Privacy Policy ("Policy")

(Last updated on 2 May 2023)

At SAFRA, the privacy and confidentiality of the personal data of our members and individuals who have participated in our events or visited our clubs are important to us. We are committed to implementing policies, practices and processes which will safeguard the collection, use and disclosure of the personal data you provide us.

This Policy sets out the manner in which SAFRA collects, uses, manages and protects Personal Data (as defined below) in compliance with the provisions of the Personal Data Protection Act 2012.

This Policy supplements but does not supersede or replace any previous consent which an Individual may have provided to SAFRA, and nothing in this Policy shall affect any rights or exemptions that SAFRA may have at law in connection with the collection, use and/or disclosure of any individual’s Personal Data.

Subject to applicable laws, the prevailing terms of the Policy from time to time shall apply. By continuing your relationship with SAFRA after any amendments have been introduced and published, you shall be deemed to have accepted the Policy as amended and given your consent for SAFRA to use your Personal Data in the manner described. For the avoidance of doubt, this Policy forms part of the terms and conditions, if any, governing an individual’s relationship with SAFRA ("Terms and Conditions") and should be read in conjunction with such Terms and Conditions. In the event of any conflict or inconsistency between the provisions of this Policy and the Terms and Conditions, the provisions of the Terms and Conditions shall prevail to the fullest extent permissible by law.

Definitions

“Event Participants” means persons (whether or not Members) who participate in contests, competitions, lucky draws or campaigns or attend events, programmes or activities organised or sponsored by SAFRA, whether on its own or together with other organisers from time to time.

“Members” mean the members of SAFRA from time to time, including alumni members who no longer have an active membership, members who have a dependent membership as well as prospective members who submit an application for membership, and shall also include members of affiliated organisations, interest groups and micro clubs organised by SAFRA.

“Non-members” means persons who are not Members of SAFRA, but who own an online account with SAFRA, or are Event Participants, or are visitors and users of SAFRA’s facilities.

“PDPA” means the Personal Data Protection Act 2012 as may be amended from time to time.

“Personal Data” means data (whether true or not) that is capable of identifying a natural person, whether on its own or in conjunction with other data that is accessible to SAFRA. Such Personal Data shall also refer to data which is already in the possession of SAFRA or that which shall be collected by SAFRA in the future.

“Personnel” shall include any person engaged under a contract of service with SAFRA, management personnel, permanent or temporary employees, as well as volunteers engaged by SAFRA from time to time (and, where appropriate, shall also include individuals who provide services to SAFRA as sole proprietors under a contract for services, and individuals employed by a third party but who perform services for SAFRA pursuant to a contract for services entered into between his or her employer and SAFRA).

“Platforms” mean the websites (including but not limited to www.safra.sg m.SAFRA ), application software (including but not limited to the mSAFRA mobile app), self-service kiosks, computer systems, computer networks and any other digital platforms operated by or on behalf of SAFRA from time to time, and which may include third party platforms used by SAFRA to conduct webinars or virtual events or other social media platforms used by SAFRA (including but not limited to Facebook).

“Potential Personnel” shall include any individual who has submitted an application to be engaged by SAFRA as Personnel.

Personal Data Collected by SAFRA

SAFRA will only collect, use or disclose Personal Data which it reasonably considers necessary for the relevant purposes underlying such collection, use or disclosure. Depending on the specific nature of an Individual’s interaction with SAFRA, Personal Data which SAFRA collects, uses or discloses may include the following (Note: the list below may not be exhaustive):

personal particulars such as name, gender, date of birth, occupation, photographs, marital status, his/her relatives, nationality, and national service standing; and contact particulars, including telephone number(s), residential/mailing address(es) and email address, employment history, and academic qualifications

unique SAFRA membership number

identification documents (such as NRIC, passport numbers, and birth certificate numbers, partial or in full), and applicable visa or permits (such as employment pass, work permit, permanent residency status) and other documents such as marriage certificates

medical declaration and details

details of CPF account, credit/debit cards or bank accounts, and copies of pay-slips

the name and contact particulars of next-of-kin and emergency contacts

hobbies or special interest areas, consumption habits, medical data such as food allergies, personal preferences or other special requests or special conditions applicable to an individual

network usage data and other data and information, submitted by the individual or gathered automatically by our Platforms, including computer IP address, links visited and other activities conducted online or using our Platforms

photographs, voice, audio, video or CCTV recordings

other information which an individual may provide to SAFRA, from time to time, in the course of such individual’s interaction with SAFRA or that may be received from a third party providing such information to SAFRA

