Campaigner Pte. Ltd. (“Campaigner”) collects information on its users when you sign up for an account, when using certain mobile applications and when you visit pages on www.campaignertech.com. When you register, we may ask you for information about you, including your first name, last name, email address, gender and birth year. Once you register with us, you are not anonymous to us.

Page visits or mobile application usage may also store information about your computer or mobile phone configuration such as your IP address, location, where you have executed transactions stored within the application, screens viewed within mobile applications, cookie information and the pages you have visited. Campaigner may use this information to help make changes to the service to better serve you and our users. We also use the information to customise content on the site or in our mobile platforms and to tailor offers displayed to you.

Campaigner may use this information to help make changes to the service to better serve you and our users. We also use the information to customise content on the site or in our mobile platforms and to tailor offers displayed to you.

If we cannot collect this data, we may be unable to on-board you as a client or provide products or services to you.

Our Privacy Policy explains: (i) how we store and use, and how you may access and correct your personal information; (ii) how you can lodge a complaint regarding the handling of your personal information; and (iii) how we will handle any complaint. If you would like any further information about our Privacy Policy or practices, please contact us at:

Campaigner Pte. Ltd. Data Protection Officer
Address: 16 Raffles Quay, Singapore 048581
E-mail: privacy@campaignertech.com

By providing your personal information to us, you consent to the collection, use, storage and disclosure of that information as described in the Privacy Policy and this collection notice.

Campaigner Personal Data Protection Policy

Campaigner Pte. Ltd. (“Campaigner”) is committed to the protection of your personal data. Campaigner collects, uses, discloses and retains your personal data in accordance with the Personal Data Protection Act 2012 (“PDPA”) and our own policies and procedures.

The purpose of this Data Protection Policy (“Policy”) is to inform you how Campaigner collects, uses, discloses and retains personal data. This Policy as part of our on-going commitment to the protection of your personal data.

When we act as a data processor on behalf of another controller, we collect, use, and disclose certain personal data only under the controller’s instruction, and our processing of your personal data is subject to their instructions and privacy policies.

Please note that links to third-party websites are subject to the third-parties’ privacy policies and terms of use, not ours, unless you are told otherwise. Also, some of Campaigner’s services are offered through third-parties, such as insurance companies or financial institutions. In those cases, the third-parties’ policies will govern their use of the personal data they process about their customers.

In this Policy, personal data refers to data, whether true or not, about an individual who can be
identified from:

• that data; or
• that data and other information to which Campaigner has, or is likely to have, access.

Where we collect your personal data to comply with law, or to enter into or perform an agreement with you, we will inform you at the time of such data collection. If we cannot collect this data, we may be unable to on-board you as a client or provide products or services to you.

1. Objectives

1. The objectives of this Policy are to:
   
2. provide a set of privacy and personal data protection standards that govern our procedures and protect the privacy of your personal data;
3. demonstrate our on-going commitment to protecting your privacy and addressing any privacy concerns that you might have;
4. describe the ways in which we collect, use, disclose and retain your data;
5. ensure that we comply with the PDPA; and
6. facilitate our compliance with any further developments in the protection of personal data.

2. Personal Data Protection Act 2012 (“PDPA”)

1. This information sets out how we collect, use, disclose and retain your personal data in accordance with the PDPA and how we administer this Policy.
   

3. Consent

1. 3.1. Consent Required
   
2. 3.1.1. Campaigner shall not collect, use, or disclose your personal data unless:
   
3. (a)you give, or are deemed to give, consent to the collection, use or disclosure of your personal data; or
   
4. (b)the collection, use, or disclosure of your personal data without your consent is required or authorised under the PDPA or written law.
   
5. We do not sell your personal data to third-parties.
   
6. 3.2. Provision of Consent
   
7. 3.2.1. Campaigner shall not, as a condition of providing a product or service to you, require you to consent to the collection, use or disclosure of your personal data beyond what is reasonable to provide the product or service to you.
   
8. 3.3. Deemed Consent
   
9. 3.3.1. You are deemed to consent to the collection, use or disclosure of your personal data for a purpose if:
   
10. (a)you voluntarily provide your personal data to Campaigner for that purpose, albeit without actually expressly providing your consent; and
    
11. (b)it is reasonable that you would voluntarily provide the data; or
    
12. (c)you create an account with us and use our loyalty system.
    
13. 3.3.2. Campaigner collects information about you when you sign up for an account, when using the mobile application, and when you visit pages on our websites. Campaigner may also collect information about you from other public websites or social networks. When you register with us, you are not anonymous to us. Page visits or mobile application usage may also store information about your computer or mobile phone configuration. This may include, for example, your IP address, location, the screens you have viewed, cookie information, and page requests
    
14. 3.3.3. You are deemed to consent to share your information with merchants listed on the Campaigner system or any new merchant that may subscribe to Campaigner subsequent to your use.
    
