1.1 This Policy statement provides information on the obligations and policies of Cranky Cats in respect of an individual’s Personal Data. Cranky Cats undertakes to use reasonable efforts in applying, where practicable, those principles and the processes set out herein to its operations.
1.2 Cranky Cats’ officers, management, and members of staff shall use reasonable endeavours to respect the confidentiality of and keep safe any and all Personal Data collected and/or stored and/or disclosed and/or used for, or on behalf of, Cranky Cats. Cranky Cats shall use reasonable endeavours to ensure that all collection and/or storage and/or disclosure and/or usage of Personal Data by Cranky Cats shall be done in an appropriate manner and in accordance with the Act and this Policy.
1.3 By interacting with us, submitting information to us, or signing up for any products or services offered by us, you agree and consent to Cranky Cats as well as to its respective representatives and/or agents collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data (as defined herein) to Cranky Cats’ authorised service providers and relevant third parties in the manner set forth in this Privacy Statement.
1.4 This Policy supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your Personal Data, and your consents herein are additional to any rights which we may have at law to collect, use or disclose your Personal Data.
1.5 For the purposes of this Policy, in line with the provisions under the Singapore Personal Data Protection Act 2012 (No. 26 of 2012) (the “Act”), “Personal Data” shall mean data, whether true or not, about an individual customer who can be identified — from that data; or from that data and other information which an organisation has or is likely to have access. Such Personal Data shall also refer to that which is already in the possession of Cranky Cats or that which shall be collected by Cranky Cats in future.
2. Contacting the Data Protection Officer
2.1 Where you legitimately request access to and/or correction of Personal Data relating to you, such Personal Data which is in the possession and control of Cranky Cats, Cranky Cats shall respond to your request within 30 days and in a manner in accordance with its standard procedures as stated hereinafter.
2.2 In accordance with the Act, Cranky Cats has established a process for receiving and responding to any query or complaint that may arise with respect to the application of this Act. To ensure that Cranky Cats receives your complaints and enquiries, please send the same via email to the Data Protection Officer (the “DPO”) of Cranky Cats at the following email address: email@example.com.
2.3 Please note that if your personal data has been provided to us by a third party (e.g. a member via a referral process), you should contact that individual to make such queries, complaints, and access and correction requests to Cranky Cats on your behalf.
2.4 Should you not wish Cranky Cats to use your Personal Data for any of the purposes listed in this Policy, or not to receive promotional materials from Cranky Cats, you may opt out by sending a clearly worded email to the DPO via the email address provided in Clause 2.2. We shall respond to your request within 30 days. Please note however that this may affect our ability to attend to your needs in the event where there is already an existing business relationship.
3. Statement of Practices
Types of Personal Data Collected
3.1 As part of its day-to-day activity, Cranky Cats may collect from you, through various means, including via our websites, events and any forms used by Cranky Cats from time to time, some or all of the following Personal Data:
Name (first and surname);
Phone number (including mobile);
Bank account/credit card details;
IP addresses; and
Photographs and images.
Purpose of Collection of Personal Data
3.2 The above Personal Data mentioned in Clause 3.1 is collected for the purposes of providing you with our services; to conduct market research and analysis; for direct marketing; sending you text messages and emails; for payment purposes; to notify you of any changes to our policies or services which may affect you; to respond to queries and feedback; maintaining and updating your details; and informing you of new developments, services, promotions of Cranky Cats and other third parties which we are associated with.
Disclosure of Personal Data
3.3 In order to carry out the functions described above, Cranky Cats may, from time to time, disclose your Personal Data between Cranky Cats’ companies.
3.4 Without derogating from any of the above, Cranky Cats may also disclose your Personal Data to the following third parties:
Regulators and law enforcement officials;
Third party service providers and consultants;
Credit, debit and charge card companies, banks and other entities processing payment;
Potential buyers or investors of Cranky Cats or any of Cranky Cats’ companies; or
Any agent or subcontractor acting on Cranky Cats’ behalf for the provision of Cranky Cats’ services.
