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Personal Data Protection

PRIVACY NOTICE

1.      INTRODUCTION

This privacy notice or policy (the “Policy“) is intended to inform you of the privacy policy practices of the Singapore Safety Driving Centre Ltd (UEN 198303427W) (“we“, “us“, the “Company” or “SSDC”).

Please read this Policy carefully and should you have any questions on how we manage, protect or process your personal data, please do not hesitate to contact our Data Protection Officer at the contact details set out below.

By accessing or using the Services, you are deemed to have consented to the terms of this Privacy Policy and our Terms of Use as amended from time to time, and this Policy supersedes any other agreement that we might have with you concerning the use of your personal data.

If you do not consent to this Policy, you should not access and use the Services. Certain features of the Services may require the provision of your personal data, and where you do not provide such requested data, we may not be able to provide you with any or all of the Services.

You undertake to keep your account details secure and confidential and that no person other than yourself shall have access or knowledge of your account details. You shall not disclose your account details to any other person. Unauthorised access and use of the Channels by any third party through your account may result in suspension or termination of your account.

 

2.      SCOPE

This Policy explains how we collect, use, disclose or process your personal data through your interactions with certain services, such as: (i) this website, https://ssdcl.com.sg/, (the “Sites”); (ii) any official social media channels created by us on any social media platforms (the “Channels”); (iii) all associated service offerings, and (iv) all other services, systems, servers, software and applications provided or operated by us, our affiliates, the Government of Singapore or our service providers (collectively, the “Services”).

Personal data includes any information relating to an identified or identifiable natural person. It does not include data that cannot be linked to an individual (such as anonymised data).

Individuals who access or use the Services, including but not limited to those who voluntarily provide personal data to us are covered by this Policy.

 

3.      SSDC PRIVACY PRINCIPLES

Your privacy matters to us. SSDC is an “organisation” or “data controller” in relation to the personal data collected from you for the purposes of providing driving lessons to you, for its own purposes and other such associated service offerings. To the extent that SSDC is required to collect, use, disclose or process your personal data on behalf of the Government of Singapore or other third parties, SSDC is a “data intermediary” or “data processor”.

We follow certain privacy principles to the extent necessary to comply with the Personal Data Protection Act 2012 of Singapore (“PDPA”) and other applicable data protection laws, including but not limited to:

  • obtaining your consent to collect, use, or disclose your personal data (unless we are otherwise required or permitted to under any applicable laws);
  • only collect and use your personal data necessary to conduct our business, to comply with a legal or regulatory obligation that we are subject to, for our legitimate interests and to provide the Services to you;
  • implementing reasonable technical and organisational measures to ensure that your personal data in our possession or under our control is secure, accurate and up to date;
  • retaining your personal data for as long as necessary to fulfil the purposes we collected it for; and
  • disclosing your personal data to the Government of Singapore (including government bodies or law enforcement authorities as the Traffic Police), our service providers (such as third party insurance providers, professional instructors, payment and photography services providers) or other third parties in relation to certain Services offered.

 

4.      PURPOSE FOR COLLECTION, USE, DISCLOSURE & PROCESSING OF PERSONAL DATA

We may collect, use, disclose or process your personal data for any or all of the following purposes:

  • establishing and maintaining of any user or membership account with us;
  • facilitating the provision of the Services, including the enrolment and provision of any courses and issuance of any licenses;
  • communicating with you about changes in the Services or providing supporting services and functions;
  • monitoring and analysing how you and other users use the Services;
  • improving and building features and offering other services you or other users may want;
  • detecting and preventing any fraud or misuse of the Services;
  • verification of your personal identity, billing, membership or other information to confirm your eligibility for the enrolment of any courses or grant / subsidies;
  • complying with the obligations, requirements, or arrangements for disclosing and using data that apply to us existing currently and as may be amended from time to time, including but not limited to:
  • any third party contractual arrangement;
    1. any applicable law, regulation, guidelines or direction given or issued by any legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of services providers existing currently and in the future that apply to us;
    2. any present or future contractual or other arrangement with local or foreign legal, regulatory, governmental, tax, law enforcement or other authorities, or self-regulatory or industry bodies or associations of financial services providers that is assumed by or imposed on us by reason of our financial, commercial, business or other interests or activities in or related to the jurisdiction of the relevant local or foreign legal, regulatory, governmental, tax, law enforcement or other authority, or self-regulatory or industry bodies or associations;
    3. complying with any obligations, requirements, policies, procedures, measures or arrangements for sharing data and information to the Government of Singapore, our service providers, any third parties or otherwise within our intragroup companies or with our affiliates, and any other use of data and information in accordance with any group-wide programmes for compliance with sanctions or prevention or detection of money laundering, terrorist financing or other unlawful activities; or
    4. other reasonable uses related to providing, maintaining, and improving our Services.

