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INTRODUCTION

JEM takes its responsibilities in relation to protecting your Personal Data and compliance with Singapore’s Personal Data Protection Act 2012 and its subsidiary legislations and regulations. We are committed to properly managing, protecting and processing your Personal Data in accordance with this Policy, which shall apply to all Personal Data we collect from you through this website: www.jem.com.sg.

Please read and review this Policy, which will inform you how we collect, use, process and disclose your Personal Data. We trust that it will assist you in making an informed decision whether to provide us with any of your Personal Data.

During our relationship with you, we may collect Personal Data from you. Examples of the types of Personal Data we may collect include your name, contact details, email address, network and device data (including your IP address and device or advertising identifiers), voice recording (for customer service calls) and any other personally identifiable information which you have provided us in any forms you may have submitted to us, or in the course of any other forms of interaction between you and JEM.

If you provide us with Personal Data relating to a third party by submitting such Personal Data 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.

By (1) clicking “Yes” on our Policy pop-up or any web form referring to this Policy on the Website, (2) submitting your Personal Data to us when submitting a webform on the Website, (3) browsing our Website, or (4) making payment for services, you are agreeing to the terms of this Policy.

We may update this Policy to ensure that it is consistent with industry trends and/or any changes in legal or regulatory requirements. You agree to be bound by the prevailing terms of the Policy as updated from time to time. We will endeavour to notify you by email or by notice on the Website of any material changes to the Policy.

HOW DO WE COLLECT YOUR PERSONAL DATA?

We collect Personal Data from you when:

  1. You submit any webform on the Website;
  2. You use any of our related services, such as subscribing to our newsletter, programme notifications;
  3. You browse our services or otherwise interact with our Website;
  4. You accept our cookies on your device;
  5. You interact with our customer experience team or other representatives, for example, via our webform, emails, telephone calls, letters, or face-to-face meetings;
  6. You interact with us on our Social Media, such as liking our posts, commenting on our posts, private messaging us on our Social Media;
  7. You participate in initiatives or any request for additional Personal Data such as feedback surveys;
  8. Your authorised representative submits your Personal Data to us for any purpose reasonably authorised by you, for example if such representative is purchasing our service in place of you in the event that you are a minor or as a gift;
  9. Our third-party analytics and other service providers provide your Personal Data to us, which was collected and processed by them and disclosed to us pursuant to their separate privacy policies; or
  10. When you voluntarily submit your Personal Data to us for any reason.

We usually do not collect your credit card details, whether to process your payment or for customer service purposes. Your credit card details are collected, processed and stored directly by our third-party payment processor pursuant to their terms of use and privacy policies. None of your credit card details are stored with us. However, we may collect your bank account details to process refunds.

We may also collect your Personal Data in circumstances where such collection does not require consent under Singapore’s Personal Data Protection Act 2012 and its subsidiary legislations and regulations.

Please ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure to do so may result in our inability to provide you with the services you have requested.

HOW WILL YOUR DATA BE USED?

We may use and disclose your Personal Data for purposes necessary to provide you with our services, including to:

  1. Process your order for our services, process or collect your payment for the order;
  2. Perform the services you purchased, including our couriers calling or messaging you to provide additional information;
  3. Process your refunds in accordance with our Terms of Service;
  4. Communicate with you in relation to your queries, requests and feedback;
  5. Monitor and enforce compliance with our Terms of Service, including dispute resolution; and
  6. Comply with (i) internal risk controls, (ii) the terms of our access to payment processing, financial or banking services such as credit card disputes, fraud, billing errors, or (iii) Singapore’s Personal Data Protection Act 2012 and its subsidiary legislations and regulations.

