The Singapore Personal Data Protection Act - 2012 (PDPA) establishes a data protection law that comprises various rules governing the collection, use, disclosure, and care of personal data. It recognizes both the rights of individuals to protect their personal data, including rights of access and correction, and the needs of organizations to collect, use, or disclose personal data for legitimate and reasonable purposes.
The PDPA takes into account the following concepts:
• Consent – Organizations may collect, use, or disclose personal data only with the individual’s knowledge and consent (with some exceptions);
• Purpose – Organizations may collect, use, or disclose personal data in an appropriate manner for the circumstances, and only if they have informed the individual of purposes for the collection, use, or disclosure; and
• Reasonableness – Organizations may collect, use, or disclose personal data only for purposes that would be considered appropriate to a reasonable person in the given circumstances. Consent
1. Types of Customer Data
The types of Customer Data that CULINARYON collects depends on the circumstances of collection and on the nature of the service requested or transaction undertaken.
There are two broad categories of Customer Data that CULINARYON collects:
1. Personal Data, which includes but is not limited to:
(i) personal information that links back to an individual e.g., name, gender, date of birth, passport or other personal identification numbers;
(ii) contact information e.g., address, phone number, email address;
(iii) payment information e.g., credit or debit card information, including the name of cardholder, card number, billing address and expiry date;
(iv) attendance information e.g., course / event attendance information, dietary and other service preferences;
(v) health information e.g., food allergies or special food requests
(vi) technical information e.g., IP address; and
2. Statistical Data e.g., number of guests, hits to website.
This is stored purely for analytical purposes, and is entirely anonymous. This information will not be stored to your customer record, and will only be aggregated for statistical analysis so that we can better understand CULINARYON's customer profile and improve CULINARYON's service offering.
For purposes of this policy statement, the phrase Customer Data includes Personal Data and Statistical Data.
The provision of Customer Data (save for where the request for data is marked “optional” in the forms used to collect personal data) is obligatory in order for CULINARYON to carry out its services to you.
The failure to supply such Customer Data may result in:
(i) CULIANRYON being unable to provide you with the services and/or products requested;
(ii) CULINARYON being unable to update you on our latest products and/or launches; and/or
(iii) your inability to enter or participate in contests, promotions or redemption activities organized by CULINARYON.
2. Purposes for Collection, Use and Disclosure
Generally, CULINARYON collects Customer Data, either directly from you or from your authorized representatives (i.e. persons whom you have authorized, persons who have been validly identified as being you or your authorized representative), from third parties (e.g., your employer or our service provider), or from publicly available sources, through our website, mobile services, and other channels, in order to fulfill the following purposes, which include but are not limited to:
- Providing services to you such as processing a transaction (e.g. booking a class / event); providing technical assistance during booking, providing alert messages about our services (e.g. event cancellation, modified time schedule, change in menu or chef), facilitating iPad class registration;
- Providing services during our events that best meet your preferences and needs;
- Marketing and communicating with you in relation to products and services offered by CULINARYON and CULINARYON's agents;
- Contacting you for product and customers satisfaction surveys and market research; and
- Safety, security and legal compliance;
CULINARYON may also use and disclose your Customer Data with and to third parties in order to fulfill the purposes listed above.
In connection with the above, we may disclose your Customer Data to third parties, such as our sales / marketing agents and freight service providers or food and beverage related businesses or technical partner companies.
In addition, CULINARYON may disclose Customer Data to our legal advisors for establishing, exercising or defending our legal rights, to our other professional advisors, or as otherwise authorized or required by law. Further, CULINARYON may disclose Customer Data, as is necessary, to investigate suspected unlawful activities including but not limited to fraud, intellectual property infringement or privacy.
3. Transfer of information overseas
CULIANRYON Head office is based in Singapore. Customer data may be transmitted to data storage facilities where CULIANRYON keeps it's central records.
You might submit a request to withdraw your consent at any time by contacting CULINARYON.
Statistical data is not linked to customer record and CULINARYON does not need to seek consent for the collection and usage of Customer Data obtained from CULINARYON's website and through CULINARYON Mobile Service and mobile application, please refer to part B.
CULINARYON reserves the right to charge a reasonable administrative fee for this service.
When destroying Customer Data, we will take commercially reasonable and technically possible measures to make the personal information irrecoverable or irreproducible in accordance with the applicable laws.
CULINARYON needs your assistance to ensure that your Personal Data is current, complete and accurate. As such, please inform CULINARYON of changes to your Personal Data by contacting CULINARYON and submitting your updated particulars to CULINARYON in writing (see Section 10). If you are a CULINARYON loyalty card or you are a registered website user, you may update your Personal Data at any time by logging on to your website account with CULINARYON.
8. Security Safeguards
As an example of a procedural safeguard, CULINARYON has implemented various authentication procedures internally and with our external service providers that may involve
CULINARYON requesting various personal particulars from you in order to verify your identity (or that of your duly authorized agent) before CULINARYON processes your request for a particular service, product or transaction.If, however, a customer does not take reasonable care to ensure the continued confidentiality and accuracy of their Customer Data, CULINARYON will not be liable for any consequential misuse and/or fraud. If you have any concerns about security, you should contact CULINARYON (see Section 10).
10. Contact Us
Cookies are small files placed on your computer by websites that you visit or certain emails you open.
Online behavioral advertising
Purposes of cookie collection and use
To enable the efficient working of the CULINARYON's websites, including but not limited to:
b) limiting traffic to key parts of the website in order to maintain performance levels; and
Cookies are used to make navigation easier for you, including but not limited to:
a) remembering your language and country selections and presenting relevant content;
b) keeping track of your Loyalty card membership number when you have logged in; and
c) providing the most relevant departure airport for your location when you are booking a flight.
Cookies are used to gather statistics on how you navigate and transact on our websites, including but not limited to:
a) gathering feedback on your satisfaction through a survey; and
b) gaining insight into how you navigate and transact on our websites so that improvements can be made to its usability.
Cookies are used to enable CULINARYON to present appropriate messages to you, including but not limited to:
a) allowing our websites to serve up different versions of a page for marketing purposes;
b) allowing third parties to display appropriate advertising and to track its effectiveness; and
c) displaying of relevant messages, which offer a selection of products based on your viewing behaviour on our websites and other selected websites.
3. Clickstream Data
In order to improve your online experience, CULINARYON may track online behaviour or clickstream data to advance your use of our web pages and track referrals from other websites. Such data will not be stored to your customer record, and will only be aggregated for statistical analysis.
CULINARYON cannot distinguish the age of persons who access and use its websites. If a minor (according to applicable laws) has provided CULINARYON with Customer Data without parental or guardian consent, the parent or guardian should contact CULINARYON (see Section 10 of Part A) to remove the relevant Customer Data and unsubscribe the minor.
6. Google Analytics