3.5 Cranky Cats may disclose your Personal Data to the abovementioned parties also in the occurrence of any of the following events:
To the extent that Cranky Cats is required to do so by the law;
In connection with any legal proceedings or prospective legal proceedings;
To establish, exercise or defend Cranky Cats’ legal rights;
To the purchaser (or prospective purchaser) of any business or asset which Cranky Cats is (or is contemplating) selling;
To any person and/or entity for the purpose of processing such information on Cranky Cats’ behalf;
To third parties who provide services to Cranky Cats or on its behalf;
To any third party that purchases Cranky Cats or Cranky Cats’ business or any part of Cranky Cats or Cranky Cats’ business;
With your consent; and
For the purposes of disaster recovery.
4. Accuracy of Personal Data
To assist in ensuring the accuracy of your Personal Data in the possession of Cranky Cats, please inform us of any updates of any parts of your Personal Data by sending a clearly worded email to the DPO at the email address provided at Section 2.2.
5. Protection of Personal Data
Cranky Cats uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your Personal Data and will not knowingly allow access to this data to anyone outside Cranky Cats, other than to you or as described in this Policy. However, Cranky Cats cannot ensure or warrant the security of any information you transmit to Cranky Cats and you do so entirely at your own risk. In particular, Cranky Cats does not warrant that such information may not be accessed, altered, collected, copied, destroyed, disposed of, disclosed or modified by breach of any of Cranky Cats’ physical, technical, or managerial safeguards.
6. Access and Correction of Personal Data
6.1 In accordance with Clause 2.1 of this Policy, you have the right to:
(a) check whether Cranky Cats holds any Personal Data relating to you and, if so, obtain copies of such data; and
(b) require Cranky Cats to correct any Personal Data relating to you which is inaccurate for the purpose for which it is being used.
7. Storage and Retention of Personal Data
Cranky Cats will delete, as reasonably possible, or otherwise anonymise any Personal Data in the event that the Personal Data is not required for any reasonable business or legal purposes of Cranky Cats and where the Personal Data is deleted from Cranky Cats’ electronic, manual, and other filing systems in accordance with Cranky Cats’ internal procedures and/or other agreements.
8. Transfer of Personal Data Overseas
Your Personal Data may, in future, be processed by Cranky Cats, its affiliates, agents and third parties providing services to Cranky Cats, in jurisdictions outside of Singapore as Personal Data may be stored in servers located outside of Singapore. In this event Cranky Cats will comply with the terms of the Act.
9. Change Policy
Cranky Cats reserves the right to alter any of the clauses contained herein in compliance with local legislation, and for any other purpose deemed reasonably necessary by Cranky Cats. You should look at these terms regularly. If you do not agree to the modified terms, you should inform us as soon as possible of the terms to which you do not consent. Pending such notice, if there is any inconsistency between these terms and the additional terms, the additional terms will prevail to the extent of the inconsistency.
10. Governing Law
This Policy is governed by and shall be construed in accordance with the laws of Singapore. You hereby submit to the exclusive jurisdiction of the Singapore courts.
11.1 This Policy only applies to the collection and use of Personal Data by Cranky Cats. It does not cover third party sites to which we provide links, even if such sites are co-branded with our logo. Cranky Cats does not share your Personal Data with third party websites. Cranky Cats is not responsible for the privacy and conduct practices of these third-party websites, so you should read their own privacy policies before disclosure of any Personal Data to these websites.
11.2 Cranky Cats will not sell your personal information to any third party without your permission, but we cannot be responsible or held liable for the actions of third party sites which you may have linked or been directed to Cranky Cats’ website.
11.3 Cranky Cats’ websites do not target and are not intended to attract children under the age of 18 years old. Cranky Cats does not knowingly solicit personal information from children under the age of 18 years old or send them requests for personal data.