A) Personal Data Protection
We at The Esplanade Co Ltd (“TECL”, “we”, “us” or “our”) take our responsibilities under Singapore's Personal Data Protection Act 2012 (the “PDPA”) seriously. We recognise the importance of safeguarding the personal data you have provided us and it is our responsibility to properly manage, protect and process your personal data.
This Policy is designed to assist you in understanding how we collect, use, disclose and/or process the personal data you have provided to us, as well as to assist you in making an informed decision before providing us with any of your personal data.
If you, at any time, have any queries on this policy or any other queries in relation to how we may manage, protect and/or process your personal data, please do not hesitate to contact our Data Protection Officer (the “DPO”) at 68288227 or email firstname.lastname@example.org.
1.1 "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.
1.2 We will collect your personal data in accordance with the PDPA either directly from you or your authorised representatives, and/or through our third party service providers (e.g. ticketing agents or survey companies). We are hereby notifying you of the purposes for which your personal data may be collected, used, disclosed and/or processed, as well as obtaining your consent for the collection, use, disclosure and/or processing of your personal data for the intended purposes, unless an exception under the law permits us to collect and process your personal data without your consent.
1.3 This Data Protection Policy additionally provides you with information on our processing of personal data pursuant to the GDPR (the European Union General Data Protection Regulation) to the extent it is applicable to us (in particular, see paragraph 10 below).
2.1 We collect personal data to the extent that it is necessary for the transaction with you at hand, for us to discharge our business activities or arising from your interaction with us. We do not collect more personal data than is necessary.
2.2 Such personal data is collected by us because of :
2.3 As we collect only such personal data as is necessary to achieve the matters highlighted in paragraph 2.2 above, your failure to provide us with personal data as requested would likely result in us being unable to carry out the matters highlighted in paragraph 2.2 above, such as our inability to enter into the transaction with you, our not being able to provide you with the information and/or services you have requested or otherwise fulfil the purpose(s) for which we have asked for the personal data, as the case may be.
3.1 TECL will/may collect, use, disclose and/or process your personal data for one or more of the following purposes:
As the purposes for which we may/will collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may 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.
3.2 In order to conduct our business operations more smoothly and to fulfill the above-said Purposes, we may also be disclosing the personal data you have provided to us to our third party service providers, agents and/or our affiliates or related corporations, and/or other third parties whether sited in Singapore or outside of Singapore, for one or more of the above-stated Purposes. Such third party service providers, agents and/or affiliates or related corporations and/or other third parties would be processing your personal data either on our behalf or otherwise, for one or more of the above-stated Purposes. Without limiting the generality of the foregoing, such third parties include
3.3 Where we disclose your personal data to third parties, we will employ reasonable measures to ensure the protection of your personal data, such as imposing suitable contractual clauses on such third parties or disclosing only to reputable organisations.
4.2 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.
4.3 You can block or deactivate cookies in your browser settings.
4.4 We use log-in cookies in order to remember you when you have logged in for a seamless experience.
4.5 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.
4.6 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 our website and the pages that you visit so we can continue to produce engaging content.
4.8 For further information on types of cookies and how they work visit www.allaboutcookies.org.
5.1 You may request to access and/or correct the personal data currently in our possession or control by submitting a written request to us. 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. Hence, please submit your written request to email@example.com.
5.2 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.
5.3 For a request to correct personal data, once we have sufficient information from you to deal with the request, we will :
5.4 Notwithstanding paragraph 5.3(b), we may, if you so consent, send the corrected personal data only to specific organisations to which the personal data was disclosed by us within a year before the date the correction was made.
5.5 We may also be charging you a reasonable fee for the handling and processing of your requests to access your personal data. We will provide you with a written estimate of the fee we will be charging. Please note that we are not required to respond to or deal with your access request unless you have agreed to pay the fee.
6.1 You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control by submitting your request to firstname.lastname@example.org and using the online form set out therein. Opt Out from Marketing Information - any email communication we send to you will contain an easy automated one click unsubscribe link so that you can opt out of the subscription. For WhatsApp subscription service, you can WhatsApp ‘UNSUB’ to the mobile number provided to unsubscribe from the service.
6.2 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.
