Privacy Policy

Your privacy is important to us. The purpose of this Privacy Policy is to inform you of how we handle or process your personal data in accordance with the Personal Data Protection Act 2012 (“the Act”). Please take a moment to read this Privacy Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data.

By interacting with us, submitting information to us or signing up for any promotions or services offered by us, you agree and consent to GINA, its related corporations and affiliates, and their respective successors-in-title as well as our respective representatives (collectively referred to herein as "GINA", "us", "we" or "our" and each) collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to GINA’s authorised service providers and relevant third parties in the manner and for any of the purposes set forth in this Privacy Policy. In addition, this Privacy Policy will also provide you with more information on the bases upon which we may lawfully collect, use and/or disclose your Personal Data without your consent, where permitted by applicable law.

This Privacy Policy supplements but does not supersede nor replace any other consents you may have previously provided to GINA nor does it affect any rights which GINA may have at law in connection with the collection, use or disclosure of your Personal Data, and any consents you may have provided in connection with this Privacy Policy are cumulative and additional to any rights which we may have under applicable law to handle or process your Personal Data.

We reserve the right to update or modify this Privacy Policy from time to time, and send you notification of updates to this Privacy Policy in any form as we may deem appropriate. While you should regularly check this Privacy Policy, we may also inform you of how we process your Personal Data by publishing (or amending) this Privacy Policy and, where required by applicable law, by posting a notice, or reaching you via other forms of communication (e.g. sending you an SMS message or email) based on the contact particulars that we may have of you in our records from time to time. You may also contact us in the manner disclosed in this Privacy Policy to learn about our handling or processing of your Personal Data.

To the maximum extent permissible under applicable law, you agree to be bound by the prevailing terms of the Privacy Policy as updated from time to time on our websites and/or as you may be notified. Hence, please check regularly for updated information on the handling of your Personal Data.

For avoidance of doubt, this Privacy Policy forms a part of the GINA Terms and Conditions ("Terms & Conditions"). In the event of any conflict, inconsistency or conflict between this Privacy Policy and the Terms and Conditions, the Privacy Policy shall prevail. All defined terms contained in Terms and Conditions shall apply to this Privacy Policy unless otherwise specifically stated.

1. Personal Data

1.1. In this Privacy Policy, "Personal Data" refers to any data or information about you from which you can be identified either (a) from that data; or (b)from that data and other information to which we have or are likely

(a) your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address, marital status, gender, date of birth, profession and any other information relating to you which you have provided us in any forms you may have submitted to us, or in other forms of interaction with you;

(b) information about your use of our Site and/or Chatbot, including cookies, IP address and rewards application details, but only to the extent that we may identify you from such information;

(d) your payment related information, such as your PayNow account information; and

(e) information about your usage of and interaction with our Chatbot including any electronic devices and connection information, device capability, bandwidth, statistics on page views, and traffic to and from our Site.

2. Collection of Personal Data

2.1. Generally, we collect your Personal Data in the following ways:

(a) when you submit forms or other documents relating to any of our products or services;

(b) when use any of our Services on Chatbot owned or operated by us;

(d) when you use some of our services;

(e) when you establish any online accounts with us;

(f) when you request that we contact you;

(g) when you are contacted by, and respond to, our marketing representatives, agents and other service providers;

(h) when you respond to our request for additional Personal Data

(i) when you ask to be included in an email or other mailing list;

(j) when you respond to our promotions and other initiatives;

(k) when you submit a job application or a scholarship application;

(l) when we receive references from business partners and third parties, for example, where you have been referred by them;

(m) when you submit your Personal Data to us for any other reason.

2.2 When you browse/use our Site and/or Chatbot, you generally do so anonymously but please see the section below on cookies and other related technologies which we have implemented on our Site and/or Chatbot. We do not, at our Site and/or Chatbot, automatically collect Personal Data unless you provide such information to us.

2.3. If you provide us with any Personal Data relating to a third party (e.g. information of spouse, children, parents, employees and/or authorised representatives), by submitting such information to us, you represent to us that you have obtained the consent of the third party to you providing us with their Personal Data for the respective purposes.

2.4 You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with products and services you have requested, or processing any requests and applications you may have made to us.