In addition, we may use and disclose your Personal Data for the following purposes, to

  1. Send you marketing communications in relation to our services, resources, promotions or the Website;
  2. Deliver ads which are related to our services which may be of interest to you on the Website;
  3. Conduct market and customer research, analysis or tracking;
  4. Promote our services on our Website;
  5. Manage the administrative and business operations of JEM and complying with internal policies and procedures;
  6. Improve your customer experience across all touchpoints and training our customer experience team, such as by recording and monitoring phone calls; and
  7. Any specific purpose in relation to a particular service, which we may separately notify you on the service page;

We may also use your Personal Data for other purposes which are reasonably related to the collection method and usage of your Personal Date in circumstances where such use does not require consent under Singapore’s Personal Data Protection Act 2012 and its subsidiary legislations and regulations.

Note: If you withdraw your consent for us to use and process your Personal Data, we may no longer be able to provide you with the related services or benefits associated with our promotion.

WHO WILL YOUR PERSONAL DATA BE SHARED WITH?

In relation to our use of your Personal Data for the Purposes or Additional Purposes, we may disclose your Personal Data to our:

  1. Employees, consultants, temporary workers;
  2. Payment processors, who process your payment on the Website and the Apps;
  3. Professional advisers and consultants;
  4. Agents, contractors or service providers who provide operational services to us, such as online cloud storage and processing, marketing optimisation, information technology, telecommunications, security or other relevant services which requires their collection, use or disclosure of your Personal Data; and
  5. Any other party whom you authorise us to disclose your Personal Data to.

We may also disclose your Personal Data for other purposes which are reasonably related to the collection and usage of your Personal Data in circumstances where such use does not require consent under Singapore’s Personal Data Protection Act 2012 and its subsidiary legislations and regulations.

We do our best to minimise the disclosure of your Personal Data to the information necessary to perform the related collection and usage of your Personal Data.

HOW CAN I ACCESS OR CORRECT MY PERSONAL DATA?

We do not offer the registration and perpetuation of user accounts on the Website. Personal Data will not be accessible or amendable through the Website. You may request to access and correct such Personal Data by submitting a written request to us via our contact form or by emailing our Data Protection Officer at data@jem.com.sg. We may need to request additional information from you to confirm your identity before providing the access or making the correction.

We will do our best to respond to Personal Data access and correction requests within 30 days. Where we are unable to meet this timeline, we will update you with the soonest possible time within we can provide the information or make the correction. Please note that certain types of Personal Data access and correction requests may be exempt under Singapore’s Personal Data Protection Act 2012 and its subsidiary legislations and regulations.

Note that we may charge you a reasonable fee for the handling and processing your Personal Data access request.

We will send your corrected Personal Data to every other person or entity to which such Personal Data was disclosed by JEM within the year before the date of the correction, unless such person or entity does not need the corrected Personal Data for any legal or business purpose.

Subject to obtaining your consent, we may send the corrected Personal Data only to specific organisations to which the Personal Data was disclosed by us within a year before the date the correction was made.

REQUEST TO WITHDRAW CONSENT

If you wish to withdraw your consent for us to send you billing, marketing or promotional information, please click on the Unsubscribe link in the promotional emails. Alternatively, you may email our Data Protection Offer at the email address provided below to request a withdrawal of your consent.

Once we receive notification that you wish to withdraw your consent for receiving marketing or promotional materials or communications, it may take up to thirty (30) days for your withdrawal to be reflected in our systems. Therefore, you may still receive marketing or promotional materials or communications during this period.

You may withdraw your consent for the collection, use and/or disclosure of any of your Personal Data in our possession or under our control by submitting a written request via email to our Data Protection Officer via data@jem.com.sg. Note that, depending on the nature of the consent withdrawal, we may not be able to continue to provide you with some or all of services. We will process such a request within a reasonable time from receiving notice from you of your withdrawal of consent. Once the processing is complete, we will no longer collect, use and/or disclose your Personal Data, except to the extent we retain your Personal Data for compliance, regulatory or other legal purposes.

ADMINISTRATION AND MANAGEMENT OF PERSONAL DATA

We will make reasonable efforts to ensure Personal Data likely to be used by us or disclosed by us to another organization is accurate and complete. However, you should update us of any changes in your Personal Data. We will not be responsible for relying on inaccurate or incomplete Personal Data if you have not updated us of changes.

