Privacy Notice

PRIVACY STATEMENT

Personal Data Protection Notice

Dear valued Setelco customers and guests, This Personal Data Protection Policy notice (“Notice”) for personal data is issued to all our valued customers of Setelco pursuant to the statutory requirements of the Personal Data Protection Act 2012 (“PDPA”).

We at Setelco Communications Pte Ltd take our responsibilities under Singapore’s PDPA seriously. We also recognize the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data. During your course of dealing with us, we may have, and / or will collect, use, disclose and process your personal data for purposes, including, to communicate with you, provide products and/or services to you, respond to your enquiries or complaints, provide you with information and/or updates on products, services and/or promotions offered by Setelco and selected third parties and other purposes required to operate and maintain our business as set out in our Personal Data Protection Policy (collectively referred to as “Purposes”).

In order to conduct our business operations more smoothly, we may also be disclosing the personal data you have provided to us to our third party service providers, agents and/or our affiliates or related corporations, 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. We will also be transferring your personal data outside of Singapore to our central customer data storage and processing servers located overseas and share your personal data with our related corporations for such Purposes.

It is necessary for us to collect and to retain your personal data. If you do not provide us with your personal data, or do not consent with this Notice or our Personal Data Protection Policy, we will not be able to effectively provide products and/or services to you or respond to your enquiries/feedback, if at all.

We are committed to ensuring that your personal data is stored securely. You have the right to request for access to, to request for a copy of and to request to update or correct your personal data held by us. You have the right at any time to request us to limit the processing and use of your personal data. (for example, requesting us to stop sending you any marketing and promotional materials or contacting you for marketing purposes).

Your written request should be addressed to:
DPO – Setelco Communications Pte Ltd
5 Upper Aljunied Link
Quartz Industrial Building
#08-05 Singapore 367903

Or
Email: dpo@setelco.com.sg
Or
Call: +65 6285 8733

Data Protection Officer
By submitting your personal data to us, you consent to us collecting, using, disclosing and processing your personal data in accordance with this Notice. We will also take it that all personal data provided by you is accurate and complete, and that none of it is misleading or out of date. You will promptly update us
in the event of any change to your personal data.

We reserve the right to update and amend this Notice and our Personal Data Protection Policy from time to time. We will notify you of any amendments to this Personal Data Protection Notice or our Personal Data Protection Policy via announcements on our website or other appropriate means. If we amend this Personal Data Protection Notice or our Personal Data Protection Policy, the amendment will only apply to personal data collected after we have posted the revised Personal Data Protection Notice or Personal Data Protection Policy.

Date of issuance of this Personal Data Privacy Notice: 17 April 2024.

Personal Data Protection Policy
General
1. Setelco Communications Pte Ltd (“us”, “we”, “our”) is the operator of www.setelco.com.sg (the “Website”). We take our responsibilities under Singapore’s Personal Data Protection Act 2012 (the “PDPA”) seriously. We also recognise the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data.

2. This Personal Data Protection Policy, together with our Terms of Service, are designed to assist you in understanding how we collect, use, disclose and/or process your personal data.

3. Unless restricted by the PDPA or any other applicable law, you agree that we may process your personal data in the manner, and for the purposes set out in the terms described in paragraph 2 above.

4. What is Personal Data? Personal data means 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.

5. Common examples of personal data could include names, identification numbers, contact information, email address, photographs and video images.

Sources for Personal Data
6. Here are examples of situations where we collect your personal data:
(a) when you register for an account on the Website or apps;
(b) when you complete purchase orders, requests or applications for our products or services (by telephone, in person, or electronically);
(c) when you make a purchase on the Website;
(d) when you communicate with us directly in relation to our products and services (in person via the people at our warehouse, by email, telephone or any other means);
(e) when you use services that are made available on the Website or at our stores; such as home delivery, assembly/installation services, etc.;
(f) when you conduct certain types of transactions such as refunds;
(g) when you apply for employment with us; or
(h) when you participate in surveys and other types of research.
(i) However, the following situations do not constitute collection of personal data:
The sighting of the name and date of birth on the NRIC/Driving License to qualify for the birthday month discount.
The sighting of the name and printed address on the NRIC or any other verifiable documents for the purpose of product warranty and/or installation.

Where there is no intention to obtain control or possession of the physical NRIC or any other verifiable documents in checking the NRIC or any other verifiable documents for the purpose of establishing or verifying the identity of the individual, and no personal data is retained once the NRIC or verifiable document is returned immediately to the individual, the PDPC Act does not consider it to be collection of personal data.

