Last Updated: [March 2021]
- “Personal information” refers to data, whether true or not, about an individual who either (a) can be identified from that data, or (b) from that data and other information to which we have or is likely to have access.
- In the case your personal information also comprises your “business contact information”, which refers to an individual’s name, position name or title, business telephone number, business address, business electronic mail address or business fax number and any other similar information about the individual, not provided by the individual solely for his personal purposes, personal information will include such business contact information.
- In relation to our activities in certain jurisdictions such as the UK, EU, European Economic Area (EEA), or Switzerland, personal information includes data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation, criminal convictions and offences (insofar as such information is capable of identifying individuals either directly or indirectly).
- If your personal information has been collected, used or disclosed by us in any particular jurisdiction which has specific requirements or exceptions regarding personal information personal information, we will comply with the applicable data protection regulations in that jurisdiction insofar that they deviate materially from data protection regulations in the Republic of Singapore.
Email : [firstname.lastname@example.org]
Post : Data Protection Officer
[Constellar Holdings Pte Ltd]
1 Expo Drive
#02-01, Singapore EXPO
[ESG requested para for SWITCH only]
Personal Information We Obtain
- Channels of collection. We generally collect your personal information using different ways and from various sources, including when you:
- Access or use our Sites.
- Register for, purchase and/or use any of our or our partners’ contents, products or services, for example, booking of Singapore EXPO halls, MAX Atria conference room or Connect@Changi facilities, or when you visit our exhibitors’ and sponsors’ booth.
- Establish any online accounts or memberships with us on our Sites.
- Make a purchase on our or our partners’ e-commerce and e-shopping Sites.
- Submit forms relating to any of our products or services.
- Request to be included in an email or other mailing list.
- Visit our premises at Singapore EXPO and MAX Atria.
- Participate in our activities, events, exhibitions or Community.
- Speak or present at any of our activities, events, exhibitions, conference or webinars, through photography, videography or screen recordings of you.
- Respond to our promotions, lucky draw, giveaways or other initiatives.
- Respond to our marketing representatives and agents, for market surveys or otherwise.
- Interact with our customer service officers or any of our staff, for example, via face-to-face meetings, business interactions in our activities, events, exhibitions, telephone calls, letters, and online forms.
- Submit a job application.
- Enter into agreements with us (in the capacity of caterer, kitchen operator, licensee, service provider, tenant, vendor or otherwise).
- Have been referred to us from our or your partners or other third-parties.
- Request that we contact you.
- Respond to our request for additional personal information.
- Submit your personal information to us for any other reason.
- Third-party channels. In addition, we may obtain information from other third-party sources, including:
- Publicly available information such as name, contact information, content and online activity that we obtain from publicly available sources and social media platforms. If your profile is public, your information may be visible to anyone on our Sites and may also be accessed or shared by other users as well as third-parties such as search engines, content aggregators and news sites.
- Video, audio and other sensory information such as images, video, and audio that may be collected or processed through our security cameras, closed-circuit television, recorded phone lines, voice recorders, and other technologies, where permitted by applicable law.
- Data from third-party sources such as personal information we obtain from our third-party service providers (including background check providers, data aggregators and data cleansing companies) and business partners (including ticketing agencies, event organisers, event sponsors, business partners, merchants, delivery partners and booking platforms and marketing partners).
- Inferences drawn from any of the above information to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behaviour, attitudes, intelligence, abilities, and aptitudes towards our products and services.
- Types of information. Depending on the nature of your interaction with us, the types of personal information and business contact information may include:
- Contact information such as your full name, salutation, designation, email address, residential/office/shipping address, fax number, and telephone/handphone number.
- Demographic information such as your age, nationality, date of birth, education, and profession.
- Financial information such as bank details, payment card number, and billing address.
- Identification information such as your passport, national registration identity card, staff or student pass, visa or other government-issued ID.
- User account information such as username, password, and user activities on our Sites.
- Preference information such as food and beverage preferences, dietary information, and special requests.
- Commercial information such as records of products or services purchased, obtained, or considered.
- Content such as photos, videos, comments, feedback, online posts and other content you provide.
- Signature, which you may provide, for example, when you sign an application or form.
- Health information such as COVID-19 vaccination status, travel history and health declaration, which you may provide, for example, when visiting Singapore EXPO, MAX Atria or Connect@Changi.
- Employment information such as employment history, education, training and skills, background check information, proof of eligibility to work in Singapore, military service, and any other information provided in connection with an application if you apply for a job with us.
- Records of phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation, and identity verification purposes.