6.3 However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal. In this regard, depending on the extent of your withdrawal of consent for us to process your personal data, it may mean that we will not be able to continue with your existing relationship with us.
6.4 Your withdrawal of consent will not affect the lawfulness of our processing of your personal data based on your consent before your withdrawal of consent.
7.1 We will take reasonable efforts to ensure that your personal data is accurate and complete, if your personal data is likely to be used by TECL to make a decision that affects you, or disclosed to another organisation. However, this means that you must also update us of any changes in your personal data that you had initially provided us with. 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.
7.2 We will also 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 unauthorised access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data. However, we cannot assume responsibility for any unauthorised use of your personal data by third parties which are wholly attributable to factors beyond our control.
7.3 We will also 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.
7.4 Where your personal data is to be transferred out of Singapore, we will comply with the PDPA in doing so. In this regard, this includes us taking appropriate steps to ascertain that the foreign recipient organisation of the personal data is bound by legally enforceable obligations to provide to the transferred personal data a standard of protection that is at least comparable to the protection under the Act. This may include us entering into an appropriate contract with the foreign recipient organisation dealing with the personal data transfer or permitting the personal data transfer without such a contract if the PDPA or law permits us to.
8.1 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.
8.2 Please contact us through one of the following methods with your complaint or grievance:
8.3 We will certainly strive to deal with any complaint or grievance that you may have speedily and fairly.
9.1 As part of our efforts to ensure that we properly manage, protect and process your personal data, we will be reviewing our policies, procedures and processes from time to time.
9.2 We reserve the right to amend the terms of this Policy at our absolute discretion. Any amended Policy will be posted on our website and can be viewed at www.esplanade.com
9.3 You are encouraged to visit the above website from time to time to ensure that you are well informed of our latest policies in relation to personal data protection.
10.1 In addition to the foregoing paragraphs, the following sub-paragraphs in this paragraph 10 apply, if and to the extent that the GDPR is applicable to your personal data and/or to the activities which we are carrying out in relation to your personal data. Typically, this would be where (a) you are a European Union resident; and (b) when you are a resident in the European Union we process your personal data in relation to our offering of goods or services to you in the European Union.
10.2 In relation to the processing of your personal data by us, we are a data controller. If the GDPR applies to your personal data that is within our possession or control, you will have rights as set out in the GDPR.
10.3 We process your personal data based on one or more of the following legal basis :
10.4 With respect to paragraph 3.2 above, Such third parties to whom your personal data is disclosed comprise :
10.5 One or more of the third parties mentioned at paragraph 10.4 are based outside of Singapore. Your personal data will be transferred by us from Singapore to them. The countries in which these third parties are based are : Malaysia, Hong Kong, Japan, South Korea, Australia, New Zealand, USA, Canada, UK, Germany and Austria. We will ensure that your personal data will be adequately protected by such third parties by executing data transfer agreements with such third parties to deal with such transfer of personal data and to ensure that your personal data will continue to be protected by such third parties.
10.6 Your rights
You may exercise the rights above (if applicable to you), by contacting our Data Protection Officer at email@example.com.
If the PDPA applies to you and not the GDPR, do note that one or more of the rights set out above are not available to you. In such a case, we will extend to you such rights as required by the PDPA.
10.7 In the event that the GDPR applies to us and you determine that we have done something that breaches the GDPR, you may choose to lodge a complaint with the relevant European Data Protection Authority, such as the Authority in the European Union member state in which you are residing in.
To improve user experience and to enable the website to function properly.
C) Terms and Conditions of Service
Your use of the ESPLANADE website as well as all ESPLANADE microsites ("Our Websites"), and ESPLANADE WhatsApp Subscription Service and other services (“Our Services”) are expressly conditioned on your acceptance of The Esplanade Co Ltd's ("TECL") Terms and Conditions of Service ("Terms and Conditions").
The Terms and Conditions apply to the use of the services on or access to the services available through Our Websites. By using Our Services and Websites, you unconditionally agree and accept to be legally bound by the Terms and Conditions. If you do not agree with any part of the Terms and Conditions, you must not, or must cease to, use Our Services and Websites, and cease to access any of the services available through Our Websites.
