This Privacy Policy (the “Policy”) applies to the collection, use and disclosure of an individual customer’s Personal Data (hereinafter defined) arising from goods and/or services offered by Global Wellness Group Pte Ltd (“GWG”).
In addition to this Policy statement, there may also be specific and additional privacy provisions, which apply to our collection and use of your personal information e.g. information provided when entering a competition, subscribing to a newsletter, or participating in a survey. If there is any inconsistency between this Privacy Policy Statement and those specific and additional provisions, the specific and additional provisions will prevail.
1.1 | This Policy statement provides information on the obligations and policies of GWG in respect of an individual customer’s Personal Data. GWG undertakes to use reasonable efforts in applying, where practicable, those principles and the processes set out herein to its operations. Please take a moment to read this Privacy Statement so that you know and understand the purposes for which we collect, use and disclose your Personal Data. |
1.2 | GWG’s 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, GWG. GWG shall use reasonable endeavours to ensure all collection and/or storage and/or disclosure and/or usage of Personal Data by GWG and by anyone acting on its behalf shall be done in an appropriate manner and in accordance to 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 GWG as well as to its respective representatives and/or agents (“Representatives”) (collectively referred to herein as “GWG”, “us”, “we” or “our”) collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to GWG’s 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 to 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 GWG or that which shall be collected by the GWG in the future. |
2.1 | Where you: (i) legitimately request access to Personal Data relating to you which is in the possession and control of GWG; (ii) have any questions or feedback relating to your Personal Data or This Policy; or (iii) or wish to correct Personal Data relating to you which is in the possession and control of GWG, you may contact our Data Protection Officer (“DPO”) in accordance with our standard procedures as stated hereinafter. We shall attain to your request a reasonable time and manner. |
2.2 | In accordance with the Act, GWG 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 GWG receives your complaints and enquiries, please send the same via email to the DPO at the following email address: DPO@gwg.com.sg |
2.3 | Please note that if your personal data has been provided to us by a third party (e.g. a member who has nominated you to receive complimentary services), you should contact that third party to make such queries, complaints, and access and correction requests to GWG on your behalf. |
2.4 | Should you not wish GWG to use your Personal Data for any of the purposes listed in Clauses 3.2 to 3.4, or not to receive promotional materials from GWG, you may opt out by sending a clearly worded email to the DPO via the email address provided in Clause 2.2. Your request shall be processed within a reasonable time. However, please note that in such an event we may not be in a position to continue to provide our products or services to you, administer any contractual relationship in place, and this may also result in the termination of any agreements with us, and your being in breach of your contractual obligations or undertakings, and our legal rights and remedies in such event are expressly reserved. |
Types of Personal Data Collected: | |||||||||||||||||||
3.1 | As part of its day to day activities, GWG may collect from you, through various means, including:
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3.2 | The type of your Personal Data that we collect may include your
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3.3 | If you provide us with any Personal Data relating to a third party (e.g. information of your spouse, friends or others), including where you have named them as beneficiaries of our services, or where you refer a third party to us for the purposes of us offering our products and/or services to that third party, by submitting such information to us, you represent to us that you have obtained the consent of the third party to you providing us with their Personal Data for the respective purposes.Cookies We use cookies on our websites to track website visitorship and experience. Most web browsers are designed to accept cookies. If you do not wish to receive any cookies, you may set your browser to refuse it. |
Purpose of Collection of Personal Data | |
3.4 | The above Personal Data mentioned in Clause 3.2 is collected for the purposes of:
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Disclosure of Personal Data | |
3.5 | In order to carry out the functions described above, we may, from time to time, disclose your Personal Data between other companies affiliated with GWG. |
3.6 | Without derogating from any of the above, we may also disclose your Personal Data to the following third parties:
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3.7 | GWG may disclose your Personal Data to the above mentioned parties also in the occurrence of any of the following events:
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Optional Provision of Personal Data | |
3.8 | Except where otherwise indicated, collection fields in our various collection avenues are optional and by providing us with that information, it shall be deemed to have been voluntarily provided. In that regard, if you should feel that any of the compulsory fields are excessive or irrelevant to the services provided, feel free to engage any of our personnel. We will consider your feedback and do our best to accede to your request. |
3.9 | In some instances, you may also be requested to provide certain Personal Data that may be used to further improve our products and services to you. In most cases, this type of data is optional although, where the requested service is a personalised service, or provision of a product or dependent on your providing all requested data, failure to provide the requested data may prevent us from providing the service to you. This type of data includes, but is not limited to:
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3.10 | Under certain circumstances, telephone calls made to us to order and/or service hotlines and/or inquiry telephone numbers are recorded for the purposes of quality control, appraisal, as well as staff management and development. In such an event, by agreeing to this Policy, you hereby give your clear and unambiguous consent for the collection, use and disclosure of such Personal Data in accordance to this Policy. |
7.1 | In accordance with Clause 2.1 of this Policy, you have the right to:
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7.2 | We reserve the right to charge a reasonable administrative fee in order to meet your requests under Clause 8.1. Upon payment of the requisite fee, your request shall be processed within a reasonable time. | ||||
7.3 | If you wish to verify the details you have submitted to us or if you wish to check on the manner in which we use and process your personal data, our security procedures mean that we may request proof of identity before we reveal information. This proof of identity will take the form of full details of name, membership number and NRIC or Passport or FIN number. You must therefore keep this information safe as you will be responsible for any action which we take in response to a request from someone using your details. |
12.1 | This Policy only applies to the collection and use of Personal Data by GWG. It does not cover third party sites to which we provide links, even if such sites are co-branded with our logo. GWG does not share your Personal Data with third party websites. GWG 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. |
12.2 | GWG 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 GWG’ website. |
12.3 | GWG’ websites do not target and are not intended to attract children under the age of 21 years old. GWG does not knowingly solicit personal information from children under the age of 18 years old or send them requests for personal data. |