FUNLAB SINGAPORE HOLDINGS PTE. LTD
A. Who Are We?
We are Funlab Singapore Holdings Pte. Ltd. (“Funlab” or “we” or “our” or “us”). We own and/or operate website(s) such as www.holeymoley.com.sg and/or any mobile apps that may be published by us (the said website and mobile apps may be collectively or individually referred to as the “Website”). We operate entertainment centres/parks/destinations. We are a limited company registered in Singapore (Co. Reg. No. 201819234H) at 150 Beach Road #35-00 Gateway West, Singapore (189720).
B. What Is The Purpose Of This Policy?
3. We take our responsibilities under Singapore’s Personal Data Protection Act (the “PDPA”) seriously. We also recognize the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data.
C. What Information Do We Collect?
6. “Personal data” is defined under the PDPA to mean data, whether true or not, about an individual 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. Funlab collects information about you, such as when you provide your information to us, when you use our Website, when you interact with us and/or when you enter into a transaction with us. Personal data which we may collect include:
Location Information of yourself and/or your computer or device
Usage and Preferences
Your purchase and/or your transactions with us
We will collect your personal data in accordance with the PDPA.
7. We may also collect and store certain information automatically when you visit the Website. Examples include the internet protocol (IP) address used to connect your computer or device to the internet, connection information such as browser type and version, your operating system and platform, a unique reference number linked to the data you enter on our system, login details, the full URL clickstream to, through and from the Website (including date and time), cookie number and/or your activity on our Website, including the pages you visited, the searches you made.
8. We may receive information about you from third parties if you use any websites or social media platforms operated by third parties (for example, Facebook, Instagram, Twitter etc.) and, if such functionality is available, you have chosen to link your profile on our Website with your profile on those other websites or social media platforms.
10. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer or device.
11. You can block or deactivate cookies in your browser settings.
12. We use log-in cookies in order to remember you when you have logged in for a seamless experience.
13. We may use session cookies to track your movements from page to page and in order to store your selected inputs so you are not constantly asked for the same information.
14. Our Website may use Google Analytics which is one of the most widespread and trusted analytics solution on the web for helping us to understand how you use the Website and ways that we can improve your experience. These cookies may track things such as how long you spend on the Website and the pages that you visit so we can continue to produce engaging content.
16. For further information on types of cookies and how they work visit www.allaboutcookies.org
E. The Purposes For Which We Collect, Use Or Disclose Your Personal Data
17. Funlab will/may collect, use, disclose and/or process your personal data for one or more of the following purposes:
processing and/or dealing with your interest in our products and/or services;
considering, processing, dealing with and/or managing, your request/application for or your purchase of or your subscription for, our products and/or services (the “Transaction”);
facilitating, processing, dealing with, administering and/or managing Transaction(s) by or with you;
administering, facilitating, managing, processing and/or dealing with your relationship with us;
administering, facilitating, processing and / or dealing in any matters relating to your use of the Website;
monitoring, processing and/or tracking your use of the Website in order to provide you with a seamless experience, facilitating or administering your use of the Website, and/or to assist us in improving your experience in using the Website;
administering, facilitating, processing and/or dealing in any transactions or activities carried out by you on the Website or at our premises/centres;
providing services to you as our account holder, as our customer, as a member of our loyalty program(s) or when requested by you; dealing with or administering your participation in contests, gamification, social events organized by us;
carrying out your instructions or responding to any enquiry given by (or purported to be given by) you or on your behalf;
contacting you or communicating with you via phone/voice call, text message and/or fax message, email and/or postal mail for one or more of the Purposes stated herein. You acknowledge and agree that such communication by us could be by way of the mailing of correspondence, documents or notices to you, which could involve disclosure of certain personal data about you to bring about delivery of the same as well as on the external cover of envelopes/mail packages;
carrying out due diligence or other screening activities (including background checks, anti-money laundering checks, know your client checks) in accordance with legal or regulatory obligations applicable to us (whether Singapore or other countries), the requirements or guidelines of governmental authorities which we determine are applicable to us (whether Singapore or other countries), and/or our risk management procedures that may be required by law (whether Singapore or other countries) or that may have been put in place by us;
to prevent or investigate any fraud, unlawful activity or omission or misconduct, whether or not there is any suspicion of the aforementioned; dealing with conflict of interests; or dealing with and/or investigating complaints;
complying with or as required by any applicable law, governmental or regulatory requirements of any jurisdiction applicable to us or our affiliates/associated companies, including meeting the requirements to make disclosure under the requirements of any law binding on us or our affiliates/associated companies, and/or for the purposes of any guidelines issued by regulatory or other authorities (whether of Singapore or other countries), with which we or our affiliates/associated companies are expected to comply;
