Privacy Policy

Apical Media Pte Ltd Privacy and Data Protection Policy (“Policy”)

Introduction

Welcome to Apical Media Pte Ltd Website.

Your privacy is important to us. The purpose of this Policy is to inform you of how Apical Media Pte Ltd and/or its related entities, affiliates and subsidiaries (collectively referred to as “Apical Media”, “us”, “we” or “our”) manages personal data in accordance with the Personal Data Protection Act 2012 (“the Act”).

Please read this Policy so that you understand the purposes for which we collect, use and disclose your Personal Data, and/or process the Personal Data you have provided to us, as well as to help you to make an informed decision before providing us with your Personal Data. This Policy is not applicable to European Union Data Subject nor EU General Data Protection Regulation as this Site and any Services provided on the Site are not intended for persons residing in the European Union.

By interacting with us and/or our websites which include our e-newsletters, submitting information to us or signing up for any promotions or services offered by us, you agree and consent to Apical Media Pte Ltd, our related corporations and affiliates, (collectively referred to herein as “Apical Media”, “us”, “we” or “our”), as well as our respective representatives collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to Apical Media’s authorised service providers and relevant third-parties in the manner set forth in this Policy.

This Policy supplements but does not supersede, replace or otherwise compromise any other consents you may have previously provided to Apical Media nor does it affect any rights which Apical Media may have at law in connection with the collection, use or disclosure of your Personal Data. Apical Media may from time to time update Policy to ensure that it is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of the Policy as updated from time to time on our websites. Please check regularly for updated information on the handling of your Personal Data. If you, at any time, have any queries on this Policy or any other queries in relation to how Apical Media manage, protect and/or process your personal data, please do not hesitate to contact us and attention your queries to our Data Protection Officer. Details on how to contact our Data Protection Officer are provided herein under.

For the avoidance of doubt, this Policy forms a part of the Website Terms and Conditions. In the event of any conflict, inconsistency or conflict between this Policy and the Website Conditions, the Policy shall prevail. All defined terms contained in the Website Terms and Conditions shall apply to this Policy unless otherwise specifically stated.

1) Your Personal Data

1.1 In this Policy, “Personal Data” refers to any data or information about you from which you can be identified either (a) from that data; or (b) from that data and other information to which we have or are likely to have access. Examples of such Personal Data which you may provide to us include (depending on the nature of your interaction with us):

(a) your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address and any other information relating to you which you have provided us in any forms you may have submitted to us, or in other forms of interaction with you;
(b) information about your use of Apical Media’s website and services, including cookies, IP address, subscription account details and membership details, but only to the extent that Apical Media may identify you from such information;
(c) your employment history, education background, and income levels;
(d) your payment related information, such as your bank account or credit card information, and your credit history; and
(e) information about your usage of and interaction with our website and/or services including computer and connection information, device capability, bandwidth, statistics on page views, and traffic to and from our website.

2) Collection of Personal Data

2.1 We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
Generally, Apical Media collects your Personal Data in the following ways:

(a) when you submit forms relating to any of our products or services;
(b) when you register for or use any of our services on websites owned or operated by us or when you register as a member of websites owned and/or operated by us, or use services on such websites;
(c) when you interact with our staff;
(d) when you use some of our services, e.g. our subscription service;
(e) when you establish any online accounts with us;
(f) when you request that we contact you;
(g) when you are contacted by, and respond to, our staff, marketing representatives and agents;
(h) when you respond to our request for additional Personal Data
(i) when you ask to be included in an email or other mailing list;
(j) when you respond to our promotions and other initiatives;
(k) when you submit a job application;
(l) when we receive references from business partners and third-parties, for example, where you have been referred by them;
(m) when you submit your Personal Data to us for any other reason.

2.2 When you browse our website, you generally do so anonymously but please see the section below on cookies.

2.3 If you provide us with any Personal Data relating to a third-party (e.g. information of spouse, children, parents, employees and/or authorised representatives), 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.

2.4 You should ensure that all Personal Data 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 products and services you have requested.