 

We may further rely on the legitimate interest exception (or other similar exceptions under applicable laws) to collect, use and disclose personal data for purposes including but not limited to:

  • improving, enhancing or developing new functions or services;
  • improving, enhancing or developing new methods or processes for operations;
  • learning or understanding your behaviour and preferences in relation to our provision of our Services;
  • conducting analyses of customer preferences, profile of customers and implementing customer segmentation strategy; and
  • CCTV and physical security data may be used for the following purposes (to the greatest extent permitted under applicable laws): detection and prevention of crime; detection and prevention of workplace or safety incidents; detection and prevention of unauthorised access to SSDC’s premises and restricted areas; detection and prevention of gross misconduct; supporting safety, security and internal investigations; supporting criminal investigations; and for reviewing security, workplace or safety incidents, including training exercises. We may deploy covert CCTV to carry out such purposes. Processing of such CCTV and physical security data for the aforesaid purposes is necessary for the purposes of our legitimate interests.

It may be necessary for you to provide us with your personal data in connection with the opening of or continuation of any user or membership accounts and the establishment or continuation of facilities or provision or continuation of any of our Services.  Failure to supply such personal data may result in our inability to open or continue accounts or establish or continue facilities or provide our Services to you.

In some cases, the parties which we use to process personal data on our behalf are based outside Singapore, and their processing of your personal data will involve a transfer of such data outside Singapore. We will only share the minimal amount of personal data necessary for the purpose of processing and, where possible, we will share the personal data in an anonymised form. Please contact us if you would like further information about the specific mechanism used by us when transferring your personal data out of Singapore (if any).

 

5.      WHAT KIND OF PERSONAL DATA DO WE COLLECT?

The types of personal data that we collect and share depend on the nature of the Services you seek from us. It includes but is not limited to:

  • contact information and other personal details: your full name, NRIC/FIN number, date of birth, nationality, registered address, email address and mobile phone number;
  • billing, enrolment, insurance or licence information: credit card or other payment information, billing name, billing address, your eyesight test result, your digital photograph, and other membership information;
  • your video and image for safety and training purposes: CCTV and In-Vehicle Camera (outward-facing) with audio and video recordings;
  • your IP address, details of visits to the Sites and Channels; and
  • your voice or video recording in phone calls for training, statistical, analytical and services improvement purposes.

We may also collect your personal data to create aggregated, de-identified or other anonymous data for other purposes such as research and development purposes. Some of the information that we collect will not personally identify you but will instead track your use of our website so that we can better understand how our Sites and Channels are used by you or other users to enhance and improve your experience in accessing the Services. This information can be obtained through the use of cookies.

 

6.      IMPORTANT CONTROLS EMPLOYED BY SSDC FOR PROTECTION OF PERSONAL DATA

Personal data in our possession and under our control shall be kept confidential and private. To the extent necessary under the PDPA, we implement reasonable technical and organisational measures to prevent the loss, misuse or alteration of your personal data.

We have designed policies and procedures in accordance with the PDPA to protect both your confidentiality and the security of your personal data.

Our Sites and Channels may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy notices. When you leave our Sites and Channels, we encourage you to read the privacy notice of every website you visit.

