This document (“DPP”) sets out the basis which Blue Sky Events Pte Ltd (including its related corporations and business units) (collectively, the “Companies”), as well as their respective agents and representatives (collectively referred to herein as “BSEPL”, “us”, “we” or “our”) may collect, use and/or disclose Personal Data (as defined below) as a result of your interaction with us whether through our website or in connection with any other transaction offline or otherwise, including but not limited to any products and services in connection with Christmas Wonderland, in accordance with the Singapore Personal Data Protection Act (No. 26 of 2012) (“the Act”). Please take a moment to read this DPP so that you know and understand how we may collect, use and/or transfer your Personal Data.
This DPP applies to Personal Data of individuals (“you” or “your”) in our possession or under our control, including Personal Data in the possession of organisations which we have engaged to collect, use and/or disclose Personal Data for our purposes.
This DPP 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 any of us may have at law to collect, use or disclose your Personal Data.
We may at our sole discretion from time to time update this DPP to ensure that this DPP is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements without any prior notice. Subject to your rights at law, your continued access and/or use of this website and/or our products and services after we update this DPP constitutes your acknowledgment of the revisions and your consent to abide and be bound by the prevailing terms of the DPP as updated from time to time on our website (http://www.christmaswonderland.sg).
Please check back regularly for updated information on the handling of your Personal Data.
HOW YOU GIVE YOUR CONSENT / AGREEMENT TO THIS DPP
By interacting with us, submitting information to us, you agree and consent to us collecting, using, and/or disclosing your Personal Data in the manner set forth in this DPP.
This DPP (i) is integrated and forms a part of any agreements governing your relationship with us (and so should be read in conjunction with those agreements), or (ii) is a condition under which we interact with you generally outside any agreement (including, in particular, where you provide or we collect Personal Data from you).
HOW WE COLLECT, USE OR DISCLOSE YOUR PERSONAL DATA
1. Personal Data
1.1 In this DPP, ‘Personal Data’ refers to any data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which we have or are likely to have access, including data in our records as may be updated from time to time.
1.2 Depending on the nature of your interaction with us, examples of Personal Data which we may collect from you include but is not limited to your name, identification number, telephone number, mailing address, email address, IP address, photographs, video and audio
recordings and any other information relating to any individuals which you have provided us, in any forms you may have submitted to us, or via any other forms of interaction you have with us.
2. Collection of Personal Data
2.1. Generally, we collect Personal Data through your interactions with us, including but not limited to the following ways:
2.1.1. when you contact us;
2.1.2. when you submit forms or applications to us;
2.1.3. when you submit queries or requests to us;
2.1.4. when you submit complaints or provide feedback;
2.1.5. when you respond to our request for additional Personal Data;
2.1.6. when you subscribe to our e-newsletter to receive latest information on the upcoming race or ask to be included in an email or other mailing list;
2.1.7. when you respond to our initiatives;
2.1.8. when you participate in our contests;
2.1.9. when you make bookings for tickets;
2.1.10. when you receive customer or technical support from us;
2.1.11. when you visit our websites (note: when you browse our website, you generally do so anonymously – but please see the section below on cookies – we do not at our website automatically collect Personal Data, including your email address unless you provide such information or login with your account credentials if we enable such features on our websites); and
2.1.12. when you submit your Personal Data to us for any other reasons.
2.2. If you provide us with any Personal Data relating to a third party (e.g. information of your dependent, spouse, children and/or parents), by submitting such information to us, you represent to us that you have obtained the consent of that third party to you providing us with their Personal Data for the respective purposes.
2.3. You further represent to us that all Personal Data submitted to us is at all times complete, accurate, true and correct. Failure on your part to ensure so may result in our inability to fulfil your requests and/or applications.
2.4. If you have provided your contact details and have indicated that you consent to receiving marketing or promotional information via such contact details, then from time to time, we may contact you using such contact details (including post, email, text, voice call and other electronic message (including SMS, MMS and WhatsApp)) with information about our and selected third parties’ products and services (including discounts and special offers).
2.5. We may also receive Personal Data regarding you from the following third parties and other sources, which are not exhaustive: our partners, agents, contractors or third party service providers (including ticketing service providers).
3. IP address and Cookies
3.1. An IP address is a number that is automatically assigned to your computer when you signed up with an Internet Service Provider. When you visit our website, your IP address is automatically logged in our server. We use your IP address to help diagnose problems with our server, and to administer our website. From your IP address, we may identify the general geographic area from which you are accessing our website however, we will not be able to pinpoint the exact geographic location from which you are accessing our website. Generally we do not link your IP address to anything that can enable us to identify you unless it is required by applicable laws and regulations.
