Personal Data Protection Act 2012
1. External Privacy Policy
FUJIFILM Asia Pacific Pte. Ltd. (“FFAP”) respect the privacy and confidentiality of the personal data of our customers, partners, visitors and other individuals whom we interact with in the course of conducting our business operation, including, but not limited to, providing our products and services. We are committed to implementing policies, practices and processes to safeguard the collection, use and disclosure of the personal data you provide us, in compliance with the Singapore Personal Data Protection Act (PDPA) 2012.
We have developed this External Privacy Policy (the “Privacy Policy”) to assist you in understanding how we collect, use, disclose, process, protect and retain your personal data that is in our possession, as well as your rights and responsibilities in relation to Your Personal Data in our possession.
2. Definitions
Except as otherwise specified herein, the following terms have the respective meanings set forth below for all purposes of this Privacy Policy:
“Act”: Singapore Personal Data Protection Act 2012 as amended from time to time and the relevant version in force at the time of application of This Privacy Policy including subsidiary legislations and Personal Data Protection Commission’s Advisory Guidelines;
"Personal Data": Data (regardless of its authenticity) about an individual, a natural person who can be identified from such data, or from such data in combination with other information to which the Company may have access, including the meaning otherwise as defined in the Act; and
“Process”: Carrying out of any operation or set of operations in relation to Personal Data including, recording; holding; organization; adaptation or alteration; retrieval; combination; transmission; erasure; or destruction, and including the meaning otherwise as defined in the Act.
“Website(s)”: Website(s) that are managed and operated by FFAP. “Company”: FFAP.
3. Scope of Application
This Privacy Policy describes the way in which we manage and Process Personal Data and Your rights and responsibilities in relation to Your Personal Data collected in the course of providing our products and services (“Your Personal Data”) This Privacy Policy also applies to Your Personal Data collected through our Website(s).
4. How We Collect Your Personal Data
We collect your Personal Data when you:
· Participate in our events or workshops
· Enquire and purchase our products or services
· Sign up as a customer for our products, services, events or workshops
· Visit our Website and leave behind your contact information
· Provide feedback to us on our products and services or quality of service
· Communicate with us via emails or written correspondences
· Submit your CV and job application form to us in response to our recruitment advertisements
· Submit your CV to recruitment firms or job portals, which are in turn forwarded to or retrieved by us
· Use our repair services
· Like, subscribe, follow and/or otherwise connect with our social media pages, posts, updates, offers etc.
However, we will not knowingly collect any sensitive Personal Data pertaining to individuals from you, unless such collection is necessary for a valid purpose.
We will also not knowingly collect, use, or disclose any Personal Data from a minor under the age of 18. Any Personal Data provided by a minor must be submitted with written consent from a person with parental responsibility such as a parent or guardians through direct off-line contact.
5. Management and Processing of Your Personal Data
Generally, we will only Process Your Personal Data for the purpose clearly indicated to you in advance and in accordance with this Privacy Policy. However, we reserve the right to conduct additional Processing to the extent permitted or required by relevant laws and regulations, or in support of any legal or criminal investigation.
6. Types of Personal Data We Collect About You
The types of Personal Data we collect about you include:
· Personal contact information (Name, Address, Phone No., Email Address)
· Personal details (Name, NRIC No./FIN No./Passport No., Gender, Date of Birth, Nationality)
· Physical Characteristics
· Health information
· Financial information (Credit/Debit Card Details, Bank Account Details)
· Transactional data (Name, Company/Organization, Designation, Residential Address, Preferences, Credit Transactions, Tax number (for companies/vendors)
· Job Applicant’s educational and professional qualifications
· Job applicant’s professional and work experience
7. How We Use Your Personal Data
We use the Personal Data you provide us for one or more of the following purposes:
· Send information, updates, and promotional materials on our services
· Conduct credit checks for creditworthiness
· Analyze your suitability for our skincare products
· Conduct maintenance on our medical systems that are purchased from us
· Obtain opinions, comments or feedback about our services or quality of service
· Respond to queries and feedback, and provide customer service and support
· Investigate complaints, claims and disputes
· Manage and improve our business and operations to serve you better or enhance customer experience
· Process job applications, recruitment, and selection
· Fulfil legal requirements
· Establishing/verifying your identity in relation to your purchase and/or use of our products and services
· Making payments to correct accounts
· Collect payments for our goods and services purchased by you
. Who We Disclose Your Personal Data To
We disclose some of the Personal Data you provide us to the following entities or organizations outside FFAP in order to fulfil our services to you:
· IT / technical support vendors and service providers
· Software suppliers
· Recruitment agencies
· Regulatory bodies and other public agencies
· Third party vendors and service providers
· Fujifilm group companies
· Payment processors / gateways
Where required to do so by law, we may disclose Personal Data about you to the relevant authorities or to law enforcement agencies.
