Last updated: 2 April 2023
This Data Protection Notice (“Notice”) sets out the basis which Klobbi Pte. Ltd. (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of our customers in accordance with the Personal Data Protection Act (“PDPA”). This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.
Here at Klobbi Pte. Ltd., we take just as much pride in providing you with data protection. This notice is to inform you on our adherence to the obligations of the PDPA as well as the steps we have taken to provide security and protection for the data you have provided. This notice will also be taken as deemed consent unless otherwise stated.
4. We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law)
5. We may collect and use your personal data for any or all of the following purposes:
a. Performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
b. verifying your identity;
c. responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
d. managing your relationship with us;
e. processing payment or credit transactions;
f. complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
g. any other purposes for which you have provided the information;
h. transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, any other purposes for which you have provided the information;
i. any other incidental business purposes related to or in connection with the above; and
j. offerings of new services that may continue to provide benefit in relation to the services requested by you or recommended by us;
k. providing you with regular or ad-hoc updates, information required for your services update, upgrade, enhancement and their respective applications;
l. processing of insurance applications meant for the coverage and safety during the delivery of our respective services;
m. submission and application for funding and certification processes to professional bodies;
n. website visitor traffic and informatics via cookies stored on our website https://www.klobbi.com/
6. We may disclose your personal data:
a. where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods and services requested by you;
b. to third party service providers, agents and other organisations we have engaged to perform any of the functions with reference to the above-mentioned purposes; or
c. complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority.
7. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under a contract with you).
8. In compliance with the PDPA, we may collect, use or disclose your personal data without your consent for the legitimate interests of Klobbi Pte. Ltd. or another person. In relying on the legitimate interests exception of the PDPA, Klobbi Pte. Ltd. will assess the likely adverse effects on the individual and determine that the legitimate interests outweigh any adverse effect.
9. In line with the legitimate interests’ exception, we will collect, use or disclose your personal data for the following purposes:
a. NIL
The purposes listed in the above clause may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter.
14. If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
15. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
16. We will respond to your request as soon as reasonably possible. In general, our response will be within seven (7) business days. Should we not be able to respond to your request within fourteen (14) days after receiving your request, we will inform you in writing within fourteen (14) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).
18. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as authentication and access controls (such as good password practices, need-to-basis for data disclosure, etc.), encryption of data, up-to-date antivirus protection, regular patching of operating system and other software, securely erase storage media in devices before disposal, web security measures against risks, usage of one time password(OTP)/2 factor authentication (2FA)/multi-factor authentication (MFA) to secure access, security review and testing performed regularly, credential exposure checks, and device vulnerability assessments and security hardening.
19. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
22. We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.
Name of DPO : Devesh Gurbani
Contact No. : 8725 9789
Email Address : dataprotection@klobbi.com
Effective date : 19/05/23
Last updated : 19/05/23
