1.1 In this Data Protection Policy, “Personal Data” refers to any data, whether true or not, about an individual 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, including website visitorship information or mobile application user information, and data in our records as may be updated from time to time.

1.2 Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us) your name, title (Mr. or Ms), telephone number(s), mailing address, email address, network data and any other information relating to any individuals which you have provided us in any forms you may have submitted to us, or via other forms of interaction with you.

2.1 Generally, we collect Personal Data in the following ways:

(a) when you submit an application form or other forms relating to any of our Products and Services. To this end, it may be necessary for you to provide us with your personal information and/or data in order to have the full benefit of and to enjoy the various services on the Electronic Platform;

(b) when you interact with our customer service officers, for example, via telephone calls, letters, face-to-face meetings and emails;

(c) when you use some of our services, for example, websites and apps with us. To this end, our web server may automatically collect information about your website activity, including but not limited to your IP address, the kind of web browser used, the type of operating system used, the domain names of your internet service providers, data on the number of people visiting our website, the pages or articles visited and the length of visit, collected on an aggregate anonymous basis and gathered through the use of web server logs and cookies;

(d) when you request that we contact you, be included in an email or other mailing list;

(e) when you respond to our promotions, initiatives or to any request for additional Personal Data;

(f) when you are contacted by, and respond to, our marketing representatives and customer service officers;

(g) when we receive references from business partners and third parties, for example, where you have been referred by them;

(h) when we seek information from third parties about you in connection with the Products and Services you have applied for; and

(i) when you submit your Personal Data to us for any other reasons.

2.2 When you browse our website, you generally do so anonymously but please see the section below on cookies. We do not at our website automatically collect Personal Data unless you provide such information or login with your account credentials.

2.3 You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with the Products and/or Services you have requested, or the full benefit or extent of our products and/or services.

3.1 Generally, eMedia collects, uses, discloses and/or processes your Personal Data for one or more of the following purposes:

(a) To provide you with the various Products and Services offered by the Site, its sub-pages therein, and the Application, and newsletters, information, and promotional and marketing materials. To this end, we may from time to time send to you newsletters and marketing materials based on the personal information and data you have provided to us. You may also be automatically signed up for our free promotions. You will be able to “opt-out” of receiving such materials or from the free promotions by choosing to unsubscribe to the said materials and/or promotions.

(b) responding to your queries and requests;

(c) managing the administrative and business operations of eMedia and complying with internal policies and procedures;

(d) facilitating business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving any of the Companies;

(e) matching any Personal Data held which relates to you for any of the purposes listed herein;

(f) resolving complaints and handling requests and enquiries;

(g) preventing, detecting and investigating crime and analyzing and managing commercial risks;

(h) providing media announcements and responses;

(i) monitoring or recording phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes;

(j) organising promotional events;

(k) legal purposes (including but not limited to obtaining legal advice and dispute resolution);

(l) conducting investigations relating to disputes, billing or fraud;

(m) meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on eMedia (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies and conducting audit checks, due diligence and investigations); and

(n) To respond to, process, deal with or complete a transaction and/or to fulfil your requests for certain products and services and notify you of service issues and unusual account actions.

(o) purposes which are reasonably related to the aforesaid.

3.2 Furthermore, where permitted under the Act:

(a) eMedia may also collect, use and disclose your Personal Data for the following “Additional Purposes”:

(i) analytics and tracking, including facilitating the sale of analytical data

(ii) conducting market research and surveys to enable us to understand and determine customer location, preferences and demographics to develop special offers and marketing programmes in relation to eMedia’s Products and Services, and to improve our service delivery and your customer experience at our touchpoints;

(iii) providing additional Products and Services and benefits to you, including promotions, loyalty and reward programmes from eMedia;

(iv) matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision, marketing or offering of Products and Services by eMedia;

(v) leads generation and management for marketing eMedia’s Products and Services;

(vi) administering contests, competitions and marketing campaigns, and personalising your experience at eMedia’s touchpoints;

(vii) communicating to you advertisements involving details of our Products and Services, special offers and rewards, either to our customers generally, or which we have identified may be of interest to you (including but not limited to upselling, cross selling and telemarketing);

(viii) organising promotional events and corporate social responsibility projects; and

(ix) purposes which are reasonably related to the aforesaid.

In addition, where permitted under the Act and subject to the provisions of any applicable law, your Personal Data may be disclosed, for eMedia Additional Purposes, to the vendors or other third party service providers in connection with promotions and services offered by eMedia.

3.3 eMedia may also collect, use and disclose your Personal Data to its suppliers, directors, officers, employees, agents, information providers, advertisers or partners, licensors and licensees, as well as its subsidiaries or affiliates and their subcontractors and their agents, directors, employees, officers, information providers, advertisers or partners, licensors and licensees, for the following purposes:-

(i) conducting market research and surveys to enable us to understand and determine customer location, preferences and demographics to develop special offers and marketing programmes with our preferred partners;

(ii) matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision, marketing or offering of products and services (including promotions, loyalty and reward programmes) by our preferred partners;

(iii) leads generation and management for marketing the products and services offered by our preferred partners;

(iv) administering contests, competitions and marketing campaigns in connection with the products and services offered by our preferred partners;

(v) sending you informational, recruitment and other notification messages communicated by our preferred partners;

(vi) communicating to you advertisements involving details of the products, services, special offers and rewards offered by our preferred partners, either to our customers generally, or which we or our preferred partners have identified may be of interest to you (including but not limited to upselling, cross selling and telemarketing); and

(vii) purposes which are reasonably related to the aforesaid.

