A) General Data Protection Policy
We at Oh Wow Pte Ltd (“OhWow”) take our responsibilities under Singapore’s
Personal Data Protection Act 2012 (the “PDPA”) seriously. We recognize the
importance of safeguarding the personal data you have provided us and it is our
responsibility to properly manage, protect and process your personal data.
This Data Protection Policy is designed to assist you in understanding how we
collect, use, disclose and/or process the personal data you have provided to
us, as well as to assist you in making an informed decision before providing us
with any of your personal data.
If you, at any time, have any queries on this policy or any other queries in
relation to how we may manage, protect and/or process your personal data,
please do not hesitate to contact our Data Protection Team (attention email
“DPT”) at firstname.lastname@example.org.
1 INTRODUCTION TO THE PDPA
1.1 “Personal Data” is defined under PDPA to
mean data, whether true or not, about an individual who can be identified from
that data, or from that data and other information to which an organization has
or is likely to have access.
1.2 We will collect your personal data in accordance with the PDPA directly
from you. 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.
2 PURPOSES FOR COLLECTION, USE, DISCLOSURE AND
PROCESSING OF PERSONAL DATA
2.1 The personal data which we collect from you
may be collected, used, disclosed and/or processed for various purposes,
depending on the circumstances for which we may/will need to process your
personal data, which include but are not limited to :
(a) Communicating with you on your enquiries,
and/or sending you marketing, advertising and promotional information and
materials relating to events; productions; shows; concerts; and/or services
that we, our partners and/or third party organizations with whom we are
collaborating, may be selling or marketing.
(b) Administrative matters on your
sign-ups/registrations for accounts, payments or refunds.
(c) Any other purposes that we notify you of at
the time of obtaining your consent (collectively, the “Purposes”)
As the purposes for which we may/will collect,
use, disclose or process your personal data depend on the circumstances at
hand, such purpose may not appear above. However, we will notify you of such
other purpose at the time of obtaining your consent, unless processing of your
personal data without your consent is permitted by the PDPA or by law.
3 SPECIFIC ISSUES FOR THE DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES
3.1 We respect the confidentiality of the
personal data you have provided to us.
3.2 In that regard, we will not disclose your
personal data to third parties without first obtaining your 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 or
authorized 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
(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 the disclosure is necessary
for any investigation or proceedings;
(e) cases in which the personal data is
disclosed to any officer of a prescribed law enforcement agency, upon production
of written authorization 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;
(f) cases in which the disclosure is to a public
agency and such disclosure is necessary in the public interest; and/or
(g) where such disclosure without your consent
is permitted by the PDPA or by law.
3.3 The instances listed above at paragraph
[3.2] are not intended to be exhaustive. For more information on the
exceptions, you are encouraged to peruse the Second, Third and Fourth Schedules
of the PDPA which is publicly available at statutes.agc.gov.sg.
3.4 Where we disclose your personal data to
third parties with your consent, we will employ our best efforts to require
such third parties to protect your personal data.
4 REQUEST FOR ACCESS AND/OR CORRECTION OF
4.1 You may request to access and/or correct the personal data currently in our
possession or control by submitting a written request to us. We will need
enough information from you in order to ascertain your identity as well as the
nature of your request, so as to be able to deal with your request. Hence,
please submit your written request to email@example.com
4.2 For a request to access personal data, once
we have sufficient information from you to deal with the request, we will seek
to provide you with the relevant personal data within 30 days. Where we are
unable to respond to you within the said 30 days, we will notify you of the
soonest possible time within which we can provide you with the information
requested. Note that the PDPA exempts certain types of personal data from being
subject to your access request.
4.3 For a request to correct personal data, once
we have sufficient information from you to deal with the request, we will: (a)
correct your personal data within 30 days. Where we are unable to do so within
the said 30 days, we will notify you of the soonest practicable time within
which we can make the correction. Note that the PDPA exempts certain types of
personal data from being subject to your correction request as well as provides
for situation(s) when correction need not be made by us despite your request;
(b) subject to paragraph [4.4], we will send the
corrected personal data to every other organization to which the personal data
was disclosed by OhWow within a year before the date the correction was made,
unless that other organization does not need the corrected personal data for
any legal or business purpose.
4.4 Notwithstanding paragraph [4.3(b)], we may,
if you so consent, send the corrected personal data only to specific organizations
to which the personal data was disclosed by us within a year before the date
the correction was made.
