Updated: 18 May 2017
I. Respecting Your Privacy
II. Collection of Personal Data
III. Purposes for Collection, Use and Disclosure of Personal Data
IV. Deemed Consent
V. Limiting Collection, Use and Disclosure of Personal Data
VI. Third Party Products and Services
VII. Specific Issues for Disclosure of Personal Data to Third Parties
VIII. Request to Withdraw Consent
IX. Request for Access and/or Correction of Personal Data
X. Administration and Management of Personal Data
XI. Complaints Process
XII. Updates on Data Protection Policy
XIII. Governing Law
We at Liberty Wireless together with our subsidiaries (the “Group”) take our responsibilities under Singapore’s Personal Data Protection Act 2012 (the “PDPA”) seriously. We also recognise the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data.
This Circles.Life Data Protection Policy is designed to assist you in understanding how we collect, use, disclose and/or process the personal data you have provided to us, as well as to assist you in making an informed decision before providing us with any of your personal data. This Policy applies to all individuals who hold accounts or receive Services from entities within our Group and any other individual who visit, access or use features on our website.
This Policy applies to entities within the Group that is: i) offering Services, and ii) collecting, using and/or disclosing personal data. As such, obligations set out in this Policy will extend to the relevant entity within the Group that is providing the Services to you or is in control and possession of your personal data. This Policy does not supersede or replace any earlier consent(s) you may have provided to the Group, and supplements all such pre-existing consents concerning the collection, disclosure and/or use of your personal data.
If you, at any time, 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 do not hesitate to contact our Data Protection Officer (the “DPO”) at:
Data Protection Officer
Liberty Wireless Private Limited
221 Henderson Building Singapore 159557
Email: [email protected]
“Personal data” is defined under the 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 organisation has or is likely to have access. Common examples of personal data could include names, identification numbers, contact information, medical records, photographs and video images. Specifically, we may collect the following types of information (which may include personal data):
We will collect your personal data in accordance with the PDPA. We 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.
By providing personal data of any other individual to us, you hereby warrant and represent that you are authorized to disclose the other individual’s personal data to us in accordance with this Circles.Life Data Protection Policy. When providing personal data, you warrant and represent to the Group that personal data disclosed by you, whether about yourself or another individual, is accurate and complete.
The personal data that we collect from you may be collected, used, disclosed and/or processed for various purposes, depending on the circumstances for which we may need to process your personal data, including:
Mobile services (postpaid only) include local and overseas voice calls (including international roaming and IDD services), local and international messaging, broadband services (including data roaming services) and a range of complementary and value-added services.
Depending on the Services which you subscribe to, your personal data may be collected, used and/or disclosed for the following purposes (Collectively “Purposes”):
As the purposes for which we may collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of your personal data without your consent is permitted by the PDPA or by law.
In order to conduct our business operations more smoothly, we may also be disclosing 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. Such third party service providers, agents and/or affiliates or related corporations and/or other third parties would be processing your personal data either on our behalf or otherwise, for one or more of the above-stated Purposes.
You are deemed to have given your consent for the collection, use and disclosure of personal data in the following circumstances:
The Group collects personal data primarily from our customers (including prospective customers). The collection of personal data is limited to that which is necessary for the identified Purposes.
Unless permitted under law, the Group will not disclose Personal Data to other persons or entities for the advertising, promotion or marketing of such other party’s products and services, and the Group will not sell for payment the personal data to anyone for any marketing purposes without your consent.
We respect the confidentiality of the personal data you have provided to us. In that regard, we will not disclose your personal data to third parties without first obtaining your consent permitting us to do so. However, please note that we may disclose your personal data to third parties without first obtaining your consent in certain situations, including, without limitation, the following:
Please note that in the event your Circles.Life number is terminated, we will update the terminated status of the Circles.Life number to the Do-Not-Call Registry such that their database is up to date.