We will also put in place reasonable security arrangements to ensure that your Personal Data is adequately protected and secured. This includes putting in place reasonable measures to prevent any unauthorised access, collection, use, disclosure, copying, modification, leakage, loss, damage or alteration of your Personal Data. However, we will not be responsible for any unauthorised use of Personal Data by third parties which is attributable to factors beyond our control.

When Personal Data in our possession is (i) no longer required for any reason connected to the purpose it was originally collected or (ii) retention by us is no longer necessary for any other legal or business purposes, we will exercise measures to ensure such Personal Data is either destroyed or anonymised.

If Personal Data is transferred out of Singapore, we will comply with Singapore’s Personal Data Protection Act 2012 and its subsidiary legislations and regulations in doing so. This includes: (i) obtaining your consent, unless an exception exists under Singapore’s Personal Data Protection Act 2012 and its subsidiary legislations and regulations or any other laws, and (ii) taking reasonable steps to ascertain whether the foreign recipient of the Personal Data is bound to comply with standards of protection that are at least comparable to the Singapore’s Personal Data Protection Act 2012 and its subsidiary legislations and regulations.

THIRD PARTY VENDORS

JEM uses the services of third party vendors. The collection, use, and disclosure of information, including Personal Data are subject to the privacy and data protections policies of the third party vendors and are not under our control.

MAILCHIMP

JEM uses Mailchimp as our primary marketing automation platform and email marketing service. Personal Data disclosed to Mailchimp included your email address, name and preferences. You may see how Mailchimp use and protect your Personal Data here and here respectively. To opt-out of any activity by Mailchimp, you may withdraw consent via promotional emails sent to you by JEM which has utilised Mailchimp’s email marketing service.

When you log on to the JEM website, JEM with the help of Google Analytics may use your browsing behaviour to connect it with any other data that has previously been provided by you, in accordance with this policy.

WOOCOMMERCE

JEM uses WooCommerce as its primary payment service provider. Personal Data collected by WooCommerce include email address, name and credit card information; bank account details; and/or PayPal account information. You may read more about WooCommerce’s Privacy Policy here.

CONTACTING US

For any questions relating to your Personal Data or about this Policy, if you have a complaint regarding the collection, use or handling of your Personal Data by us, or a question about how we are complying with Singapore’s Personal Data Protection Act 2012 and its subsidiary legislations and regulations, you may contact our Data Protection Officer via one of the following methods:

  1. Singapore telephone number: +65 6385 8232
  2. Email address: data@jem.com.sg
  3. Office address: 1 Irving Place, #08-12, The Commerze @ Irving, Singapore 369546

For any questions relating to your Personal Data or about our Privacy Policy, you may email here.

Emails and letters should clearly state that you are making a data protection query, request or complain in the subject line to ensure the matter is dealt with expediently. We will strive to deal with any query, request or complaint promptly and fairly.e the matter is dealt with expediently. We will strive to deal with any query, request or complaint promptly and fairly.

GOVERNING LAW

This Policy and your use of this Website shall be governed in all respects by the laws of Singapore.

UPDATES ON DATA PROTECTION POLICY

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. In this regard, JEM may update this Policy to ensure that it is consistent with industry trends and any changes in legal or regulatory requirements. We reserve the right to amend the terms of this Policy at our absolute discretion.

Subject to your rights at law, you agree to be bound by the prevailing terms of the Policy as updated from time to time on our Website. Any amended Policy will be posted on our website and can be viewed at www.jem.com.sg/privacy-policy. By continuing to use our Website and/or services after the Policy has been amended, you hereby agree to be bound by the terms of such amended Policy.

You are encouraged to visit the above Website from time to time to ensure that you are well-informed of our latest policies in relation to Personal Data protection.

Last updated on: October 22, 2018