1.1 This Policy statement provides information on the obligations and policies of Anthem in respect of an individual customer’s Personal Data. Anthem undertakes to use reasonable efforts in applying, where practicable, those principles and the processes set out herein to its operations.
1.2 Anthem’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, Anthem. Anthem shall use reasonable endeavours to ensure all collection and/or storage and/or disclosure and/or usage of Personal Data by Anthem shall be done in an appropriate manner and in accordance to the Act and this Policy.
1.3 For the purposes of this Policy, in line with the provisions under the 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 to 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 Anthem or that which shall be collected by Anthem in the future.
2. Contacting the Data Protection Officer
2.1 Where you legitimately request access to and/or correction of Personal Data relating to you which is in the possession and control of Anthem, Anthem 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, Anthem 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 Anthem receives your complaints and enquiries, please send the same via email to the Data Protection Officer (the “DPO”) of Anthem at the following email address: email@example.com
2.3 Should you not wish Anthem 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 Anthem, 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 activities, Anthem may collect from you, through various means, including via our websites, smart phone applications, marketing events such as road shows and any forms used by Anthem from time to time, the following Personal Data: name (first and surname); postal address; phone number (including mobile); fax number; e-mail address; bank account/credit card details; gender; Personal Data of your emergency contacts; 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 processing your application and registration of your membership and to ascertain if you are eligible for discounts, privileges or benefits or other related purposes; to conduct market research and analysis; for direct marketing through voice calls; text messages; email; direct mail and facsimile messages; for payment and/or credit control purposes; to notify you of any changes to our policies or services which may affect you; to respond to queries and feedback; for identification and club access; maintaining and updating your membership details; and informing you of new developments, services, promotions of Anthem and other third parties which we are associated with.
Disclosure of Personal Data
3.3 In order to carry out the functions described above, Anthem may, from time to time, disclose your Personal Data between the Cyclique Pte Ltd companies.
3.4 Without derogating from any of the above, Anthem may also disclose your Personal Data to the following third parties, namely: regulators and law enforcement officials; lawyers; auditors; third party service providers and consultants; third party investors; credit, debit and charge card companies, banks and other entities processing payment; and any agent or subcontractor acting on the Anthem’s behalf for the provision of Anthem’s services.
3.5 Anthem may disclose your Personal Data to the abovementioned parties also in the occurrence of any of the following events, namely, to the extent that Anthem is required to do so by the law; in connection with any legal proceedings or prospective legal proceedings; to establish, exercise or defend Anthem’s legal rights; to the purchaser (or prospective purchaser) of any company, business or asset which Anthem is (or is contemplating) selling; to any person and/or entity for the purpose of processing such information on the Anthem’s behalf; to third parties who provide services to Anthem or on its behalf; to any third party that purchases Anthem, business or any part of Anthem’s business; for the purposes of disaster recovery; and any other purpose with your specific consent.
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 Anthem’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 Anthem from providing the service to you. This type of data includes, but is not limited to: your age; gender; salary range and employment details; education and profession; hobbies and leisure activities; other related products and services subscribed to; and family and household demographics.
3.7 Under certain circumstances, telephone calls made to any of Anthem order and/or service hotlines and/or inquiry telephone numbers 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 Anthem, its affiliates, agents and third parties providing services to the Anthem, in jurisdictions outside of Singapore. In this event, Anthem will comply with the terms of the Act.
5. Accuracy of Personal Data
Where possible, Anthem will validate data provided using generally accepted practices and guidelines. This includes the use of check sum verification on some numeric fields such as account numbers or credit card numbers. In some instances, Anthem is able to validate the data provided against pre-existing data held Anthem. In some cases, Anthem is required to see original documentation before we may use the Personal Data such as with Personal Identifiers and/or proof of address. To assist in ensuring the accuracy of your Personal Data in the possession of Anthem, 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 earlier provided.
6. Protection of Personal Data
Anthem 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 Anthem, other than to you or as described in this Policy. However, Anthem cannot ensure or warrant the security of any information you transmit to Anthem and you do so entirely at your own risk. In particular, Anthem does not warrant that such information may not be accessed, altered, collected, copied, destroyed, disposed of disclosed or modified by breach of any of Anthem’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 Anthem holds any Personal Data relating to you and, if so, obtain copies of such data; and
b) require Anthem to correct any Personal Data relating to you which is inaccurate for the purpose for which it is being used.
7.2 Anthem 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 Anthem or if you wish to check on the manner in which Anthem uses and processes your personal data, Anthem’s security procedures mean that Anthem may request proof of identity before we reveal information. This proof of identity will take the form of full details of name, membership number and NRIC or Passport or Fin number. You must therefore keep this information safe as you will be responsible for any action which Anthem takes in response to a request from someone using your membership details. We would strongly recommend that you do not use the browser's password memory function as that would permit other people using your terminal to access your personal information.
8. Storage and Retention of Personal Data
Anthem 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 Anthem and where the Personal Data is deleted from Anthem’s electronic, manual, and other filing systems in accordance with Anthem’s internal procedures and/or other agreements.
9. Contacting you
To the extent that any of the communication means which you have provided Anthem 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 signing of the Membership Agreement Form or the Members’ Consent Form, or by any other means of indication, you hereby grant Anthem your clear and unambiguous consent to contact you using all of your communication means you have provided to Anthem including using SMS and MMS messages for the above purposes. This will ensure your continued enjoyment of Anthem’s promotional rates and services
10. Change Policy
Anthem 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 Anthem. 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 Anthem. It does not cover third party sites to which we provide links, even if such sites are co-branded with our logo. Anthem does not share your Personal Data with third party websites. Anthem 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 Anthem 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 Anthem’s website.
12.3 Anthem’s websites do not target and are not intended to attract children under the age of 18 years old. Anthem does not knowingly solicit personal information from children under the age of 18 years old or send them requests for personal data.