1.1 This Policy statement provides information on the obligations and policies of Vintage Studio in respect of an individual customer’s Personal Data. Vintage Studio undertakes to use reasonable efforts in applying, where practicable, those principles and the processes set out herein to its operations.
1.2 Vintage Studio’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, Vintage Studio. Vintage Studio shall use reasonable endeavours to ensure that all collection and/or storage and/or disclosure and/or usage of Personal Data by Vintage Studio shall be done in an appropriate manner and in accordance with the Act and this Policy.
1.3 By interacting with us, submitting information to us, or signing up for our membership program or any products or services offered by us, you agree and consent to Vintage Studio as well as to its respective representatives and/or agents (“Representatives”) collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to Vintage Studio’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 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 Vintage Studio or that which shall be collected by Vintage Studio in future.
2. Contacting the Data Protection Officer
2.1 Where you legitimately request access to and/or correction of Personal Data relating to you, such Personal Data which is in the possession and control of Vintage Studio, Vintage Studio shall provide and/or correct that data in a reasonable time and manner in accordance with its standard procedures as stated hereinafter.
2.2 In accordance with the Act, Vintage Studio 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 Vintage Studio receives your complaints and enquiries regarding Personal Data, please send the same via email to any of our Data Protection Officer at email@example.com.
2.3 Please note that if your personal data has been provided to us by a third party (e.g. a member via a referral process) you should inform us if such consent to collect, use and disclose your Personal Data had not been given. Of course, Vintage Studio, would have done its due diligence to ascertain that your consent had already been obtained before collecting, using or disclosing your Personal Data.
2.4 Should you not wish Vintage Studio 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 Vintage Studio, 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.
3. Statement of Practices
Types of Personal Data Collected:
3.1 As part of its day-to-day activity, Vintage Studio may collect from you, through various means, including via our application forms, phone calls, websites, smart phone applications, marketing events such as road shows and any forms used by Vintage Studio from time to time, some or all of the following Personal Data (as and when if required):
• Name (first and surname);
• Phone number (including mobile);
• Date of Birth;
• Email address;
• IP addresses; and
• Photographs and images;
Purpose of Collection of Personal Data
3.2 The above Personal Data mentioned in Clause 3.1 is collected for the purposes of managing your membership with Vintage Studio, managing your appointments with us, tending to your queries and feedback, managing any refunds of goods and services, offer further related services, sending you marketing and promotional material either via your email, mobile or post, and for identification and verification. If you would like to withdraw your consent for any of the above purpose, you may send a clearly worded email stating the above as mentioned in Clause 2.4 of this Policy.
Disclosure of Personal Data
3.3 In order to carry out the functions described above, Vintage Studio may, from time to time, disclose your Personal Data to various parties that work with us to provide you with the top service we take pride in.
3.4 Vintage Studio may disclose your Personal Data to the following third parties:
• Relevant authorities;
• Regulators and law enforcement officials;
• Third party service providers and consultants;
• Product Suppliers of Vintage Studio (only with your further consent and confirmation);
• Credit, debit and charge card companies, banks and other entities processing payment;
• Potential buyers or investors of Vintage Studio;
• Any online/offline data storage facility provider working with Vintage Studio; and
• Any agent or subcontractor acting on Vintage Studio’s behalf for the provision of Vintage Studio’s services.
3.5 Vintage Studio may disclose your Personal Data to the abovementioned parties also in the occurrence of any of the following events:
• To the extent that Vintage Studio is required to do so by the law;
• In connection with any legal proceedings or prospective legal proceedings;
• To establish, exercise or defend Vintage Studio’s legal rights;
• To the purchaser (or prospective purchaser) of any business or asset which Vintage Studio is (or is contemplating) selling;
• To any person and/or entity for the purpose of processing such information on Vintage Studio’s behalf;
• To third parties who provide services to Vintage Studio or on its behalf;
• To any third party that purchases Vintage Studio or Vintage Studio’s business or any part of Vintage Studio or Vintage Studio’s business;
• With your consent; and
• For the purposes of disaster recovery.
Optional Provision of Personal Data
3.6 In some instances, you may also be requested to provide certain Personal Data that may be used to further improve Vintage Studio’s products and services and/or better tailor the type of information presented 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 Vintage Studio from providing the service to you.
