Updated 21 August 2018
PERSONAL DATA PROTECTION POLICY
This Personal Data Protection Policy (“Policy”) sets out the basis upon which Jadon Solutions Pte Ltd (UEN No: 201624243Z), whose registered address is 400 Orchard Road, #05-16, Orchard Towers, Singapore 238875 (“Jadon”, “we”, “us”, or “our”) may collect, use, disclose, and/or otherwise process personal data in accordance with the Personal Data Protection Act (No. 26 of 2012) of Singapore (“PDPA”) and all the associated regulations and guidelines as may from time to time be issued under it. Please read the following carefully to understand our policies and practices regarding the handling of your personal data.
- YQueue mobile application software, including the YQueue Customer App, YQueue Merchant App and YQueue Donations App (as defined in the Client Merchant Agreement and/or Charities Agreement, as applicable) (“YQueue App”), once you have downloaded or streamed a copy of the YQueue App onto your mobile telephone or handheld device (“Device”).
- YQueue web portal (“YQueue Website”)
This Policy is legally binding when you use our YQueue App, YQueue Website and Services. By continuing your interactions with us, such as by submitting information to us, or using our YQueue App and Services, you confirm that you understand and consent to the collection, use, disclosure, and processing of your personal data (or the personal data of any individual you provide) in the manner as set forth in this Policy.
Questions, comments and requests regarding this Policy are welcomed and should be addressed to the Data Protection Officer (“DPO”) Kah Wee Oh, at Jadon Solutions Pte Ltd, 400 Orchard Road, #05-16, Orchard Towers, Singapore 238875, or at the following contact number: +65 6904 4827 during business hours (Singapore time).
- SCOPE OF THIS POLICY
As used in this Policy, “personal data” means data, whether true or not, about an individual who can be identified: (a) from that data; or (b) from that data and other information to which we (and all our affiliated entities and relevant unaffiliated third parties) have or are likely to have access. Personal data may include (depending on the nature of your interaction with us), without limitation, your (or such person’s): name; address; telephone number(s); email addresses; date of birth; gender; nationality; marital status; passport number, date and place of issue; NRIC number; driver’s licence number and expiration; photographs and other audio-visual material; employment information; payment information; credit card numbers; marketing preferences; and preferred communication methods.
However, “business contact information” (which means your or such person’s name, position name or title, business telephone number, business address, business electronic mail address or business fax number and other similar information about you or such person, not provided by you or such person solely for your or his/her personal purposes, as the case may be) is not regarded as personal data for the purposes of this Policy.
- INFORMATION WE COLLECT FROM YOU
We may collect and process the following data about you:
- Information you give us (“Submitted information”): This is information you give us about you by filling in forms on the YQueue App, YQueue Website and the Services Sites or by corresponding with us (for example, by e-mail). It includes information you provide when you download the YQueue App, register to use the YQueue App, subscribe to any of our Services, search for an App or Service, share data via the YQueue App’s social media functions, enter a competition, promotion or survey, and when you report a problem with the YQueue App, our Services, or Our Sites. If you contact us, we will keep a record of that correspondence. The information you give us may include your name, address, e-mail address and phone number, the Device’s phone number, username, password and other registration information.
- Information we collect about you and your Device. Each time you use the YQueue App or visit Our Sites, we may automatically collect, process and store the following information:
- technical information, including the type of mobile device you use, a unique device identifier (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use and time zone setting (“Device Information”);
- details of your use of the YQueue App or your visits to any of Our Sites including, but not limited to traffic data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise (“Log Information”);
- information relating to the rewards scheme function found in the YQueue App, including but not limited to information on the rewards you have collected, and the frequency and value of your purchases at Merchants (“Rewards Scheme Information”);
- information relating to the ordering system function found in the YQueue App, including but not limited to information on your orders made at store such as your frequent purchases, your decisions to dine in/out, and the size of the group that you booked a table for (“Ordering System Information”);
- Information relating to the donations function found in the YQueue App, including but not limited to information on your donations to any charities via the YQueue App (“Donations”) including but not limited to: the Charities to which you have made Donations, the frequency of your Donations, and the amounts of your Donations (“Donations Information”).
- Location information. When you use any of our location-enabled services, we may collect and process information about your current actual location, which we use GPS technology to determine, as well as the locations of Merchants which you have previously visited and utilised the YQueue App. Some of our location-enabled services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose. You may withdraw this consent at any time by turning off the location services on the Device settings.
