DATA PROTECTION NOTICE
This Data Protection Notice (“Notice”) sets out the basis which 7Moments pte. ltd. (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of our customers in accordance with the Singaporean Personal Data Protection Act (“PDPA”). This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.
1. As used in this Notice:
“customer” means an individual who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us; and
“personal data” means data, whether true or not, about a customer who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.
2. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you may include your name, email address, IP address and usage patterns (e.g. which sites you visit and how you scroll through and use the website). Usage patterns are collected through cookies and similar technologies, see below for more information.
3. Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).
COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
4. We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
5. We may collect and use your personal data for any or all of the following purposes:
(a) performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
(b) responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
(c) managing your relationship with us;
(d) complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
(e) any other purposes for which you have provided the information;
(f) transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
(g) any other incidental business purposes related to or in connection with the above.
6. We may disclose your personal data:
(a) where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods or services requested by you; or
(b) to third party service providers, agents and other organisations we have engaged to perform any of the functions listed in clause 5 above for us.
7. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).
The types of cookies used are as follows:
(i) Mandatory cookies: The cookies which are essential for enabling users to access and use the Platform and their services.
(ii) Preference cookies: The cookies which collect information about how users use the Platform in order for us to improve the Platform’s design and accessibility.
(iii) Statistics cookies: The cookies which provide statistics and reporting on the performance of the Platform, through Google Analytics. No personally identifiable data will be collected through these cookies.
(iv) Marketing cookies: The cookies which track users’ behaviour on the Platform and potentially across other websites, in order to target content that are relevant for the users. Users would not be personally identified through this information.
11. We use the Facebook Pixel to monitor our Facebook and Instagram advertising. The Facebook Pixel is used to track the actions of users who click or view an ad on Facebook, Instagram or Facebook’s Audience Network. The Facebook Pixel provides us with data such as how many users click on an ad and visit our website, and how many users complete an enquiry form on our website after clicking or viewing one of our Facebook and Instagram ads. We use the Facebook Pixel to build advertising audiences based on behaviours such as visits to our website. The data provided to us is anonymised in that we cannot see information such as your name or email address.
12. 7Moments gathers certain information and stores them in log files automatically in order to improve the Platform’s services. This information includes operating system, internet protocol addresses, internet service provider, referring/exit pages, files viewed on the Platform, date/time stamp, clickstream data and/or browser type. This information may be combined with other information 7Moments collects about users. 7Moments and/or its service providers may use local storage to store content information and preferences.
13. Compilation of cookies and storage times.
Cookie Provider Description Expiry
_ga Google Analytics Used to distinguish users. 2 years
_gid Google Analytics Used to distinguish users. 24 hours
_ga_<container-id> Google Analytics Used to persist session state. 2 years
_gac_gb_<container-id> Google Analytics Contains campaign related information. If you have linked your Google Analytics and Google Ads accounts, Google Ads website conversion tags will read this cookie unless you opt-out. Learn more.
WITHDRAWING YOUR CONSENT
14. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.
15. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.
16. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 8 above.
17. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclosure without consent is permitted or required under applicable laws.
ACCESS TO AND CORRECTION OF PERSONAL DATA
18. If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
19. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
20. We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within fifteen (15) business days after receiving your request, we will inform you in writing within fifteen (15) business days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).
PROTECTION OF PERSONAL DATA
21. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as minimised collection of personal data, authentication and access controls (such as good password practices, need-to-basis for data disclosure etc.), encryption of data, up-to-date antivirus protection and the use of privacy filters to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis.
22. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
ACCURACY OF PERSONAL DATA
23. We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.
RETENTION OF PERSONAL DATA
24. We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
25. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.
TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
26. Any personal data provided to us may be transferred to, stored by or disclosed to an overseas recipient. For example, we may use a server hosted overseas to store data, which may include your personal data.
27. Your personal data may also be processed by employees or by other third parties operating outside of Singapore, who work for us, or by the representatives and employees of our parent company.
28. We will take reasonable steps, in the circumstances, before your personal data is disclosed to an overseas recipient, to ensure that the overseas recipient provides a standard of protection to personal data so transferred that is comparable to the protection under the PDPA.
DATA PROTECTION OFFICER
29. You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:
Data Protection Officer: Patrik Arnesson
EFFECT OF NOTICE AND CHANGES TO NOTICE
30. This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
31. We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.
Effective date : July 9th, 2021
Last updated : July 9th, 2021