4. Purposes for the Collection, Use and Disclosure of Your Personal Data
4.1. Generally, BSEPL collects, uses and discloses your Personal Data for the following purposes:
4.1.1. performing obligations in the course of or in connection with our products and services requested and/or accessed by you (including participating in the Christmas Wonderland lucky draws);
4.1.2. processing your instructions including processing your purchases or signups for services;
4.1.3. managing the administrative and business operations of BSEPL and complying with internal policies and procedures;
4.1.4. verification of identity;
4.1.5. managing your relationship with us;
4.1.6. matching any Personal Data held which relates to you for any of the purposes listed herein;
4.1.7. responding to, handling and processing queries, requests, applications, complaints and feedback from you;
4.1.8. maintaining the security of BSEPL premises (including but not limited to CCTV surveillance);
4.1.9. meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on BSEPL (including but not limited to disclosures to regulatory bodies, conducting audit checks, surveillance and investigation) and to assist in law enforcement and investigations by the relevant authorities;
4.1.10. detecting, preventing, investigating, or otherwise addressing fraud, security or technical issues associated with the services;
4.1.11. record keeping purposes where there are legal or business reasons for retaining such records;
4.1.12. legal purposes (including but not limited to drafting and reviewing documents, obtaining legal advice and facilitating dispute resolution);
4.1.13. sending you marketing communications including newsletters, notifications about new products and services, conducting surveys, advertising of similar products and services and event invitations, for which you have the right to unsubscribe from such marketing communications;
4.1.14. any other purposes for which you have provided your Personal Data; and
4.1.15. any other purposes which are reasonably related to the aforesaid.
4.2. In addition, BSEPL collects, uses and discloses your Personal Data for the following purposes depending on the nature of our relationship with you:
4.2.1. Without limiting the foregoing, if you are participating in a survey, BSEPL collects, uses and discloses your Personal Data such as your name, contact number / email address for the following purposes:
18.104.22.168. generating a report for survey findings for, and meeting requirements by, relevant government regulators, ministries, statutory boards, authorities or related associations, in connection with gauging interest level and reception for relevant initiatives;
22.214.171.124. (as part of voluntary opt-in via participation in the survey) inclusion of Personal Data for electronic direct mailers (‘EDMs’); and
126.96.36.199. purposes which are reasonably related to the aforesaid.
4.2.2. If you are a representative / employee of a corporate customer, BSEPL collects, uses and discloses your Personal Data such as your name, contact number, email address, address of you or your PIC (via, e.g. the booking forms at point of purchase of tickets) for the following purposes:
188.8.131.52. processing purchase, sale, and collection of tickets;
184.108.40.206. issuing invoices to the corporate customer;
220.127.116.11. establishing a record of purchases for the purposes of supporting customer service requests, facilitating the provision of services requested and maintaining our records and database so as to optimise work productivity;
18.104.22.168. facilitating the sending of newsletters / updates.
4.2.3. Without limiting the foregoing, if you are a contractor or service provider supplying products and services to / in connection with our F&B operations, BSEPL collects, uses and discloses Personal Data such as names, NRIC numbers, passport numbers:
22.214.171.124. of food handlers (and their certification), to meet and comply with regulatory certifications and other food and safety requirements;
126.96.36.199. mobile numbers, photographs, vehicle numbers of your staff for creating staff access passes or establishing security, including security clearance, authentication of credibility of staff, handling emergencies and police screening (including security auxiliary services);
188.8.131.52. mobile numbers and signatures of staff handling logistics (including deliveries) to confirm / facilitate deliveries, attend to accounting and billing requirements;
184.108.40.206. CVs, photographs and bank account numbers for persons providing hospitality services (and particulars of PICs) to administer contracts for / of services, handle payroll processes, facilitate registration of staff and manage accreditation for access to circuit park such as during race event days; and
220.127.116.11. for purposes which are reasonably related to the aforesaid.
4.2.4. Without limiting the foregoing, if you submit an application to us as a candidate for an employment or representative position, BSEPL collects, uses and discloses your Personal Data such as your contact details, curriculum vitae details (e.g. education and employment history), family background, banking information, for the following purposes:
18.104.22.168. conducting interviews;
22.214.171.124. processing your application (including pre-recruitment checks involving your qualifications);
126.96.36.199. providing or obtaining employee references and for background screening;
188.8.131.52. processing employment pass applications, visa applications and offer of employment;
184.108.40.206. facilitating payroll processes;
220.127.116.11. evaluating and assessing your suitability for the position applied for; and
18.104.22.168. purposes which are reasonably related to the aforesaid.
4.2.5. If you are a dependent of an existing employee of BSEPL, BSEPL collects, uses and discloses your Personal Data for the following purposes:
22.214.171.124. applying for dependent passes;
126.96.36.199. applying for long term social visit passes; and
188.8.131.52. purposes which are reasonably related to the aforesaid.
4.2.8. If you are a member of the public, participating in photographs and videography (whether on site at our events or otherwise), and the photo is taken at an event which is accessible to the public / or subject to invitation or attendance conditions which provide that consent is given for the taking of such photographs or videos, such photos and videos (and any other Personal Data which may be given to us by you), may be used by us for development / use in marketing collaterals (including brochures, electronic direct mailers, commercials etc).