9. How We Manage the Collection, Use and Disclosure of Your Personal Data
9.1 Obtaining Consent
a. Before we collect, use or disclose your Personal Data, we will notify you of the purpose why we are doing so. We will obtain written confirmation from you on your expressed consent. We will not collect more Personal Data than is necessary for the stated purpose. We will seek fresh consent from you if the original purpose for the collection, use or disclosure of your personal data has changed
b. Deemed Consent by Conduct: Under certain circumstances, we may assume deemed consent by conduct from you when you voluntarily provide your Personal Data for the stated purpose, e.g., when you purchase a product from us.
9.2 Withdrawal of Consent
a. If you wish to withdraw consent, you should give us reasonable advance notice. We will advise you of the likely consequences of your withdrawal of consent, e.g., without your personal contact information we may not be able to inform you of our future events and product launches.
b. Your request for withdrawal of consent can take the form of an email or letter to us. The contact details for you to write to us is provided below.
9.3 Use of Your Personal Data
a. We will only use Your Personal Data for the authorized business purpose and NOT for any other purpose – unless you give your consent for that particular purpose or there is a legal obligation to do so.
b. We will not disclose, supply, share or otherwise distribute Your Personal Data to third parties except when:
· Your consent is given in advance or deemed to be given;
· it is necessary to commission operations to the FUJIFILM group companies worldwide;
· We determine, from Your inquiry in relation to Our products/services, that it is appropriate for the FUJIFILM group companies worldwide providing our products/services to respond to Your inquiry;
· You order products or use other services which require a fee. Your name, address, credit card number, and other information is disclosed to financial institutions or other parties for payment settlement;
· Our business is assigned or transferred either by operation in law or otherwise including mergers, consolidations and dissolution or transfer of operations;
· Your Personal Data disclosure is required by relevant laws and regulations, or such disclosure is otherwise necessary in support of any criminal or other legal investigation or proceeding conducted by relevant authorities; or
· There is an immediate need for disclosure to protect human life or human rights.
c. We will try and ensure that your Personal data is accurately processed and recorded. Where relevant, we will verify the accuracy of your Personal Data provided such as checking the Personal Data against some form of unique identification.
d. We will protect and secure any document containing sensitive Personal Data by putting in place appropriate procedures to prevent unauthorized access.
9.4 Disclosure of Your Personal Data
a. We will disclose Your Personal Data only to those third parties who have agreed with us:
· to use Your Personal Data only for the purpose agreed upon in advance;
· not to sell Your Personal Data to any other third parties; and
· not to disclose Your Personal Data to any other third parties except as may be required by law
b. We will not disclose Your Personal Data indiscriminately to people who request for it until you verify their identity and that they are entitled to such information.
c. We will not entertain requests for Your Personal Data over the phone. You should write to us in the manner described in This Privacy Policy should you have any request in relation to Your Personal Data.
d. We will not disclose Your Personal data to any unauthorized persons.
e. When sharing Your Personal Data with any third party, we will put in place an appropriate data sharing agreement. We will ensure that we do not disclose more Personal Data than is necessary for the third party’s purpose of processing.
f. If we are required to transfer Your Personal Data outside Singapore, then we will follow the data transfer obligation as required by the Act.
