Privacy Policy
This Hmlet Privacy Policy (Privacy Notice) outlines how Hmlet manages the Personal Data we hold. This policy applies to all entities under HMLET Central Pte. Ltd. (Reg. No. 201723163W), and/ or its related affiliates (referred to hereunder as “Hmlet”, “we”, “us” or “our”) collectively or singularly as the context requires.
The term “personal information” shall have the same definition as “personal data” in accordance to the General Data Protection Regulation (”GDPR”). The terms “use” and “process” shall have the same meaning and “processing” prescribed in the GDPR which means, any operation or set of operations which is performed on personal data or on sets of personal data, regardless of means.
Hmlet recognizes the importance of proper data management and protection in order to preserve the trust of Members who provide personal information to us. To fulfil this responsibility, Hmlet complies with all laws and regulations concerning protection of personal information.
| 1. | INFORMATION ABOUT US | ||
| 1.1 | HMLET Central Pte. Ltd. is a Private Limited Company incorporated under the laws of the Territory with registration number 201224126W (“Hmlet”). | ||
| 1.2 | HMLET Central Pte. Ltd's registered address is 25A Teo Hong Road, Singapore 088333. | ||
| 1.3 | HMLET Central Pte. Ltd is committed to protecting and respecting your privacy when you use our website at hmlet.com (the “Site”) and/or any application made by HMLET Central Pte. Ltd | ||
| 1.4 | The Hmlet Group is made up of a mix of companies set up as different legal entities. | ||
| 1.5 | We will let you know with which entity you have a relationship with when you engage with a particular entity. | ||
| 1.6 | You can find out more about the Hmlet Group at hmlet.com. | ||
| 2. | TYPES OF PERSONAL DATA | ||
| 2.1 | “Personal Data” refers to any data or information that can be used to identify a person (”data subject”) directly or indirectly. Examples of such Personal Information which may be requested (depending on the nature of your interaction with us) include: | ||
| a. | Personal identification Data including your name, email address, mobile number, NRIC number, passport number or other identification numbers and any other information relating to you which you have provided to us in any form; | ||
| b. | Usage Data including information about your use of our website and mobile application, browser type and version, time zone, location, operating system and platform, and other technology on the devices that are used to access our website, and or mobile application; | ||
| c. | Profile Data including your interests, preferences, feedback, age, gender, survey responses, contact preferences, services or requests made by you, and similar information; | ||
| d. | Marketing and Communication Data including your preferences in receiving marketing material and your communication preferences; | ||
| 3. | COLLECTION OF PERSONAL DATA | ||
| 3.1 | You directly provide Hmlet with most of the data collected. We collect and process data when: | ||
| a. | you submit forms, information or feedback through any of our platforms of communication (including our Lead Form, ChatBot, WhatsApp or advertisements); | ||
| b. | you register for or use any of our services on websites or applications owned or operated by us or when you register to be a member of Hmlet; | ||
| c. | you interact with our member experience team or any of our staff, for example, via face-to-face meetings, telephone calls, mobile chat interface (through the mobile application); | ||
| d. | you use or purchase our services or products; | ||
| e. | you ask to be included in our mailing list; | ||
| f. | you respond to Hmlet partnership promotions; | ||
| g. | we receive references from third parties such as online travel agents, business partners, for example where you have been referred by them; | ||
| h. | you browse our website after providing consent for cookies to run. Please refer to Article 8. Cookie Policy for more information. | ||
| 3.2 | Hmlet may supervise or record phone calls for quality assurance, employee training and performance evaluation, respond to your queries and requests and resolve complaints and other related purposes. The mentioned recording will be in accordance with applicable law, including obtaining explicit consent where required. | ||
| 3.3 | If you provide Personal Data of a third party (e.g. information of your spouse, dependent, parents) to us, you represent and warrant that the collection use, and disclosure of that Personal Data to us, as well as future processing of that Personal Data by Hmlet is lawful. | ||
| 3.4 | Where Article 3(1) applies, in relation to the offer of information society services directly to a child, the processing of Personal Data of a child may occur where the child is at least 16 years old. Where the child is below the age of 16 years, Personal Data may be processed where consent is given or authorized by the holder of parental responsibility over the child. Should the child be below the age of 13 years, the Personal Data will not be processed in any form. | ||
| 4. | USE OF PERSONAL INFORMATION | ||
| 4.1 | HMLET Central Pte. Ltd. will use your personal information only for the purposes disclosed in point 4.2. of Article 4 (User of Personal Information) and will not use the information for other purposes unless your consent has been obtained or where it is permitted by law. | ||