When Personal Data Collected and what is Collected
7. You can use and browse the Website without disclosing your personal data. The provision of your personal data is voluntary. But, if you do not provide your personal data to us, we may not be able to provide the products and services that you require of us.

8. We collect personal data through registration, placement of orders, completion of forms, emails, inquiries, requests, and other situations where you have chosen to provide personal data to us.

9. Other examples of the types of personal data which we may collect about you include:
(a) contact information such as names, addresses, telephone numbers, and email addresses;
(b) billing information such as billing address and credit card information;
(c) unique information such as contact preferences, and date of birth;
(d) details of any membership that you have with us, such as by creating an account through the app or our website;
(f) details of your visits to the Website, such as location data, and the resources that you access on the Website; and
(g) your transaction history.

Purposes for Collection, Use, Disclosure and Processing of Personal Data
10. You may, in certain circumstances, provide us with personal data relating to third parties (for example, your next-of-kin or any person who may receive delivery of your purchased item on your behalf). When this happens, you are deemed to have represented and confirmed to us that you have obtained the consent of such third party to provide his/her personal data to us for processing in the manner set out in paragraph 2 above.

11. We collect personal data if it is necessary for us to conduct our everyday activities or functions.

12. 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, including:
(a) to communicate with you;
(b) to maintain and improve customer relationship;
(c) to assess, process and provide products, services and/or facilities to you;
(d) to administer and process any payments (including refunds) related to products, services and facilities requested by you;
(e) to establish your identity and background;
(f) to respond to your enquiries or complaints and resolve any issues and disputes which may arise inconnection with any dealings with us;
(g) to provide you with services or assistance that you have requested;
(h) to provide you with information and/or updates on our products, services, upcoming promotions offered by us and/or events organised by us and selected third parties which may be of interest to you from time to time;
(i) for direct marketing purposes via SMS, phone call, email, fax, mail, social media and/or any other appropriate communication channels, if you are our company’s customer, in accordance with your consent;
(j) to facilitate your participation in, and our administration of, any events including contests, promotions or campaigns;
(k) to award points in a loyalty or rewards programme;
(l) to maintain and update internal record keeping;
(m) for internal administrative purposes;
(n) to send you seasonal greetings messages from time to time;
(o) to send you invitation to join our events and promotions and product launch events;
(p) to monitor, review and improve our events and promotions, products and/or services;
(q) to conduct credit reference checks and establish your credit worthiness, where necessary, when providing you with products, services and/or facilities;
(r) to administer, process and fulfil your commercial transactions with us (such as a purchase on the Website, a tender award or contract for service);
(s) to process any payments related to your commercial transactions with us;
(t) to process and analyse your personal data either individually or collectively with other individuals
(u) to conduct market research or surveys, internal marketing analysis, customer profiling activities, analysis of customer patterns and choices, planning and statistical and trend analysis in relation to our products and/or services;
(v) to share any of your personal data with the auditor for our internal audit and reporting purposes;
(w) to share any of your personal data pursuant to any agreement or document which you have duly entered with us for purposes of seeking legal and/or financial advice and/or for purposes of commencing legal action;
(x) to share any of your personal data with our business partners to jointly develop products and/or services or launch marketing campaigns;
(y) to share any of your personal data with financial institutions necessary for the purpose of applying and obtaining credit facility(ies), if necessary;
(z) for audit, risk management and security purposes;
(aa) for detecting, investigating and preventing fraudulent, prohibited or illegal activities;
(bb) for enabling us to perform our obligations and enforce our rights under any agreements or documents that we are a party to;
(cc) to transfer or assign our rights, interests and obligations under any agreements entered into with us;
(dd) for meeting any applicable legal or regulatory requirements and making disclosure under the requirements of any applicable law, regulation, direction, court order, by-law, guideline, circular or code applicable to us;
(ee) to enforce or defend our rights and your rights under, and to comply with, our obligations under the applicable laws, legislation and regulations;
(ff) to carry out verification and background checks as part of any recruitment and selection process in connection with your application for employment with us; and/or
(gg) for other purposes required to operate, maintain and better manage our business and your relationship with us; which we notify you of at the time of obtaining your consent.

13. 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(s) at the time of obtaining your consent, unless we are permitted by the PDPA or any other applicable law to process your personal data without your consent.

Specific Issues for the Disclosure of Personal Data to Third Parties

14. In order to smoothly conduct our business operations or to fulfil our obligations to you, we may also disclose the personal data that you have provided to us to our third party service providers, agents, affiliates or related corporations, who may be situated inside or outside of Singapore, for one or more of the purposes stated in or notified to you under the Purposes for Collection, Use, Disclosure and Processing of Personal Data section. We will also disclose your personal data to government regulators or authorities in order to comply with any laws, rules, guidelines, regulations or schemes that apply to us.