4.5 We will also be charging you SGD 28 for the handling and processing of your
requests to access your personal data. We will provide you with a written
estimate of the fee we will be charging. Please note that we are not required
to respond to or deal with your access request unless you have agreed to pay
5 REQUEST TO WITHDRAW CONSENT
5.1 You may withdraw your consent for the collection, use and/or disclosure of
your personal data in our possession or under our control by submitting your
request to firstname.lastname@example.org
5.2 We will process your request within a
reasonable time from such a request for withdrawal of consent being made, and
will thereafter not collect, use and/or disclose your personal data in the
manner stated in your request.
5.3 However, your withdrawal of consent could result in certain legal
consequences arising from such withdrawal. In this regard, 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 continue with your existing relationship
6 ADMINISTRATION AND MANAGEMENT OF PERSONAL DATA
6.1 We will take reasonable efforts to ensure
that your personal data is accurate and complete, if your personal data is
likely to be used by OhWow to make a decision that affects you, or disclosed to
another organization. However, this means that you must also update us of any
changes in your personal data that you had initially provided us with. We will
not be responsible for relying on inaccurate or incomplete personal data
arising from your not updating us of any changes in your personal data that you
had initially provided us with.
6.2 We will also put in place reasonable
security arrangements to ensure that your personal data is adequately protected
and secured. Appropriate security arrangements will be taken to prevent any unauthorized
access, collection, use, disclosure, copying, modification, leakage, loss,
damage and/or alteration of your personal data. However, we cannot assume
responsibility for any unauthorized use of your personal data by third parties
which are wholly attributable to factors beyond our control.
6.3 We will also put in place measures such that
your personal data in our possession or under our control is destroyed and/or anonymized
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
6.4 Where your personal data is to be transferred out of Singapore, we will
comply with the PDPA in doing so. In this regard, this includes us obtaining
your consent unless an exception under the PDPA or law applies, and taking
appropriate steps to ascertain that the foreign recipient organization of the
personal data is bound by legally enforceable obligations to provide to the
transferred personal data a standard of protection that is at least comparable
to the protection under the Act. This may include us entering into an
appropriate contract with the foreign recipient organization dealing with the
personal data transfer or permitting the personal data transfer without such a
contract if the PDPA or law permits us to.
7 COMPLAINT PROCESS
7.1 If you have any complaint or grievance
regarding about how we are handling your personal data or about how we are
complying with the PDPA, we welcome you to contact us with your complaint or
7.2 Please contact us through one of the
following methods with your complaint or grievance:
7.3 We will certainly strive to deal with any complaint or grievance that you
may have speedily and fairly.
8 UPDATES ON DATA PROTECTION POLICY
8.1 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.
8.2 We reserve the right to amend the terms of
this Data Protection Policy at our absolute discretion. Any amended Data
Protection Policy will be posted on our website.
8.3 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.
Please note that we
and they store/record information about your visit to and use of the website.
Cookies can compile information about your browsing habits and can also enhance
your browsing experience.
following purposes :
to improve your user experience on this website;
(b) to remember your preferences;
(c) to help us understand how this website is
(d) to monitor traffic to the
(e) to enable this website to
(collectively the “Purposes”) You can control cookies through your web
browser settings. This allows you to determine which cookies to allow and which
you may not be able to access the full range of functions that our website
offers. Personal data (if any) that we collect from you through cookies may be
passed to our third party service providers, whether located in Singapore or
elsewhere, for one or more of the Purposes, for managing and/or administering
our website, or for the purpose of data hosting/storage/backup. Your use of our
C) TERMS AND CONDITIONS OF SERVICE Your
use of the OhWow website is expressly conditioned on your acceptance of OhWow
Terms and Conditions of Service (“Terms and Conditions”). The Terms and
Conditions apply to the use of the services on or access to the services
available through Our Websites. By using Our Websites, you unconditionally
agree and accept to be legally bound by the Terms and Conditions. If you do not
agree with any part of the Terms and Conditions, you must not, or must cease
to, use the services on and cease to access any of the services available
through Our Websites. Certain products and services have their own
specific governing terms and conditions which shall apply in addition to the
Terms and Conditions. These specific terms and conditions shall include any
terms and conditions found on your screens and when using any part of Our
Websites. In the event of any inconsistency between the specific terms and
conditions and the Terms and Conditions, the specific terms and conditions
shall prevail in relation to the product or service in question.