| 4.2 | Subject to applicable law, process your Personal Data for the following purposes; | ||
| Data Subject | Purpose | Legal basis | |
|---|---|---|---|
| Everyone | communicate with you and respond to your queries | Contract | |
| Everyone | protect and enforce our legal rights and contractual obligations including repayment obligations | Contract | |
| Everyone | aid us to review, develop and improve our products and services that require the use of Personal Data, including analysing future customer needs and data analytics for example to enable us to understand and determine customer preferences and demographics. Hmlet guarantees that the data collected will not result in automated decision- making activity as regulated under the GDPR; | Legitimate interest (to enhance the Hmlet Group’s products and services) | |
| Everyone | handle disputes, conduct and facilitate investigations and proceedings; | Legitimate interest (to defend Hmlet’s Group’s rights) | |
| If you are a Member | when you sign a membership agreement with Hmlet, we process your Personal Data such as name, email, address, NRIC and or Passport number, validity of work permit and bank details which are necessary to carry out the conceptual agreement between you and us and to allow us to comply with our legal obligations. If you do not provide such Personal Data, we may not be in a position to continue to provide our products and services to you; | Contract | |
| If you are a Member | process your application for the account; | Contract | |
| If you are a Member | maintain your account with us; | Contract | |
| If you are a Member | provide services and benefits to you including partnership promotions, newsletters and other information on our products which may be of interest to you and conduct market research for future promotions, partnerships and rewards; | Consent | |
| If you download and or use our mobile application | process your application for the account; | Contract | |
| If you download and or use our mobile application | maintain your account with us; | Contract | |
| If you download and or use our mobile application | provide you with the goods and services that you have signed for; | Contract | |
| If you download and or use our mobile application | resolve issues and inquiries raise through the mobile application (app) | Contract | |
| If you are a prospective vendor, vendor, prospective contractor or contractor | communicate with you or your deployed staff after award of contract, who are in Hmlet properties to carry out work or services, and for any emergency and or security concerns; | Contract |
| 4.3 | The Personal Data collected for the purposes mentioned in 4.2. of this Privacy Policy will be collected, processed and disclosed to relevant members of the Hmlet Group and may be shared with relevant contractors or vendors where necessary. | ||
| 4.4 | As the Hmlet Group is located in more than one (1) country, your data may be transferred outside of Singapore where required. | ||
| 4.5 | Hmlet promises to keep your data protected and confidential, subject to the provisions of any applicable law, your Personal Data may, depending on the concern, be disclosed to third parties mentioned below. In each instance, your Personal Data will only be disclosed to the extent necessary. | ||
| The third parties are: | |||
| a. | other entities within the Hmlet Group; | ||
| b. | Hmlet contractors, vendors, third party service providers who have been contracted to provide us with services in pursuance of the purposes set out in this Policy, such as processing, market research, storage, archival, payment and information technology; | ||
| c. | any third party business partners who offer promotional events or goods and services; | ||
| d. | any debt collection agencies or centers, in the event of disputes; | ||
| e. | any business partner, investor or assignee to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving the Hmlet Group; | ||
| f. | our professional advisors such as auditors and lawyers; | ||
| g. | relevant government regulators, authority or law enforcement agencies to comply with any laws imposed by relevant government bodies; | ||
| h. | anyone to whom we transfer our rights and obligations to handle any aspect of processing your Personal Data notified to you in accordance with this Privacy Policy; | ||
| 5. | PROPER MANAGEMENT AND PROTECTION OF PERSONAL DATA | ||
| 5.1 | The Personal Data that we collect from you may be transferred to, and stored at, a destination outside of the Territory. | ||
| 5.2 | Your Personal Data may be processed by people outside of the Territory who work for HMLET CENTRAL PTE. LTD. or for one of our suppliers, pursuant to a data processing agreement entered into with us, which is compliant with this Privacy Policy. | ||
| 5.3 | The Hmlet group will use reasonable efforts to ensure that your information is treated securely and in accordance with this Privacy Policy. | ||
| To ensure proper Personal Data management, the Hmlet group has implemented the following practices to properly manage and protect your Personal Data: | |||
| a. | establishment of internal company processes based on the GDPR guidelines concerning the handling of personal information; | ||
| b. | training of Hmlet employees to ensure that they understand the importance of Data Protection processes and follow the implemented rules and guidelines when handling Personal Data; | ||
