We at Mount Faber Leisure Group Pte. Ltd (“MFLG”), take our responsibilities under Singapore’s Personal Data Protection Act 2012 (the “PDPA”) and complying with all appropriate legislation, seriously. We also recognize the importance of the Personal Data You have entrusted to us and believe that it is our responsibility to properly manage, protect and process your Personal Data.
This Policy is applicable on You when You access and use our website, use our service and facilities or visit us at our premises. By accessing and/ or using our website and/ or facilities in MFLG, You signify your acceptance of the Policy and expressly consent to our collection, use, disclosure, and retention of your Personal Data as described in this Policy. If you do not wish for your personal data to be collected and used in compliance with Singapore PDPC, we kindly request that you do not use our website or submit any personal data to us.
Where Personal Data is submitted by You on behalf of another individual or concerns another individual other than yourself (or, in situations where You represent your company or organisation and submit the Personal Data to us), You represent and warrant to us, that all the necessary consents (procured in accordance with all applicable data protection legislation) have been obtained from the relevant individuals and that You have retained proof of these consents, such proof to be provided to us upon our request
If you, at any time, have any queries on this Policy or any other queries in relation to how we may manage, protect and/or process your Personal Data, please do not hesitate to contact our Data Protection Officer (the “DPO”) at [email protected].
1.1 “Personal Data” is defined under the PDPA to mean data, where true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access.
1.2 We will collect your Personal Data in accordance with the PDPA. We will notify you of the purposes for which your Personal Data may be collected, used, disclosed, and/or processed, as well as obtain your consent for the collection, use, disclosure and/or processing of your Personal Data for the intended purposes, unless an exception under the law permits us to collect and process your Personal Data without your consent.
2.1 The Personal Data which we collect from You may be collected, used, disclosed and/ or processed for various purposes, depending on the circumstances for which we may/ will need to process your Personal Data, including:
(a) evaluating and/or processing your Faber Licence Membership application whereby You will be given access to possible rewards, discounts, privileges, promotions, offers, services and/or products offered by MFLG, MFLG’s related corporations or associated companies, as well as partners, merchants and/or third party organisations with whom MFLG may collaborate, partner or tie up with (collectively the “Member Benefits”)( MFLG’s related corporations or associated companies, as well as partners, merchants and/or third party organisations with whom MFLG may collaborate, partner or tie up shall be referred to as “MFLG Partners”);
(b) administering, dealing with, managing and/or maintaining your Faber Licence Membership with MFLG including but not limited to administering and dealing with your Member Benefits, sharing your Personal Data with MFLG Partners to administer and deal with Member Benefits, contacting You through various modes of communication such as via phone/voice call, text message and/or fax message, email and/or postal mail for such purposes, dealing in any matters relating to your membership (including the mailing of correspondence, statements, information, invoices, or notices to you, which could involve disclosure of certain Personal Data about You to bring about delivery of the same), performing internal administrative, operational and technology tasks for the said purposes, storage and/or backup of your Personal Data;
(c) administering, dealing with and/or managing your purchases and/or bookings on our websites;
(d) providing and sending You marketing, advertising and/or promotional information and materials relating to Member Benefits as well as products, attractions, events and/or services that MFLG or MFLG Partners may be selling, marketing, offering and/or promoting, on Sentosa island and Mount Faber Peak Singapore, via various modes of communication such as (a) postal mail to your postal address(es) and/or electronic transmission to your email address(es) and (b) via telephone/voice calls, SMS/MMS and/or facsimile to your telephone number(s);
(e) dealing with or facilitating customer service and reservations, carrying out your instructions, or dealing with or responding to any enquiries given by You or on your behalf;
(f) complying with or as required by any applicable law, governmental or regulatory requirements of any relevant jurisdiction, including meeting the requirements to make disclosure under the requirements of any law binding on MFLG or on MFLG’s related corporations or associated companies (such as the Sentosa Development Corporation) and for the purposes of any guidelines issued by regulatory or other authorities, whether in Singapore or elsewhere, with which MFLG or MFLG’s related corporations or associated companies is/are expected to comply;
(g) producing statistics and research for internal and statutory reporting and/or record-keeping requirements;
(h) conducting research, analysis and development activities (including but not limited to data analytics, surveys, product and service development and/or profiling) to improve MFLG’s services or products and/or to enhance your membership experience, via various modes of communication such as (i) postal mail to your postal address(es) and/or electronic transmission to your email address(es) and (ii) via telephone/voice calls, SMS/MMS and/or facsimile to your telephone number(s);
(i) assessing the suitability of your application for a position with us and management of your employment with MFLG if you accepted a position from MFLG:
(j) during emergency where disclosure is required to safeguard the life or health of an individual.