- Any other information you or your representatives/agents provide to us.
- Photography, videography and screen captures. By participating in our activities, events, exhibitions and/or the Community, or accessing or using our products and services including when you join any online sessions or webinars managed by any member of the Community, you consent to be photographed, filmed and/or recorded by third-parties, and you consent to the use of any such film, image or recording for public transmission, including for advertising and promotional purposes. We or our any member of our Community may, without prior notice, use images taken or videos recorded at our activities, events, exhibitions, and any screenshot or screencast of any online session or webinar with your photograph, name, image, likeness, voice, biography and abstract in any media (including publication within and outside Singapore) and for any purpose without identification, compensation or payment of any kind.
If you do not agree to being photographed, filmed or recorded, please do not allow yourself to do so, such as turning off your microphone and webcam, and inform us or the relevant host/organiser accordingly.
- Cookies and similar technologies. We may also collect information from you on our Sites automatically through cookies, web beacons or similar technologies, such as:
- Technical information such as your internet protocol addresses, browsing history, mobile carrier, time zone settings, geolocation data, identifiers for advertising purposes, the version of the app you are using, and the device you are using to access or use our Sites such as the model of your device, the device system, network type, device ID, your screen resolution and operating system.
- Behavioural information regarding your online activities such as preferences you set for ease of use and accessibility of our Sites, how you engage with our Sites, including how you interact with content we show to you, the advertisements you view, videos you watch, and problems encountered.
- You should ensure that all information 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 content, products and/or services you have requested.
How We Use Personal Information
- General purposes. Personal information and business contact information collected by us may be used by us for the following purposes, including:
- Performing obligations in the course of or in connection with our provision of the products or services requested by you including organising our events, exhibitions, Interchange activities and web sessions.
- Communicate with you, processing and responding to your requests, queries including media requests, applications, complaints and feedback from you.
- Providing Media announcements and responses.
- Verifying your identity.
- Processing your personal and credit card or bank account information to process your registration and fulfil your purchases and orders.
- Maintaining the safety and security of our premises such as with the use of security cameras) and our online community platforms.
- Review, improve, enhance or develop our goods or services, or methods or processes for our operations including compiling data and conducting statistical, demographic and data analysis, and market research.
- Sending you information, updates, invitations, feedback/surveys, competitions, promotions, lucky draws, marketing and advertising materials, information about our (online) activities and sessions, local and global events, exhibitions and conferences, open community platforms, industry developments, business matching, call for speakers, collaboration projects and any of our other products and services.
- Facilitating the provision of products and services by our third-party vendors, service providers, insurance providers and professional advisers.
- Facilitating any proposed or actual business asset transactions, assignments or transfers in any of our rights or obligations in relation to your information.
- Protect and enforce our contractual and legal rights and obligations, including our Terms of Service available at our Sites and [https://constellar.co/].
- Managing our infrastructure and business operations, and complying with our internal policies and procedures, and any applicable law, rules and regulations, codes of practice, guidelines, court order, legal processes or other legal requirements of any governmental authority.
- Handle disputes and conduct and facilitate investigations and proceedings, including to prevent, detect and investigate crime, including fraud and money-laundering, and analyse and manage other commercial risks.
- Any other legitimate business or interest purposes relating to or in connection with the above such as providing products and services to you, managing the relationship between you and us, facilitating internal business purposes, to comply with statutory and/or contractual requirement, and to perform any contract you have agreed with us or perform services that you have requested.
- Any other purposes which you have provided the information for, which we have notified you or obtained your consent, or we reasonably deem you have consented to.
- Our Sites. If you download, access or use any of our Sites, the purposes include:
- Processing your purchase of products or application for services or user/membership accounts.
- Maintaining your user/membership account with us.
- Verifying and processing your personal particulars and process payments in relation to our provision of products and services.
- Providing you with the goods and services which you have requested.
- Placing and transmitting orders you place on our e-commerce / e-shopping Sites with/to our suppliers/distributors/merchants and our delivery partners.
- Communicating with you administrative information.
- Resolving complaints and handling requests and enquiries.
- Conducting market research for statistical, profiling and statistical analysis for the improvement of products and services provided to you.
- Providing you with effective and dynamic digital community and e-commerce/e-shop platforms (such as Interchange) on our mobile and web applications to:
- improve, promote and develop our digital platforms;
- allow you to participate in interactive features of our digital platforms;
- enable you to share user content and interact/socialise with other members of our Community;
- provide you with user support and administering our digital platforms;
- ensure your safety and security when accessing or using our digital platforms;
- personalising the content you receive and providing you with tailored content on our digital platforms regarding our products and services that will be of interest to you.