| c. | implementation of appropriate and reasonable security measures to prevent unauthorised access to, or leakage, destruction or alteration of Personal Data without consent; | ||
| 6. | RETENTION OF PERSONAL DATA | ||
| 6.1 | We will keep your Personal Information for as long as you maintain an account with HMLET CENTRAL PTE. LTD. or such other period as may be required by Applicable Law. | ||
| 6.2 | After you terminate your account with HMLET CENTRAL PTE. LTD., we may keep your Personal Information for up to 5 years (the “Retention Period”) if your Personal Data is required to comply with any applicable laws, or if your Personal Data is required to establish, exercise or defend a legal claim, on a need-to-know basis only. To the extent, the Hmlet Group will restrict the processing of your Personal Data for such limited purpose. Where we no longer require your Personal Data for those purposes, we will delete and therefore cease to retain the mentioned Personal Data in accordance with our internal retention policy. | ||
| 7. | YOUR RIGHTS | ||
| 7.1 | In accordance with the GDPR you will have the following rights (except where the exercise of these rights are restricted under applicable laws): | ||
| a. | you have the right to obtain data from us without undue delay, the rectification of inaccurate personal data. You have the right to have any incomplete Personal Data completed; | ||
| b. | you have the right under certain circumstances to obtain from us the erasure of Personal Data without undue delay and the Hmlet Group will have to obligation to erase Personal Data without undue delay | ||
| c. | you have the right to obtain from the Hmlet Group restriction of Personal Data Processing if you believe your Personal Data is inaccurate, unlawfully processed, or you believe the Hmlet Group no longer needs your Personal Data to be processed; | ||
| d. | you have the right to receive Personal Data concerning you (Data Portability), which you have provided to the Hmlet Group based on consent pursuant of Article 3(1), in a structured, commonly used, and machine-readable format; | ||
| e. | you have the right to object to Personal Data being processed, on grounds relating to your situation at any time to processing of Personal Data based on the terms mentioned in Article 4(2) including profiling based on those provisions; | ||
| f. | you have the right to obtain confirmation as to whether or not your Personal Data is being processed, and, where that is the case, access to the personal data; | ||
| 7.2 | Upon erasure, restriction of process or rectification of Personal Data, the Hmlet Group will communicate any changes to each recipient who's Personal Data is affected unless this proves impossible or involves disproportionate effort. The Hmlet Group will inform the data subject about those recipients if the data subject requests it. | ||
| 7.3 | Upon objection to processing of Personal Data, your Personal Data will no longer be processed. Depending on the Personal Data objected, the Hmlet Group may not be in a position to continue to provide our products and services to you. | ||
| 8. | COOKIE POLICY | ||
| 8.1 | Hmlet uses cookies on our website. For purposes relating to website improvement, including enhancing information and services provided. A cookie is an electronic file that is transmitted from a particular web page to a browser viewing that page, which can be retrieved later to distinguish the user’s computer. The Hmlet website uses two (2) types of cookies - Session Cookies and Persistent Cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be accessed every time you use our website. | ||
| 9. | THIRD-PARTY WEBSITES | ||
| 9.1 | The Online Tools may, from time to time, contain links to and from third party websites. | ||
| 9.2 | If you follow a link to/from any third-party websites, you do so at your own risk, and subject to whatever privacy policy/website terms that govern the use of such websites. | ||
| 9.3 | HMLET CENTRAL PTE. LTD does not accept responsibility or liability for the content of third-party websites, or any information you provide to them. | ||
| 10. | MANDATORY DATA BREACH NOTIFICATION | ||
| 10.1 | In the unlikely case of a data breach pertaining to unauthorized access or disclosure of personal data being stored or processed by us, the Hmlet Group shall without undue delay, and where feasible, not later than 72 hours after having become aware of it, notify the personal data breach to the supervisory authority, and affected individuals. Where the notification to the supervisory authority is not made within 72 hours, it shall be accompanied by reasons for the delay. | ||
| 11. | HOW TO CONTACT US | ||
| 11.1 | If you have any questions about this Privacy Policy or any queries relating to your Personal Data, or you would like to obtain access and/ or make corrections to your Personal Data records, please contact Hmlet at: | ||
| Name: Nur Halmi Bulat | |||
| Email: dpo@hmlet.com | |||
| Number: +65 9769 2589 | |||
| 12. | GOVERNING LAW | ||
| 12.1 | This Privacy Policy and your use of the Hmlet website and mobile application shall be governed in all respects by the Singapore law. For the avoidance of doubt, where applicable, the processing of Personal Data is also subject to the data protection policies of the General Data Protection Regulation (GDPR) laws. | ||
| This Privacy Policy was last updated on 19 August 2022 | |||