PDPA

PERSONAL DATA PROTECTION ACT

General

1. Shimano (S) Pte Ltd ("us", "we", "our") manages http://fish.shimano.com.sg/  (the "website"). We strictly abide by Singapore’s Personal Data Protection Act 2012 (the "PDPA") and understand the importance of all personal data, including and not limited to, your name, email address, telephone number and age that you have entrusted to us. Properly managing, protecting and processing your personal data is our responsibility.

2. Together with our Privacy Policy, the Personal Data Protection Policy is provided for your understanding on the collection, usage, disclosure and/or processing your personal data.

3. You agree that we may process your personal data within the boundaries of the PDPA or any other applicable laws. Please refer to our policies stated in point 2 for further information.

What is Personal Data

4. 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. Examples of personal data could include, but not limited to, full name, photograph or video image of an individual, mobile telephone number, residential telephone number, personal email address, and residential address.

How Personal Data is collected

6. Here are some ways where your personal data may be collected:

      (a) through direct communication regarding our products and services (by email, telephone or any other methods);

      (b) during your participation in our promotions, competitions, contests, lucky draws or special events like open houses and exhibitions;

      (c) through your submission of our surveys and other types of research.

When Personal Data Collected and what is Collected

7. Personal data is collected through various means such as registration, completion of forms, emails, inquiries, requests, and other situations in which you have actioned to provide personal data to us. Your personal data provided assists us in responding to your requests.

8. Other examples of the types of personal data which we may collect about you include, but not limited to:

      (a) contact information such as name, address, telephone number, and email address;

      (b) unique information such as photograph, contact preference, and date of birth; 

      (c) details of your visits to our website, such as traffic data, location data and the extent of your access on our website.


Purposes for Collection, Use, Disclosure and Processing of Personal Data

9. You may, in certain situations, provide us with the personal data of a third party (for example, your friend or any person who may be interested in information regarding our products and services). In such a case, you are deemed to have obtained the consent of the third party in the provision of his/her personal data for processing as stated in point 2 above.

10. Personal data is collected if it is needed to carry out daily activities or functions. 

11. 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) for communication purposes;

      (b) for customer relationship and services;

      (c) to understand your identity and background;

      (d) to respond to your enquiries or complaints and resolve issues in connection with any dealings with us;

      (e) to process your requests of our services or assistance;

      (f) for provision of information and/or updates on products, services, promotions and/or events;

      (g) for direct marketing purposes using but not limited to SMS, phone call, email, mail, social media with your consent;

      (h) to facilitate participation and administration of events including but not limited to contests and campaigns;

      (i) to maintain and update internal record keeping;

      (j) for internal administrative purposes;

      (k) to send invitations for various events and promotions;

      (l) to keep track of and improve events and promotions, products and/or services;

      (m) to analyse the personal data either individually or collectively with other individuals for usage in, but not limited to, market research in trends and purchashing patterns regarding our products and/or services;

      (n) to share any of your personal data with the auditor for our internal audit and reporting purposes;

      (o) 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 advice and/or for purposes of commencing legal action;

      (p) to share any of your personal data with our business partners to launch marketing campaigns;

      (q) for audit, risk management and security purposes;

      (r) for detecting, investigating and preventing fraudulent, prohibited or illegal activities;

      (s) for enabling us to perform our obligations and enforce our rights under any agreements or documents that we are a party to;

      (t) to transfer or assign our rights, interests and obligations under any agreements entered into with us;

      (u) 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;

      (v) to enforce or defend our rights and your rights under, and to comply with, our obligations under the applicable laws, legislation and regulations; and/or

      (w) for other purposes required to operate, maintain and better manage our business and your relationship with us; which we inform you of at the time of obtaining your consent.

14. As the objectives for which we may/will collect, use, disclose or process your personal data depend on the situations at hand, such purpose may not be stated above. However, we will inform 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

15. To perform business operations or fulfill our obligations to you, we may also disclose your personal data to our third party service providers, who may be located inside or outside of Singapore, for one or more of the purposes mentioned in or informed 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.

16. Examples of third parties that we disclose your personal data to include:

      (a) third party service providers who provide operational services in connection with our business such as postal services or services relating to marketing and promotional activity; and

      (b) relevant government regulators or authorities.

17. The third parties whom we perform business with are only authorised to use your personal data to conduct 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.

18. We respect the confidentiality of the personal data that you provide to us. We never sell personal data to any third party.


Request for Access and/or Correction of Personal Data

19. You may request to access and/or update your personal data in our possession or under our control by writing to us at fish@shimano.com.sg

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

21. Where a request cannot be fulfilled with within the above time frame, we will notify you of the rationally quickest time in which we will respond.

22. For requests to correct personal data, we will:

      (a) update your personal data as soon as feasible after the request has been made unless we have reasonable grounds not to do so; and

      (b) subject to point 23 below, we will send the updated personal data to every other organisation to which the personal data was disclosed by us within a year before the date the update was made, unless that other organisation does not need the updated personal data for any legal or business purpose.

23. We may, if consented, send the updated personal data only to specific organisations to which the personal data was disclosed by us within a year before the date the update was made.

24. Depending on the scope and nature of the work required to process your access request, we may be required to impose a charge to recover our administrative costs. This will be reviewed on a case-by-case basis. Where such a charge is to be imposed, we will provide you with a written estimate of the charge for your consideration. Please note that we will only process your request once you have agreed to the payment of the charge. 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 the written estimate of the charge, if any.

25. You understand that we depend 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 using any inaccurate or incomplete personal data where you have provided and/or have failed to update us of any changes in your personal data.

Request to Withdraw Consent

26. You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control by writing to us at fish@shimano.com.sg

27. 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.

28. Your withdrawal of consent may result in certain repercussions. 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 repercussions after we receive your request for withdrawal.

29. 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 needed or authorised to do so under the PDPA or any other applicable law.

Protection and Destruction of Personal Data

30. We will put in place reasonable security arrangements to ensure that your personal data is suitably protected and secured. In particular, reasonable security arrangements will be taken to prevent any unauthorised access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data. However, we cannot assume responsibility for any unauthorised use of your personal data by third parties which are wholly attributable to factors beyond our control.

31. We will also position 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 objective 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 needed for any other legal or business purposes.

Complaint Process

32. If you have any complaint or grievance regarding about how we are handling your personal data or about how we are complying with the PDPA, please get in touch with us by writing to us at fish@shimano.com.sg

33. We will certainly strive to handle with any complaint or grievance that you may have quickly and fairly.

Contact Us

34. You may contact us (or send us any request or complaint form) by email at the following address: fish@shimano.com.sg

Updates on Personal Data Protection Policy

35. As part of our efforts to ensure that we properly manage, protect and process your personal data, we will be assessing our policies, procedures and processes from time to time.

36. We reserve the right to edit the terms of this Personal Data Protection Policy at our absolute discretion. Any edited Personal Data Protection Policy will be posted on our website http://fish.shimano.com.sg/. No individual notice will be sent to you.

37. You are deemed to have acknowledged and consented to any edited version of this Personal Data Protection Policy if you continue to use our 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.