that such transfers are compliant with the requirements under the PDPA. In this regard, we will take such necessary measures to ensure that such overseas recipients are bound by legally enforceable obligations to ensure that these overseas recipients provide a standard of protection to the personal data so transferred that is comparable to the protection under the PDPA.
5 Protection of Personal Data
To safeguard your personal data, all electronic storage and transmission of personal data are secured with reasonable security technologies and arrangements. This site may contain links to other sites 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.
6 Withdrawal of Consent
6.1 You may withdraw your consent to the collection, use and/or disclosure of your personal data by PIGEON Singapore for any purpose by giving reasonable written notice to PIGEON Singapore's data protection officer(s), delivered by way of e-mail transmission, providing relevant details of the personal data and the purposes for which you are withdrawing consent.
6.2 PIGEON Singapore's data protection officer(s) will notify you of the consequences of the withdrawal of your consent by way of e-mail within 14 business days/a reasonable period of time of your request to withdraw your consent. Should you confirm your request to withdraw your consent by way of e-mail in reply to such notice, we will stop collecting, using, disclosing and/or processing your personal data for the specified purpose.
7 Accuracy and Correction
All personal data provided by you to PIGEON Singapore shall be deemed in all respects to be accurate and complete. PIGEON Singapore may however require your assistance to verify the accuracy and completeness of your personal data from time to time. You may also request, by way of e-mail to PIGEON Singapore's data protection officer(s), to correct an error or omission in your personal data in PIGEON Singapore's possession or under its control. Your e-mail should provide sufficient detail to enable PIGEON Singapore to respond to your request.
You may request, by way of e-mail to PIGEON Singapore's data protection officer(s), to have access to your personal data in PIGEON Singapore's possession or under its control and information about the ways in which your personal data may have been used and/or disclosed by PIGEON Singapore within the period of one year before the date of request. Your e-mail should provide sufficient detail to enable PIGEON Singapore to respond to your request. Please note that PIGEON Singapore may charge you a fee for responding to your request. If so, PIGEON Singapore will provide you with a written estimate of such fee for your agreement.
9.2 You have the ability to accept or decline cookies by modifying the setting in your browser. If you would like to do this, please see the help menu of your browser. However, you may not be able to use all the interactive features of our website if cookies are disabled.
10 Updates on Data Protection Policy
10.1 As part of our efforts to ensure that we properly manage, protect and process your personal data, we will be reviewing our policies, procedures and processes from time to time.
10.2 We reserve the right to amend the terms of this Policy at our absolute discretion. Any amended Policy will be posted on this website.
10.3 You are encouraged to visit this website from time to time to ensure that you are well informed of our latest policies in relation to personal data protection.
(collectively, the “Purposes”)