3. Purposes for the Collection, Use and Disclosure of Your Personal Data

3.1. Generally, we collects, uses and discloses your Personal Data for the following purposes:

(a) responding to, processing and handling your queries, requests, complaints and feedback;

(b) managing the infrastructure and business operations of GINA and complying with internal policies and procedures;

(d) matching any Personal Data held which relates to you for any of the purposes listed herein;

(e) verifying your identity;

(f) preventing, detecting and investigating crime, including fraud and money-laundering, and analyzing and managing other commercial risks;

(g) protecting and enforcing our contractual and legal rights and obligations;

(h) conducting audits, reviews and analysis of our internal processes, action planning and managing commercial risks;

(i) preventing, detecting and investigating crime and managing the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances);

(j) compliance with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities; and/or

(k) any other purpose relating to or reasonably necessary for any of the above.

3.2. In addition, where permitted under the applicable laws, we may also collect, use and disclose your Personal Data, and share your Personal Data with GINA’s business partners, service providers and/or other third parties for the following purposes (which we may describe in our documents and agreements as "Additional Purposes" for the handling of Personal Data):

(a) providing services, products and benefits to you, including promotions, loyalty and reward programmes;

(b) matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision or offering of products and services, whether by GINA or other third parties;

(c) administering contests, competitions and conducting lucky draws, including, where necessary, in order to announce the results of these contests, competitions and lucky draws and identify and contact the winners, and in order to publicise and conduct marketing strictly related to these contests, competitions and lucky draws;

(d) sending you details of products, services, special offers and rewards, either to our customers generally, or of particular products and services, special offers and rewards which may be of interest to you; and

(e) conducting market research, data analytics, understanding and determining customer location, preferences and demographics for us, our service providers and/or other third parties to develop insights into the industry, review, develop and improve our, our business partners', service providers' and/or other third parties' products, services and also develop special offers and marketing programmes on an anonymous basis.

3.3. In relation to particular products or services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, then we will collect, use and disclose your Personal Data for these purposes as well.

3.4. You may withdraw your consent for receiving marketing or promotional materials/communication by contacting us at contactus@gina.sg. Once we receive confirmation that you wish to withdraw your consent for marketing or promotional materials/communication, it may take up to 30 calendar days for your withdrawal to be reflected in our systems. Therefore, you may still receive marketing or promotional materials/communication during this period of time. Please note that even if you withdraw your consent for the receipt of marketing or promotional materials, we may still contact you for other purposes in relation to the products and services that you have requested or purchased from GINA.

3.5. For the same purposes, and the provision of goods and services by such counterpart(ies) following such transaction, as may be relevant.

4. Disclosure of Personal Data

4.1. We will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, this Personal Data may be disclosed, for the purposes listed above (where applicable), to the following third parties, whether they are located overseas or in Singapore:

(a) our affiliates;

(b) agents, contractors or third party service providers who provide operational services to GINA, such as telecommunications, information technology, payment, payroll, processing, training, market research, storage, archival or other services to GINA;

(c) vendors or any third party business partners who offer goods and services or sponsor contests or other promotional programs on our sites and/or Chatbot, whether in conjunction with us or not;

(d) external business and charity partners in relation to corporate promotional events;

(e) the Credit Bureau, or in the event of default or disputes, any debt collection agencies or dispute resolution centres;

(f) any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale);

(g) anyone to whom we transfer or may transfer our rights and duties;

(h) banks and their respective service providers;

(i) our professional advisors such as our auditors and lawyers;

(j) relevant government regulators or authority or law enforcement agency to comply with any laws or rules and regulations imposed by any governmental authority; and

(k) any other party to whom you authorise us to disclose your personal data.

5. Deemed Consent

5.1. In addition to the matters set forth above, subject to and in accordance with applicable law, you shall be deemed to have consented to GINA collecting, using, disclosing and sharing amongst ourselves your Personal Data, and disclosing such Personal Data to GINA's authorised service providers and relevant third parties:

(a) where in response to a request for your Personal Data in connection with identified purposes, you voluntarily provide such Personal Data to GINA for such purpose(s);

(b) where the collection, use or disclosure of your Personal Data is reasonably necessary for the conclusion and/or performance of a contract between you and us or any other organisation entered into at your request, which may include recipients of your Personal Data not indicated in this Privacy Policy; or

(c) where we have brought to your attention our intention to collect, use or disclose your personal data for identified purposes, and you have not taken any action to opt out within the period specified in our notices. For this purpose, you agree that we may provide you such notices via the Site, or via other forms of communication (e.g. SMS or email) based on the contact particulars that we may have of you in our records from time to time.

