(Version as of 11 August 2020)
the Personal Data Protection Act 2012 (the “PDPA”), which is reviewed and updated periodically in accordance with the latest amendments to the PDPA or guidelines or regulations issued by the Personal Data Protection Commission
What does this Policy Cover?
- 1.2 By accessing Seraya Energy’s website and using Seraya Energy’s online services, communicating with Seraya Energy through email, by telephone, in writing, or by providing your personal information to Seraya Energy, you thereby consent
and agree to the collection of your personal data in the manner described in this policy.
Collection of Personal Data
- 2.1 Seraya Energy only collects, uses and discloses personal data with an individual’s consent or deemed consent or as otherwise permitted under the PDPA or other applicable laws and regulations.
- 2.2 In order for Seraya Energy to render and perform the services contracted between Seraya Energy and the individual, it is necessary for Seraya Energy to collect and use certain personal data.
- 2.3 While the specific types of Personal Data you submit through Seraya Energy’s website may vary depending on the services used and rendered, and whether you maintain an account with us, there are ten (10) broad categories of Personal Data
which are collected by us and/or our Affiliates:
- (a) Your name;
- (b) Identity Data (which includes your country of residence, job title, age, marital status and/or gender);
- (c) Contact Data (which includes your email address and online passwords, fax and/or telephone number);
- (d) Transaction Data (which includes your credit card details, your billing address, your mailing address or the mailing address of the intended recipient of your order, payments and orders to and from you, and other details of products
and services that you have supplied to or purchased from us);
- (e) Records of communications with Seraya Energy;
- (f) Usage Data (which includes information about how you use our website (including the time you visited our website, the duration of your visit, the types of products and/or services you are searching for and/or how you are searching
for such products and/or services);
- (g) Marketing and Communications Data (which includes your interests, feedback, survey responses, preferences in receiving marketing materials from us and your communication preferences, as well as your preferences for a product or service);
- (h) Technical Data, which includes your Internet Protocol (IP) address, the internet device identity or media access control address of your device, information regarding the manufacturer, model or operating system of the device that
you use and/or information about the web browser that you use to access our website);
- (i) Data for ensuring IT security and resource management and site security, with view of improving Seraya Energy’s website; and
- (j) Data in compliance with applicable laws and regulations of regulatory authorities and enforcement agencies.
- 2.4 Seraya Energy may collect your Personal Data from you in one of the following ways:
- (a) Directly from you when you provide us with your identity, contact, profile and transaction data through one or the following (whether on your own behalf or on behalf of your organisation):
- i. Use our website;
- ii. Create an account on our website;
- iii. Enter into a contract with us for the purchase of our products and/or services;
- iv. Apply for or enquire about our website or products and/or services;
- v. Participate in a promotion, survey, event or other marketing campaign organized by us;
- vi. Subscribe to our newsletters or alerts;
- vii. Request for marketing materials to be sent to you; or
- viii. Contact us, if you get in touch to provide us with some feedback.
- (b) From your authorized representatives. We may also collect your identity contact, profile and transaction data from your authorized representatives. These include persons whom you have authorized and persons who have
been validly identified as acting on your behalf pursuant to our security procedures.
- (c) When you interact with our website. As you interact with our website, we may automatically collect your technical data through for example, website cookies.
- (d) Third parties or publicly available sources. We may receive your Personal Data from third parties which are located in various countries. These include:
- i. Technical Data from analytics providers, advertising networks and social media platforms; and
- ii. Contact and Transaction Data from providers of technical, payment and delivery services.
- 2.5 There may be situations where Seraya Energy collects and uses personal data which are outside a person’s reasonable expectation. When this occurs, Seraya Energy is committed to providing the relevant individual with an explanation for
the possible use of the personal data when asking for the individual’s consent.
- 2.6 We use “cookies” to provide visitors with a personalized experience on our website. Cookies are pieces of information that a website transfers to the memory or hard drive of a visitor’s computer for record-keeping purposes. We may use
“cookies” to retrieve and store information specific to your computer and on use of the website and the online services via your computer. We also use this information to verify that visitors meet the criteria required to process their
- 2.7 Most browsers used by visitors have options that allow the visitor to control whether the browser will accept cookies, reject cookies, or notify the visitor each time a cookie is sent. As such, you may disable the cookies by changing
the right to delete your cookies from your browser program at any time.
- 2.8 Seraya Energy does not collect sensitive information without the individual’s consent and only if it is specifically relevant and necessary for Seraya Energy’s primary purpose of conducting, improving, maintaining and developing a business
- 2.9 In processing personal data, Seraya Energy shall take into account the nature of its sensitivity, and will only process sensitive data upon the express consent of the data subject and only for the purposes for which it was provided,
or in accordance with the law. Seraya Energy shall also inform data subjects of the sensitive data that is necessary to fulfill the core functionality of the product or service, and the consequences of refusal to the processing, for the
purpose of allowing the data subjects to decide whether or not to give consent.