How SAFRA collects Personal Data

Generally, SAFRA may collect Personal Data about an Individual in one or more of the following ways:

Directly from an individual

i.		through correspondence, emails, electronic messages or other forms of communications with SAFRA or its representatives or information that may be posted on the Platforms;
ii.		through an individual’s verbal interactions with SAFRA (including voice or video calls or face-to-face interactions)
iii.		through application or registration forms
iv.		through registration for an online account with SAFRA (as online SAFRA account holder)
v.		through retrieval of data from the Myinfo portal of individuals with their consent
vi.		through information obtained from the mobile devices of individuals with consent (including but not limited to location information)
vii.		through surveys conducted with and/or feedback
viii.		when submitted for any reason such as to participate in a lucky draw, contest, campaign, event or competition organised by SAFRA.

From a third party and affiliated organisations

i.		from the Singapore Armed Forces, Ministry of Defence and other public agencies
ii.		from the family members or associates of an individual
iii.		through third party business partners or associates of SAFRA including but not limited to transactions carried out by individuals at points of sale at vendors premises or outlets located at SAFRA’s clubhouses or elsewhere

Other monitoring

i.		through the individual’s access to and/or use or navigation of the Platforms and the use of cookies
ii.		through recordings taken via security cameras or other forms of photography or video or sound recording at SAFRA’s premises or at any events or programmes organised by SAFRA including but not limited to instances of entry into and exit from carparks at SAFRA’s clubhouses

Purposes for which SAFRA may collect, use and/or disclose Personal Data

In addition to the statutorily provided situations in which Personal Data may be collected, used or disclosed without consent, generally, SAFRA may collect, use and/or disclose Personal Data for one or more of the following purposes and any purposes reasonably related and/or ancillary to any of the below-mentioned purposes:

Members:

i.		administering and managing Member relationships with SAFRA, including but not limited to verification of an individual’s eligibility to be a Member of SAFRA, the provision of services to Members, and providing Members with information regarding the expiry and renewal of their membership and other service-related announcements such as the conduct of annual general meetings and policy changes
ii.		providing Members with information and updates concerning services, facilities and/or other benefits or promotions being offered or made available by SAFRA to Members and where applicable, allowing the Members to book, subscribe and/or purchase the same (this may require SAFRA to share Personal Data with the merchants to establish a Member’s eligibility for a benefit or promotion)
iii.		providing Members with information about third party and/or external vendor/supplier promotions, benefits, deals and/or other services being offered or made available to Members, through partnerships, associations and/or other collaborations involving such third parties or external vendors/suppliers and SAFRA
iv.		tailoring activities or services available to match Members’ preferences and to personalise their experience

Event Participants

i.		organising, administering and/or facilitating events, activities contests, competitions, lucky draws, campaigns, and programmes (“Events”), administering and managing the Event Participant’s relationship with SAFRA, which includes verifying the identity and eligibility of individuals to participate, notifying individuals of the Events, submitting forms for such Events and publishing the results of Events (particularly in the case of lucky draws or contests)
ii.		promotional and publicity purposes of SAFRA (and its event co-organisers and co-sponsors, as may be applicable), including recording videos or taking photographs of Event Participants

Visitors and users of SAFRA facilities

i.		i. recording and verifying the identity of visitors to SAFRA’s premises for safety, health and security purposes
ii.		monitoring the activities of visitors to SAFRA’s premises to ensure compliance with SAFRA’s club rules and regulations and statutory regulations or other directions from the Singapore public agencies

Non-members

i.		providing Non-members with information and updates concerning services, facilities and/or other benefits or promotions being offered or made available by SAFRA to Non-members and where applicable, allowing the Non-members to book, subscribe and/or purchase the same (this may require SAFRA to share Personal Data with the merchants to establish a Non-member's eligibility for a benefit or promotion)
ii.		providing Non-members with information about third party and/or external vendor/supplier promotions, benefits, deals and/or other services being offered or made available to Non-members, through partnerships, associations and/or other collaborations involving such third parties or external vendors/suppliers and SAFRA
iii.		tailoring activities or services available to match Non-members' preferences and to personalise their experience

Personnel

i.		administering and managing Personnel relationships with SAFRA, including but not limited to making payment to Personnel (whether via GIRO or through other payment platforms where Personal Data is submitted) and evaluating the performance of Personnel
ii.		monitoring performance and compliance with SAFRA rules and regulations and the terms of the Personnel’s contract with SAFRA
iii.		organising and undertaking training and quality assurance activities
iv.		providing Personnel with information about services, facilities and/or other benefits being offered or made available by SAFRA to such Personnel as well as information about such services, facilities and benefits
v.		making nomination or participation in awards organised by external organisations
vi.		submitting information to third party consultants for work efficiency and quality improvement initiatives or programs organized by SAFRA