- Information we receive from other sources (“Third Party Information”). We are working closely with third parties (including, for example, Facebook Inc., Google Inc., merchants such as restaurants and cafes (“Merchants”), registered charities including religious-affiliated charities such as churches (“Charities”) and other business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies), and may receive information about you from such third parties.
Cookies are small text files stored in your computing or other electronic devices which allow us to remember you or other data about you. The cookies placed by our server are readable only by us, and cookies cannot access, read or modify any other data on an electronic device. For the avoidance of doubt, our cookies do not collect personal data and we do not combine the general information collected through our cookies with other personal data such as to render you identifiable.
- USES OF THE INFORMATION
We use information held about you in the following ways:
- Submitted Information, Location Information, Rewards Scheme Information and Ordering System Information:
- to deliver the Services to you and to allow Merchants and Charities to deliver the Services to you;
- to carry out our obligations arising from any agreements entered into between you and us and to provide you with such information or Services as you may request from us;
- to allow you to participate in interactive features of Our Sites or any of our Services (when you choose to do so);
- to help improve the design, functionality, performance, and content of Our Sites and our Services and for the internal operational and administrative purposes of Our Sites and our Services;
- to contact you to send you information about our Services, and to notify you about changes or updates to the YQueue App, YQueue Website or our Services;
- in respect of Location Information, Rewards Scheme Information and Ordering System Information only: to be used by Jadon to facilitate Merchants in carrying out the following purposes: targeted marketing through trend analysis; determining staffing needs based on demand and peak times; and reconnecting with customers who have not visited within a predetermined period. Any Location Information, Rewards Scheme Information and Ordering System Information provided to Merchants will be aggregated and anonymised.
- in respect of Donations Information only: to facilitate Charities in carrying out the following purposes: the Charities’ operations and the Charities’ issuing of tax invoices to you in respect of Donations (if applicable), and to facilitate the Charities’ and our compliance with any obligations under the Charities Act (Cap. 37) and its related subsidiary legislation, regulations, guidelines and advisories.
- Device information, Content Information and Log information: to administer the YQueue Website, the YQueue App and the Services, and for our internal operations, including to keep the YQueue Website and the YQueue App safe and secure, to understand how well our Services are working as well as for troubleshooting, data analysis, testing, research, statistical and survey purposes. This allows us to help improve the design, functionality, performance, and content of our website and our Services to you, personalise your user experience and measure overall effectiveness.
- Third Party Information: We may receive information about you from third parties such as Google Inc. and Facebook Inc. and in such cases, we will take reasonable steps to check that you have provided consent to such third parties or that no consent is required. We will only use such information for the purposes as set out in this Policy.
- DISCLOSURE OF THE INFORMATION
We may share your information with selected third parties, including:
- affiliates, business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you, such as Facebook Inc. and Google Inc.;
- advertisers and advertising networks solely to select and serve relevant advertisements to you and others; and
- analytics providers that assist us in the improvement and optimisation of the YQueue App and YQueue Website.
We may disclose your personal data to third parties:
- in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets;
- if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our EULA (accessible at: https://www.yqueue.co/terms) and other applicable agreements; or to protect the rights, property, or safety of Jadon, our customers, Merchants or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction;
- to assist us in conducting or co-operating in investigations or proceedings relating to fraud or other illegal activity where we believe it is reasonable and appropriate to do so;
- to prevent and/or detect fraud or crime;
- in response to a subpoena, warrant, court order, order or notice of any government authority, public agency, or law enforcement agency, or as otherwise required by law;
- to assess financial and insurance risks;
- to recover debt or in relation to your insolvency;
- to develop customer relationships, services and systems;
- for any purpose reasonably required by Charities or Jadon to comply with applicable laws and regulations; and
- for any purpose reasonably required by Merchants to properly complete orders in accordance with customers’ reasonable expectations.
- WHERE WE STORE YOUR PERSONAL DATA
The data that we collect from you may be transferred to, and stored at, a destination outside Singapore. It may also be processed by staff operating outside Singapore, who work for us or for one of our suppliers. These staff may be engaged in the fulfilment of your request, order or reservation, the processing of your payment details and the provision of support services. By submitting your personal data to us, you agree to such transfer, storage and processing of your personal data. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Policy and the applicable laws and regulations.