OhWow is the operator of this site. Our Websites, and each of
its respective modules, together with the arrangement and compilation of the
content found on Our Websites, are the copyrighted property of OhWow. Nothing
contained on Our Websites should be construed as granting, by implication,
estoppel, or otherwise, any license or right to use any of the content on Our
Websites or Trademarks without the prior written permission of OhWow, or such
other party that may own the content on the site or the 1028 Trademarks.
OhWow grants you a limited, non-exclusive,
non-transferable right to use Our Websites in accordance with the Terms and
Conditions. You agree that you:
A) shall not employ misleading email addresses
or falsify information in the header, footer, return path, or any part of any
communication, including emails, transmitted through Our Websites.
B) shall not copy, reproduce, republish, upload,
post, transmit distribute or otherwise communicate to the public any of the
content provided in Our Websites, including the text, graphics, button icons,
audio and video clips, digital downloads, data compilations and software,
without the prior written permission of OhWow, except that you may download,
display and print the materials presented on Our Websites for your personal,
non-commercial use only.
C) shall not alter, modify, translate,
decompile, adapt, disassemble, reverse engineer or create derivative works from
any content or component from Our Websites without the prior written permission
D) shall not use any “robot,” “spider”,
“crawler” or other automated device, or a program, algorithm or methodology
having similar processes or functionality, or any manual process, to monitor or
copy any of the web pages, data or content found on Our Websites, in any case
without the prior written permission of OhWow and/or its third party providers
E) shall not transmit or otherwise transfer any
web pages, data or content found on Our Websites to any other computer, server,
web site, or other medium for mass distribution or for use in any commercial
enterprise. The use of such materials on any other web site or in any environment
of networked computers is prohibited.
F) shall not post or transmit any information which (i) infringes the rights of
others or violates their privacy or publicity rights, (ii) is protected by
copyright, trademark or other proprietary right, unless with the express
written permission of the owner of such right, (iii) contains a virus, bug,
worm, time bomb, trojan horse, trap door or other harmful item, (iv) is used to
unlawfully collude against another person in restraint of trade or competition,
or (v) creates any liability on OhWow or causes OhWow to lose (in whole or in
part) the services of our internet service providers or other suppliers.
You agree that you shall be solely liable for
any damages resulting from any infringement of copyright, trademark, or other
proprietary right, or any other loss or harm resulting from your use of Our
Registration Use of Our Websites may require you
to register and provide certain personal information to access and/or download
certain information and materials, and/or to sign-up for OhWow’s mailing lists.
You may choose not to provide any personal information, but if you decline to
provide any mandatory information required, you may not be able to complete the
In consideration of OhWow permitting you to use the site, in registering and
providing such personal information, you represent and warrant that: (a) the
information about yourself is true, accurate, current, and complete (apart from
optional items) as required by various registration forms on the site (the
“Registration Data”) and (b) you will maintain and promptly update the
Registration Data to keep it true, accurate, current and complete. If you
provide any information that is untrue, inaccurate, not current or incomplete,
or if OhWow has reasonable grounds to suspect that such information is untrue,
inaccurate, not current or incomplete, OhWow has the right to suspend or
terminate your account and refuse any and all current or future access to and
use of Our Websites.
You have read OhWow ’s Data Protection Policy,
the terms of which are incorporated herein and which are an integral part of
the Terms and Conditions, and you agree that the terms of such policy are
You consent to the use and processing of your Registration Data and other
personally identifiable user information by OhWow in accordance with the terms
of and for the purposes set forth OhWow ’s Data Protection Policy. You
acknowledge and agree that the technical processing of Our Websites and the
transmission of transaction messages relating to the products and services on
Our Websites may involve (a) transmissions of your Registration Data and other
data collected and maintained by OhWow with regard to you, over various
networks and to various countries; and (b) changes to conform and adapt your
Registration Data and other data collected and maintained by OhWow with regard
to you to technical requirements of connecting networks or devices.
The information and materials contained in Our
Websites, including text, graphics, links or other items are provided “As is”,
“As available”. No warranty of any kind (implied, express or statutory) is
given in conjunction with the information and materials contained herein
including but not limited to accuracy, adequacy or completeness;
non-infringement of third party rights; title; merchantability; fitness for a
particular purpose and freedom from computer virus. OhWow expressly disclaims
liability for any loss or damage arising out of or in connection with the
reliance on, use of or inability to access such information and materials.
Links to third party websites contained in Our
Websites are provided for your convenience only, and not for the purposes of
making any endorsement or recommendation thereof. OhWow does not warrant and is
you access through links which are contained in Our Websites.
Updated as at March 2016