10. How We Ensure the Accuracy of Your Personal Data
10.1 We will take reasonable steps to ensure that Your Personal Data which we collect is accurate, complete and kept up to date.
10.2 From time to time, we may do a data verification exercise for you to update us on any changes to Your Personal Data. If we are in an ongoing relationship with you, it is important that you update us of any changes to Your Personal Data (such as a change in your mailing address).
11. How We Protect Your Personal Data
11.1 Your Personal Data shall be managed in an appropriate manner under the responsibility of each division of FFAP that receives such Personal Data.
11.2 We will put in place appropriate information security and technical measures (such as data encryption, firewalls, and secure network protocols) to protect the Personal Data we hold about you against loss; misuse; destruction; unauthorized alteration/modification, access, disclosure; or similar risks.
11.3 We will also put in place reasonable and appropriate organizational measures to maintain the confidentiality and integrity of Your Personal Data, and will only share your data with authorized persons on a ‘need to know’ basis.
12. How We Retain Your Personal Data
12.1 We have a document retention policy that keeps track of the retention schedules of various documents in paper or electronic forms. We will not retain any of Your Personal Data when it is no longer needed for any business or legal purposes.
12.2 We will dispose of or destroy such documents containing Your Personal Data in a proper and secure manner when the retention limit is reached.
13. How You Can Access and Make Correction to Your Personal Data
13.1 You may write in to us to find out what Personal Data about you that we have in our possession or under our control and how it may have been used and/or disclosed by us in the previous one year. Before we accede to your request, we may need to verify your identity by checking your NRIC or other legal identification document. We will respond to your request as soon as possible, or within 30 days from the date we receive your request. If we are unable to do so within the 30 days, we will let you know and give you an estimate of how much longer we require. We may also charge you a reasonable fee for the cost involved in processing your access request.
13.2 If you find that the Personal Data, we hold about you is inaccurate, incomplete or not up-to-date you may ask us to correct the data. Where we are satisfied on reasonable grounds that a correction should be made, and we will correct the data as soon as possible, or within 30 days from the date we receive your request.
14. How We Transfer Your Personal Data
14.1 We are a global group of companies and have databases in different countries, some of which are operated by one of our affiliates or by third parties on behalf of them. We may transfer Your Personal Data to one of the Company’s databases outside your country of domicile. We will ensure that all cross- border data transfer shall be in compliance with This Privacy Policy and applicable laws and regulations. If Your Personal Data are transferred to countries which may not necessarily require an adequate level of protection for Your Personal Data compared with the level provided by the Act, we will make reasonable efforts to ensure effective levels of data protection.
14.2 If there is a need for us to transfer Your Personal Data to another organization outside of Singapore, we will ensure that the standard of data protection in the recipient country is comparable to that of the Act. If this is not so, we will enter into a data transfer agreement with the receiving party to accord similar levels of data protection as that in Singapore.
15. Your Right of Access, Correction, Deletion & Withdrawal of Consent
15.1 You may request us to access, update, correct or delete Your Personal Data (or any part thereof) or withdraw Your Consent or object to management and Processing of Your Personal Data. In the case
of electronic direct marketing, we will provide You with a method to opt out of receiving further marketing materials or with a method to opt in if required by relevant laws and regulations.
15.2 If you want to exercise Your rights set forth above or have any questions or concerns in relation to Your Personal Data, please contact our Data Protection Officer at ffap.dpo@fujifilm.com. with the following information:
· Copies of proper identification of You;
· How You provided Personal Data; and
· Specific information regarding Your Personal Data that You would like to access, or request for updating, correcting, or deleting.