Potential Personnel

i.		evaluating the suitability and eligibility of Potential Personnel to be engaged by SAFRA, including but not limited to conducting interviews and assessing suitability for the position applied for processing your application (including but not limited to pre-recruitment checks involving qualifications, obtaining employee references to conduct background screening and facilitating interviews)
ii.		attending to the enrolment of successful applicants

In addition to the abovementioned purposes, SAFRA may also use Personal Data for the purposes below:

Marketing

sending marketing, advertising and promotional information concerning SAFRA and its affiliated organisations, interest groups, micro-clubs and third party service providers/suppliers/vendors engaged by or working in collaboration with SAFRA in relation to promotions, Events, deals and/or services being offered or made available to you

General business purposes

i.		managing the administrative and business operations of SAFRA (which may include collection, use and disclosure of Personal Data in order to comply with governmental directions or other rules, regulations and advisories relating to the management of the COVID-19 situation.)
ii.		responding to complaints, queries and/or requests
iii.		conducting market research for statistical profiling, compiling data, statistics and other information, for participating in industry exercises and studies, and/or generally for data analytics initiatives to enable us to better understand and determine user preferences and demographics to develop special offers or fine tune services and to improve SAFRA’s services
iv.		assessing insurance policies or assessing, evaluating or making insurance claims with our insurance providers and enabling our insurance providers to provide their services to us
v.		safety and security purposes, including but not limited to preventing, detecting or investigating any actual or potential crime, fraud, misconduct, unlawful action, breach or dispute (including taking action to prevent bodily harm)
vi.		legal and record-keeping purposes (including but not limited to purposes of accounting or auditing or obtaining financial, or tax advice obtaining legal advice and dispute resolution) or the recovery of bad debts or damages and complying with laws, regulations, codes or guidelines binding on SAFRA, making disclosures to regulatory authorities or other public agencies
vii.		transmitting Personal Data to third parties engaged by or working in collaboration with SAFRA to facilitate any of the above-mentioned purposes (such as external consultants or outsourced service providers) or to such parties as may be directed by the relevant authorities or as may be required under applicable laws.

Consent

Unless otherwise permitted under the PDPA or any other applicable law, SAFRA will not collect, use or disclose an individual’s Personal Data without his/her consent or without notifying the individual of the collection, use or disclosure of his or her Personal Data.

Where consent / notification is required to be obtained / provided to an individual, SAFRA will take reasonable steps to highlight the relevant purposes, by appropriate means, at the point or time of collection of the Personal Data, which may include:

via express provisions in contracts, application forms and/or registration forms to be signed with or submitted to SAFRA;
via notifications on or through the Platforms; and
in the course of verbal communications.

An individual who provides SAFRA with Personal Data relating to a third party (e.g. information of his/her spouse or children) for any particular purpose, represents to SAFRA that he/she has obtained the consent of the relevant third party to SAFRA collecting, using or disclosing such Personal Data for the relevant purpose. By providing us with any Personal Data relating to any third party (“Third Party Personal Data”), you represent and warrant that you have ensured the accuracy of such Third Party Personal Data provided and have also obtained such third party’s consent for our collection, use and disclosure of such Third Party Personal Data. You also agree to keep us indemnified from and against any and all damages, losses, costs, legal fees (on a solicitor-client basis), penalties and proceedings, imposed or charges by any regulator or authority arising out of or in connection with your acts or omission, fault or negligence which results in our breach of relevant laws.

In so far as SAFRA collects Personal Data from any third party(ies), SAFRA will take reasonable steps to inform the relevant third party(ies) of SAFRA’s purposes for collecting the Personal Data and to verify that consent from the individual has been obtained by the relevant third party(ies) to such disclosure for the intended purpose. If the third party is exempt from the provisions of the PDPA, and your consent is required, SAFRA shall take reasonable steps to contact you and confirm that you wish for your Personal Data to be used.

Cookies

When you visit our Platforms, we may send one or more cookies to your computer and/or other devices. The information obtained from such cookies may be used by us for storing user preferences and to enable SAFRA or third party advertising partners to display targeted advertisements which may be of interest to you.

We also collect information which is sent to us by your web browser. When you browse our Platforms, we automatically receive your computer’s Internet protocol (IP) address which provides us with information that helps us learn about your browser and operating system, such as the name of your operating system and the name and version of your browser.

