JCB SingaporeData Protection Policy
We at JCB International Co. Ltd. and JCB International Asia Pacific Pte. Ltd. (collectively, "JCB") take our responsibilities under Singapore’s Personal Data Protection Act 2012 (the "PDPA") seriously. We also recognize the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data.
This Data Protection 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 of your 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 your personal data, please do not hesitate to contact our Data Protection Officer (the "DPO") using the contact details below.
1 INTRODUCTION TO THE PDPA
"Personal Data" is defined under the PDPA to mean data, whether true or not, about an individual 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. Common examples of personal data could include names, identification numbers, addresses, contact information, credit card numbers and credit card transaction records.
We will collect your personal data in accordance with the PDPA. We will notify you of the purposes for which your personal data may be collected, used, disclosed and/or processed, as well as obtain your consent for the collection, use, disclosure and/or processing of your personal data for the intended purposes, unless an exception under the law permits us to collect and process your personal data without your consent.
2 PURPOSES FOR COLLECTION, USE,DISCLOSURE AND PROCESSING OF PERSONAL DATA
The personal data which we collect from you may be collected, used, disclosed and/or processed for various purposes, depending on the circumstances for which we may/will need to process your personal data, including :
Processing your JCB card transaction (including without limitation your JCB credit card payment, chargeback and retrieval)
Opening, processing, administering, managing and/or maintaining your JCB card and relationship with us
Providing you with the JCB cardmember benefits
Providing you with the services available or offered at the JCB Plaza Lounge and the JCB Plaza in Singapore
Carrying out your instructions or responding to any enquiry purporting to be given by you or on your behalf
Dealing in any matters relating to your JCB card
Carrying out due diligence or other screening activities (including background checks) in accordance with legal or regulatory obligations or our risk management procedures (including but not limited to those designed to combat financial crime, "know-your customer", anti-money laundering, counter-terrorist financing or anti-bribery), that may be required by law or that may have been put in place by us
Creation of records as to the business carried on by us
To prevent or investigate any fraud, unlawful activity or omission or misconduct, whether relating to your JCB card or any other matter arising from your JCB card, and whether or not there is any suspicion of the aforementioned
To perform data analytics or analysis that is reasonably necessary for us to provide, improve and/or assess the suitability of, your JCB card and JCB cardmember benefits, including but not limited to assessment of customer preferences or needs, or customer satisfaction
To carry out or perform, administrative, operational and technology tasks (including technology infrastructure maintenance and support, application maintenance and support, risk management, systems development and testing, and business continuity management, quality assurance surveys, and market customer satisfaction research)
Complying with or as required by any applicable law, governmental or regulatory requirements of any relevant jurisdiction; and
If consented by you, providing and sending you marketing, advertising and promotional information, materials and/or documents, via any communication to your postal or email addresses, or via electronic messages, SMSes, voice calls and/or facsimiles to your designated telephone numbers.
collectively, the "Purposes"
As the purposes for which we may/will collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of your personal data without your consent is permitted by the PDPA or by law.
Your personal data may be used, disclosed, maintained, accessed, processed and/or transferred to the following, whether sited in Singapore or outside of Singapore, for one or more of the Purposes:
JCB's headquarters, affiliates, subsidiaries and related companies
JCB's lawyers and auditors
Third party business establishments (including hotels, retail stores, restaurants, tour agencies, spas and ticketing companies)
JCB's vendors, agents, contractors or service providers who may from time to time be engaged to provide administrative, computer, data processing, telecommunications, booking, advertising, market research, payment or other services in connection with the Services; and
Public and governmental / regulatory authorities, statutory boards, industry associations; and
collectively, the "Permitted Parties"
3 SPECIFIC ISSUES FOR THE DISCLOSUREOF PERSONAL DATA TO THIRD PARTIES
We respect the confidentiality of the personal data you have provided to us.
In that regard, we will not disclose your personal data to third parties without first obtaining your consent permitting us to do so. However, please note that we may disclose your personal data to third parties without first obtaining your consent in certain situations, including, without limitation, the following :
Cases in which the disclosure is required or authorized based on the applicable laws and/or regulations
Cases in which the purpose of such disclosure is clearly in your interests, and if consent cannot be obtained in a timely way
Cases in which the disclosure is necessary to respond to an emergency that threatens the life, health or safety of yourself or another individual
Cases in which the disclosure is necessary for any investigation or proceedings
Cases in which the personal data is disclosed to any officer of a prescribed law enforcement agency, upon production of written authorisation signed by the head or director of that law enforcement agency or a person of a similar rank, certifying that the personal data is necessary for the purposes of the functions or duties of the officer
Cases in which the disclosure is to a public agency and such disclosure is necessary in the public interest; and/or
Where such disclosure without your consent is permitted by the PDPA or by law.
The instances listed above at paragraph [3.2] are not intended to be exhaustive. For more information on the exceptions, you are encouraged to peruse the Second, Third and Fourth Schedules of the PDPA which is publicly available at "http://statutes.agc.gov.sg."