- Any other purposes related to any of the above.
- Tenants and licensees. If you are a tenant or licensee, or a prospective tenant or licensee, of any of our properties, the purposes include:
- Conducting due diligence checks on you.
- Preparing lease or licence agreements, and any other related documents.
- Performing administration of the lease or licence.
- Performing financial transactions such as rental payments and utilities fees.
- Communicate with you administrative information.
- Any other purposes related to any of the above.
- Vendors and contractors. If you are a vendor or contractor, a prospective vendor or contractor, the purposes include:
- Evaluating your proposal.
- Conduct due diligence checks on you.
- Communicate with your personnel who are in our properties for site visits, to carry out work or services, and for any emergency and/or security concerns.
- Any other purposes related to any of the above.
- If you are our employee, or apply to us as a candidate for employment, the purposes include:
- Processing your application including pre-employment checks.
- Providing or obtaining employment references.
- Collecting information about your suitability for the position applied for.
- Organising training and staff development programmes.
- Assessing your performance.
- Administering benefits and payroll processing.
- Providing you with tools to facilitate or as required for you to do your job.
- Communicating with you to comply with our policies and processes, including for business continuity purposes.
- Any other purposes related to any of the above.
- If you have opted-in to receive marketing materials, event collaterals as well as industry news and updates from us and/or our Marketing Affiliates, the purposes may also include:
- Conducting market research and surveys to help us and/or our Marketing Affiliates understand and determine customer location, preferences and demographics to develop special offers and marketing programmes in relation to our and/or our Marketing Affiliates’ activities, events, exhibitions, products and services.
- Matching information we and our Marketing Affiliates have collected, including other data for other purposes and from other sources, in connection with marketing, offering or provision of our and/or our Marketing Affiliates’ activities, events, exhibitions, products and services.
- Lead generation and management for marketing of activities, events, exhibitions, products and services offered by us and/or our Marketing Affiliates.
- Administering contests, competitions and marketing campaigns in connection with the activities, events, exhibitions, products and services offered by us and/or our Marketing Affiliates.
- Communicating to you advertisements involving activities, events, exhibitions, products, services offered by us and/or our Marketing Affiliates including special offers, promotions, loyalty and reward programmes, upselling, cross selling and online marketing.
- Any other purposes related to any of the above.
If you have provided your telephone number(s) and have indicated that you consent to receiving marketing information via your telephone number(s), then from time to time, we and/or our Marketing Affiliates may contact you using such telephone number(s) (including via voice calls, SMS, fax, instant messaging or other means) with such marketing information.
- Do-Not-Call. We will abide by the Do-Not-Call provisions of the Singapore Personal Data Protection Act 2012. We will refrain from sending you such marketing messages if you have registered your Singapore telephone number on the relevant Do-Not-Call registry, unless we are allowed to do so under applicable law. However, if you have given us consent to send you marketing messages, we may continue sending you marketing messages until you withdraw your consent to us.
- Derivative Data. We may anonymise, aggregate, combine, compile, de-identify, and/or merge personal information and business contact information collected from you with information from other third-party sources (including information collected on our Sites and information collected offline), and derive or generate secondary data (through human intervention or automatically using computer AI), to:
- Help us improve our activities, events, exhibitions, products, services, marketing, and communications with you.
- Help us tailor our interactions with you and improve your customer experience.
- For the purposes described above or otherwise specified by us at the time of collection of your information.
How We Share Personal Information
- Persons we share with. All personal information and business contact information held by us will be kept confidential, but we may, where such disclosure is necessary to satisfy the purposes above, or a directly related purpose for which your information purpose was collected, share such information to the following persons who may be located in Singapore or elsewhere:
- Other divisions or entities within the Group.
- Our agents, contractors, suppliers, specialist advisers and third-party service providers who process your information (including for administrative, analysis and analytics, archival, audit, background and credit checks, data hosting or management, delivery/shipping, development, financial, identity verification, information technology services and support, marketing, market research, operational, payment, payroll, research, reservations, security, storage, telecommunications, ticket operations, and training).
- Our advertising, marketing and promotion agents and representatives, including for contests, lucky draws, giveaways, outreach measurement, and Community engagement such as business matching, Community updates on our digital platforms, online sessions and activities, global events and roadshows, and industry developments.
- Banks, payment gateways, credit card issuing companies, credit bureau, or collection agencies necessary to establish and support the payment of any products and/or services due or requested.
- Our lawyers, auditors, insurers, insurance investigators, credit providers, and other professional advisers.