(k) compliance with internal policies, procedures, monitoring and audit reviews.
(l) carrying out billing, processing credit notes, accounting, auditing and the maintenance of proper book-keeping for MFLG’s operations by MFLG or MFLG’s agents and service providers;
(m) maintaining the safety and security of MFLG’s premises including enforcement of security checks for access to MFLG’s facilities and/ or premises;
(n) contact tracing in accordance with the recommended industry practice.
(o) Investigating allegation or suspicion of fraud, misconduct, any unlawful action or omission;
(p) fulfilling any other reasonable purpose which may, in the ultimate discretion of MFLG, be necessary for administrative and/or operational purposes; and
(i) any other purposes which we notify You of at the time of obtaining your consent.
(collectively, the “Purposes”)
As the Purposes for which we may/will collect, use, disclose or process your Personal Data depend on the circumstances at hand, such purpose may not appear above. However, we will notify You of such other purpose at the time of obtaining your consent, unless processing of your Personal Data without your consent is permitted by the PDPA or by law.
2.2 In order to conduct our business operations more smoothly, we may also be disclosing the Personal Data You have provided to us to our third-party service providers, agents and/or our affiliates or related corporations, and/or other third parties whether sited in Singapore or outside of Singapore, for one or more of the Purposes. Such third-party service providers, agents and/or affiliates or related corporations and/or other third parties would be processing your Personal Data either on our behalf or otherwise, for one or more of the Purposes.
3.1 We respect the confidentiality of the Personal Data You have provided to us.
3.2 In that regard, we will not disclose your Personal Data to third parties without first obtaining your consent permitting us to do so. However, please note that we may disclose your Personal Data to third parties without first obtaining your consent in certain situations, including, without limitation, the following:
(a) cases in which the disclosure is required or authorized based on the applicable laws and/or regulations;
(b) cases in which the purpose of such disclosure is clearly in your interests, and if consent cannot be obtained in a timely way;
(c) cases in which the disclosure is necessary to respond to an emergency that threatens the life, health or safety of yourself or another individual;
(d) cases in which the disclosure is necessary for any investigation or proceedings;
(e) cases in which the Personal Data is disclosed to any officer of a prescribed law enforcement agency, upon production of written authorisation signed by the head or director of that law enforcement agency or a person of a similar rank, certifying that the Personal Data is necessary for the purposes of the functions or duties of the officer;
(f) cases in which the disclosure is to a public agency and such disclosure is necessary in the public interest; and/or
(g) where such disclosure without your consent is permitted by the PDPA or by law.
3.3 The instances listed above at paragraph 3.2 are not intended to be exhaustive. For more information on the exceptions, You are encouraged to peruse the Second, Third and Fourth Schedules of the PDPA which is publicly available at https://sso.agc.gov.sg/Act/PDPA2012
3.4 Where we disclose your Personal Data to third parties with your consent, we will employ our best efforts to require such third parties to protect your Personal Data.
4.1 You may request to access and/or correct the Personal Data currently in our possession or control by submitting a written request to us. We will need enough information from You in order to ascertain your identity as well as the nature of your request, so as to be able to deal with your request. Hence, please contact us at [email protected]
4.2 For a request to access Personal Data, once we have sufficient information from You to deal with the request, we will seek to provide You with the relevant Personal Data within 30 days. Where we are unable to respond to You within the said 30 days, we will notify You of the soonest possible time within which we can provide You with the information requested. Note that the PDPA exempts certain types of Personal Data from being subject to your access request.
4.3 For a request to correct Personal Data, once we have sufficient information from You to deal with the request, we will:
(a) correct your Personal Data within 30 calendar days. Where we are unable to do so within the said 30 calendar days, we will notify You of the soonest practicable time within which we can make the correction. Note that the PDPA exempts certain types of Personal Data from being subject to your correction request as well as provides for situation(s) when correction need not be made by us despite your request; and
(b) subject to paragraph 4.4, we will send the corrected Personal Data to every other organisation to which the Personal Data was disclosed by MFLG within a year before the date the correction was made, unless that other organisation does not need the corrected Personal Data for any legal or business purpose.
4.4 Notwithstanding paragraph 4.3(b), we may, if You so consent, send the corrected Personal Data only to specific organisations to which the Personal Data was disclosed by us within a year before the date the correction was made.
4.5 We may also be charging You a reasonable fee for the handling and processing of your requests to access your Personal Data. We will provide You with a written estimate of the fee we will be charging. Please note that we are not required to respond to or deal with your access request unless You have agreed to pay the fee.
5.1 You may withdraw your consent for the collection, use and/ or disclosure of your Personal Data in our possession or under our control by contacting us at [email protected]
5.2 We will process your request within a reasonable time from such a request for withdrawal of consent being made, and will thereafter not collect, use and/or disclose your Personal Data in the manner stated in your request.
