PDPA Privacy Policy

This Privacy Policy (the “Policy”) applies to the collection, use, and disclosure of an individual customer’s Personal Data (hereinafter defined) arising from goods and/or services offered by "Global Info Edge" (collectively referred to as “Global Info Edge").

1.1 This Policy statement provides information on the obligations and policies of "Global Info Edge" in respect of an individual customer’s Personal Data. "Global Info Edge" undertakes to use reasonable efforts in applying, where practicable, those principles and the processes set out herein to its operations.

1.2 "Global Info Edge"’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, "Global Info Edge". "Global Info Edge" shall use reasonable endeavours to ensure that all collection and/or storage and/or disclosure and/or usage of Personal Data by "Global Info Edge" shall be done in an appropriate manner and in accordance with the Act and this Policy.

1.3 By interacting with us, submitting information to us, or signing up for any products or services offered by us, you agree and consent to "Global Info Edge" as well as to its respective representatives and/or agents (“Representatives”) (collectively referred to herein as “JS”, “JS-Solutions”, “us”, “we” or “our”) collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to "Global Info Edge"’s authorized service providers and relevant third parties in the manner set forth in this Privacy Statement.

1.4 This Policy supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your Personal Data, and your consents herein are additional to any rights which we may have at law to collect, use or disclose your Personal Data.

1.5 For the purposes of this Policy, in line with the provisions under The Personal Data Protection Bill, 2019 was introduced in Lok Sabha by the Minister of Electronics and Information Technology, Mr Ravi Shankar Prasad, on December 11, 2019. The Bill seeks to provide for the protection of the personal data of individuals and establishes a Data Protection Authority for the same. 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 which an organization has or is likely to have access. Such Personal Data shall also refer to that which is already in the possession of "Global Info Edge" or that which shall be collected by "Global Info Edge" in the future.

2.1 Where you legitimately request access to and/or correction of Personal Data relating to you, such Personal Data which is in the possession and control of "Global Info Edge", "Global Info Edge" shall provide and/or correct that data within 30 days and in a manner in accordance with its standard procedures as stated hereinafter.

2.2 In accordance with the Act, "Global Info Edge" 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 "Global Info Edge" receives your complaints and inquiries, please send the same via email to the Data Protection Officer (the “DPO”) of "Global Info Edge" at the following email address: [email protected].

2.3 Please note that if your personal data has been provided to us by a third party (e.g. a member via a referral process), you should contact that individual to make such queries, complaints, and access and correction requests to "Global Info Edge" on your behalf.

2.4 Should you not wish "Global Info Edge" 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 "Global Info Edge", 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 30 days. Please note however that this may affect our ability to attend to your needs in the event where there is already an existing business relationship.

Types of Personal Data Collected:

3.1 As part of its day-to-day activity, "Global Info Edge" may collect from you, through various means, including via our websites, marketing events such as lucky draws and contests, social networking sites, and any forms used by "Global Info Edge" from time to time, some or all of the following Personal Data used by "Global Info Edge" from time to time, some or all of the following Personal Data:

We use cookies on our websites to track website visitorship and experience. Most web browsers are designed to accept cookies. If you do not wish to receive any cookies, you may set your browser to refuse it.

Purpose of Collection of Personal Data

3.2 The above Personal Data mentioned in Clause 3.1 is collected for the purposes of: amongst others, conducting data/market research, analysis, and evaluation, providing benefits and/or compensation, processing payment, and providing you with any goods and/or services, marketing and communication, delivery of products and services, accounting and auditing, investigating complaints, claims, and disputes, responding to inquiries and provide customer services, as well as verification of the identity of clients.

Disclosure of Personal Data

3.3 In order to carry out the functions described above, "Global Info Edge" may, from time to time, disclose your Personal Data between "Global Info Edge"’s companies.

3.4 Without derogating from any of the above, "Global Info Edge" may also disclose the data subject’s Personal Data to third parties such as accounting firms; embassies; service providers; lawyers; credit, debit, and charge card companies, banks, and other entities processing payment; potential buyers or investors of "Global Info Edge" or any of "Global Info Edge"’s companies; and any agent or subcontractor providing services on "Global Info Edge"’s behalf for the provision of "Global Info Edge"’s services.

