TANAH MERAH COUNTRY CLUB
Personal Data Protection Policy
Tanah Merah Country Club (“TMCC” or the “Club”) takes our responsibilities under Singapore’s Personal Data Protection Act 2012 (the “PDPA”) seriously.
This Data Protection Policy serves, inter alia, to notify you of the purposes for which the Club collects, uses and discloses personal data relating to you, and the personal data which you have provided us, including your family members’ personal data (collectively known as “your personal data”).
This Policy supplements but does not supersede or replace any previous consent which an Individual may have provided to TMCC, nor does it affect any rights that the Club may have at law in connection with the collection, use and/or disclosure of any Individual’s Personal Data.
If you, at any time, have any queries on this policy or any other queries in relation to how we manage, protect and/or process your personal data, please do not hesitate to contact our Data Protection Officer (the “DPO”), listed on the Club’s website.
1 PERSONAL DATA
1.1 “Personal Data” is defined under the 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 organisation has or is likely to have access. Common examples of personal data could include names, identification numbers, contact information, photographs, and video images.
1 PURPOSES FOR COLLECTION, USE, DISCLOSURE AND PROCESSING OF PERSONAL DATA
1.1 The personal data which we collect from you may be collected, used, disclosed, and/or processed for various purposes, including:
(a) administering, dealing with, managing and/or maintaining your membership with the Club, contacting you through various modes of communication such as via phone/voice call, text message and/or fax message, email and/or postal mail for such purposes to deal in matters relating to your membership (including the mailing of correspondence, statements, information, invoices, or notices to you, which could involve disclosure of certain personal data about you to bring about delivery of the same), performing internal administrative and operational tasks for the said purposes;
(b) providing and sending you marketing, advertising and/or promotional information and materials (relating to, among other things, membership benefits as well as products, attractions, events and/or services that TMCC or TMCC partners may be selling, marketing, offering and/or promoting) via various modes of communication such as (a) postal mail to your postal address(es) and/or electronic transmission to your email address(es) (based on our records that we have of your postal address(es) and email address(es) or any new or amended postal or email address(es) that you may provide us with from time to time) and (b) via telephone/voice calls, SMS/MMS and/or facsimile to your telephone number(s) (based on our records that we have of your telephone number(s) or any new telephone number(s) that you may provide us with from time to time);
(c) dealing with, or facilitating customer service, booking of Club facilities, golf sessions, tournaments, events and/or any other facilities and services extended by TMCC or our reciprocal or affiliate clubs, carrying out of your instructions, or dealing with or responding to any enquiries given by you or on your behalf;
(d) implementing physical and information technology safety and security measures, including closed-circuit video surveillance;
(e) conducting research, analysis, and development activities (including but not limited to data analytics, surveys, product, and service development and/or profiling) to improve TMCC’s services or products or to enhance your membership experience;
(f) general administration and record-keeping, audit, risk management or compliance purposes;
(g) complying with any applicable law, governmental or regulatory requirements of any relevant jurisdiction, including meeting the requirements to make disclosure under the requirements of any law binding on the Club; and
(h) any other purposes in connection with the above or for which we notify you of at the time of obtaining your consent.
(collectively, the “Purposes”).
1.2 In order to conduct TMCC operations smoothly, we may also be disclosing the personal data you have provided to us to our third-party service providers, agents and/or other third parties whether sited in Singapore or outside of Singapore, for one or more of the above-stated Purposes. Such third-party service providers, agents and/or affiliates or related corporations and/or other third parties would be processing your personal data either on our behalf or otherwise, for one or more of the above-stated Purposes.
2 DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES
2.1 We respect the confidentiality of the personal data you have provided to us.
2.2 We will only share your personal data with a third party for the Purposes described above. This may include companies providing services to the Club, such as our professional advisers, including our consultants, auditors and lawyers, third party organizers of Club events and other third party service providers for insurance, courier services, telecommunications, information technology, payment, printing, billing, technical services, training, market research, security, marketing or other services provided to the Club.
2.3 We may also share your personal data with relevant government bodies, ministries, regulatory, statutory boards, authorities, or law enforcement agencies to comply with any laws, rules, guidelines, regulations, or government schemes.
2.4 We will not disclose your personal data to third parties without first obtaining your consent unless such disclosure without your consent is permitted by the PDPA or by law.
2.5 We may disclose your personal data for cases in which the disclosure is to a public agency and such disclosure is necessary in the public interest
3 REQUEST FOR ACCESS AND/OR CORRECTION OF PERSONAL DATA
3.1 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 to ascertain your identity as well as the nature of your request, to be able to deal with your request.
4 REQUEST TO WITHDRAW CONSENT
4.1 You may withdraw your consent for the collection, use and/or disclosure of your personal data in relation to specific Purposes in our possession or under our control by contacting our DPO, listed on the Club’s website.
4.2 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.
4.3 However, your withdrawal of consent could result in certain consequences arising from such withdrawal. The Club may not be able to continue maintaining or administering your membership effectively and/or you may miss or fail to receive relevant notices and messages related to your ongoing relationship with the Club. 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 with us.
5 ADMINISTRATION AND MANAGEMENT OF PERSONAL DATA
5.1 We will take reasonable efforts to ensure that your personal data is accurate and complete. 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.
5.2 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.
6.1 When you access, use and/or interact with TMCC online, we or our authorized service providers may use “cookies” and other tracking technologies where small data files are sent to the app and/or browser, application or device to store and track information about you. The “cookies” and other tracking technologies are used to track information such as the number of users and their frequency of use, online behavioural data, profiles of users and their preferred sites. They enable our own system to recognise you when you visit us again, enhance your web-viewing experience and allow for more effective online targeted advertising. You may accept or decline cookies by modifying the settings in the app and/or browser, application, or device, if the app and/or browser, application or device so permits. However, please note that you may not be able to use all interactive features if cookies have been disabled completely.
7 EXTERNAL SITES
7.1 External sites that are linked to or from the Club’s website are not under our control and you are advised to review their privacy statement. Users should note there are inherent risks associated with the transmission of information via the internet and you should therefore make your own assessment of the potential risk to the security of your information.
8 GENERAL INFORMATION
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. 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 and can be viewed at www.tmcc.org.sg.
8.2 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.
8.3 This Data Protection Policy is to be read together with our TMCC Club Rules and applies to all products and services provided by TMCC.
Issued: 20 July 2020