3) Purposes for the Collection, Use and Disclosure of Your Personal Data

3.1 We may collect or use your personal data for any or all of the following purposes:
Generally, Apical Media collects, uses and discloses your Personal Data for the following purposes:

(a) responding to your queries and requests and responding to complaints;
(b) managing the infrastructure and business operations of Apical Media and complying with internal policies and procedures;
(c) facilitating business asset transactions (which may extend to any merger, acquisition or asset sale);
(d) matching any Personal Data held which relates to you for any of the purposes listed herein;
(e) verifying your identity;
(f) preventing, detecting and investigating crime, including fraud and money-laundering, and analysing and managing other commercial risks;
(g) protecting and enforcing our contractual and legal rights and obligations;
(h) conducting audits, reviews and analysis of our internal processes, action planning and managing commercial risks;
(i) preventing, detecting and investigating crime and managing the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances
(j) processing payment or credit transactions.
(k) complying with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities;
(l) publishing your feedback at our internal and external events, feedback exercises and/or as part of our marketing and promotional activities;
(m) processing, storing, and/or performing internal administrative, operational and technology tasks to facilitate, administer or manage information related to your relationship with Apical media;
(n) any other purpose relating to any of the above.

3.2 In addition, Apical Media may collect, use and disclose your Personal Data for the following purposes, depending on the nature of our relationship with you:

(a) If you have a subscription or membership account with us:

(i) to process your application for Online Subscription Services and/or Print Subscription Services;
(ii) to maintain your account with us;
(iii) to verify and process your personal particulars and payments in relation to provision of Online Subscription Service and/or Print Subscription Services to you;
(iv) to provide you with the goods and services which you have signed up for, including the provision and delivery of newspapers and magazines requested;
(v) communicating with you to inform you of changes and development to Apical Media policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you;
(vi) resolving complaints and handling requests and enquiries;
(vii) conducting market research for statistical, profiling and statistical analysis for the improvement of services provided to you; and
(viii) the processing of your Personal Data in relation to any of the purposes stated above.

(b) If you use download or use any of our Apps:

(i) where the App includes App Subscription Services, to process your application for these services;
(ii) to maintain your account with us and to ensure your access of the App is within the scope of your subscription;
(iii) to verify and process your personal particulars and payments in relation to provision of goods and services connected to the App;
(iv) to provide you with the goods and services which you have signed up for and to push articles to you which may be relevant to you;
(v) communicating with you to inform you of changes and development to Apical Media policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you;
(vi) resolving complaints and handling requests and enquiries;
(vii) conducting market research for statistical, profiling and statistical analysis for the improvement of services provided to you; and
(viii) the processing of your Personal Data in relation to any of the purposes stated above.

(c) If you submit advertisements to us through any of our other online advertising portals:

(i) to verify and process your personal particulars and payments made for the posting of the advertisements;
(ii) communicating with you to inform you of changes and development to Apical Media policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you;
(iii) resolving complaints and handling requests and enquiries;
(iv) conducting market research for statistical, profiling and statistical analysis for the improvement of services provided to you; and

(d) If you submit an application to us as a candidate for employment or an internship:
(i) processing your application including pre-recruitment checks;
(ii) providing or obtaining employee references or other references where relevant for background screening/vetting;
(iii) collecting information about your suitability for the position applied for;
(iv) organising training and staff development programs;
(v) assessing your performance;
(vi) administering benefits and payroll processing;
(vii) providing you with tools to facilitate or as required for you to do your job;
(viii) communicating with you as required by Apical Media to comply with its policies and processes, including for business continuity purposes; and
(ix) any other purposes relating to the aforesaid.

3.3 In addition, where permitted under the Act, Apical Media may also collect, use and disclose your Personal Data for the following purposes (which we may describe in our documents and agreements as “Additional Purposes” for the handling of Personal Data):

(a) providing services, products and benefits to you, including promotions, loyalty and reward programmes;
(b) matching Personal Data with other data collected for other purposes and from other sources (including third-parties) in connection with the provision or offering of products and services, whether by Apical Media or other third-parties;
(c) administering contests, competitions and conducting lucky draws, including, where necessary, in order to announce the results of these contests, competitions and lucky draws and identify and contact the winners, and in order to publicise and conduct marketing strictly related to these contests, competitions and lucky draws;
(d) sending you details of products, services, special offers and rewards, either to our customers generally, or of particular products and services which may be of interest to you; and
(e) conducting market research, understanding and determining customer location, preferences and demographics for us to review, develop and improve our products, services and also develop special offers and marketing programmes.