Certain products and services have their own specific governing terms and conditions which shall apply in addition to the Terms and Conditions. These specific terms and conditions shall include any terms and conditions found on your screens and when using any part of Our Services and Websites. In the event of any inconsistency between the specific terms and conditions and the Terms and Conditions, the specific terms and conditions shall prevail in relation to the product or service in question.
TECL is the operator of this site. Our Websites, and each of its respective modules, together with the arrangement and compilation of the content found on Our Websites, are the copyrighted property of TECL and/or its various third party providers and distributors and which is licensed to TECL. Much of the content found on Our Websites is owned by third party providers and distributors, though certain data is the copyrighted work of TECL and other information providers.
In addition, the trademarks, logos and service marks displayed on Our Websites (collectively, the "ESPLANADE Trademarks") are registered and common law Trademarks of TECL, its affiliates, and various third parties, and are protected by statute as well as common law.
Nothing contained on Our Websites should be construed as granting, by implication, estoppel, or otherwise, any license or right to use any of the content on Our Websites or Trademarks without the prior written permission of TECL, or such other party that may own the content on the site or the ESPLANADE Trademarks.
TECL grants you a limited, non-exclusive, non-transferable right to use Our Websites in accordance with the Terms and Conditions. You agree that you:
Use of Our Services and Websites may require you to register and provide certain personal information to access and/or download certain information and materials, and/or to sign-up for My Esplanade's mailing lists and/or WhatsApp subscription services. You may choose not to provide any personal information, but if you decline to provide any mandatory information required, you may not be able to complete the registration process.
In consideration of TECL permitting you to use the site, in registering and providing such personal information, you represent and warrant that: (a) the information about yourself is true, accurate, current, and complete (apart from optional items) as required by various registration forms on the site (the "Registration Data") and (b) you will maintain and promptly update the Registration Data to keep it true, accurate, current and complete. If you provide any information that is untrue, inaccurate, not current or incomplete, or if TECL has reasonable grounds to suspect that such information is untrue, inaccurate, not current or incomplete, TECL has the right to suspend or terminate your account and refuse any and all current or future access to and use of Our Services and Websites.
Upon registering, you will receive a password and user ID. You agree to be responsible for maintaining the confidentiality of the password and user ID, and to accept full responsibility for all activities that occur under your password or user ID. You may only maintain one user ID and password at any one time and may not use multiple user IDs or passwords. You are required to use your password for your own use only and not to permit others to use your password. You agree to (a) immediately notify TECL of any unauthorised use of your password or account or any other breach of security, and (b) ensure that you exit from your account at the end of each session. TECL cannot and will not be liable for any loss or damage arising from your failure to comply with this requirement.
You have read TECL's Data Protection Policy, the terms of which are incorporated herein and which are an integral part of the Terms and Conditions, and you agree that the terms of such policy are reasonable.
You consent to the use and processing of your Registration Data and other personally identifiable user information by TECL and/or its third party providers and distributors in accordance with the terms of and for the purposes set forth in TECL's Data Protection Policy.
You acknowledge and agree that the technical processing of Our Services, Websites and the transmission of transaction messages relating to the products and services on Our Websites may involve (a) transmissions of your Registration Data and other data collected and maintained by TECL with regard to you, over various networks and to various countries; and (b) changes to conform and adapt your Registration Data and other data collected and maintained by TECL with regard to you to technical requirements of connecting networks or devices.
If you use Our Services and Websites, you represent that you are of sufficient legal age to use Our Services and Websites and to create binding legal obligations for any liability you may incur as a result of the use of Our Services, Websites and of activities that occur under your account or password. You understand and represent that you are and are capable of being legally responsible for all uses of Our Services and Websites by you and those using your login information.
The information and materials contained in Our Services and Websites, including text, graphics, links or other items are provided "As is", "As available". No warranty of any kind (implied, express or statutory) is given in conjunction with the information and materials contained herein including but not limited to accuracy, adequacy or completeness; non-infringement of third party rights; title; merchantability; fitness for a particular purpose and freedom from computer virus. TECL expressly disclaims liability for any loss or damage arising out of or in connection with the reliance on, use of or inability to access such information and materials.
Last updated: Mar 2022