We at Moonshadow Stories Pte Ltd (MS) are committed to safeguarding the personal data you have provided us, and it is our responsibility to properly manage, protect and process your personal data. This policy may change from time to time so please check it periodically. This update is correct as of 1 December 2020.
If you have any queries on this policy or any other queries in relation to how we may manage, protect and/or process your personal data, please contact our Manager who serves as our Data Protection Officer ("DPO") at Tel: +65 9060 6170 or email: [email protected]
1. INTRODUCTION TO THE PDPA
1.1 "Personal Data" is defined under PDPA to mean 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 organization has or is likely to have access.
1.2 MS will collect your personal data in accordance with the PDPA either directly from you or your authorized representatives, and/or through our third-party service providers (e.g ticketing agents or surveys).
1.3 MS will notify you of the purposes for which your personal data may be collected, used, disclosed and/or processed, as well as obtain your consent for the collection, use, disclosure and/or processing of your personal data for the intended purposes, unless an exception under the law permits us to collect and process your personal data without your consent.
2. PURPOSES FOR COLLECTION, USE, DISCLOSURE AND PROCESSING OF PERSONAL DATA
2.1 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, which include but are not limited to:
- Communicating with you on your enquiries.
- Sending you marketing, advertising and promotional information and materials relating to our events, and productions, or any services that we may be selling or marketing under our company.
- Administrative matters on your ticket purchases.
- Managing your subscription and/or processing your sign ups/registrations for workshops, events, activities, mailing lists, etc.
- Conducting market research and customer satisfaction surveys on our services; and
- Any other purposes that we notify you of at the time of obtaining your consent.
(the above collectively known as the "Purposes")
As the purposes for which MS may/will collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, MS will notify you of such other purposes at the time of obtaining your consent, unless processing of your personal data without your consent is permitted by the PDPA or by law.
2.2 Should MS be required to disclose the personal data you have provided to us to our third-party service providers, agents and/or our affiliates or related corporations, and/or other third parties whether sited in Singapore or outside of Singapore, for one or more of the above-stated Purposes, MS will make known any such disclosures to you for your approval and opt-in. In any such cases, the disclosure will be for these third-party service providers, agents and/or affiliates or related corporations and/or other third parties to process your personal data either on our behalf or otherwise, for one or more of the above stated Purposes.
3. SPECIFIC ISSUES FOR THE DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES
3.1 MS respects the confidentiality of the personal data you have provided to us. As such, MS will not disclose your personal data to third parties without first obtaining your consent permitting us to do so.
3.2 However, please note that MS may disclose your personal data to third parties without first obtaining your consent in certain situations, including, without limitation, the following:
- cases in which the disclosure is required or authorized based on the applicable laws and/or regulations.
- cases in which the purpose of such disclosure is clearly in your interests, and if consent cannot be obtained in a timely manner.
- cases in which the disclosure is necessary to respond to an emergency that threatens the life, health or safety of yourself or another individual.
- cases in which the disclosure is necessary for any investigation or proceedings.
- cases in which the personal data is disclosed to any officer of a prescribed law enforcement agency, upon production of written authorization signed by the head or director of that law enforcement agency or a person of a similar rank, certifying that the personal data is necessary for the purposes of the functions or duties of the officer.
- cases in which the disclosure is to a public agency and such disclosure is necessary for the public interest; and/or
- where such disclosure without your consent is permitted by the PDPA or by law.
3.3 The instances listed above at paragraph [3.2] are not intended to be exhaustive. Should you require more information, kindly refer to the Second, Third and Fourth Schedules of the PDPA which is publicly available at https://sso.agc.gov.sg/Act/PDPA2012
3.4 Where we disclose your personal data to third parties with your consent, we will employ our best efforts to require such third parties to protect your personal data.
4. REQUEST FOR ACCESS AND/OR CORRECTION OF PERSONAL DATA
4.1 You will be able to update your personal data (e.g Name, Email address, Mobile number) and preferences (e.g Interest and Marketing permissions) from the ‘Preference’ link that you will be able to access at the foot of the EDMs that have been emailed to you.
4.2 You may also request to access and/or correct the personal data currently in MS’s possession or control by submitting a written request to MS. Please provide MS with adequate information to confirm your identity, as well as details on the nature of your request, to [email protected].
4.3 For a request to access personal data, once MS receives sufficient information from you to deal with the request, MS will seek to provide you with the relevant personal data within 30 days. Note that the PDPA exempts certain types of personal data from being subject to your access request. We will also be charging you a reasonable fee for the handling and processing of your requests to access your personal data. We will provide you with a written estimate of the fee we will be charging. Please note that we are not required to respond to or deal with your access request unless you have agreed to pay the fee.
4.4 For a request to correct personal data, once MS receives sufficient information from you to deal with the request, we will correct your personal data within 30 days. Where we are unable to do so within the said 30 days, we will notify you of the soonest practicable time within which we can make the correction. Note that the PDPA exempts certain types of personal data from being subject to your correction request as well as provides for situation(s) when correction need not be made by us despite your request; and
4.5 MS may, if you so consent, send the corrected personal data only to specific organizations to which the personal data was disclosed by us with your prior consent, within a year before the date the correction was made.
5. REQUEST TO WITHDRAW CONSENT
5.1 You may also withdraw your consent for the collection, use and/or disclosure of your personal data in MS’ control by submitting your request to [email protected] or by opting out of our mailing lists via our electronic direct mailers.
5.2 MS 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.
5.3 However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal. In this regard, depending on the extent of your withdrawal of consent for us to process your personal data, it may mean that MS will not be able to continue with your existing relationship with the company.
6. ADMINISTRATION AND MANAGEMENT OF PERSONAL DATA
6.1 MS will take reasonable efforts to ensure that your personal data is accurate and complete if your personal data is likely to be used by MS to make a decision that affects you. However, this means that you must update MS of any changes in your personal data that you had initially provided us with. MS will not be responsible for relying on inaccurate or incomplete personal data arising from you not updating us of any changes in your personal data that you had initially provided the company with.
6.2 MS will also put in place reasonable security arrangements to ensure that your personal data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorized access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data. However, MS cannot assume responsibility for any unauthorized use of your personal data by third parties which are wholly attributable to factors beyond our control.
6.3 MS will also put in place measures such that your personal data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data, and (ii) retention is no longer necessary for any other legal or business purposes.
6.4 Where your personal data is to be transferred out of Singapore, MS will comply with the PDPA in doing so. In this regard, this includes obtaining your consent unless an exception under the PDPA or law applies and taking appropriate steps to ascertain that the foreign recipient organization 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.
7. COMPLAINT PROCESS
7.1 Should you have any complaint or grievance regarding about how MS is handling your personal data or about how MS should be complying with the PDPA, please contact us with details of your complaint or grievance via:
- Telephone number : +65 9060 6170
- Email: [email protected]
8. UPDATES ON DATA PROTECTION POLICY
8.1 As part of MS’ efforts to ensure that your personal data is properly managed, protected and processed, MS will be reviewing its policies, procedures and processes periodically.
8.2 MS reserves the right to amend the terms of this Data Protection Policy at the company’s discretion. Any amended Data Protection Policy will be posted on our website and can be viewed at www.moonshadowstories.com