1.1 This Policy statement provides information on the obligations and policies of Zipplefy in respect of an individual's Personal Data. Zipplefy undertakes to use reasonable efforts in applying, where practicable, those principles and the processes set out herein to its operations.
1.5 For the purposes of this Policy, in line with the provisions under the Singapore Personal Data Protection Act 2012 (No. 26 of 2012) (the "Act"), "Personal Data" shall mean data, whether true or not, about an individual customer who can be identified — from that data; or from that data and other information which an organisation has or is likely to have access. Such Personal Data shall also refer to that which is already in the possession of Zipplefy or that which shall be collected by Zipplefy in future.
2. Contacting the Data Protection Officer
2.1 Where you legitimately request access to and/or correction of Personal Data relating to you, such Personal Data which is in the possession and control of Zipplefy, Zipplefy shall provide and/or correct that data within 30 days and in a manner in accordance with its standard procedures as stated hereinafter.
2.2 In accordance with the Act, Zipplefy has established a process for receiving and responding to any query or complaint that may arise with respect to the application of this Act. To ensure that Zipplefy receives your complaints and enquiries, please send the same via email to the Data Protection Officer (the "DPO") of Zipplefy at the following email address: firstname.lastname@example.org.
2.3 Please note that if your personal data has been provided to us by a third party, you should contact that individual to make such queries, complaints, and access and correction requests to Zipplefy on your behalf.
2.4 Should you not wish Zipplefy to use your Personal Data for any of the purposes listed in Clauses 3.2 to 3.4, you may opt out by sending a clearly worded email to the DPO via the email address provided in Clause 2.2. Your request shall be processed within 30 days. Please note however that the Act is subject to other laws and regulations, and where not required under such other laws and regulations, the withdrawal of consent may affect our ability to attend to your needs.
2.5 We may rely on the legitimate interests exception of the Act to collect, use or disclose personal data without consent for some or all of the following purposes:
2.6 For more information on our reliance on the legitimate interests exception, please contact the relevant data protection officer as listed in Clause 2.2.
3. Statement Of PracticesTypes of Personal Data Collected:
3.1 As part of its day-to-day activity, Zipplefy may collect from you, through various means, including via forms used by Zipplefy from time to time, some or all of the following data in general:
3.2 Where the data mentioned in Clause 3.1 falls within the definition of Personal Data under the Act, such Personal Data is collected for the purposes of our provision of services to you; for creation of your online account on our website; for payment and/or credit control purposes; to notify you of any changes to our policies or services which may affect you; to respond to queries and feedback; for identification and access; for security purposes; and any other purposes as notified to you from time to time.Disclosure of Personal Data
3.3 In order to carry out the functions described above, Zipplefy may, from time to time, disclose your Personal Data between Zipplefy's employees, agent(s) and authorised service providers and vendors including but not limited to the payment processing vendor.
3.4 Without derogating from any of the above, Zipplefy may also disclose your Personal Data to the following third parties:
3.5 Zipplefy may disclose your Personal Data to the abovementioned parties also in the occurrence of any of the following events:
3.6 Under certain circumstances, telephone calls made to Zipplefy's office may be recorded for the purposes of quality control, appraisal, as well as staff management and development. In such an event, by agreeing to this Policy, you hereby give your consent for the collection, use and disclosure of such Personal Data for the purposes of our records, following up with your enquiry and/or request, and for quality control and training purposes.Cookies
4. Transfer of Personal Data Overseas
Your Personal Data may, in future, be processed by Zipplefy, its affiliates, agents and third parties providing services to Zipplefy, in jurisdictions outside of Singapore as Personal Data may be stored in servers located outside of Singapore. In this event Zipplefy will comply with the terms of the Act.
5. Accuracy of Personal Data
Where possible, Zipplefy will validate data provided using generally accepted practices and guidelines. This includes the use of check sum verification on some numeric fields such as account numbers or credit card numbers. In some instances, Zipplefy is able to validate the data provided against pre-existing data held by Zipplefy. In some cases, Zipplefy is required to see original documentation before we may use the Personal Data such as with Personal Identifiers and/or proof of address. To assist in ensuring the accuracy of your Personal Data in the possession of Zipplefy, please inform us of any updates of any parts of your Personal Data by sending a clearly worded email to the DPO at the email address provided at Section 2.2.
6. Protection of Personal Data
Zipplefy uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your Personal Data and will not knowingly allow access to this data to anyone outside Zipplefy, other than to you or as described in this Policy. However, Zipplefy cannot ensure or warrant the security of any information you transmit to Zipplefy and you do so entirely at your own risk. In particular, Zipplefy does not warrant that such information may not be accessed, altered, collected, copied, destroyed, disposed of, disclosed or modified by breach of any of Zipplefy's physical, technical, or managerial safeguards.
7. Access and Correction of Personal Data
7.1 In accordance with Clause 2.1 of this Policy, you have the right to:
7.2 Zipplefy reserves the right to charge a reasonable administrative fee in order to meet your requests under Clause 7.1(a). Upon payment of the requisite fee under Clause 7.1(a) and/or receipt of your request under Clause 7.1(b), your request shall be processed within 30 days.
7.3 If you wish to verify the details you have submitted to Zipplefy or if you wish to check on the manner in which Zipplefy uses and processes your personal data, Zipplefy's security procedures mean that Zipplefy may request proof of identity before we reveal information.
8. Storage and Retention of Personal Data
Zipplefy will delete, as reasonably possible, or otherwise anonymise any Personal Data in the event that the Personal Data is not required for any reasonable business or legal purposes of Zipplefy and where the Personal Data is deleted from Zipplefy's electronic, manual, and other filing systems in accordance with Zipplefy's internal procedures and/or other agreements.
9. Contacting you
Zipplefy will be allowed to contact you using all of your communication means you have provided to Zipplefy, for the purposes as stated above in Paragraph 3.2.
10. Change Policy
Zipplefy reserves the right to alter any of the clauses contained herein in compliance with local legislation, and for any other purpose deemed reasonably necessary by Zipplefy. You should look at these terms regularly. If you do not agree to the modified terms, you should inform us as soon as possible of the terms to which you do not consent. Pending such notice, if there is any inconsistency between these terms and the additional terms, the additional terms will prevail to the extent of the inconsistency.
11. Governing Law
This Policy is governed by and shall be construed in accordance with the laws of Singapore. You hereby submit to the non-exclusive jurisdiction of the Singapore courts.
Last Updated: 2 August 2021