3.6 In some instances, you may also be requested to provide certain Personal Data that may be used to further improve "Global Info Edge"’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 personalized service, or provision of a product or dependent on your providing all requested data, failure to provide the requested data may prevent "Global Info Edge" from providing the service to you. This type of data includes, but is not limited to:

3.7 Under certain circumstances, telephone calls made to any of "Global Info Edge"’s companies to order and/or service hotlines and/or inquiry telephone numbers may be recorded for the purposes of quality control and training. In such an event, by agreeing to this Policy, you hereby give your consent for the collection, use, and disclosure of such Personal Data for the purposes of our records, following up with your inquiry and/or transaction, and for quality control and training purposes.

Your Personal Data may be processed by "Global Info Edge", its affiliates, agents, and third parties providing services to "Global Info Edge", in jurisdictions outside of Singapore. In this event "Global Info Edge" will comply with the terms of the Act.

Where possible, "Global Info Edge" will validate data provided using generally accepted practices and guidelines. This includes the use of checksum verification on some numeric fields such as account numbers or credit card numbers. In some instances, "Global Info Edge" is able to validate the data provided against pre-existing data held by "Global Info Edge". In some cases, "Global Info Edge" 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 "Global Info Edge", 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 provided in Section 2.2.

"Global Info Edge" 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 "Global Info Edge", other than to you or as described in this Policy. However, "Global Info Edge" cannot ensure or warrant the security of any information you transmit to "Global Info Edge" and you do so entirely at your own risk. In particular, "Global Info Edge" does not warrant that such information may not be accessed, altered, collected, copied, destroyed, disposed of, disclosed, or modified by breach of any of "Global Info Edge"’s physical, technical, or managerial safeguards.

7.1 In accordance with Clause 2.1 of this Policy, you have the right to:

a) check whether "Global Info Edge" holds any Personal Data relating to you and, if so, obtain copies of such data;

and

b) require "Global Info Edge" to correct any Personal Data relating to you which is inaccurate for the purpose for which it is being used.

7.2 "Global Info Edge" reserves the right to charge a reasonable administrative fee in order to meet your requests under Clause 7.1(a). Upon payment of the requisite fee under Clause 7.1(a) and/or receipt of your request under Clause 7.1(b), your request shall be processed within 30 days.

7.3 If you wish to verify the details you have submitted to "Global Info Edge" or if you wish to check on the manner in which "Global Info Edge" uses and processes your personal data, "Global Info Edge"’s security procedures mean that "Global Info Edge" 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 that "Global Info Edge" takes in response to a request from someone using your [membership] details. We would strongly recommend when you log in to your online account on our websites 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.

"Global Info Edge" will delete, as reasonably possible, or otherwise anonymous any Personal Data in the event that the Personal Data is not required for any reasonable business or legal purposes of "Global Info Edge" and where the Personal Data is deleted from "Global Info Edge"’s electronic, manual, and other filing systems in accordance with "Global Info Edge"’s internal procedures and/or other agreements.

To the extent that any of the communication means which you have provided "Global Info Edge" with (which may include, your telephone number and fax number) is/will be listed on the Do Not Call Registry (the “DNC”), by indicating on the Booking Form, or by any other means of indication, you hereby grant "Global Info Edge" your clear and unambiguous consent to contact you using all of your communication means you have provided to "Global Info Edge" including using via voice calls, SMS, Whatsapp, MMS, fax or other similar communications applications or methods, for the purposes as stated above in Paragraph 3.2. This will ensure your continued enjoyment of "Global Info Edge"’s promotional rates and services.

"Global Info Edge" reserves the right to alter any of the clauses contained herein in compliance with local legislation, and for any other purpose deemed reasonably necessary by "Global Info Edge". 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.

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 India courts.

12.1 This Policy only applies to the collection and use of Personal Data by "Global Info Edge". It does not cover third-party sites to which we provide links, even if such sites are co-branded with our logo. "Global Info Edge" does not share your Personal Data with third-party websites. "Global Info Edge" 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 "Global Info Edge" 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 "Global Info Edge"’s website.

12.3 "Global Info Edge"’s websites do not target and are not intended to attract children under the age of 18 years old. "Global Info Edge" does not knowingly solicit personal information from children under the age of 18 years old or send them requests for personal data.