15. 3.3.4. If you subscribe to our newsletters, we will use your name and email address to send them to you. You may choose to stop receiving our newsletter or marketing emails at any time by following the unsubscribe instructions included in these emails or accessing the email preferences in your account.
    
16. 3.3.5. You consent to the placement of Cookies on your computer or mobile device created as a result of your use of or mobile application or web sites. Cookies are small files with a unique identifier that are transferred to your browser through our websites. These technologies allow us to collect information such as browser type, time spent on our websites, pages visited, language preferences, and your relationship with us. We can use this information to analyse trends, administer the website(s), track users’ movements around the website, measure the effectiveness of our communications, tailor our advertising to you, and gather demographic information about our user base as a whole. These technologies may provide us with information about devices and networks you utilise to access our services, and other information regarding your interactions with us and the services we offer.
    
17. 3.3.6. Subject to local law restrictions, we may disclose certain information (such as your email address) with third parties – such as Facebook so that we can better target ads and content to our users, and others with similar interests on these third parties’ platforms or networks (“Custom Audiences”). We may also work with third-party ad networks and marketing platforms that enable us and other participants to target ads to Custom Audiences submitted by us and others. Out websites may include social media features, such as the Facebook “Like” button, either hosted by a third-party or hosted directly on our website (“Widgets”). Please refer to the privacy policies of the relevant third-party websites or services to find out more about the collection, use, and disclosure of your information through such features. We will comply with any legal obligations placed on the use of these technologies by certain jurisdictions, which may affect how these Widgets function.
    
18. 3.4. Withdrawal of Consent
    
19. 3.4.1. On providing reasonable notice to Campaigner, you may at any time withdraw any consent given, or deemed to be given, in respect of the collection, use or disclosure of your personal data by Campaigner for any purpose.
    
20. 3.4.2. You may submit the withdrawal of consent via mail, email, or by selecting the provided options in our application.
    
21. 3.4.3. On receipt of such notice, Campaigner shall inform you of the likely consequences of withdrawing your consent.
    
22. 3.4.4. Please allow up to 30 days for Campaigner to process and update your request if delivered by mail or email. You may still receive marketing messages and other product information from Campaigner within these 30 days while we process your request.
    
23. 3.4.5. Campaigner shall not prohibit you from withdrawing your consent to the collection, use or disclosure of your personal data.
    
24. 3.4.6. If you withdraw your consent, then Campaigner shall cease collecting, using or disclosing your personal data unless otherwise required under the PDPA or other written law.
    
25. 3.4.7. Although you may have withdrawn consent for the collection, use or disclosure of your personal data, Campaigner may retain your personal data in accordance with Campaigner Records and Retention Policy.
    

4. Purpose Limitation Obligation

1. 4.1. Limitation of Purpose
   
2. 4.1.1. Campaigner shall collect, use or disclose your personal data only for purposes:
   
3. (a)that a reasonable person would consider appropriate in the circumstances; and
   
4. (b)where you have been informed in accordance to clause 3.2 of this Policy, to the extent applicable.
   
5. 4.1.2. Campaigner may use your personal data to help make changes to the service to better serve you and our users. We also use the information to customise content on the site or in our mobile applications to match offers to you to provide you better service.
   
6. 4.2. Notification of Purpose
   
7. 4.2.1. Campaigner shall provide you with the following information whenever we seek to obtain your consent to the collection, use or disclosure of your personal data, except under circumstances where your consent is deemed or is not required:
   
8. the Campaigner Terms and Conditions of Use on sign-up or before collecting your personal data;
   
9. any other purpose(s) for the use of your personal data of which you have not been informed under clause 3.2.1 of this Policy, before the use or disclosure of your personal data for that purpose; and
   
10. on request by you, the contact details of the Campaigner Data Protection Officer who can answer your questions about collection, use or disclosure of your personal data.
    
11. 4.3. Personal Data and Business Partners
    
12. 4.3.1 In accordance with clause 3.3, information may be shared with merchants. Campaigner does not assume liability or responsibility of how the information is used by the merchant
    

5. Accessing and correcting your personal data

1. 5.1. Access to Your Personal Data
   
2. 5.1.1. On your request, and subject to the restrictions set forth in the PDPA, Campaigner shall, as soon as reasonably possible, provide you with:
   
3. (a)your personal data that is in retained by or controlled by Campaigner; and
   
4. (b)information about the ways in which your personal data has or may have been used or disclosed by Campaigner within a year before the request.
   
5. 5.2. Correction of Your Personal Data
   
6. 5.2.1. You may request Campaigner correct an error or omission in your personal data that is under control or possession by Campaigner. Unless Campaigner is satisfied on reasonable grounds that a correction should not be made or the law states otherwise, Campaigner shall:
   
7. (a)correct your personal data as soon as practicable; and
   
8. (b)send your corrected personal data to every organisation to which your personal data was disclosed by Campaigner within a year before the correction was made, unless that other organisation does not need the corrected personal data for any legal or business purpose.
   
