1. What is this policy about?
This policy explains the key measures we have taken to implement the requirements of the Personal Data Protection Act 2012 (“PDPA”). It aims to answer the questions you might have about how we collect, use and disclose your personal data. If you have any further questions about Spark Plus’s privacy practices, please contact our Personal Data Officer at firstname.lastname@example.org or by writing to us at 12 Marina View #11-01 Asia Square Tower 2 Singapore 018961.
2. What data have you collected about me?
We collect and hold data that you have provided to us about yourself, and information about your use of our services such as membership information and information about your use of our clubs. The information that we collect will depend on how you use the services offered by Spark Plus.
Data that you might have provided to us includes:
- data provided as part of your use of Spark Plus’s website and web services – for example, the email address you provide to participate in our events and roadshows, information you provide about your investment preferences and mandate; and
3. What do you do with this data?
We use and disclose your personal data to provide you with Spark Plus products and services. We may also use personal data for related purposes and for purposes permitted under the PDPA such as:
- maintaining our relationship with you, including responding to your questions;
- helping us to identify and inform you about other Spark Plus products or services that are likely to be of interest to you;
- internal accounting and administration, including sharing information with our related bodies corporate for reporting purposes;
- photos for posting on social media and other marketing materials;
- protecting you and Spark Plus from error and fraud; responding to police or regulatory authority enquiries or investigations; preventing a serious credit infringement; improving the website; and developing a better understanding of our customers’ needs.
If you do not provide us with your personal data, we may not be able to provide you with these services.
4. Are there any other times when you use my personal data for any other purpose or give this information to someone else?
Spark Plus recognises the trust you place in us when you give us your personal data. Other than disclosure to service providers (explained below) or as required by law (for example, disclosure to various Government departments or to Courts), our policy is that we do not generally give your personal data to other organisations unless you have given us your consent to do so.
We may share your personal data with certain third parties, such as: providers of the electronic systems we use to collect and store your personal data; and other service providers we use to help us run aspects of our business efficiently. Occasionally Spark Plus might also use your personal data for other purposes or share your information with another organisation because:
we believe it is necessary to provide you with a service which you have requested; we believe it is necessary to protect the rights, property or personal safety of you; we believe it is necessary to do so to prevent or help detect fraud or serious credit infringements - for example, we may share information with credit reporting agencies, law enforcement agencies and fraud prevention units; for obtaining legal advice; we believe it is necessary to protect the interests of Spark Plus – for example, disclosure to a Court in the event of legal action to which Spark Plus is a party; or the assets and operations of the business are being transferred to another party as a going concern.
5. Do I have to receive marketing information from Spark Plus?
Spark Plus will keep you up to date with our special offers, products and services, where you have consented to receive materials containing such information. Please note that you can choose not to receive marketing information from us by contacting the Spark Plus team on email@example.com or by speaking to a member of the team during events and roadshows.
7. How can I access the information you keep about me?
If at any time you want to know what personal data we hold about you, or about how such personal data has been or will be used, you are welcome to request a copy of your customer record by contacting Spark Plus on firstname.lastname@example.org. We aim to respond to most requests within 14 days, or if the request is more detailed, within 30 days. Spark Plus may recover from you its reasonable cost of supplying you with this information.
8. How do I change or delete the information that you have about me?
9. Is the information Spark Plus has about me secure?
Spark Plus endeavours to take all reasonable steps to keep your personal data secure. We store this information on secure servers that are protected in access-controlled facilities. Only authorised users can access your personal data, and access is only for approved purposes. We train our staff and require our data operators to respect the privacy and confidentiality of your information. Unfortunately, we can’t give you an absolute guarantee that your information is always secure. For example, no data sent over the internet is 100% secure. While we ensure reasonable security arrangements to prevent unauthorised access, collection or use of your data, we can’t be held responsible for events arising from unauthorised access to your personal data.
10. What happens to my information if I enter it on a different website linked to the Spark Plus site?
11. Do you have data on people other than customers?
Most of the personal data that Spark Plus collects relates to our investors and corporates. But we may also keep information about people who provide information via the website, such as by entering events, or applying for Spark Plus career positions. This policy applies to those people as well. We also hold personal data on our employees and contractors, which are covered by separate policies.
12.What if ownership of the Spark Plus business changes?
In the unlikely event that ownership of part or all of the Spark Plus business changes, your personal data will be transferred to the new owner of the business.
13. What to do if I have a problem, question or complaint?
14. Future changes