- 2.10 Seraya Energy does not knowingly collect personal data from children under the age of 13. Should you be under the age of 13, please do not provide personal data of any kind whatsoever. If a child under the age of 13 provides Seraya
Energy with personal data, a parent or guardian of that child may have request to have this information deleted from Seraya Energy’s records by submitting a written request to the Data Protection Officer atDPO@geneco.sg.
Use of Personal Data
- 3.1 The use of your personal information for these purposes will be kept to the minimum required. Where necessary, Seraya Energy and its affiliates may also use the information to resolve any disputes that may arise.
- 3.2 First, Seraya Energy may use your Personal Data for the following purposes:
- (a) To register you as a new customer;
- (b) To process and deliver the services contracted for to you;
- (c) To manage your account, including managing payments, fees and charges and collection of fees due to us;
- (d) To manage our relationship with you;
- (e) To better the services of Seraya Energy and its business partners;
- (f) Tracking and verifying compliance with Seraya Energy’s internal personal data protection policies;
- (g) Meeting laws and/or for fulfilling editorial and feedback solicitation purposes;
- (h) To administer, operate, provide, maintain and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data, as well as ensuring that unauthorized
users do not access the information on our website);
- (i) To deliver relevant information about our events, news, announcements or promotions;
- (j) Where Seraya Energy has to use your Personal Data for another purpose as required by law or regulation, for example, to respond to administrative, judicial or law enforcement requests or to comply with applicable laws and regulations;
- (k) To contact you in relation to all of the above.
- 3.3 Second, Seraya Energy may also transfer this information to other affiliates of Seraya Energy for purposes of updating and enhancing their respective records and for Seraya Energy and its affiliates to:
- (a) collect, retain, use, process and disclose your personal information;
- (b) monitor your access to and use of this website and its various services;
- (c) contact you by telephone, facsimile and/or e-mail; and
- (d) advise you of products and services which may be of interest to you.
- 3.4 Third, Seraya Energy may also disclose and share aggregate information about our users with advertisers, business partners, sponsors and other third parties. This data is used to customise Seraya Energy’s content and advertising to deliver
a better experience to users.
- 3.5 We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If there is any change in
the purpose for which we collect your Personal Data, we will inform you of such change by way of email via the email address that you have provided to us earlier. If you wish to have an explanation as to how the processing for the new
purpose is compatible with the original purpose, please contact Seraya Energy atDPO@geneco.sg. If we need to use your Personal Data for an unrelated purpose, we will notify you and explain the legal basis
which allows us to do so.
Disclosure of Personal Data
- 4.1 Seraya Energy will only disclose Personal Data in the following situations:
- (a) For the primary purpose(s) for which it was collected;
- (b) For purposes that a reasonable person will consider appropriate in the circumstances;
- (c) Where the individual in question has provided consent;
- (d) For direct marketing by Seraya Energy where consent has been given but giving individuals the opportunity to opt out of such marketing. Seraya Energy includes its contact details in any direct marketing; or
- (e) Where permitted under the PDPA or any other applicable law, or if required by law.
- 4.2 Seraya Energy does not disclose your personal data for any secondary purposes unless your consent has been given or if so permitted or required under the PDPA or any other applicable laws and regulations.
- 4.3 Other than those individuals and entities listed below, your personal information will not be revealed by Seraya Energy to any external body. Seraya Energy does not disclose your Personal Data to unaffiliated third parties for their
independent use unless we have obtained your express consent to do so and pursuant to executing confidentiality agreements with such unaffiliated third parties, or where Seraya Energy is under either a legal obligation or any other duty
to do so. For the avoidance of doubt, the information provided by you at this website may be disclosed by Seraya Energy to:
- (a) regulators;
- (b) lawyers/accountants/auditors;
- (c) suppliers, agents or contractors in connection with the services they perform for Seraya Energy pursuant to agreements;
- (d) third parties to comply with a legal obligation, when Seraya Energy believes in good faith that an applicable law so requires it, at the request of government authorities conducting an investigation, to verify or enforce our contractual
rights or other applicable policies, to detect and protect against fraud or any technical or security vulnerabilities, to respond to an emergency, or otherwise to protect the rights, property, safety or security of third parties and
visitors to our website or to the public; and
- (e) any agents acting on our behalf.
- 4.4 We also require all third parties to respect the security of your Personal Data and to treat it in accordance with the law. Seraya Energy uses industry standard practices to safeguard your personal information. Seraya Energy shall, on
a best efforts basis, ensure that all communications and identifiable information will not be disclosed to third parties, and that communications and personal identifiable information received through the website will remain confidential.
Retention of Information
- 5.1 Your personal information will not be kept longer than necessary, and only for as long as it is necessary for us to use your Personal Data as described above. However, please be advised that we may retain some of your Personal Data after
you cease to use our services, for instance if that data is necessary to meet our legal obligations, such as retaining the information for tax and accounting purposes. You may also request for information on our policies regarding the
purpose and duration of retention of your personal data via email sent toDPO@geneco.sg.