9. 5.2.2. Campaigner is not required to correct or alter an opinion, including professional or an expert opinion.
   

6. Protection Obligation

1. Campaigner shall protect personal data in its possession or control by making reasonable security arrangements such as encryption to prevent unauthorised access, collection, use, disclosing, copying, modification, disposal or any other similar risks.
   
2. The security of your personal data is important to us. We have implemented safeguards designed to protect the personal data submitted to us. Please note that no data transmission over the internet cannot be guaranteed to be 100% secure. As a result, we cannot guarantee or warrant the security of any personal data that we process.
   
3. Our website may contain links to websites operated by third parties. Those links are provided for convenience and may not remain current or be maintained. Unless expressly stated otherwise, we are not responsible for the privacy practices of, or any content on, those linked websites, and have no control over or rights in those linked websites. The privacy policies that apply to those other websites may differ substantially from our Policy, so we encourage individuals to read them before using those websites.
   

7. Retention Limitation

1. Campaigner shall cease to retain your personal data, or remove the means by which your personal data can be associated with you, as soon as it is reasonable to assume that:
   
2. the purpose for which your personal data was collected is no longer being served by retention of your personal data; and
3. retention is no longer necessary for legal or business purpose.

8. Transfer Limitation Obligation

1. Campaigner shall not transfer your personal data outside of Singapore except in accordance with the requirements of the PDPA.
   

9. Do Not Call Provisions

1. 9.1. Campaigner shall not send a specified message to a Singapore telephone number without first checking with the Do Not Call Registry established by the Personal Data Protection Commission (“PDPC”) and receiving confirmation from the PDPC that such Singapore telephone number is not listed on the Do Not Call Registers.
   
2. 9.2. Campaigner shall not, and ensure that its agents shall not, send a specified message to a Singapore telephone number, unless the specified message includes clear and accurate information identifying the person sending the specified message and/or Campaigner, and such person’s and/or contact information retained by Campaigner.
   
3. 9.3. The prescribed duration within which Campaigner must check with the Do Not Call Registry before sending a specified message to a Singapore telephone number will be 30 days.
   
4. You may continue to receive marketing messages and other product information from Campaigner within the prescribed validity period.
   
5. 9.4. Campaigner shall not require a subscriber or user of a Singapore telephone number to consent to the sending of a specified message beyond what is reasonable for Campaigner to provide its goods and services. Campaigner shall not obtain or attempt to obtain such consent by:
   
6. (a)providing false or misleading information; and
   
7. (b)using deceptive or misleading practices.
   
8. 9.5. If a subscriber or user of a Singapore telephone number gives notice withdrawing consent for the sending of a specified message to that number, then Campaigner shall cease (and cause its agents to cease) sending specified messages to that number.
   

10. Complaint Handling Procedure

1. 10.1. Should you be unhappy with our treatment of your personal data or you believe there has been a breach of this Policy, please contact the Campaigner Data Protection Officer (details in clause 13 below) and clearly set out the nature of your concern.
   
2. 10.2. Complaints may be initially made orally, or in writing. Where a complaint is made orally, you must confirm the complaint in writing as soon as possible. If you require assistance in lodging your complaint, please contact us.
   
3. 10.3. Your complaint will be reviewed and you will be provided with a written response within 15 working days.
   

11. Compliance with this Policy

1. 11.1. Campaigner implements this Policy through the use of proper procedures and staff training to ensure compliance with this Policy.
   
2. 11.2. We ensure that our employees and any representatives who deal with personal data are aware of the standards of this Policy.
   
3. 11.3. Campaigner requires that all of its employees and representatives with access to personal data maintain confidentiality concerning that personal data. We implement that requirement through appropriate contractual terms and internal policies.
   
4. 11.4. Our procedures for handling personal data are developed to implement the standards of this Policy. Campaigner trains its employees in the proper conduct of those procedures that are relevant to their duties.
   

12. Review of the Campaigner Data Protection Policy

1. 12.1. Campaigner ensures that this Policy remains current and continues to fulfil its objectives. This is achieved through periodical reviews, having regards to:
   
2. 12.1.(a) the need to actively consider privacy and data protection issues as new products and services are developed or offered;
   
3. 12.1.(b) any guidance issued in relation to PDPA; and
   
4. 12.1.(c) any changes to PDPA.
   
5. 12.2. Campaigner will provide a notification on our website when this Policy has been updated or changed.
   

13. Contact us

1. For further information about this Policy or to access our complaint handling procedures, please address your correspondence to:
   
2. Campaigner Pte. Ltd. Data Protection Officer
   Address: 16 Raffles Quay, Singapore 048581
   E-mail: privacy@campaignertech.com