You acknowledge that in addition to the exceptions under the PDPA, the Group may collect, use and disclose your personal data without your consent in accordance with the Telecommunications Code of Practice in the following situations:
The instances listed in the paragraph above are not intended to be exhaustive. For more information on the exceptions, you are encouraged to peruse the Second, Third and Fourth Schedules of the PDPA that is publicly available at http://statutes.agc.gov.sg.
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.
You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control by submitting your request to the Data Protection Officer.
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.
However, our 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 we may not be able to provide you with the Services, or a part thereof.
Notwithstanding any withdrawal of consent, (a) unless otherwise agreed by the Group, you will still be bound by your agreements for Services with the relevant entity in the Group, and should you choose to terminate the relevant contract(s), early termination charges and other charges, penalties or contractual consequences may apply in accordance with the contract(s) or under applicable laws and the Group reserves its rights thereof, and (b) the Group has the right to terminate the contracts in its discretion, without liability to you. If you have indicated their consent to receiving marketing communications from the Group, you may separately withdraw such consent via the unsubscribe options as stated on the SMS or email marketing message, via Manage My Account (MMA) on our website or by calling our Customer Service Hotline at 1627.
You may request to access and/or correct the personal data currently in our possession or control by submitting a written request to us. We will need enough information from you in order to ascertain your identity as well as the nature of your request, so as to be able to deal with your request. Hence, please submit your written request to our Data Protection Officer.
For a request to access personal data, once we have sufficient information from you to deal with the request, we will seek to provide you with the relevant personal data within 30 days. Where we are unable to respond to you within the said 30 days, we will notify you of the soonest possible time within which we can provide you with the information requested. Note that the PDPA exempts certain types of personal data from being subject to your access request. For example, the Group may not provide access to personal data if such provision could reveal personal data about another person, if such information is subject to legal privilege or if such provision will be contrary to national interest. If access to personal data cannot be provided, the reasons for denying access will be provided upon request, to the extent permitted under applicable law.
For a request to correct personal data, once we have sufficient information from you to deal with the request, we will:
Notwithstanding the paragraph above, we may, if you so consent, send the corrected personal data only to specific organisations to which the personal data was disclosed by us within a year before the date the correction was made.
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.
We will take reasonable efforts to ensure that your personal data is accurate and complete, if your personal data is likely to be used by the Group to make a decision that affects you, or disclosed to another organisation. However, this means that you must also update us of any changes in your personal data that you had initially provided us with. We will not be responsible for relying on inaccurate or incomplete personal data arising from your not updating us of any changes in your personal data that you had initially provided us with.
We 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, we cannot assume responsibility for any unauthorized use of your personal data by third parties that are wholly attributable to factors beyond our control.
We 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 (a) the purpose 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 necessary for any other legal or business purposes.
Where your personal data is to be transferred out of Singapore, we will comply with the PDPA in doing so. In this regard, this includes us obtaining your consent unless an exception under the PDPA or law applies, and taking appropriate steps to ascertain that the foreign recipient organisation 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. This may include us entering into an appropriate contract with the foreign recipient organisation dealing with the personal data transfer or permitting the personal data transfer without such a contract if the PDPA or law permits us to.
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, we welcome you to contact us with your complaint or grievance. Please contact our Data Protection Officer with your complaint or grievance.
Where it is an email or a letter through which you are submitting a complaint, your indication at the subject header that it is a PDPA complaint would assist us in attending to your complaint speedily by passing it on to the relevant staff in our organisation to handle. For example, you could insert the subject header as “PDPA Complaint”.
We will certainly strive to deal with any complaint or grievance that you may have speedily and fairly.
As part of our efforts to ensure that we properly manage, protect and process your personal data, we will be reviewing our policies, procedures and processes from time to time. We reserve the right to amend the terms of this Circles.Life Data Protection Policy at our absolute discretion. Any amended Data Protection Policy will be posted on our website and can be viewed at https://www.circles.life/static/terms/dataprotection. 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.
This Policy is governed under the laws of Singapore.
For the purposes of this Policy, the following capitalized terms, unless elsewhere defined in this Policy, shall have the following meanings:
Thank you for taking the time to understand our Data Protection Policy!