Data Protection Policy

Your personal data is important to us and it is our policy to respect the confidentiality of information and the privacy of individuals. This Policy outlines how we collect and manage the personal data in our possession or under our control in compliance with the Personal Data Protection Act 2012 of Singapore and its regulations (the “PDPA”) and applies to JML Singapore Pte. Ltd. (“JML”, “we”, “us” or “our”).   We also comply with local data protection and privacy laws in our operations outside of Singapore.

By interacting with us, submitting information to us, signing up for any products or services offered by us or taking any other action indicating your intent to do so, you agree and consent to JML and our affiliates and other related persons (and any of our or their agents, representatives or authorised service providers or any other persons acting on our or their behalf) collecting, using and disclosing your Personal Data in the manner set forth in this Policy.

For the avoidance of doubt, this Policy supplements but does not supersede or replace any other consents which you may have previously provided to us, or which you may specifically provide us.

Background

The PDPA establishes a general data protection law in Singapore which governs an organisation’s activities relating to the collection, use and disclosure of individuals’ personal data.  The administration and enforcement of the PDPA is handled by the Personal Data Protection Commission (“PDPC”), a Singapore Government statutory body established on 2 January 2013 under the authority of the PDPA. The other roles of PDPC include undertaking public education and engagement programmes to help organisations understand and comply with the PDPA as well as to promote greater awareness of the importance of personal data protection in Singapore.  Its website address is www.pdpc.gov.sg.

Scope and Objective

This Policy defines the responsibilities of JML to ensure that we are in compliance with the PDPA in the collection, use, disclosure, accuracy maintenance, handling and security of personal data in a manner that recognises both the right of individuals to protect their personal data and the need of the organisation to collect, use and disclose personal data for purposes that a reasonable person would consider appropriate in the circumstances.

Data Protection Officers

We are required to designate at least one individual, as our data protection officer, to be responsible for ensuring that we comply with the PDPA.  We have designated the following data protection officers:

For Employee Relations:

Edmond Tai

Email:  edmond.tai@jmldirect.com.sg

For Customer Relations:

Deljay Dizon Espiritu

Email:  Deljay.dizon@jmldirect.com.sg

Their address and phone number are as follows:

JML Singapore Pte. Ltd.

10 Changi South Lane, #01-02

Singapore 486162

+65 6742 1771
 

Your Personal Data

In this Policy, "Personal Data" refers to any data or information about you from which you can be identified either from that data or from that data and other information to which we have or are likely to have access. Examples of such Personal Data include:

1. your name,
2. your NRIC, passport or other identification number(s),
3. your telephone number(s),
4. your mailing/residential address(es),
5. your email address(es),
6. your credit card information,
7. your employment and education background,
8. your religion,
9. information about your spouse, children or extended families,
10. your photos or images which may be captured on our CCTV cameras, and
11. any other information relating to you which you have provided to JML or which JML has collected in its interaction with you.

 

Collection of Personal Data

In general, JML may collect your Personal Data in various ways, including but not limited to the following:

1. when you submit any form or application to us relating to any of our products or services,
2. when you access our website or perform an online or telephone enquiry,
3. when you make a purchase from us,
4. when you interact with any of our employees or staff members, including telemarketers,
5. when you register for events organised by us or our service providers, or respond to our promotions or other initiatives,
6. when you request that we contact you,
7. when images are captured on our CCTV cameras,
8. when you submit an employment application or when you provide documents or other information in connection with any appointment as an employee, officer or any other position in JML, and
9. when you submit your Personal Data to us for any other reason.

You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Your failure to do so may result in our inability to provide you with, or delay in our provision of, the products or services requested.

If you provide us with any Personal Data relating to a third party (including your spouse or any of your dependents, children or parents), by doing so you represent to us that you have obtained all necessary consents from such third party to our collection, use and disclosure of their Personal Data, and will make such third party aware of all matters listed in this Policy (for example, by referring such third party to our website where a copy of this Policy may be accessed).

We do not at our website automatically collect Personal Data unless you provide such information or login with your account credentials. However, our website uses cookies (being small data files sent to your browser when you visit our website to track information such as number of users, frequency of use, profiles of users and preferred sites) to help us provide you with a more customised website experience and to improve the efficiency of our website. Most internet browsers allow you to disable cookies associated with these technologies (or otherwise turn off the processing of cookies) - in most cases, you will still be able to navigate our website fully but other functionality may be impaired as you may not be able to enter certain parts of our website.  Please note that you may delete cookies from your browser after visiting our website.

We assume no responsibility for the data protection practices, content or security of any third parties whose websites we link to on our website. We recommend that you review each third party website’s data protection and privacy policy before disclosing any data on that website.

