PRIVACY POLICY

Protection of your Personal Data is important to us. The CTTB Personal Data Protection Policy (Policy) outlines our management of your Personal Data.

We respect the confidentiality of Personal Data and privacy of individuals and we are committed to complying with the Personal Data Protection Act (PDPA). The PDPA is designed to protect the confidentiality of data and the privacy of individuals by regulating the way in which Personal Data is managed.

Please read this Policy carefully so that you know and understand the purposes for which we collect, use and disclose your Personal Data.

1. Your Personal Data

1.1 “Personal Data” refers to any data or information about you from which you can be identified either (a) from that data; or (b) from that data and other information to which we have or are likely to have access. Examples of such Personal Data which you may provide CTTB may include, amongst other things:

(i) your name, NRIC number, passport number or other identification number, telephone number(s), mailing address, email address and any other information relating to you which you have provided us in any form you may have submitted to us, or in other forms of interaction with you;

(ii) information about your use of our websites and services, including cookies, IP addresses, subscription account details and membership details; and

(iii) your payment related information, such as your bank account or credit card information.

2. Collection of Personal Data

2.1 Generally, CTTB may collect your Personal Data in the following ways:

(i) when you submit forms relating to any of our products or services;

(ii) when you register for or use any of our services on websites owned or operated by us or when you register as a member of websites owned and/or operated by us;

(iii) when you interact with our customer service officers, including during face-to-face meetings or by way of the telephone;

(iv) when you use or purchase our services or products;

(v) when you establish any online accounts with us;

(vi) when you request that we contact you;

(vii) when you respond to our request for additional Personal Data;

(viii) when you ask to be included in an email or other mailing list;

(ix) when you respond to our promotions and other initiatives;

(x) when you respond to our market surveys;

(xi) when we receive references from business partners and third parties, for example, where you have been referred by them;

(xii) when you submit your Personal Data to us for any other reason; and

(xiii) when you browse our website. Please refer to our Cookie Policy outlined below for more information.

2.2 If you provide Personal Data of a third party (e.g. information of your dependent, spouse, children and/or parents) to us, you represent and warrant that the consent of that third party has been obtained for the collection, use and disclosure of the Personal Data for the purposes set out above.

3. How do we use this Personal Data and to whom may we disclose it?

3.1 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.

3.2 In general, CTTB 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 by analysing customer needs and identifying potential customer needs;

(c) to communicate with you and respond to your queries, requests and complaints;

(d) to provide ongoing information about our products and services which may be of interest to you;

(e) to handle disputes and conduct and facilitate investigations and proceedings;

(f) to protect and enforce our contractual and legal rights and obligations;

(g) to manage our infrastructure and business operations and to comply with internal policies and procedures;

(h) 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.

3.3 In addition, we may collect, use and disclose your Personal Data for the following purposes, depending on the nature of our relationship with you:

(a) If you have a membership account with us:

(i) to process your application for the account;

(ii) to maintain your account with us;

(iii) to verify your personal particulars and process payment requests in relation to provision of the services which you may be entitled to or which you may have requested for;

(iv) to provide you with the goods and services which you have signed up for;

(v) to communicate with you of changes and development to our policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you;

(vi) to resolve complaints and handle requests and enquiries;

(vii) to conduct market research for statistical, profiling and statistical analysis for the improvement of services provided to you; and

(viii) to process your Personal Data in relation to any of the purposes stated above.

(b) If you use download or use any of our mobile applications (apps):

(i) to process your application for subscription services if they are provided in the apps;

(ii) to maintain your account with us;

(iii) to verify and process your personal particulars and process payment requests in relation to provision of goods and services connected to the app;

(iv) to provide you with the goods and services which you have signed up for;

(v) to communicate with you changes and development to our policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you;

(vi) to resolve complaints and handling requests and enquiries;

(vii) to conduct market research for statistical, profiling and statistical analysis for the improvement of services provided to you; and

(viii) to process your Personal Data in relation to any of the purposes stated above.

3.4 Where you have provided us with specific consents, CTTB may also collect, use and disclose your Personal Data for the following purposes:

(a) providing services and extending benefits to you, including promotions, loyalty and reward programmes, and sending you newsletters and other information on our products, services, offers or promotions which may be of interest to you;

(b) matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision or offering of products and services, whether by us or third parties; and

(c) conducting market research to understand and determine customer locations, preferences and demographics for us to review, develop and improve our products, services and also develop special offers, promotional and/or marketing programmes.

3.4 In relation to particular products or services or in your interactions with us, we may also notify or have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.