3.4 If you have provided your Singapore telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your Singapore telephone number(s), then from time to time, Apical Media may contact you using such Singapore telephone number(s) (including via voice calls, SMS, fax or other means) with information about our products and services (including discounts and special offers).

3.5 In relation to particular products or services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, then we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.

3.6 You also consent to the collection, use and disclosure of your Personal Data by Apical Media in connection with any transaction relating to the acquisition, divestment, securitisation, amalgamation, listing or other transaction relating to any interest in Apical Media, the shares or assets of Apical Media, and any other corporate transaction involving Apical Media, including any evaluation or due diligence relating thereto, as well as to the collection, use and disclosure of such information by the counterpart(ies) thereto for the same purposes, and the provision of goods and services by such counterpart(ies) following such transaction, as may be relevant.

4) Disclosure of Personal Data

4.1 Apical Media will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, this Personal Data may be disclosed, for the purposes listed above (where applicable), to the following third-parties, whether they are located overseas or in Singapore:

(a) Apical Media affiliates;
(b) agents, contractors or third-party service providers who provide operational services to Apical Media, such as telecommunications, information technology, payment, payroll, processing, training, market research, magazine vendor services, magazine delivery services, storage, archival or other services to Apical Media;
(c) vendors or any third-party business partners who offer goods and services or sponsor contests or other promotional programs on Apical Media’s sites, whether in conjunction with us or not;
(d) external business and charity partners in relation to corporate promotional events;
(e) the Credit Bureau, or in the event of default or disputes, any debt collection agencies or dispute resolution centres;
(f) any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale;
(g) anyone to whom we transfer or may transfer our rights and duties;
(h) banks, credit card companies and their respective service providers;
(i) our professional advisors such as our auditors and lawyers;
(j) relevant government regulators or authority or law enforcement agency to comply with any laws or rules and regulations imposed by any governmental authority; and
(k) any other party to whom you authorise us to disclose your personal data.

5) Use of Cookies

5.1 When you interact with us on our websites, we may collect or analyse anonymised information from which individuals cannot be identified (“Aggregate Information”), such as number of users and their frequency of use, the number of page views (or page impressions) that occur on the website and common entry and exit points into website.

5.2 Apical Media uses “cookies”, where a small data file is sent to your browser to store and track Aggregate Information about you when you enter our websites. The cookie is used to track information such as the number of users and their frequency of use, profiles of users and their preferred sites.

5.3 Apical Media may use an independent company (the “Third-party Market Research Company”) to measure and analyse the Internet usage across Apical Media websites. Apical Media may use the Third-party Market Research Company’s services to collect the following core information on the usage of our websites, including:

(a) The number of page views (or page impressions) that occur on Apical Media websites;
(b) The number of unique visitors to Apical Media websites;
(c) How long these unique visitors (on average) spend on Apical Media websites when they do visit; and
(d) Common entry and exit points into Apical Media websites.

5.4 This information is aggregated by the Third-party Market Research Company and provided to Apical Media to assist in analysing the usage of Apical Media websites.

5.5 Pages on Apical Media websites may be coded with software which enables the Third-party Market Research Company to track visitors to our websites.

5.6 For more information about the cookies we use, please see our Cookie Policy. Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser. However, you may not be able to enter certain part(s) of our website.

6) Third-Party Sites

6.1 Our website may contain links to other websites operated by third-parties, such as our business partners. We are not responsible for the privacy practices of websites operated by third-parties that are linked to our website. We have no control over personal data that you submit to or receive from these third parties. We encourage you to learn about the privacy policies of such third-party websites. Some of these third-party websites may be co-branded with our logo or trademark, even though they are not operated or maintained by us. Once you have left our website, you should check the applicable terms, conditions and policies of the third-party website to determine how they will handle any information they collect from you. As a reminder, you should always remain alert and exercise caution when accessing third-party sites.