complying with or as required by any request or direction of any governmental authority (whether Singapore or other countries) which we are expected to comply with; or responding to requests for information from public agencies, ministries, statutory boards or other similar authorities. For the avoidance of doubt, this means that we may/will disclose your personal data to the aforementioned parties upon their request or direction;
conducting research, analysis and development activities (including but not limited to data analytics, surveys and / or profiling) to improve our products, services and/or facilities in order to enhance any continued interaction between yourself and us connected or in relation to the Website, or your Transaction(s); or to improve any of our products or services or, whether now or in the future. Without limiting the generality of the foregoing, we may/will in this regard send you surveys or request a face to face interview survey, by way of email or postal mail;
for marketing purpose and in this regard, we would be providing you with marketing, advertising and promotional information, materials and/or documents relating to products, contests, services and/or events (including products, services and/or events of third party organisations with which we may collaborate with) that we (including our affiliates/related corporations) or such third party organisations may be selling, marketing, offering, organizing, involved in or promoting, whether such products, services and/or events exist now or are created in the future,
if you have separately expressly consented to one or more of the following 3 DNC Modes, by way of the 3 modes of communications of voice calls, text messages or faxes (the “3 DNC Modes”) to your Singapore telephone number, in compliance with the requirements of the PDPA; and/or
Notwithstanding (ii) above, regardless that you have not separately provided express consent as aforementioned in (ii) above, Funlab reserves its right to send a specified fax message (as defined in Singapore’s Personal Data Protection (Exemption from Section 43) Order 2013) (the “Exemption Order”) and/or a specified text message (as defined in the Exemption Order) (i.e. a marketing fax message or marketing text message) to your Singapore telephone number, if:
there is an ongoing relationship between Funlab and you and the purpose of the message is related to the subject of the ongoing relationship, pursuant to the requirements and conditions of the Exemption Order; or
the law permits.
storing, hosting, backing up (whether for disaster recovery or otherwise) of your personal data, whether within or outside Singapore;
maintaining and/or developing our IT or business systems and infrastructure including testing and upgrading of these systems;
creating reports with respect to your Transaction(s) and/or transactions that we have with our customers;
facilitating, dealing with and/or administering external audit(s) or internal audit(s) of the business of Funlab and/or of its affiliates/related corporations, Transaction(s), and/or our transactions with our customers;
anonymization of your personal data. In this regard, you acknowledge that personal data that has been anonymized is no longer personal data and the requirements of the PDPA would no longer apply to such anonymized data;
dealing with and/or facilitating a business asset transaction or a potential business assert transaction, where such transaction involves Funlab as a participant or involves only a related corporation or affiliated company of Funlab as a participant or involves Funlab and/or any one or more of Funlab’s related corporations or affiliated companies as participant(s), and there may be other third party organisations who are participants in such transaction. “business asset transaction” means the purchase, sale, lease, merger or amalgamation or any other acquisition, disposal or financing of an organisation or a portion of an organisation or of any of the business or assets of an organisation;
record-keeping purposes and producing statistics and research for internal and/or statutory reporting and/or record-keeping requirements, of Funlab or of its affiliates/related corporations;
Funlab, Funlab Group Companies’ or Funlab’s parent corporation’s reporting purposes including but not limited to reporting on Funlab’s business performance (“Funlab Group Companies” means Funlab, its affiliates, related corporations and associated companies globally); and
to deal with the or as part of a bankruptcy, winding up, reorganization, restructuring, insolvency, receivership or an assignment for the benefit of creditors, of Funlab;
(the purposes set out in this paragraph 17 above shall be collectively referred to as the “Purposes”)
18. Funlab may/will need to disclose your personal data to third parties, whether located within or outside Singapore, for one or more of the above Purposes, as such third parties, would be processing your personal data for one or more of the above Purposes. In this regard, you hereby acknowledge, agree and consent that we may/are permitted to disclose your personal data to such third parties (whether located within or outside Singapore) for one or more of the above Purposes and for the said third parties to subsequently collect, use, disclose and/or process your personal data for one or more of the above Purposes. Without limiting the generality of the foregoing or of paragraph 17, such third parties include:
our associated or affiliated organisations or related corporations;
any of our agents, contractors or third party service providers that process or will be processing your personal data on our behalf including but not limited to those which provide administrative or other services to us such as mailing houses, telecommunication companies, information technology companies and data centres; and
third parties to whom disclosure by Funlab is for one or more of the Purposes and such third parties would in turn be collecting and processing your personal data for one or more of the Purposes.