4.3. Without limiting the foregoing, members of the public may also have opted in and participated or interacted with BSEPL’s marketing activities and initiatives such as signing up for e-newsletter subscription, participating in marketing contests, participating in our street videos / ‘activations’. If so, BSEPL may collect your Personal Data and for purposes as follows:
4.3.1. (for newsletters) your name and email address so as to manage subscriptions and forward news and updates;
4.3.2. (for marketing contests) your name, email address, country of residence (for fulfilment, profiling and to assist in verification of transactions), mailing address, photos, other information submitted as part of the contest terms so as to facilitate the administration of the contest, including verifying eligibility / compliance with contest terms, determining and contacting winners, and delivering prizes; and
4.3.3. (for street videos / on the ground ‘activations’) your name, email address, telephone number, photos or recordings submitted as part of the activation / videos for use in promotion (including publicity purposes), so as to market appropriate products, send you newsletters, facilitate exclusive previews to their context and maintain contact with you.
4.4. Without limiting the foregoing, where you have purchased tickets to BSEPL organised / related events, BSEPL may collect your Personal Data such as your bank account details, phone numbers, email addresses, credit card details, delivery address, nationality, country of residence, personal profiles such as gender and year of birth for purposes of the purchase, sale, invoicing, delivery, of tickets. In respect of some of the information requested such as nationality / country of residence, the purposes include to assist in fraud detection, and meeting legal and reporting requirements to relevant Singapore authorities.
4.5. In addition, where permitted under the Act, BSEPL may also collect, use and disclose your Personal Data as follows:
4.5.1. conducting analytics of our products and services;
4.5.2. organising promotional and corporate events;
4.5.3. (only when you have subscribed to them) sending you newsletters / e-newsletters;
4.5.4. (only when you have opted in to receive such updates) sending you updates about products, special offers, rewards, upcoming events, promotions, rewards, including those which we have identified may be of interest to you (including via telemarketing to such numbers as you may have provided to us, subject to your clear consent);
4.5.5. leads generation and management;
4.5.6. (in aggregate and therefore anonymously) for market research purposes, including to:
184.108.40.206. track activity on our websites, to publish trends and/or to improve usefulness and content;
220.127.116.11. understand and determine customer location, preferences and demographics;
18.104.22.168. review, develop and improve our products, services and also develop special offers and marketing programmes;
22.214.171.124. conduct internal analysis of the event demographics to tailor our marketing efforts in the different territories the following year; and
4.5.7. for any other purpose that we may notify to you and have your consent.
4.6. 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. By your continued access and/or use of such products and services or interactions with us, you consent to us collecting, using and disclosing your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.
4.7 The foregoing purposes may continue to apply even in situations where your relationship with us 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 any contract with you).
5. Disclosure of Personal Data
5.1. Generally, your Personal Data held by us shall be kept confidential. However, in order to provide you with effective and continuous products and services, for the purposes listed above (where applicable) and as permitted or required under applicable laws, your Personal Data may be disclosed to the following recipients (both situated within and outside of Singapore):
5.1.1. entities within BSEPL and our related corporations;
5.1.2. agents, contractors or third party service providers who provide operational services to BSEPL, such as courier services, telecommunications, information technology, payment, payroll, processing, training, market research, storage, archival or other services to BSEPL;
5.1.3. agents, contractors or third party service providers involved in your interaction with us, whether through our website or in connection with any other transaction offline or otherwise, including our participating partners of Christmas Wonderland;
5.1.4. 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) involving BSEPL;
5.1.5. external banks, credit card companies and their respective service providers;
5.1.6. our professional advisers such as financial advisors, auditors and lawyers;
5.1.7. persons or entities to whom we are under any obligation or otherwise required to make disclosure pursuant to legal process or legal or regulatory obligation or request, including relevant government regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority;
5.1.8. counterparties, billing organisations and their respective banks in relation to fund transfers and payments; and
5.1.9. any other party to whom you authorise us to disclose your Personal Data.
5.2. We will reasonably endeavour to ensure that any third party who receives your Personal Data from us shall handle such Personal Data in accordance with the Act.
5.3. Where we transfer your Personal Data to recipients outside of Singapore, 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 Act.
6. Contacting Us – Withdrawal of Consent, Access to and Correction of your Personal Data
6.1. If you:
6.1.1. have any questions or feedback relating to your Personal Data or this DPP;
6.1.2. would like to withdraw your consent to any use of your Personal Data as set out in this DPP; or
6.1.3. would like to obtain access and make corrections to your Personal Data records,
please contact BSEPL as follows:
Email: [email protected]
Write in: Blue Sky Events Pte Ltd
50 Cuscaden Road
#08-01 HPL House
6.2. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of your request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within of receiving it.
6.3. Whilst we respect your decision to withdraw your consent, please note that (depending on the nature and scope of your request), we may not be in a position to continue providing our products or services to you and this may affect the administration of any contractual relationship which you may have with us. All our legal rights and remedies in such event are expressly reserved.
6.4. Please note that the withdrawal of your consent does not affect our right to continue to collect, use and disclose Personal Data where such collection, use and disclosure without consent is permitted or required under applicable laws.
6.5. Please note that a reasonable fee may be charged for an access request, and we will notify you of such fee before processing your request. We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) 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 Act).