ShopPass Digital Services Privacy Policy

This ShopPass Digital Services Privacy Policy (the "Privacy Policy") must be read in conjunction with the ShopPass Digital Services Terms of Use (the "Terms") that you must agree to be legally bound by in order to access and/or use (1) ShopPass; (2) the ShopPass Digital Services, which include but are not limited to, the ShopPass website (accessible at shoppass.sg or such other website as may be specified by us from time to time; the "Website"), the ShopPass Mobile application (the "Application") and the ShopPass Service Provider interfaces (the "APIs") (collectively, the "ShopPass Digital Services"); (3) the Service Provider Digital Services available or provided through ShopPass Digital Services; and (4) any Content made available and accessible therein (collectively, the "Services"). In this Privacy Policy, "Service Providers" mean Shoptima Pte Ltd and other Organsations which services may be integrated with ShopPass Digital Services. Unless otherwise stated, all other capitalized terms contained in this Privacy Policy shall have the meaning given to it in the Terms.

  1. The ShopPass Digital Services are provided to you by Shoptima Pte Ltd. ("we", "us"" or "our"). The purpose of this Privacy Policy is to inform you and provide you with an understanding of how we handle, collect, use, disclose and deal with any data, including Personal Data, that you provide to us (collectively, "Data"). Please read this Privacy Policy carefully.
  2. Types of Data that we collect

  3. We may request certain types of Data from you in connection with your access to or use of the Services. Examples of the types of Data which we may request and collect include, but are not limited to:
    1. information relating to your Account, such as your Account ID;
    2. your contact information, including your mobile phone number, email and mailing addresses;
    3. questions and answers that may be used to facilitate Account access recovery in cases of loss of access, including loss of access credentials;
    4. information relating to your age and/or birthdate, marital status, gender and such other demographical or profile information as may be provided by, or collected from, you as required by us or relevant Service Providers authorized by you;
    5. IP addresses, device fingerprint records (including but not limited to information relating to your Device, including model type, operating system and the state of your Device) and other forms of metadata generated through the use of the Services;
    6. information relating to the version of the ShopPass Digital Services and your use of the Services, including but not limited to information relating to the usage of the various functionalities, features or clicks on the Content available therein as well as other Device permissions granted to the ShopPass Digital Services, such as the permission to push notifications, use location services, use any connectivity services, and other similar information;
    7. such other information as may be provided by or collected from you.
  4. We may also collect other types of information relating to your activities in respect of the Services. Such information may be collected through various technologies including but not limited to:
    1. Analytics Tags: Analytics Tags are used by us to analyse the effectiveness of the functionalities and features of the ShopPass Digital Services and user preferences relating to the Services in order to improve your user experience. We may use information collected through such analytics tags in combination with anonymised data (such as transactional history and demographic information) to understand more about the profile of our users.
    2. Cookies: Cookies are small data files which are sent to your browser or Device to store and track information about you when you use the Services. Cookies are also used to improve and maintain the functionality of the Services, and to track information such as the number of users of the Services, their frequency of use, the profile of the users and other similar information relating to the use of the Services. While these cookies can tell us when you access and use our Services, they cannot read data off your hard disk. Not all cookies collect Personal Data and you may configure your preferences and settings to reject the use of cookies. However, this may mean you may not be able to take full advantage of the Services, including the features or the functionalities of the ShopPass Digital Services.
    3. Server Logs: Server logs are files and records of activity created by the Device that you access and use the Services from. For example, a web server log may record a history of page requests whereas other logs may record errors, access attempts or other information about your Device, such as your IP address and your Device's cookie settings. We collect and retain such server logs for administrative, security and troubleshooting purposes.
  5. By continuing to use the Services, you are agreeing to the use of the aforementioned technologies on your Device through the Services.
  6. Why we collect Data

  7. Data requested and collected from you may be used, disclosed and processed by us for any, some or all of the following purposes:
    1. to assist, process and facilitate your access or use of the Services, including registering and creating your Account, logging into your Account and using any features or functionalities of the Services;
    2. to consolidate, maintain and protect your Data within the Services and enable centralized management of your Data;
    3. to share your Data and identify you to relevant Service Providers, in accordance with authorizations granted by you;
    4. to administer, process and facilitate any transactions or activities conducted under your Account through the Services, whether with us or any other Service Providers, and whether for your own benefit, or for the benefit of an Organisation on whose behalf you are duly authorised to act;
    5. to carry out your instructions or respond to any queries, feedback or complaints provided by (or purported to be provided by) you or on your behalf, or otherwise for the purposes of responding to or dealing with your interactions with us;
    6. to monitor and track usage of the Services, in order to assist us in understanding user behaviour, trends and preferences, and in improving the Services and other services and products provided by Service Providers. For the avoidance of doubt, we may also collect, use, disclose and process such Data to create reports and produce statistics regarding the above for record-keeping and reporting or publication purposes (whether internally or externally). Data used in such reports and statistics will be anonymised before publication;
    7. for the purposes of storing or creating backups of your Data for contingency or business continuity purposes;
    8. to prevent or investigate any fraud, unlawful activity or omission or misconduct, whether or not there is any suspicion of the aforementioned; dealing with conflict of interests; or dealing with and/or investigating complaints; and/or
    9. to enable us to contact you or communicate with you on any matters relating to your access or use of the Services, including but not limited to the purposes set out above, via email, SMS, voice call, push notifications or such other forms of communication that we may introduce from time to time depending on the functionality of the Services and/or your Device,