All information you provide to us, except your credit card information, will be stored via cloud computing with a third party provider. We do not store your credit card information, or carry out any payment transactions (including Donations). For the purposes of any such payment transactions (including Donations), you will be directed to the payment webpage(s) of the relevant third-party provider of payment processing services. You may choose to save your credit card information on your Device for use in conjunction with the YQueue App. Our third-party providers of payment processing services are PCI DSS compliant and certified. Any payment transactions (including Donations) carried out by our chosen third-party provider of payment processing services will be encrypted using the following: Advance Encryption Standard (AES), RSA Algorithm, and Secure Sockets Layer (SSL) / Transport Layer Security (TLS). Further information on such encryption methods may be available on the payment webpage(s) and/or website(s) of the relevant third-party provider of payment processing services. Where we have given you (or where you have chosen) a password that enables you to access certain parts of the YQueue App or Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
As you will know, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, as we cannot guarantee the security of your data transmitted to the YQueue App or Our Sites; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal, or similar risks. We restrict access of your personal data to those employees of Jadon who have a business reason for knowing such information. We continuously educate and train our employees about the importance of confidentiality and protection of customer information. We maintain physical, electronic and procedural safeguards that comply with applicable laws and regulations (including, without limitation, the PDPA to protect your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal, or similar risks.
- YOUR RIGHTS
On giving reasonable notice to us, you have the right to ask to stop collecting, using, disclosing, and/or otherwise processing your personal data for any or all purposes, by contacting us at firstname.lastname@example.org and indicating the specific purposes for which you would like us to cease collecting, using, disclosing and/or otherwise processing your personal data.
Within five (5) Business Days from our receipt of your request, we will notify you of the consequences of our acceding to the same. Please note that, depending on the nature and scope of your request, we may not be in a position to continue providing our products or services to you. If you do not respond to our notice within five (5) Business Days of such notice (e.g., by confirming or retracting your request), we will proceed to process your request.
Notwithstanding any such request, we may be entitled to continue retaining your personal data in accordance with applicable laws and regulations.
The YQueue App and Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these have their own data protection or privacy policies and that we do not accept any responsibility or liability for them. Please check these policies before you submit any personal data to these websites.
- DATA ACTIVITY RELATING TO MINORS
We do not knowingly collect or retain personal data about persons under the age of 18 years. Any person who provides their personal data to us via the YQueue App or Our Sites represents that they are 18 years of age and above. We encourage parents and legal guardians to monitor the activity of those under 18 years of age.
Parents or legal guardians of minors can contact us to review any personal data collected about their child or ward, have this information deleted, and/or request that there be no further collection or use of their child or ward’s personal data. We will take steps to verify the identity of anyone requesting personal data about a minor and to ensure that the person is in fact the minor’s parent or legal guardian.
- ACCESS TO AND CORRECTION OF INFORMATION
Subject to applicable laws and regulations, you may have the right to request for access to your personal data that is in our possession or under our control, as well as information about the ways in which such personal data has been or may have been used or disclosed by us. Your right of access can be exercised in accordance with applicable laws and regulations. To meet our costs in providing you with details of the information we hold about you, any access request may be subject to a reasonable fee, which will be charged to your registered credit card. This fee will vary on a case by case basis, depending on the scope of the access request. Should a fee apply, we will inform you of the fee in writing, prior to providing access to the personal data requested. Jadon reserves the discretion to waive such fees.
Subject to applicable laws and regulations, you may also have the right to request for us to correct your personal data that is in our possession or under our control.
If the correction request is made by a person other than the individual who is the subject of the personal data, the request will be refused unless the consent of the individual is obtained.
All access and correction requests must be made in writing and delivered either by post or electronic mail to the DPO whose contact details are listed out in Clause 1 of this Policy.
- CHANGES TO DATA PROTECTION POLICY
We may change this Policy at any time by posting a revised version on this page. The revised version will be effective once it is posted. Where appropriate, we may notify you of any changes to this Policy by email. Please check back frequently to see if there are any updates or changes to our Policy, as it is legally binding on you.
If you register for a YQueue account using Facebook or Google Plus, or interact with us through any other third-party social media sites and applications, we may have access to certain information from your social media account such as user name, profile picture, information about friends and followers, and content posted or viewed through the social media sites and applications. We may use this information to confirm identity, deliver personalised content or as part of the operation of the YQueue Website, the YQueue App and our Services.
We may associate any category of information with any other category of information and will treat the combined information as personal data in accordance with this Policy for as long as it is combined.