In so far as an Individual’s data is being collected by cookies, the Individual may disable the use of cookies when accessing the Platforms. However, this may result in the loss of functionality, restrict the Individual’s use of the Platforms and/or delay or affect the way in which the Platforms operate.

Third party websites

SAFRA is not responsible in any way for the security and/or management of Personal Data shared by or collected from you through third party websites such as our partners which are not managed by SAFRA and accessible through links on the Platforms.

Retention of Personal Data

Your personal data is retained as long as the purpose for which it was collected remains and/or until your personal data is no longer necessary for any other legal or business purposes.

Protection of Personal Data

SAFRA shall make reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks to Personal Data in its possession. Subject to the foregoing and at all times the provisions of the PDPA, we cannot assume responsibility for any unauthorized use of your personal data by third parties which are wholly attributable to factors beyond our control.

SAFRA will ensure that third parties who receive Personal Data from SAFRA protect such Personal Data in a manner consistent with this Policy and not use such Personal Data for any purposes other than those specified by SAFRA, by incorporating appropriate contractual terms in its written agreements with these third parties.

10.

Overseas transfer of data

If SAFRA transfers or hosts Personal Data outside Singapore, SAFRA will take reasonable steps to ensure that the Personal Data that is transferred to the transferee or host overseas receives a standard of protection for personal data that is comparable to the protection received under the PDPA.

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 organisation 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 organisation dealing with the personal data transfer or permitting the personal data transfer without such a contract if the PDPA or law permits us to.

11.

Withdrawal of Consent / Unsubscribing

Members / Online SAFRA account holders may unsubscribe from receiving electronic direct mailers (for marketing purposes) by altering their consent settings through logging into their accounts on the respective Platforms, such as mySAFRA. Alternatively, if Members/Online SAFRA account holders are unable to do so for technical reasons, they may write to SAFRA’s Data Protection Officer at dpo@safra.sg and clearly indicate their intention to withdraw their consent to the use, or disclosure of Personal Data by SAFRA.

Not consenting to or removal of consent to receiving marketing materials from SAFRA and its affiliates does not mean that you will not receive service-related messages and updates from SAFRA, including but not limited to notifications that your SAFRA membership is expiring or notifications of an amendment to SAFRA’s policies or Terms and Conditions.

By signing up as a Member, an online SAFRA account holder, or an Event Participant, you have consented to receiving service-related messages and updates. Depending on the extent to which you withdraw consent to any or all use or disclosure of your Personal Data by SAFRA, such withdrawal of consent may result in SAFRA’s inability to provide services to you and/or you having to cease participation in the Events and this may be considered as a termination by you of any agreement between SAFRA and you. SAFRA’s legal rights and remedies are expressly reserved in such event.

12.

Accuracy of Personal Data & Notification of Changes

You agree that you shall be responsible for ensuring that all Personal Data submitted by you to SAFRA is complete and accurate, and that you shall update SAFRA in a timely manner of all changes to your, or your family members’ Personal Data.

SAFRA may take reasonable steps to periodically verify Personal Data in its possession, taking into account the exigencies of its operations but shall not be held liable for any inability to attend to or provide services to any person (including participation in an Event) who fails to ensure that his/her Personal Data submitted to SAFRA is complete and accurate or who fails to notify SAFRA of any relevant changes to such Personal Data.

13.

Contacting SAFRA on Personal Data matters

If you have questions or feedback relating to this Policy, would like information about the ways in which your Personal Data held by SAFRA has been or may have been used or disclosed by SAFRA, or have other queries or concerns about your Personal Data, please contact SAFRA's Data Protection Officer by email at dpo@safra.sg.

Please note that SAFRA is not required, under the PDPA, to provide access and correction to Personal Data in certain situations. SAFRA reserves the right to charge a reasonable fee for the handling and/or processing of access requests.

Depending on the complexity of the request, SAFRA may require up to 30 calendar days from the date of the request to respond and effect any change requested, and if additional time is required, SAFRA will notify you accordingly.

14.

Amendments or Updates to this Policy

SAFRA reserves the right to amend or update this Policy to ensure it is consistent with its future developments or business purposes or to accommodate future changes to applicable legal, business or regulatory requirements. All amendments or updates to this Policy will be published at www.safra.sg and appropriate notifications of any material revisions will be issued to the relevant persons (unless such persons have unsubscribed from our notification channels).

15.

Governing Law

This Policy shall be governed by and construed in accordance with the laws of Singapore. Any dispute arising out of or in connection with this Policy including any question regarding its existence, validity or termination, shall be referred to and finally resolved by the Courts of Singapore.