Privacy Policy

Updated: 10 January 2022

The G.H.Y Culture & Media Holding Co., G.H.Y Culture & Media (Singapore) Pte Ltd and/or its related corporations (“GHY”, “we”, “us” or “our”) operates (“Website”). We are committed to respecting and protecting your privacy in respect of personal data collected in connection with the Website.

1. Introduction
We take our responsibilities under Singapore’s Personal Data Protection Act 2012 (the “PDPA”) seriously. We also recognise the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process personal data provided to us by you.
This Privacy Policy is designed to assist you in understanding how we collect, use, disclose and/or process the personal data you have provided to us, as well as to assist you in making an informed decision before providing us with any personal data.
If you, at any time, have any queries on this policy or any other queries in relation to how we may manage, protect and/or process personal data, please do not hesitate to contact our Data Protection Officer (“DPO”) at the contact details below.
This Privacy Policy sets out the basis on which we use and process any personal data we collect from you as a user of the Website. By accessing the Website, you hereby agree to be bound by the terms of this Privacy Policy. If you do not agree with any terms of this Privacy Policy, you should not use the Website.
The Website may from time to time, contain links to and from the websites of our partner networks, advertisers, affiliates or other third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies. As these websites are not owned or operated by us, we do not accept any responsibility or liability for the contents of these websites and their privacy policies, and you access and provide personal data to these third-party websites at your own risk. Please check these policies before you submit any personal data to any such websites.

2. Information we collect
We may collect and process personal data such as:
Information that you may provide when contacting us for any reason, such as your name, email address and contact details.
If you contact us for any reason, we may keep a record of that correspondence.
Personal data that may be captured via any error logging and reporting tool that captures error report data and, at your option and with your consent, send this data to us in order for us to be informed of any software errors or problems that may occur during the use of the Website.
Details of visits to the Website, the activities you engage in when using the Website and the resources that you access on or via the Website.

3. How we use personal data
We may collect, use and process your personal data for one or more of the following purposes:
To facilitate your use of our Website and to operate our Website;
To verify your identity for the purposes of processing and administering any membership application, registration or services;
To conduct marketing activities including market research, customer profiling, customer insights and targeted marketing activities;
To send you notifications and marketing messages in relation to our promotional events, offers, opportunities, products, benefits and programmes, if so consented by you;
To respond to, handle, and process queries, requests, applications, complaints, and feedback from you;
To contact you through the contact information provided by you in order to provide you with information that you request from us;
To collect information relating to online interactions with us (including, for example, your IP address and the pages you view) so that we can offer you a more consistent and personalised experience in your relationship with us;
To store, host and/or back up (whether for disaster recovery or otherwise) personal data, whether within or outside Singapore;
For record-keeping purposes;
To conduct research, analysis and development activities (including but not limited to data analytics, surveys and/or profiling) to improve the Website;
To administer and conduct programmes, promotions and events that you have registered for and to inform you of any changes or updates to the same;
To notify you of any administrative updates that are not marketing or advertising in nature;
To respond to any legal processes, pursue legal rights and remedies, and manage any complaints or claims;
To respond to requests for information from public and governmental / regulatory authorities, statutory boards, related companies, whether in Singapore or abroad, for audit, compliance, investigation and inspection purposes;
To inform you of updates on and/or changes to our programmes, policies, terms and conditions, updates and other administrative information;
To comply with any applicable law, regulation, legal process or government request;
For any other purposes for which you have provided the information; and
For any other incidental purposes related to or in connection with the purposes as set out above or otherwise described in this Privacy Policy.

4. Disclosure of personal data
Personal data provided to us by you may be used, disclosed, maintained, accessed, processed and/or transferred to the following third parties, whether sited in Singapore or outside of Singapore, for the purposes set out below:
our headquarters, subsidiaries and group companies;
third party service providers which require the processing of personal data, for example, third party service providers which have been engaged by us to
to provide and maintain any IT equipment used to store and access personal data;
to host and maintain the Website;
our auditors and legal advisors;
public and governmental / regulatory authorities, statutory boards, industry associations, whether in Singapore or abroad; and/or
courts and other alternative dispute forums.
In certain circumstances we may provide third parties (whether or not located in Singapore) with aggregate information about our Website’s users. This may include information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is anonymised statistical data about our users’ browsing actions and patterns, and does not identify any individual.
We may also disclose personal data in order to comply with any legal obligation, or in order to enforce or apply any terms and conditions between you and us; or to protect the rights, property, or safety of any person (including for example for the purposes of fraud detection and prevention).

5. Transfer of personal data outside of Singapore for storage
The personal data that we collect from you may be transferred to, used, processed and stored outside of Singapore for one or more of the purposes set out above. By submitting personal data and/or using the Website, you agree and consent to such transfer, storing or processing.
We will take reasonable steps to maintain appropriate physical, technical and administrative security to help prevent the loss, misuse, unauthorized access, disclosure or modification of personal data.

6. Updating your information
Where you submit personal data to us, you should ensure such personal data is accurate, and let us know if such personal data changes so that we are not holding any inaccurate personal data about you.
You may request to update or amend your personal data by notifying us through e-mail to our DPO (details set out in paragraph 10 below).

7. Retention of personal data
Your personal data will be retained by us for as long as the original purposes or the legal or business purposes for which your personal data was collected continues. If retention is no longer necessary, we will use reasonable efforts to delete, destroy or de-identify your personal data unless retention of the same is required to satisfy legal or regulatory requirements or to protect our interests or in accordance with our policies.

8. Your rights
You may withdraw your consent for us to collect, use, disclose and/or process your personal data for some or all of the purposes listed in this Privacy Policy.
You may request to access and/or correct the personal data currently in our possession by writing to the DPO using the contact details provided below. Please note that we may charge you a reasonable fee for the handling and processing of your requests to access your personal data.

9. Changes to this privacy policy
We reserve the right to amend the terms of this Privacy Policy at our absolute discretion. Any amended Privacy Policy will be posted on our Website. You are expected to check this page from time to time to take notice of any changes we have made as they are binding on you. Your continued use of the Website following any amendment of this Privacy Policy will signify your assent to and acceptance of its revised terms.

10.Further information about protection of personal data and the Personal Data Protection Act 2012
If you want to contact us with specific queries or concerns in relation to this Privacy Policy, or if you have any questions or complaints as to how your personal data is collected, used, disclosed and/or processed by us, please contact our DPO at