Where we disclose your personal data to third parties with your consent, we will employ our best efforts to require such third parties to protect your personal data.
4 REQUEST FOR ACCESSAND/OR CORRECTION OF PERSONAL DATA
You may request to access and/or correct the personal data currently in our possession or control by submitting a written request to us. We will need enough information from you in order to ascertain your identity as well as the nature of your request, so as to be able to deal with your request. Hence, please submit your written request to our Data Protection Officer at the contact details below.
For a request to access personal data, once we have sufficient information from you to deal with the request, we will seek to provide you with the relevant personal data within 30 days. Where we are unable to respond to you within the said 30 days, we will notify you of the soonest possible time within which we can provide you with the information requested. Note that the PDPA exempts certain types of personal data from being subject to your access request.
For a request to correct personal data, once we have sufficient information from you to deal with the request, we will :
Correct your personal data within 30 days. Where we are unable to do so within the said 30 days, we will notify you of the soonest practicable time within which we can make the correction. Note that the PDPA exempts certain types of personal data from being subject to your correction request as well as provides for situation(s) when correction need not be made by us despite your request.; and
Subject to paragraph [4.4], we will send the corrected personal data to every other organisation to which the personal data was disclosed by JCB within a year before the date the correction was made, unless that other organisation does not need the corrected personal data for any legal or business purpose.
Notwithstanding paragraph [4.3(b)], we may, if you so consent, send the corrected personal data only to specific organisations to which the personal data was disclosed by us within a year before the date the correction was made.
We will also be charging you a reasonable fee for the handling and processing of your requests to access your personal data. We will provide you with a written estimate of the fee we will be charging. Please note that we are not required to respond to or deal with your access request unless you have agreed to pay the fee.
5 REQUEST TO WITHDRAW CONSENT
You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control by submitting your request to our Data Protection Officer at the contact details below.
We will process your request within a reasonable time from such a request for withdrawal of consent being made, and will thereafter not collect, use and/or disclose your personal data in the manner stated in your request.
However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal. In this regard, depending on the extent of your withdrawal of consent for us to process your personal data, it may mean that we will not be able to process your JCB card transactions and provide you with the JCB cardmember benefits.
6 ADMINISTRATION AND MANAGEMENTOF PERSONAL DATA
We will take reasonable efforts to ensure that your personal data is accurate and complete, if your personal data is likely to be used by JCB to make a decision that affects you, or disclosed to another organisation. However, this means that you must also update us of any changes in your personal data that you had initially provided us with. We will not be responsible for relying on inaccurate or incomplete personal data arising from your not updating us of any changes in your personal data that you had initially provided us with.
We will also put in place reasonable security arrangements to ensure that your personal data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorized access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data. However, we cannot assume responsibility for any unauthorized use of your personal data by third parties which are wholly attributable to factors beyond our control.
We will also put in place measures such that your personal data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes.
Where your personal data is to be transferred out of Singapore, we will comply with the PDPA in doing so. In this regard, this includes us obtaining your consent unless an exception under the PDPA or law applies, and taking appropriate steps to ascertain that the foreign recipient organisation of the personal data is bound by legally enforceable obligations to provide to the transferred personal data a standard of protection that is at least comparable to the protection under the Act. This may include us entering into an appropriate contract with the foreign recipient organisation dealing with the personal data transfer or permitting the personal data transfer without such a contract if the PDPA or law permits us to.
7 COMPLAINT PROCESS
If you have any complaint or grievance regarding about how we are handling your personal data or about how we are complying with the PDPA, we welcome you to contact us with your complaint or grievance.
Please contact us through one of the following methods with your complaint or grievance :
JCB International Asia Pacific Pte. Ltd.
Singapore telephone number : +65 67380321
E-mail : firstname.lastname@example.org Attention it to the 'Data Protection Officer'.
Office address : 230 Orchard Road #10-234/236 Faber House Singapore 238854. Attention it to the 'Data Protection Officer'
JCB International Co. Ltd.
Tokyo telephone number : +81 357787053
E-mail : email@example.com Attention it to the 'Data Protection Officer'.
Office address : 5-1-22, Minami Aoyama, Minato-ku, Tokyo 107-8686, Japan. Attention it to the 'Data Protection Officer'
Where it is an email or a letter through which you are submitting a complaint, your indication at the subject header that it is a PDPA complaint would assist us in attending to your complaint speedily by passing it on to the relevant staff in our organisation to handle. For example, you could insert the subject header as "PDPA Complaint".
We will certainly strive to deal with any complaint or grievance that you may have speedily and fairly.
8 UPDATES ON DATA PROTECTION POLICY
As part of our efforts to ensure that we properly manage, protect and process your personal data, we will be reviewing our policies, procedures and processes from time to time.
We reserve the right to amend the terms of this Data Protection Policy at our absolute discretion. Any amended Data Protection Policy will be notified.
July 29, 2014