15. Examples of third parties that we disclose your personal data to include:
(a) data entry service providers;
(b) professional advisors, consultants and/or external auditors;
(c) storage and warehousing facility providers (which may include data storage and processing servers located overseas);
(d) third party service providers who provide administrative or operational services in connection with our business such as telecommunications, information technology, logistics, delivery, assembly, installation, printing and postal services or services relating to marketing and promotional activity;
(e) relevant government regulators or authorities;
(f) other Setelco franchisees and our related corporations and affiliates either in Singapore or overseas; and
(g) to third-party credit reporting or employment agencies as part of the recruitment and selection process and/or otherwise in connection with your application for employment with us.

16. The third parties whom we conduct business are only authorized to use your information to perform the service for which they were hired. As part of our agreement with them, they are required to adhere to the PDPA and any policies that we provide, and to take reasonable measures to ensure your personal data is secure.

17. We respect the confidentiality of the personal data that you provide to us. We do not sell personal data to any third party. Request for Access and/or Correction of Personal Data

18. You may request to access and/or correct your personal data that is in our possession or under our control by writing to us at:

DPO – Setelco Communications Pte Ltd
5 Upper Aljunied Link
Quartz Industrial Building
#08-05 Singapore 367903

Or
Email: dpo@setelco.com.sg
Or
Call: +65 6285 8733

19. For a request to access personal data, we will provide you with the relevant personal data within thirty (30) days from such a request being made.

20. Where a request cannot be complied with within the above time frame, we will inform you of the reasonably soonest time in which we will respond.

21. For a request to correct personal data, we will:
(a) correct your personal data as soon as practicable after the request has been made unless we have reasonable grounds not to do so; and
(b) subject to paragraph 23 below, we will send the corrected personal data to every other organisation to which the personal data was disclosed by us within a year before the date the correction was made, unless that other organisation does not need the corrected personal data for any legal or business purpose.

22. We may, if you do consent, send the corrected personal data only to specific organisations to which the personal data was disclosed by us within a year before the date the correction was made.

23. Depending on the scope and nature of the work required to process your access request, we may be required to impose a fee to recover our administrative costs. This will be assessed on a case-by-case basis by our Data Protection Officer. Where such a fee is to be imposed, we will provide you with a written estimate of the fee for your consideration. Please note that we will only process your request once you have agreed to the payment of the fee. In certain cases, we may also require a deposit from you before we process the access request. You will be notified if a deposit is required when we provide you with then written estimate of the fee, if any.

24. You understand that we are reliant on you to provide us with accurate and complete personal data and with updates if there are any changes to your personal data. We will not be responsible for relying or using any inaccurate or incomplete personal data where you have provided us with such personal data and/or have failed to update us of any changes in your personal data.

25. 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.

26. Your withdrawal of consent may result in certain consequences. For example, it may mean that we will not be able to provide you with certain products or services that you have requested or that we will not be able to continue with your existing relationship with us. We will inform you of such consequences after we receive your request for withdrawal.

27. However, you understand that notwithstanding your withdrawal of consent, we will still be entitled to collect, use or disclose your personal data if we are required or authorised to do so under the PDPA or any other applicable law.

Protection and Destruction of Personal Data
28. We will put in place reasonable security arrangements to ensure that your personal data is adequately protected and secured. In particular, reasonable 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.

29. We will also put in place measures to ensure that any of your personal data that is in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that:
(a) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and
(b) retention is no longer necessary for any other legal or business purposes.

Complaint Process
30. If you have any complaint or grievance regarding how we are handling your personal data or about how we are complying with the PDPA, we welcome you to contact us:
DPO – Setelco Communications Pte Ltd
5 Upper Aljunied Link
Quartz Industrial Building
#08-05 Singapore 367903

Or
Email: dpo@setelco.com.sg
Or
Call: +65 6285 8733

31. We will certainly strive to deal with any complaint or grievance that you may have speedily and fairly. Updates on Personal Data Protection Policy.

32. 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.

33. We reserve the right to amend the terms of this Personal Data Protection Policy at our absolute discretion. Any amended Personal Data Protection Policy will be posted on the Website and can be viewed at www.setelco.com.sg. No individual notice will be sent to you.

34. You are deemed to have acknowledged and agreed to any amended version of this Personal Data Protection Policy if you continue to use the Website after the changes have taken place. As such, 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.

Last Updated on 14 April 2024.