5.3 However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal. In this regard, depending on the extent of your withdrawal of consent for us to process your Personal Data, it may mean that we will not be able to continue with your existing relationship with us.
6.1 We will take reasonable efforts to ensure that your Personal Data is accurate and complete, if your Personal Data is likely to be used by MFLG to make a decision that affects you, or disclosed to another organisation. However, this means that You must also update us of any changes in your Personal Data that You had initially provided us with. We will not be responsible for relying on inaccurate or incomplete Personal Data arising from You not updating us of any changes in your Personal Data that You had initially provided us with.
6.2 We will also put in place reasonable security arrangements to ensure that your Personal Data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorized access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your Personal Data. However, we cannot assume responsibility for any unauthorized use of your Personal Data by third parties which are wholly attributable to factors beyond our control.
6.3 We will also put in place measures such that your Personal Data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that (i) the purpose for which that Personal Data was collected is no longer being served by the retention of such Personal Data; and (ii) retention is no longer necessary for any other legal or business purposes.
6.4 Where your Personal Data is to be transferred out of Singapore, we will comply with the PDPA in doing so. In this regard, this includes us obtaining your consent unless an exception under the PDPA or law applies, and taking appropriate steps to ascertain that the foreign recipient organisation of the Personal Data is bound by legally enforceable obligations to provide to the transferred Personal Data a standard of protection that is at least comparable to the protection under the Act. This may include us entering into an appropriate contract with the foreign recipient organisation dealing with the Personal Data transfer or permitting the Personal Data transfer without such a contract if the PDPA or law permits us to.
6.5 Notwithstanding our security measures for protecting your Personal Data, You acknowledge that no data transmission over the internet is completely secure and by providing your Personal Data over the internet, You are transmitting information at your own risk.
7.1 When you visit our website, we may assign your computer one or more “cookies”. By accessing our website, you agree that we can place cookies on your device.
7.3 Most browsers automatically accept cookies, but you can modify your browser setting to decline cookies. Generally, you can remove these cookies by following directions provided in your Internet browser’s “help” file. If you choose not to allow us to place a cookie on your computer, you may be restricted from some services and some of the interactive features offered on our websites may be similarly restricted or rendered inoperable.
7.4 Personal data (if any) that we collect from you through cookies may be passed to our third-party service providers, whether located in Singapore or elsewhere, for one or more of the Cookie Purposes, for managing and/or administering our website, or for the purpose of data hosting/storage/backup.
8.1 If You have any complaint or grievance regarding about how we are handling your Personal Data or about how we are complying with the PDPA, we welcome You to contact us with your complaint or grievance.
8.2 Please contact us through one of the following methods with your complaint or grievance:
(q) E-mail: [email protected] – (Attention to the ‘Data Protection Officer’)
(b) Office address: 109 Mount Faber Road, Mount Faber Peak Singapore 099203 – (Attention to the ‘Data Protection Officer’)
8.3 Where it is an email or a letter through which You are submitting a complaint, your indication at the subject header that it is a PDPA complaint would assist us in attending to your complaint speedily by passing it on to the relevant staff in our organisation to handle. For example, You could insert the subject header as “PDPA Complaint”.
8.4 We will strive to deal with any complaint or grievance that You may have speedily and fairly.
9.1 This section of the Data Protection Policy applies only if You are located in the EU and supplements the information in this Data Protection Policy.
9.2 We are the controller of Personal Data only when we collect it and determine the purposes and means of processing that Personal Data.
9.3 Our business may require us to transfer your Personal Data to countries outside of the EU, including to countries that may not provide the same level of data protection as your home country. We take appropriate steps to ensure that recipients of your Personal Data are bound to duties of confidentiality and we implement measures such as standard contractual clauses.
9.4 European Union Data Subject Rights: Where You are a resident in the EU, You may have certain rights under the GDPR in relation to the Personal Data we hold about you, which we detail below. Some of these rights only apply in certain circumstances as set out in more detail below:
9.5 If You wish to exercise any of the rights above, please contact us at:
10.1 As part of our efforts to ensure that we properly manage, protect and process your Personal Data, we will be reviewing our policies, procedures and processes from time to time.
10.2 We reserve the right to amend the terms of this Data Protection Policy at our absolute discretion. Any amended Data Protection Policy will be posted on our website and can be viewed at https://www.mountfaberleisure.com/privacy-policy/
10.3 You are encouraged to visit the above website from time to time to ensure that You are well informed of our latest policies in relation to Personal Data protection.
10.4 This Policy is to be read together with our Faber Licence Membership Terms and Conditions and Terms and Conditions that apply to all products and services provided by MFLG thereunder.
Last Updated on 31 March 2023