6. Other Bases for Handling or Processing Your Personal Data

6.1. In addition to and without limiting the consents you have provided to our collection, use and disclosure of your Personal Data for the purposes set out elsewhere in this Privacy Policy, where permitted by applicable law, GINA may also in accordance with the requirements thereof also collect, use and/or disclose your Personal Data as further detailed below including without your further consent, where we meet the requirements of applicable law:

(a) for our legitimate interests or the legitimate interests of any other person, including but not limited to the purposes expressly set forth in this Privacy Policy; or

(b) for improving our products, services, processes or business, understanding customer preferences and personalising experiences and recommendations, based on your Personal Data records with any GINA Companies (regardless whether you are an existing or prospective customer of any GINA Companies).

7. Use of Cookies and Related Technologies

7.1. When you interact with us on our Chatbot or Services, we may collect or analyse anonymised information from which individuals cannot be identified ("Aggregate Information"), such as number of users and their frequency of use, the number of page views (or page impressions) that occur on the website and common entry and exit points into website.

7.2. GINA uses cookies, and other related technologies which have different functions. They are either necessary for the functioning of our services, help us improve our performance, or serve to provide you with extra functionalities.

Cookies – Small data file which is sent to your browser to store and track Aggregate Information about you when you enter our websites. The cookie is used to track information such as the number of users and their frequency of use, profiles of users and their preferred sites.

Cookies can be disabled or removed by tools that are available in most commercial browsers. The preferences for each browser you use will need to be set separately and different browsers offer different functionality and options.

Web beacons - Small graphic images (also known as "pixel tags" or "clear GIFs") that are not apparent to the user. Tracking links and/or similar technologies consist of a few lines of programming code and can be embedded in our websites or platforms. Web beacons are usually used in conjunction with cookies and primarily used for statistical analysis purposes. This technology can also be used for tracking traffic patterns on websites and platforms, as well as finding out if an e-mail has been received and opened and to see if there has been any response.

7.3. We may use the terms "cookies" or "related technologies" interchangeably in our policies to refer to all technologies that we may use to collect or store information in your browser or device or that collect information or assist in identifying you as a unique user in the manner described above

7.4. GINA may use an independent company (the "Third Party Market Research Company") to measure and analyse the Internet usage across the Site and/or the Chatbot. GINA uses the Third Party Market Research Company's services to collect the following core information on the usage of our websites, including:

(a) The number of page views (or page impressions) that occur on GINA websites;

(b) The number of unique visitors to the Site;

(d) Common entry and exit points into the Site.

7.5. This information is aggregated by the Third Party Market Research Company and provided to GINA to assist in analysing the usage of GINA Site and/or Chatbot. Such data is also accessible by media organizations and research companies, for the purpose of conducting industry comparisons with other Internet portals.

7.6. Pages on GINA Site may be coded with software which enables the Third Party Market Research Company to track visitors to our websites.

7.7. Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser. However, you may not be able to enter certain part(s) of our Site.

8. Third-Party Sites

8.1. Our Site and/or our Chatbot may contain links to other websites operated by third parties, such as our business partners. We are not responsible for the privacy practices of websites operated by third parties that are linked to our Site. We encourage you to learn about the privacy policies of such third party websites. Some of these third party websites may be co-branded with our logo or trademark, even though they are not operated or maintained by us. Once you have left our Site, you should check the applicable terms, conditions and policies of the third party website to determine how they will handle any information they collect from you.

9. Withdrawal, Access and Correction of your Personal Data

9.1. Should you wish to withdraw consent to use of your Personal Data or obtain access to or make corrections to your Personal Data records, please log in to the relevant account through which the Personal Data was provided, if any, failing which please contact the relevant Personal Data Protection Officer, contact details of which are found in the Personal Data Protection Statement or similar document elsewhere on the relevant GINA Site.

9.2. Please note that if your Personal Data has been provided to us by a third party, you should contact such third party directly to make any queries, feedback, and access and/or correction requests to GINA on your behalf.

9.3. Please note that if you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, GINA may not be in a position to continue to provide its products or services to you or administer any contractual relationship in place, and this may also result in the termination of any agreements with GINA and your being in breach of your contractual obligations or undertakings, and GINA's legal rights and remedies in such event are expressly reserved.

10. Governing Law

10.1. This Privacy Policy shall be governed in all respects by the laws of Singapore.

(Updated as of July 8, 2022)