6.2. In respect of Third Party Personal data of any individuals whatsoever which you may, from time to time, disclose to us, (“Third Party Personal Data”) you hereby represent, undertake and warrant to us that:

(i) in disclosing such information to us, you have obtained the appropriate, prior and informed consent from the individuals whose Third Party Personal Data are being disclosed;

(ii) that such Third Party Personal Data is accurate;

(iii) that if in the event such Third Party Personal Data is updated or changed as the case may be, the same to be notified in writing to us as soon as reasonably practicable,

(iv) should you become aware that such individual has withdrawn his/her consent as referred to in sub-clause (i) above, such withdrawal of consent to be notified to us in writing as soon as reasonably practicable.

7) Withdrawal, Access and Correction of your Personal Data

7.1 Should you wish to withdraw consent to use of your Personal Data or obtain access to or make corrections to your Personal Data records, please log in to the relevant account through which the Personal Data was provided, if any, failing which please contact the relevant Personal Data Protection Officer, contact details of which are found in the Personal Data Protection Statement or similar document elsewhere on the relevant Apical Media website.

7.2 Please note that if your Personal Data has been provided to us by a third-party, you should contact such party directly to make any queries, feedback, and access and correction requests to Apical Media on your behalf.

7.3 Please note that if you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, Apical Media may not be in a position to continue to provide its products or services to you or administer any contractual relationship in place, and this may also result in the termination of any agreements with Apical Media and your being in breach of your contractual obligations or undertakings, and Apical Media’s legal rights and remedies in such event are expressly reserved.

8) Withdrawing Your Consent

8.1 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.

8.2 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. Notwithstanding, any necessary extension of time beyond ten (10) days shall remain at the sole and absolute discretion of Apical Media.

8.3 Whilst we respect your decision to withdraw your consent, please note that
depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described herein above.

8.4 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.

9) Access To and Correction of Personal Data

9.1 If you wish to make (a) an access request for access to a copy of the personal
data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.

9.2 Please note that a reasonable fee may be charged for an access request. If
so, we will inform you of the fee before processing your request.

9.3 We will respond to your request as soon as reasonably possible. In general, our
response will be within fourteen (14) business days. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

10) Protection of Personal Data

10.1 To safeguard your personal data from unauthorised access, collection, use,
disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption, use of privacy filters, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis.

10.2 You should be aware, however, that no method of transmission over the
Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

11) Accuracy of Personal Data

11.1 We generally rely on personal data provided by you (or your authorised
representative).In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.

12) Retention of Personal Data

12.1 We may retain your personal data for as long as it is necessary to fulfil the purpose(s) for which it was collected, or as required or permitted by applicable laws.

12.2 We will cease to retain your personal data, or remove the means by which
the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.

13) Transfers of Personal data Outside of Singapore

13.1 We generally do not transfer your personal data to countries outside of
Singapore. However, if we do so, we will obtain your consent for such transfer to be made and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.

14) Data Protection Officer

14.1 You may contact our Data Protection Officer if you have any enquiries or
feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:

Attention Mr/Ms
By email:

You may also write to our Data Protection Officer to the following address:

15) Modifications

15.1 As part of our efforts to ensure that we properly manage, store, protect,
preserve and process your personal data, Apical Media reserves the right to modify, review or amend this Policy at any time. We reserve the right to amend this Policy at our sole and absolute discretion. Any amended Policy will be posted and dated on Apical Media website. You are therefore encouraged to visit the website from time to time to ensure that you are well informed of the latest policies in relation to personal data protection.

16) General

16.1 Your consent that is given pursuant to this Policy is additional to and does not supersede any other consent that you had provided to Apical Media with regard to the processing of your personal data.

16.2 For the avoidance of doubt, in the event that Singapore personal data protection law permits an organisation such as Apical Media to collect, use or disclose your personal data without your consent, such permission granted by the law shall continue to apply. This also applies to foreign data protection laws for non-Singapore residents.

17) Governing Law

17.1 This Policy shall be governed in all respects by the laws of Singapore.