      (collectively, the "Purposes").
  8. We will not collect, use, disclose or process your Data for other purpose(s) that do not appear above.
  9. If you provide us with Data:
    1. We will share your Data only with relevant Service Providers authorized by you to receive your Data on an ongoing basis until such authorization is revoked by you or us.
    2. We will NOT share your Data with entities which are not Service Providers, except where such sharing is necessary for such entities to assist us in providing the Services to you. For example, sharing your mobile number with the SMS provider for the purpose of sending Sms notifications
    3. For your convenience, we may also display to you Data you had previously supplied us. This will speed up the transaction(s) and save you the trouble of repeating previous submissions. Should the Data be out-of-date, you shall be required to supply the latest Data through the relevant functionality in the Services without delay.
  10. Data from Third Party Sources

  11. We may collect Data, excluding Personal Data, from sources other than yourself, for any, some or all of the above Purposes. Such Data may be used, disclosed and/or processed by itself or together with or in conjunction with other Data that you have provided to us for any, some or all of the Purposes set out above (depending on the types of information we receive).
  12. We will not collect Personal Data from any source other than yourself and your Devices and we will NOT retain any Personal Data from Third Parties.
  13. For the avoidance of doubt, we may receive Personal Data from Third Parties, as required for the proper functioning of parts of the Services, but such Personal Data will NOT be retained or used by us for the purposes listed in Clauses 5.2 and 5.3.
  14. In the course of your access or use of the Services, we may collect Data relating to other individuals from you. Where this involves the Personal Data of such other individuals, you represent and warrant that:
    1. for Personal Data relating to other individuals that you provide to us, you would have, prior to disclosing such Personal Data:
      1. notified these individuals (i) that you will be providing their Personal Data to us; and (ii) of the purposes for which we will be collecting, using, disclosing and/or processing their Personal Data, as set out in this Privacy Policy and/or as notified by us to you from time to time; and
      2. obtained consent from the individuals whose Personal Data are being disclosed, permitting (i) you to disclose the Personal Data to us; and (ii) us to collect, use, disclose and/or process these individuals' Personal Data, for the purposes referred to in Clause 11.1(a)(ii).
    2. that you have the valid authority and consent from these individuals to act on their behalf and provide their Personal Data to us to collect, use, disclose and/or process for the purposes referred to in Clause 11.1(a)(ii).
  15. You have no obligation to provide us or any of our Service Providers complete or accurate Personal Data relating to yourself or other individuals, except specific data you are explicitly required to provide accurately by our Terms or relevant Third Party Terms.
  16. How we handle and manage your Data

  17. Your Data may be stored in servers, systems or devices owned, operated or managed by us, and/or our third party service providers or collaborators, or on your Device, and may be used by us or our third party service providers or collaborators, such as but not limited to other Service Providers, to facilitate your access or use of the Services.
  18. We will take reasonable measures to safeguard Personal Data that is in our possession or under our control to protect it from loss, misuse, unauthorised access or disclosure, alteration or destruction. This may include, without limitation, securing all electronic storage and transmission of Personal Data with appropriate security technologies.
  19. You may withdraw your consent to the retention, use and disclosure of your Personal Data by us with reasonable notice and subject to any prevailing legal or contractual restrictions; however, doing so may prevent the proper functioning of parts or all of the Services and may also result in the cessation of parts or all of the Services to you.
  20. In the event, your consent to retain, or and disclose of your Personal Data by us is withdrawn, we may undertake necessary steps to remove, replace or irrevesibly obfuscate your Personal Data within ShopPass Digital Services to the extent that they are no longer relatable to you.
  21. We are unable to process the withdrawal of consent to the retention, use and disclosure of your Personal Data by relevant Service Providers, you may withdraw your consent in accordance to the relevant Service Provider terms and privacy polices.
  22. You acknowledge and agree that copies of Data shared with Service Providers, as authorized by you, are not within our possession or under our control. Such copies of Data are held and managed by the relevant Service Provider and NOT covered by the ShopPass Digital Services Terms of Use and the ShopPass Digital Services Privacy Policy.
  23. General Information

  24. We are not responsible for the content and privacy practices of any Third Parties including Service Providers and their services, products and/or websites;
  25. You are encouraged to consult the privacy notices of those sites or privacy policies applicable to relevant Third Parties including Service Providers and their services, products and/or websites.
  26. You agree that we and relevant Third Parties are not responsible or liable for any loss of Data that is a result of any event, actions or occurrence beyond the control of Service Providers or from the actions or omissions of other users or third parties.
  27. We reserve the right to change or amend the Privacy Policy at any time, by posting the revised Privacy Policy on or through the ShopPass Digital Services, or through such other means as we may deem appropriate. Your continued access or use of the Services following the posting of any changes or modifications will constitute your acceptance of such changes, modifications, supplements and of such revised or modified Privacy Policy. Please check our Privacy Policy regularly to ensure that you are kept informed of the latest changes to the same. The most current version of this Privacy Policy can be accessed at https://shoppass.sg/privacy or such other URL as we may notify on or through the ShopPass Digital Services from time to time.
  28. Please contact support@shoppass.sg if you:
    1. have any enquires, complaints or feedback on our data protection policies and procedures; or
    2. need more information on or access to data which you have provided to us in the past.
    3. wish to withdraw your consent for our use and disclosure of your Personal Data.

This version of the Privacy Policy is dated 18 March 2019