Purposes for the Collection, Use and Disclosure of Personal Data

In general, JML may collect, use and disclose your Personal Data for the following purposes:

1. processing and fulfilling customer orders, including online sales,
2. delivering goods or services to customers,
3. tracking warranty coverage,
4. preparing and sending you communications or information on our products and services (including discounts and special offers) or other marketing or promotional communications or information, and conducting other marketing and research activities,
5. organising promotional events,
6. conducting market research or analysis for profiling or other purposes to enable us to understand customer behaviour, preference and market trends and to review, develop and improve the quality of our products and services,
7. responding to your queries, complaints and requests,
8. monitoring customer interactions for quality assurance, employee training and performance evaluation,
9. managing our administrative and business operations, complying with internal policies and procedures and for conducting financial reporting and analysis related to our business operations,
10. maintaining records of customer instructions,
11. processing employment applications, paying salaries to employees, managing and terminating employment relationships and staff benefit schemes such as training and educational subsidies, and other human resources matters,
12. protecting and enforcing our contractual or legal rights and complying with applicable laws, regulations and other requirements or guidelines,
13. facilitating transactions involving the transfer of JML or our business or assets,
14. other purposes reasonably related to the foregoing or to our business, and
15. any other purposes for which you have provided your Personal Data to us or for which we have specifically obtained your consent.

Disclosure of Personal Data

We may disclose your Personal Data for the purposes listed above to the following parties:

1. our joint venture or business partners, investors, affiliates, group companies and other related persons, including our parent company in Japan and associated companies in England and the British Virgin Islands,
2. our service providers, advisers, vendors, contractors and agents who provide administrative, financial, legal, accounting, audit, information technology, research, delivery, courier, logistics or other services,
3. our insurers, credit providers, financial institutions, credit reporting or reference agencies and insurance investigators,
4. courts, tribunals, law enforcement agencies, regulatory authorities and other governmental authorities and agencies,
5. actual or potential assignees or transferees of JML or our business or assets,
6. any other party to whom you authorise us to disclose your Personal Data, and
7. any other persons to whom disclosure is reasonable for the purposes listed above.

We will not disclose your Personal Data to any other third parties except when required under the PDPA or other applicable laws.

Protection of Personal Data

We take various measures to protect your Personal Data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. The measures which we have implemented include but are not limited to the following:

1. Our employees and relevant service providers must sign a letter of understanding whereby they acknowledge that JML has data obligations under the PDPA and that they have read and understood this Policy (among other things).
2. We maintain strict security systems designed to prevent unauthorised access to your Personal Data.
3. Softcopy databases are password protected where applicable and stored in our dedicated computer/server, and can be accessed only by our authorised employees and only if those employees are physically in our office.
4. No employees of JML are allowed to save any copies of databases in their personal computer, hard drives or portable storage drives, except for the purpose of transfer of information from one computer to another where contents are deleted once such purpose is achieved.
5. Hardcopy registration files and forms containing Personal Data are kept strictly under JML’s care in locked cupboards, and employees are prohibited from removing them from JML’s office premises.

However, you will appreciate that it is not for us to perfectly secure your Personal Data from cyber-attacks, such as hacking, spyware and viruses. Accordingly, we will not be liable for any unauthorised disclosure, loss or destruction of your Personal Data arising from such risks.

We will ensure that any transfers of your Personal Data to a jurisdiction outside of Singapore will be in accordance with the PDPA.

Retention of Personal Data

We will retain your Personal Data only for as long as it is reasonable to fulfil the purposes for which the information was collected or to meet any of our employment, business or legal needs. Once it is no longer subject to retention, we will promptly anonymise or destroy records containing your Personal Data in such manner as we consider appropriate, including shredding paper records and permanently deleting electronic records.

Access and Corrections to Personal Data

We aim to keep your Personal Data in our records accessible to you and accurate and up-to-date.  You may request access to your Personal Data records (and information about the ways in which your Personal Data has been or may have been used or disclosed by us within a year before the date of the request) or request a correction to your Personal Data records by completing, signing and dating the Request to Access Personal Data Form attached as Annex A or the Personal Data Correction Form attached as Annex B and submitting it to the relevant data protection officer named above.

We may charge a reasonable fee for processing your request to access your Personal Data in accordance with the PDPA and will inform you of the estimated fee in writing upon receiving your request.

Withdrawal of Consent

If you wish to withdraw your consent to any use or disclosure of your Personal Data as set out in this Policy, you may contact the relevant data protection officer named above. Upon receiving notice of your withdrawal of your consent, we will inform you of the likely consequences of such withdrawal. We will cease collecting, using or disclosing your Personal Data unless required under applicable laws, and will cease sending marketing or promotional communications and/or other information to you.

Please be aware that once we receive your notice of withdrawal of consent, we may require a reasonable period to time to process your withdrawal and for your withdrawal to be reflected in our systems.

Complaints and Inquiries

If you have any complaints concerning the collection, use or disclosure of your Personal Data, please complete, sign and date the Complaint Form attached as Annex C and submit it to the relevant data protection officer named above.  Please also contact the relevant data protection officer if you have any questions or wish to know more about our data protection policies and practices.

Updates

As we continue to improve the services, products and features we provide, we may update this Policy from time to time.  Any updates to this Policy will be made available on our website at www.jml.sg.  Subject to your rights at law, you agree to be bound by the prevailing terms of this Policy as so updated.

 

DOWNLOADABLE FORMS:

Request to Access Personal Data Form - DOC PDF

Personal Data Correction Form - DOC PDF

Complaint Form - DOC PDF