- Our joint venture and collaboration partners, and any third-party business partners/merchants who offer products and services, or sponsor contests or other promotional programmes, whether jointly with us or independently.
- Our business partner, investor, assignee, transferee, or other third-party (actual or prospective), to facilitate business asset transactions, in the event that we sell or buy any business or assets or if we sell, buy, merge, are acquired by, or partner with other companies or businesses, or sell some or all of our assets (including in the event of a merger, acquisition, joint venture, reorganisation, divestiture, dissolution, or liquidation).
- Government authorities, law enforcement agencies, regulators, dispute resolution centres, and their representatives in compliance with applicable law, rules and regulations, codes of practices, guidelines, court orders and other legal processes or requirements to:
- comply with any legal obligation, process or request;
- enforce our agreements, policies and standards, including investigation of any potential violation thereof;
- detect, prevent or otherwise address security, fraud or credit issues; or
- protect the rights and property, prevent physical harm or financial loss, and enhancing the security and safety of the Group, our Community, you or your organisation, or third-parties or the public, as required or permitted by applicable law.
- Any person or company who is acting for, jointly or on our behalf, in respect of the purposes above or a directly related purpose for which your information was provided.
- Other ways for which we have provided specific notice at the time of collection of your information and obtained your consent, to the extent required by applicable law.
- Affiliate marketing. When you participate in an activity, event, exhibition or the Community, or use a product or service, which is offered jointly by us and our affiliates and partners, we may also collect, use and disclose your personal information and business contact information for the purpose of sharing your information with our affiliates and partners for them to offer, market and promote to you activities, events, exhibitions, products, or services, which our affiliates and partners think may be of interest to you, in accordance with applicable law.
- Data transfers. Our business may require us to transfer your personal information to, and store your personal information in external servers located in, Singapore and other countries outside of the country in which the information originally was collected (including the jurisdictions in which our service providers operate) that may not provide the same level of data protection as your home country. We will take appropriate safeguards to ensure that we protect your information in accordance with applicable law including ensuring that the relevant recipients of your personal information are bound to duties of confidentiality and implement standard contractual clauses.
How We Protect Your Personal Information
- Protection of personal information. We will use reasonable administrative, technical and physical measures and safeguards to protect your personal information against accidental, unlawful, or unauthorised destruction, loss, alteration, access, disclosure, or use.
- Service providers. We require that organisations outside our Group which handle or obtain your personal information as service providers to us to protect the confidentiality of personal information, undertake to comply with applicable data protection and privacy laws, regulate and safeguard your data protection rights, and use your information only for our purposes strictly in accordance with our directions and instructions. While we take reasonable care in our selection of our service providers, we are only responsible for our own compliance with applicable law.
Retention of Your Personal Information
- To the extent permitted by applicable law, we will retain your personal information for as long as it is needed for the purposes for which such information is collected or used (as notified to you) continues, or where necessary, for our legitimate business purposes or legal purposes. Where we no longer require your personal information for those purposes, we will cease to retain your personal information.
Your Rights and Choices
- You have certain rights and choices in connection with the personal information we obtain about you, such as how we use the information and how we communicate with you. You may exercise the rights below by contacting us at [email@example.com]. To help protect your privacy and maintain security, we may take steps to verify your identity and request for further information before processing your request.
To the extent permitted by applicable law, a nominal charge may apply to your exercise of the rights described above, to cover our cost of verifying the request and locating, retrieving, copying, correcting, deleting or porting your personal information (as the case may be).
- Access, correction and deletion. We will keep all personal information collected as accurate, complete and up to date as necessary, taking into account its intended use and the interests of the Group and the Community. Where possible, we will validate the personal information using generally accepted practices and guidelines.
- Withdrawal of consent. You have the right to withdraw any consent you previously provided to us or object at any time to the processing of your personal information for marketing purposes or on legitimate grounds to any other processing of your personal information.
- Depending on the extent of your request and the purposes for which your personal information was collected for, we may no longer be able to provide or continue providing certain products or services to you.
- You may also withdraw your consent for us and/or our Marketing Affiliates to send you marketing information via email, SMS or instant messaging, by following the unsubscribe procedure in the marketing information received.
- Your withdrawal or objection will however not affect the lawfulness of our processing of your personal information based on your consent or our legitimate grounds before your withdrawal.
- Data porting. Subject to applicable law, you may also have the right to receive, in a structured, commonly used, and machine-readable format, the personal information that you provided us with, as well as the right to have this information transmitted to another organisation, where it is technically feasible.
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