- 5.2 In some circumstances, we may anonymize your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
- 5.3 Your personal information in Seraya Energy’s website will be destroyed if you apply to deregister your records. However, this may result in the termination of your access to the secured portions in the website.
Accuracy and Correction of Personal Data
- 6.1 Seraya Energy takes steps to ensure that the information collected is accurate and up to date by updating its records whenever any changes to information come to its attention. Seraya Energy shall disregard information which seems, on
a reasonable basis, be inaccurate or out of date by reason of the time which has elapsed since it was collected or by reason of any other information in its possession.
- 6.2 If you have submitted personal data to Seraya Energy electronically or otherwise and would like to edit such personal data, a written request should be sent by email to Seraya Energy’s Data Protection Officer atDPO@geneco.sg.
After receipt of the written request, Seraya Energy shall comply with the individual’s request to correct their personal data as soon as practicable.
- 6.3 Should Seraya Energy disagree and reject the individual’s written request for a correction of their personal data on reasonable grounds, Seraya Energy shall annotate the personal data with the correction that was requested but not made.
Access to Personal Data
- 7.1 If an individual wishes to be provided with information regarding their Personal Data that is in the possession or under the control of Seraya Energy, or the ways in which such Personal Data has been used or disclosed by Seraya Energy
in the year preceding such request, that individual must send a written request by email to our Data Protection Officer atDPO@geneco.sg. Seraya Energy shall handle such requests as soon as reasonably
possible in accordance with the PDPA.
International transfer of Information
- 8.1 Any personal data provided to Seraya Energy may be transferred to, stored by or disclosed to an overseas recipient.
- 8.2 Where our partners who help us in the administration or operation of our organisation are based in other locations, your Personal Data may be transferred outside of Singapore. When we send your Personal Data outside of Singapore, Seraya
Energy shall ensure that your Personal Data is protected to at least the same standard as that in Singapore and comparable to the protection under the PDPA, and that there is a proper contract governing such data transfer.
- 9.1 Seraya Energy’s management and their teams take commercially reasonable precautions to keep all information obtained from our online visitors secure against unauthorized access (e.g. a data breach) and use, and we periodically review
our security measures. Seraya Energy is committed to employing reasonable security measures, regularly reviewing our security practices (such as security risk assessments and audits) and providing regular awareness training to all staff.
- 9.2 Any data destroyed by Seraya Energy is disposed of in a manner that protects the privacy of personal data in an appropriate manner.
- 9.3 If you use a login user ID or password obtained through the website, you shall be responsible for maintaining the confidentiality of the user ID and password and not to share or authorise the use of the user ID and password by third
parties. You shall be responsible for all activities undertaken using your user ID and password whether authorised or otherwise. You shall immediately notify us if it comes to your knowledge that your user ID and/or password has been compromised
or there has been unauthorised use.
- 9.4 Seraya Energy uses website security certificates. Please be aware that these protection tools do not protect information that is not collected through our website, such as information provided to Seraya Energy through email.
Withdrawal of Consent
- 10.1 You may choose whether or not to provide your personal data, and if already provided, you may choose to exercise your right to object, block or remove such personal data as provided by law.
- 10.2 Your consent given here will override any registration on the Do Not Call Registry and shall apply to Singapore telephone numbers under your name (including your employee, representative or authorised person), including new telephone
numbers which you may provide Seraya Energy from time to time.
- 10.3 You may withdraw your consent for the collection, use or disclosure of personal data by giving Seraya Energy reasonable notice via a written request made by email to our Data Protection Officer atDPO@geneco.sg.
Once a written request is submitted, Seraya Energy shall inform the individual of the likely consequences of the withdrawal of consent. Thereafter, Seraya Energy shall cease to collect, use or disclose the personal data upon such withdrawal
unless otherwise permitted or required by the PDPA or any other applicable laws and regulations.
- 10.4 To keep you in control of your personal information and the communications sent to you, you may opt out of the following services: (a) receiving communications from Seraya Energy and our affiliates about new features, products or services;
and (b) receiving communications about offers from third-party companies that offer a product or a service that we think would be of value to you. If you object to any of the above services for any reason, you may stop that service by
e-mail request made toDPO@geneco.sg. Information provided when purchasing products from any of our websites may be used for marketing and promotional purposes.
Links to Other Sites
- 11.2 Seraya Energy is not responsible for any privacy statements and practices of other third-party websites even if you accessed the third-party website through links from our website or you linked to our website from a third-party website.
We encourage you to read the privacy policies of other websites you link to from Seraya Energy’s website.
Limitation of Liability
- 12.1 Seraya Energy and its affiliates are not liable for any direct, indirect, special or consequential damages or loss of any kind as a result of:- (a) any unauthorised use of your user ID and/or password; and/or (b) your access to and/or
use of the website and/or any online services; and/or (c) your non-compliance of this Policy Statement.
the website and/or its online services.
Attn: Data Protection Officer
Seraya Energy Pte Ltd
450 Alexandra Road #01-01