3.5 Your Personal Data will be protected and kept confidential, but subject to the provisions of any applicable law, your Personal Data may, depending on the products or services concerned, be disclosed to the following third parties:

(a) CTTB’s joint venture/ alliance partners;

(b) agents, contractors, third party service providers and specialist advisers to CTTB who have been contracted to provide CTTB with administrative, financial, research, operational or other services, such as telecommunications, information technology, payment, payroll, processing, training, market research, storage and archival;

(c) any third party business partners who offer goods and services or sponsorships or other promotional programmes, whether in conjunction with CTTB or not;

(d) insurers or insurance investigators and credit providers;

(e) any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving CTTB;

(f) our professional advisors such as our auditors and lawyers;

(g) relevant government regulators or authority or law enforcement agency to comply with any laws or rules and regulations imposed by any governmental authority;

(h) anyone to whom we transfer or may transfer our rights and obligations;

(i) banks, credit card companies and their respective service providers; and

(j) any other party as may be consented to by you, as specified by that individual or in the applicable contract.

We require that organisations outside CTTB which handle or obtain Personal Data as service providers to CTTB acknowledge the confidentiality of this data, undertake to respect any individual's right to privacy and comply with the PDPA. We also require that these organisations use this information only for our purposes and follow our reasonable directions with respect to this information.

4. Keeping Your Personal Data Accurate and Up-To-Date

4.1 We endeavour to ensure that all Personal Data we have about you is accurate and up-to-date. We understand that this information changes frequently with changes of address and other personal circumstances. We encourage you to contact us as soon as possible to enable us to update any Personal Data we have about you. Incomplete or outdated Personal Data may result in our inability to provide you with products and services you have requested.

5. Use of Cookies (“Cookie Policy”)

5.1 This Cookie Policy applies to any websites which are operated by or on behalf of CTTB (“Website”).

By using and accessing our Website, you are consenting to our use of cookies in accordance with this Cookie Policy. This Cookie Policy may be updated from time to time. Updates to the Cookie Policy will be posted on our Website.

If you do not agree to our use of cookies as set out in this Cookie Policy you should disable the cookies associated with our Website by changing your browser settings accordingly. 

However, you may not be able to enter certain part(s) of the Website, and some of the functions and services may not be able to function without cookies. This may also impact your user experience while on our Websites.

What are Cookies?

Cookies are small files containing a string of characters that is sent to your computer when you visit our Website.

Depending on the type of cookies, they may store user preferences and other information.

 What do we use Cookies for?

We use cookies to track information such as the number of users and their frequency of use, profiles of users and their preferred sites.

We use cookies to make the Website easier to use and to better tailor our products and services to your interests and needs. Cookie may also be used to help speed up your future activities and experience on our Website.

When you interact with us on our Website, we may collect for the purposes of analysis statistical information from which individuals cannot be identified (“Aggregate Information”), such as number of users, their frequency of use, the number of page views (or page impressions) that occur on the Website and common entry and exit points into and out of the Website.

We use such statistical information to understand how people use our Website and to help us improve their structure and contents. We cannot identify you personally from this information.

 5.2 By interacting with us on our websites, you acknowledge the terms of our Cookie Policy. Should you wish to disable the use of cookies, you may do so by changing the settings on your browser. However, you may not be able to enter or use certain part(s) of our websites.

Our Cookie Policy may be updated from time to time and we encourage you to check back regularly for updates to the same.

6. Third-Party Sites

6.1 Our website may contain links to other websites operated by third parties, such as our business partners. We are not responsible for the privacy practices of websites operated by third parties that are linked to our website. We encourage you to learn about the privacy policies of such third party websites. Once you have left our website, you should check the applicable privacy policy of the third-party website to determine how they will handle any information they collect from you.

7. Storing of Personal Data

7.1 We will safeguard the confidentiality of your Personal Data, whether you interact with us personally, by telephone or mail, over the Internet or other electronic media. We hold Personal Data in a combination of secure computer storage facilities and paper based files and other records and take steps to protect the Personal Data we hold from misuse, loss, unauthorised access, modification or disclosure. Where we no longer require any Personal Data that we hold, that Personal Data would be destroyed or have particulars or information which may identify individuals removed.

8.Withdrawal of Consent

8.1 You may withdraw your consent given for any or all purposes set out in this Policy in writing by writing to us at hello@calledtothebarre.com. If you withdraw your consent to any or all purposes and depending on the nature of your request, CTTB may not be in a position to continue to provide our products or services to you. Without prejudice to the foregoing, you agree and acknowledge that any withdrawal of your consents in accordance with the terms set out in this Policy will not affect any consent which you may have provided to CTTB in respect of the use of your Singapore telephone number(s) for the receiving of marketing or promotional information.

9. Management and Security

9.1 We have established a process for receiving and responding to any query or complaint that may arise with respect to the application of the PDPA. To ensure that CTTB receives your complaints and enquiries, please send the same via email to hello@calledtothebarre.com.

10. How to contact us

10.1 If you have any questions about this Policy or any complaints relating to your Personal Data, or you would like to obtain access and make corrections to your Personal Data records (for which we reserve the right to charge a reasonable administrative fee in order to meet your requests), you may write to us at hello@calledtothebarre.com.

11. Review of the Policy

11.1 This Policy will be reviewed from time to time by CTTB. CTTB may also from time to time update this Policy to take account of new laws and technology, changes to our operations and practices and the changing business environment. If you are unsure whether you are reading the most current version, please contact us.