3.7 Under certain circumstances, telephone calls made to/from Vintage Studio 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.
4. Transfer of Personal Data Overseas
Your Personal Data may be processed by Vintage Studio, its affiliates, agents and third parties providing services to Vintage Studio, in jurisdictions outside of Singapore. In this event, Vintage Studio will comply with the terms of the Act.
5. Accuracy of Personal Data
Where possible, Vintage Studio will validate data provided using generally accepted practices and guidelines. In some instances, Vintage Studio is able to validate the data provided against pre-existing data held by Vintage Studio. In some cases, Vintage Studio is required to see original documentation before we may use the Personal Data. To assist in ensuring the accuracy of your Personal Data in the possession of Vintage Studio, please inform us of any updates of any parts of your Personal Data by sending a clearly worded email to the DPO at the email address provided at Section 2.2.
6. Protection of Personal Data
Vintage Studio uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your Personal Data and will not knowingly allow access to this data to anyone outside Vintage Studio, other than to you or as described in this Policy. However, Vintage Studio cannot ensure or warrant the security of any information you transmit to Vintage Studio and you do so entirely at your own risk. In particular, Vintage Studio does not warrant that such information may not be accessed, altered, collected, copied, destroyed, disposed of, disclosed or modified by breach of any of Vintage Studio’s physical, technical, or managerial safeguards.
7. Access and Correction of Personal Data
7.1 In accordance with Clause 2.1 of this Policy, you have the right to:
a) check whether Vintage Studio holds any Personal Data relating to you and, if so, obtain copies of such data; and
b) require Vintage Studio to correct any Personal Data relating to you which is inaccurate for the purpose for which it is being used.
7.2 Vintage Studio reserves the right to charge a reasonable administrative fee in order to meet your requests under Clause 7.1. 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 Vintage Studio or if you wish to check on the manner in which Vintage Studio uses and processes your personal data, Vintage Studio’s security procedures mean that Vintage Studio may request proof of identity before we reveal information. This proof of identity will take the form of full details of name and NRIC or Passport or Fin number. You must therefore keep this information safe as you will be responsible for any action which Vintage Studio takes in response to a request from someone using your details.
8. Storage and Retention of Personal Data
Vintage Studio will delete, as reasonably possible, or otherwise anonymise any Personal Data in the event that the Personal Data is not required for any reasonable business or legal purposes of Vintage Studio and where the Personal Data is deleted from Vintage Studio, electronic, manual, and other filing systems in accordance with Vintage Studio internal procedures and/or other agreements.
9. Contacting you
To the extent that any of the communication means which you have provided Vintage Studio with (which may include, your telephone number and fax number) is/will be listed on the Do Not Call Registry (the “DNC”), by agreeing to this Policy through your acceptance of our quotation, or by any other means of indication, you hereby grant Vintage Studio your clear and unambiguous consent to contact you using all of your communication means you have provided to Vintage Studio including using via voice calls, SMS, Whatsapp, MMS, fax or other similar communications applications or methods, for the purposes as stated above in Paragraph 3.2. This will ensure your continued enjoyment of Vintage Studio’s promotional rates and services
10. Change Policy
Vintage Studio reserve the right to alter any of the clauses contained herein in compliance with local legislation and/or to meet its global policy requirements, and for any other purpose deemed reasonably necessary by Vintage Studio. You should look at these terms regularly. If you do not agree to the modified terms, you should inform us as soon as possible of the terms to which you do not consent. Pending such notice, if there is any inconsistency between these terms and the additional terms, the additional terms will prevail to the extent of the inconsistency.
11. Governing Law
This Policy is governed by and shall be construed in accordance with the laws of Singapore. You hereby submit to the non-exclusive jurisdiction of the Singapore courts.
12.1 This Policy only applies to the collection and use of Personal Data by Vintage Studio. It does not cover third party sites to which we provide links, even if such sites are co-branded with our logo. Vintage Studio does not share your Personal Data with third party websites. Vintage Studio 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 Vintage Studio 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 Vintage Studio’s website.
12.3 Vintage Studio’s website does not target and is not intended to attract children under the age of 18 years old. Vintage Studio does not knowingly solicit personal information from children under the age of 18 years old or send them requests for personal data.