HYDROGEN AND FUEL CELL ASSOCIATION OF SINGAPORE
PERSONAL DATA PROTECTION POLICY
Issue Date: 31 Dec 2019
1. General
1.1 The purpose of this Personal Data Protection Policy ("Policy") is to inform you of the measures we take to protect your Personal Data and the ways in which we collect, use, disclose and retain your Personal Data in order to operate the activities and operations of the Hydrogen and Fuel Cell Association of Singapore ("HFCAS"). Our Policy is designed to meet the requirements of Singapore's personal data protection laws and we are constantly reviewing our practices and procedures herein.
1.2 "Personal Data" shall mean 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.
2. Application of Policy
2.1 When you become a member or a representative of a corporate member of the HFCAS (collectively, "HFCAS Member"), you agree to the terms of this Policy as updated from time to time. The HFCAS reserves the right, at our sole discretion, to change, modify, add, or remove portions of this Policy at any time.
2.2 Our Policy applies to all HFCAS Members, all participants of HFCAS activities and programmes and to all our suppliers, service providers, contractors, associates and affiliates.
3. Types of Personal Data collected
3.1 Our Policy applies to Personal Data that the HFCAS collects, uses and discloses in order to operate
the HFCAS’ activities or to enable you to access the HFCAS website and online service portals ("Website"). For example, we may collect Personal Data from you in the following (non-exhaustive) ways:
(a) When an individual enrols for membership (whether as a representative of a corporate member or otherwise), we are required to collect personal data such as the individual's name, the last 4 characters of the NRIC/ FIN/ passport number, date of birth, age, gender, nationality, residential address, employment information and any other personal data as set out in the membership application form, which may be updated from time to time.
(b) When a HFCAS Member registers for a HFCAS event, we may collect personal data including but not limited to the member's name, contact number, email address, the last 4 characters of the NRIC/ FIN/ passport number, age, employer details and nationality.
(c) When a HFCAS Member makes a purchase on our Website, we or our designated payment processor may collect the HFCAS Member's credit card number and expiry date to process the payment.
3.2 This Policy does not apply to aggregated information which summarizes statistical information about groups of HFCAS Members, and which does not include name, contact information, or any other information that would allow any particular individual to be identified.
3.3 Both the type and scope of Personal Data collected will be limited to that which is reasonable to
enable the provision of the products or services offered by the HFCAS and/or the Website.
4. How we collect Personal Data
4.1 Most of the Personal Data we collect comes from you, such as when you apply for membership, enroll in the HFCAS's activities/ events or send us an electronic mail.
4.2 The HFCAS may automatically collect non-personal information about you such as the type of internet browsers you use or the Website from which you linked to this Website. We may also automatically collect aggregate information about the use of this Website and aggregate details which you have submitted to this Website. You cannot be identified from this information and it is only used to assist us in providing an effective service on this Website. We may from time to time supply third parties with this non-personal or aggregated information.
5. Use of your Personal Data
5.1 Your Personal Data may be used to:
(d) perform obligations in the course of or in connection with our provision of the goods and/or services requested by you;
(e) verify your identity;
(f) manage your relationship with us;
(g) respond to, handle, and process queries, requests, applications, complaints, and feedback from you;
(h) send email-based newsletters and other information to you as you request;
(i) notify you from time to time about updates, services and events offered by the HFCAS;
(j) tailor and improve the features of the HFCAS's services offered on this Website;
(k) create products or services that may meet your needs;
(l) comply with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
(m) any other purposes for which you have provided the information;
(n) transmit to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
(o) any other incidental business purposes related to or in connection with the above
5.2 We will not collect, use or disclose your Personal Data for other purposes without obtaining your further consent, except where authorized or required by law or the courts.
6. Sharing and disclosing your Personal Data
6.1 The HFCAS may disclose your Personal Data:
(a) where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods and services requested by you;
(b) to organisations that provide services to help us with our activities such as organising joint events with partners and offering products and services for the above-mentioned purposes;
(c) as required to do so under the Personal Data Protection Act 2012 or by law or legal process, including but not limited to complying with a subpoena;
(d) when we believe in good faith that disclosure is necessary to protect and/or defend our rights, to protect your personal or property safety or those of others, to prevent, investigate fraud or other crime, or to respond to a written government request; or
(e) to any other third party with your prior consent to do so.
6.2 The HFCAS will share your Personal Data with authorised service providers of the HFCAS and third parties only in the ways that are described in this Policy. We do not otherwise sell your Personal Data to these authorised service providers and third parties.
7. Withdrawal of consent
7.1 The consent that you provide for the collection, use and disclosure of your Personal Data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your Personal Data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.
7.2 Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.
7.3 It is important to note that in the event you do withdraw consent, we will be unable to collect, use, or disclose your Personal Data, which means we will no longer be able to maintain and service your membership and will have to terminate it. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described above.
7.4 Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
8. Altering your Personal Data
8.1 All your Personal Data is accurate based on the information which was originally submitted to us. If you would like to access, review or change the details of your Personal Data, or find out how your Personal Data has been used and disclosed for the last twelve (12) months to the extent your right is allowed by law, you may do so by contacting the Data Protection Officer whose contact details are set out below. Please note that you may be charged an administrative fee.
9. Data Protection Officer
9.1 Please direct any questions or comments on the Policy to our Data Protection Officer, whose details are as follows:
pda@hfcas.org