In addition, where permitted under the Act and subject to the provisions of any applicable law, your Personal Data may be disclosed, for Preferred Partners’ Additional Purposes, to the vendors or other third party service providers in connection with promotions and services offered by eMedia’s preferred partners. However, please be assured that we do not disclose your Personal Data to our preferred partners other than for the purposes of the above.

3.4 If you have provided your Singapore telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your Singapore telephone number(s), then from time to time, eMedia may contact you using such Singapore telephone number(s) (including via voice calls, text, fax, in-app notifications or other means) with information about our Products and Services or those products and services offered by our preferred partners (including discounts and special offers).

3.5 In relation to particular Products and Services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.

3.6 You have a choice to withdraw your consent for receiving marketing or promotional materials/communication. You may contact us using the contact details found at Clause 6.1 below.

3.7 Please be aware that once we receive confirmation that you wish to withdraw your consent for marketing or promotional materials/communication, it may take up to 7 working days for your withdrawal to be reflected in our systems. Therefore, you may still receive marketing or promotional materials/communication during this period of time. Please note that even if you withdraw your consent for the receipt of marketing or promotional materials, we may still contact you for other purposes in relation to the Products and Services that you hold or have subscribed to with eMedia.

4.1 eMedia will take reasonable steps to protect your Personal Data against unauthorised disclosure. Only our duly authorized staff will be permitted to access users’ personal information and data, and we will not release such personal information save for the purposes as set out in Clause 3 above, where it is required or allowed by law, or the following:- :

(a) eMedia’s subsidiaries, affiliates and related corporations and their employees, in order to provide content, Products and Services to you, address your questions and requests in relation to your customer accounts, subscription and billing arrangements with us as well as our Products and Services, to activate, deactivate, install, maintain and operate our systems and/or services;

(b) companies providing services relating to insurance and consultancy to eMedia;

(c) agents, contractors or third party service providers who provide operational services to eMedia, such as courier services, telecommunications, information technology, payment, printing, billing, payroll, processing, technical services, training, market research, call centre, security or other services to eMedia;

(d) vendors or third party service providers in connection with marketing promotions and services offered by eMedia or its preferred partners;

(e) commercial shops and retailers in relation to providing rewards and benefits;

(f) other telecommunications, content or other service providers to facilitate their provision of content or services, or for interconnection, inter-operability, system operation and maintenance and billing between service providers;

(g) any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving any of the Companies;

(h) collection and repossession agencies in relation to the enforcement of repayment obligations for debts;

(i) external banks, credit card companies and their respective service providers;

(j) our professional advisers such as auditors and lawyers;

(k) relevant government regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and

(l) any other party to whom you authorise us to disclose your Personal Data to.

4.2. By your continuous usage of the Site and the Application, you are deemed to have given your consent for the collection, storage, disclosure and/or use of such personal data.

5.1 A cookie is a small piece of information that is placed on your computer when you visit certain websites which makes it possible to identify repeated visitors for the duration of their visit to our web pages. They will save you from having to enter data several times, facilitate the transmission of specific contents, and generally enhance your user experience and the user friendliness of a website.

5.2 eMedia uses cookies on its websites for the following purposes:

(a) enabling certain features and functions on our websites, e.g. remembering your user-id, favourite articles, watchlist, browsing and other service preferences;

(b) building up a profile of how you and other users use the website;

(c) improving the efficiency of our website;

(d) administering services to you and to advertisers; and

(e) establishing usage statistics

5.3 Most internet browsers provide you the option of turning off the processing of cookies (please see the “help” section of your browser), but this may result in the loss of functionality, restrict your use of the website and/or delay or affect the way in which it operates.

5.4 Advertisements on the eMedia website may be provided by third party advertisers and their agencies. These may generate cookies to track how many people have seen a particular advertisement (or use the services of third parties to do this), and to track how many people have seen it more than once. eMedia does not control these third parties and their cookie policies, and if you have questions about their cookie policies, please contact eMedia and we will try our best to assist by providing you information about these third party advertising agencies.

5.5 eMedia is not responsible for the Personal Data policies (including Personal Data protection and cookies), content or security of any third party websites linked to the eMedia website.

6.1 If you:

(a) have any questions or feedback relating to your Personal Data or our Data Protection Policy;

(b) would like to withdraw your consent to any use of your Personal Data as set out in this Data Protection Policy; or

(c) would like to obtain access and make corrections to your Personal Data records, please contact eMedia as follows:

Email: dpo@pnl-group.com

Write in:

Data Protection Officer

Pioneers & Leaders eMEDIA Pte Ltd

4 Ubi View, Pioneers & Leaders Centre

Singapore 408557

6.2 Please note that if your Personal Data has been provided to us by a third party (e.g. a referrer), you should contact that organisation or individual to make such queries, complaints, and access and correction requests to eMedia on your behalf.

6.3 If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, eMedia may not be in a position to continue to provide its Products and Services to you, administer any contractual relationship in place, which in turn may also result in the termination of any agreements with eMedia, and your being in breach of your contractual obligations or undertakings. EMedia’s legal rights and remedies in such event are expressly reserved.

7.1 This Data Protection Policy shall be construed and its performance governed in accordance with the law of the Republic of Singapore. By accessing the Site and/or using the Application, you fully agree to submit to the exclusive jurisdiction of the Singapore courts.