15.3 If you have any query or feedback regarding this Data Protection Notice, or any complaint you have relating to how we manage your Personal Data, you may contact our Data Protection Officer (DPO) at: ffap.dpo@fujifilm.com. Any query or complaint should include, at least, the following details:
· Your full name and contact information
· Brief description of your query or complaint
15.4 Should you choose to write to us instead, then you may do so by writing to us at: “FUJIFILM Asia Pacific Pte. Ltd
10 New Industrial Road, Fujifilm Building, Singapore 536201
Attention: Data Protection Officer”
15.5 We will treat all requests, queries and feedback in relation to Your Personal Data seriously and will deal with them confidentially and within a reasonable time.
16. Use of Cookies & Internet Tags (for Website(s) users)
16.1 Cookies
Cookies are a mechanism to store information, including the recording of a user’s browsing activities, in order to facilitate more convenient use of websites. The Company uses “session-cookies” for privacy protection purposes. For more detailed information about cookies, please visit http://www.allaboutcookies.org.
16.2 The Website(s) may use cookies for the following purposes while ensuring that the identity of the user is not disclosed.
· To provide the “Save Password” function for members-only websites where customers and/or visitors input their ID and password to view content;
· To analyze customer and visitors’ access to the Website(s) in order to improve operability or to identify the cause of problems on the Website(s);
· To display the most appropriate advertisements on third party sites based on customer interests or previous usage of the Website(s);
· To enhance services; or
· To prompt customers and/or visitors to re-enter their password for security purposes after a certain period of time has elapsed.
16.3 The Company may save and refer to cookies via a third party being outsourced by the Company for the delivery of advertisements.
16.4 By changing the settings on the Internet browser, you may disable their cookies or set it so that a warning will appear on the computer screen before cookies are issued. However, some services provided through the Website(s) may not be usable if cookies are disabled.
17. Internet Tags & Third Party Web Partners (for Website(s) users)
The Company may use internet tags such as Web Beacons (also known as a clear Graphic Interchange Format (GIF) or a pixel tag and may deploy these tags through a third-party advertising partner or a Web analytical service partner (collectively “Third Party Web Partners”) located outside Singapore and they may store the respective information outside Singapore. Our Third-Party Web Partners may be able to collect Your Personal Data because of these internet tags and cookies and may provide us with reports summarizing Your Website activities. We use internet tags to measure your responses to the Website(s).
18. Use of DNT & Social Media Features and Widgets (for Website(s) users)
18.1 Do-Not-Track
You may prevent tracking of Your online activity by setting a Do-Not-Track signal (“DNT”) in Your browser that alerts websites You visit that You do not want them to collect certain information about You. However, Our Website(s) may not recognize or take action in response to DNT signals from Web browsers. For more detailed information about DNT, please visit https://allaboutdnt.com.
18.2 Social Media Features and Widgets
Our Website(s) include social media features, such as Facebook’s “Like” button, and widgets, such as the “Share This” button or interactive mini-programmes that run on the Website(s). These features are recognizable by their third party brand and may collect Your IP address, pages you are visiting on our Website(s) and set a cookie to enable the feature. Social media features and widgets are either hosted by a third party or hosted directly on our Website(s). Your interaction with these features shall be governed by the respective privacy policies of individual organizations providing such features.
19. Google Analytics (for Website(s) users)
The Company uses Google Analytics service offered by Google Inc. for the purpose of evaluating the use of Website(s), optimizing traffic to and between Website(s) or integrating Web pages where appropriate. The information generated by the cookies about Your use of Website(s), including Your IP address, will be anonymized and transmitted to Google servers. For more information on IP anonymization, please refer to https://support.google.com/analytics/answer/2763052.
20. Third Party Links on our Website(s)
The Privacy Policy shall not apply to other websites owned by third parties to which we may provide links (as in the link to Google Analytics in the above Paragraph 19). The Company cannot guarantee the privacy standards of third parties links on our Website(s) or be responsible for the contents of such third party website linked on our Website(s).
21. Changes to this Privacy Policy
21.1 We may update this Privacy Policy from time to time. We will notify you of any changes by posting the latest Privacy Policy on our website. Please visit our website periodically to note any changes.
21.2 Changes to this Privacy Policy take effect when they are posted on our Website.