19. We may share your information with any member of our group (which means our subsidiaries, our ultimate holding company and its subsidiaries), which may be based in countries other than Singapore, from time to time for one or more of the Purposes.
20. Should you provide us with personal data of your child or children, you confirm, declare and agree that you are the parent and/or legal guardian of such child/children, and that we may collect, use and/or disclose your child’s or children’s personal data for the Purposes set out at paragraph 17 above and in the manner as set out at paragraph 18 above.
21. You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control by emailing us at [email protected] We will process your request within a reasonable time from such a request for withdrawal of consent being made, and will thereafter not collect, use and/or disclose your personal data in the manner stated in your request, unless an exception under the law or a provision in the law permits us to. However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal, including us being unable to perform the transactions requested by you or the termination of your relationship with us (depending on the extent of your withdrawal), as the case may be.
22. We may collect, use, disclose or process your personal data for other purposes that do not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of your personal data without your consent is permitted by the PDPA or by law.
23. To the extent permitted by law, we may/will also be collecting from sources other than yourself, personal data about you, for one or more of the above Purposes, and thereafter using, disclosing and/or processing such personal data for one or more of the above Purposes. We may combine information we receive from other sources with information you give to us and information we collect about you. We may use this information and the combined information for the Purposes set out above (depending on the types of information we receive).
24. We take reasonable steps to ensure that any personal data we collect, disclose and use is accurate and complete, if your personal data is likely to be used by us to make a decision that affects you, or disclosed to another organisation. However, it is important that you advise us of any changes to your personal data or if there are any errors in the personal data we hold about you. We will not be responsible for relying on inaccurate or incomplete personal data arising from your not updating us of any changes in your personal data that you had initially provided us with.
F. How Do We Store Data?
25. Security of your personal data is important to us. We will put in place reasonable security arrangements to ensure that your personal data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorized access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data. However, we cannot assume responsibility for any unauthorized use of your personal data by third parties which are wholly attributable to factors beyond our control.
26. We will put in place measures such that your personal data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes.
27. You have the right to ask us not to use your personal data for marketing purposes. Please let us know if you want to withdraw your consent by emailing us at [email protected]
28. You have the right to access and/or correct any personal data that we hold about you, subject to exceptions under the law. This right can be exercised at any time by emailing us at [email protected] We will need enough information from you in order to ascertain your identity as well as the nature of your request, so as to be able to deal with your request. With respect to your access request, we may charge a fee in order to process it.
29. For a request to access personal data, once we have sufficient information from you to deal with the request, we will seek to provide you with the relevant personal data within 30 days. Where we are unable to respond to you within the said 30 days, we will notify you of the soonest possible time within which we can provide you with the information requested. Note that the PDPA exempts certain types of personal data from being subject to your access request.
30. For a request to correct personal data, once we have sufficient information from you to deal with the request, we will correct your personal data within 30 days. Where we are unable to do so within the said 30 days, we will notify you of the soonest practicable time within which we can make the correction. Note that the PDPA exempts certain types of personal data from being subject to your correction request as well as provides for situation(s) when correction need not be made by us despite your request.
31. We hold and deal with your personal data in accordance with the PDPA.
H. Complaint Process
32. If you have any complaint or grievance regarding about how we are handling your personal data or about how we are complying with the PDPA, we welcome you to contact us with your complaint or grievance.
33. Please contact us with your complaint or grievance by emailing us at [email protected]
34. Where you are sending an email in which you are submitting a complaint, your indication at the subject header that it is a PDPA complaint would assist us in attending to your complaint speedily by passing it on to the relevant staff in our organisation to handle. For example, you could insert the subject header as “PDPA Complaint”.
35. We will certainly strive to deal with any complaint or grievance that you may have speedily and fairly.
37. For the avoidance of doubt, in the event that Singapore personal data protection law permits an organisation such as us to collect, use or disclose your personal data without your consent, such permission granted by the law shall continue to apply.
Last Updated on 16 October 2018