 

7.      SHARING YOUR PERSONAL DATA WITH THIRD PARTIES AND INTERNATIONAL TRANSFERS

SSDC may share your personal data to the certain third parties for certain purposes as set out in Paragraph 4 above. Where any third parties processes your personal data either on our behalf or otherwise may be located in a different country from the point of collection of your personal data we do so only in compliance with the PDPA.

Where your personal data must be shared with third parties in circumstances that are not reasonably contemplated within the normal course of our dealings with you, we would first seek your consent unless the disclosure:

  • is required or authorised based on the applicable laws and/or regulations;
  • is clearly in your interests, and if consent cannot be obtained in a timely way;
  • is necessary to respond to an emergency that threatens the life, health or safety of yourself or another individual;
  • is necessary for any investigation or proceedings;
  • is required by a law enforcement agency;
  • is to a public agency and necessary in the public interest; and/or
  • where such disclosure without your consent is permitted by law.

 

8.      CERTAIN RIGHTS IN RELATION TO YOUR PERSONAL DATA

To the extent permitted under the PDPA, you may ascertain whether the information we hold about you is accurate and current, and you may also access and correct your personal data. The procedure to do so is set out as follows:

(a) Right to access and/or to correction of personal data. Any right to request to access to or correct your personal data (with sufficient particulars) held by us by must be made in person at our Service Counter or notified to us in writing at [email protected].

  1. We may require further information from you to verify your identity as well as the nature of your request, to deal with your request. Handling and processing fees may be payable before we can proceed with your request.
  2. Once we have sufficient information to deal with your request, we will seek to provide you with the relevant personal data or information within thirty (30) days of your request, unless otherwise stated.
  3. There are certain circumstances in which we may decline to comply with your request under Paragraph 8(a) such as where:
    • a government agency in Singapore or regulator with jurisdiction over us direct us not to comply with a customer’s request;
    • the information may, in our discretion, affect the safety of any person or persons; and
    • the data may be relevant to a regulator or official investigators as part of an investigation into criminal conduct or breach of applicable laws.

(b) Withdrawal of consent to use your personal data. Should you wish to withdraw your consent to our use of your personal data, please stop using the Services immediately and notify us in writing at [email protected] to inform us that you wish for us to stop collecting, using or sharing your personal data and we will process your request within a reasonable time.

  1. If you are only electing to withdraw your consent to the use of your personal data for a specific purpose, please provide us with sufficient and specific information to enable us to comply with your request.
  2. However, your withdrawal of consent could result in certain consequences arising from such withdrawal. Depending on the extent of your withdrawal of consent for us to process your personal data, it may mean that we will not be able to provide any or all our Services to you. We are not responsible for any such inability to provide you with any or all our Services to you.

 

9.      RETENTION, ADMINISTRATION & MANAGEMENT OF PERSONAL DATA

We will take reasonable efforts to ensure that your personal data is accurate and complete, based on the information that you have provided us with. Please ensure that all information provided to us is up to date and keep us informed of any relevant changes.

We value your privacy and have security arrangements to ensure that your personal data is adequately protected and secured. We will also put in place measures such that your personal data in our possession or under our control is securely destroyed within seven (7) years from the date on which the Personal Data was collected, as soon as it is reasonable to assume that: (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes. Otherwise, personal data collected by us is generally only retained for as long as it is reasonably necessary for the purpose for which the data provided and we may destroy or delete any information or personal data provided by you thereafter, unless required by law, regulation or other business or audit requirements.

 

10.   CONTACT US

If you have any complaint or feedback regarding about how we handle or process your personal data, please contact us with sufficient particulars and details in writing to:

Attention:                      Data Protection Officer

E-mail address:             [email protected]

Mailing Address:           2 Woodlands Industrial Park E4, Singapore 757387

 

11.   UPDATES ON PRIVACY NOTICE

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 and may update, at our absolute discretion, the terms of this Policy from time to time. Any revised Policy will be posted on our Sites and can be accessed at https://ssdcl.com.sg/privacy-notice

You are encouraged to visit our Sites to access this Policy from time to time to ensure that you are well informed of our latest policy.

 

Updated on 29 July 2024

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