This Policy sets out the manner in which Toy Outpost / HAKO collects, uses, manages and protects Personal Data (as defined below) in compliance with the provisions of the Personal Data Protection Act 2012.
This Policy applies to all individuals (as defined below) who provide Toy Outpost / HAKO with Personal Data or whose Personal Data is otherwise collected, used and/or disclosed by Toy Outpost / HAKO in connection with and/or for the purposes of its operations.
Toy Outpost / HAKO shall, in its collection, processing, disclosure, transportation or other use of personal data in the course of fulfilling its obligations under the contractual agreement adhere to the requirements of PDPA. The organisation shall not by act or omission to be in breach of PDPA.
This Policy supplements but does not supersede or replace any previous consent which an individual may have provided to Toy Outpost / HAKO, nor does it affect any rights that Toy Outpost / HAKO may have at law in connection with the collection, use and/or disclosure of any Individual’s Personal Data. Subject to that, Toy Outpost / HAKO will not collect any Personal Data from an Individual unless the Individual has voluntarily chosen to provide us with it.
Amendments or Updates to this Policy
Toy Outpost / HAKO reserves the right to amend or update this Policy to ensure it is consistent with its future developments or business purposes or to accommodate future changes to applicable legal or regulatory requirements. All amendments or updates to this Policy will be published at www.toyoutpost.sg / www.hako.sg and appropriate notifications of any material revisions will be issued to the relevant persons. Subject to an Individual’s rights at law, the prevailing terms of the Policy from time to time shall apply. By continuing their relationship with Toy Outpost / HAKO after any amendments have been introduced and published, Individual shall be deemed to have accepted the Policy as amended. For avoidance of doubt, this Policy forms part of the terms and conditions, if any, governing an Individual’s specific relationship with Toy Outpost / HAKO (“Terms and Conditions”) and should be read in conjunction with such Terms and Conditions. In the event of any conflict or inconsistency between the provisions of this Policy and the Terms and Conditions, the provisions of the Terms and Conditions shall prevail to the fullest extent permissible by law.
Personal Data collected by Toy Outpost / HAKO
Toy Outpost / HAKO will only collect, use or disclose Personal Data about an Individual which it reasonably considers necessary for the relevant purposes underlying such collection, use or disclosure. Depending on the specific nature of an Individual’s interaction with Toy Outpost / HAKO, Personal Data which Toy Outpost / HAKO collects, uses or discloses concerning an Individual may variously include the following :
a) the Individual’s personal particulars such as name, date of birth, photographs; and contact particulars, including telephone number(s), residential / mailing address(es) and email address;
b) details of the Individual’s identification documents (such as NRIC or passport numbers), and applicable visa or permits (such as employment pass, work permit, permanent residency status);
c) details of the Individual’s personal preferences or other special requests or special conditions applicable to the Individuals;
d) photographs and video or CCTV recordings of the Individual; and
e) other information which the individual may provide to Toy Outpost / HAKO, from time to time, in the course of such Individual’s interaction with Toy Outpost / HAKO
How Toy Outpost / HAKO collects Personal Data
Generally, we collect an Individual’s Personal Data in the following ways:
a) when you submit contractual agreement forms relating to any of our rental lockers or consignment sales arrangement.
b) when you submit forms relating to any of our services
c) when you interact with our customer service officers or any of our staff, for example, via face-to-face meetings, telephone calls, letters, online forms (such as any “Contact Us” forms on our websites), reservation chat, social media platforms and emails;
d) when you request that we contact you;
e) when you respond to our request for additional Personal Data;
f) when you ask to be included in an email or other mailing list;
g) when you submit a job application or a internship application;
h) when you submit your Personal Data to us for any other reason
Purposes for which Toy Outpost / HAKO may collect, use and / or disclose Personal Data
In general, we will, subject to applicable law, use and disclose your Personal Data for the following purposes:
a) provide you with the products or services that have been requested including payments;
b) communicate with you and respond to your queries, requests and complaints;
c) handle disputes and conduct and facilitate investigations and proceedings;
d) protect and enforce our contractual and legal rights and obligations;
e) prevent, detect and investigate crime, including fraud and money-laundering, and to analyse and manage other commercial risks;
f) manage our infrastructure and business operations and comply with internal policies and procedures;
h) comply with any applicable rules, laws and regulations, codes of practice or guidelines or assist in law enforcement and investigations by relevant authorities.
In addition, we may use and disclose your Personal Data for the following purposes, if you have registered for a merchant ID with any of Toy Outpost or HAKO outlets
(a) process your application for the account and for the lease of locker facilities
(b) maintain your account with us
(c) prepare locker lease documentation and any other documents as may be required
(d) perform administration of the locker lease;
(e) perform financial transactions such as payments for the lease of locker facility and cashout;
(f) verify your personal particulars and process payment requests in relation to provision of the services which you may be entitled to or which you may have requested for;
(g) provide you with the goods and services which you have signed up for;
(h) communicate with you of changes and development to our policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you;
(i) resolve complaints and handle requests and enquiries;
(j) conduct due diligence checks;
(k) communicate with you changes and development to our policies, terms and conditions and other administrative information; and
(l) any other purpose related to any of the above.
Consent
Unless otherwise authorised under the PDPA or any other applicable law, Toy Outpost / HAKO will not collect, use or disclose an Individual’s Personal Data without his / her consent.
Toy Outpost / HAKO will take reasonable steps to highlight the purposes relevant to an Individual, by appropriate means, at the point or time of collection of the Personal Data from such Individual, including:
a) via express provisions in contracts, application forms, merchant agreement and / or registration forms to be signed with or submitted to Toy Outpost / HAKO;
b) via notifications on or through the Platforms, portals and electronic communication
c) in the course of verbal and / or written communications
d) Where feasible Toy Outpost / HAKO will inform the Individual of purposes that are intrinsic to the relationship between Toy Outpost / HAKO or to the provision of services to such Individual, as well as purposes that are optional.
e) in so far as any purpose(s) are intrinsic to the relationship or provision of services, Toy Outpost / HAKO reserves the right to decline to engage in the relevant relationship or to provide the relevant services to the Individual if he or she does not consent to Toy Outpost / HAKO’s collection, use or disclosure of his / her Personal Data for such purpose.
f) Individuals who:
– voluntarily provide their Personal Data to Toy Outpost / HAKO for the specified purposes.
– use or access the merchant platform;
– enter Toy Outpost / HAKO’s premises or using any of the facilities thereon; and / or
– Attend or participate in events or programmes organised by Toy Outpost / HAKO will be deemed to agree and consent to Toy Outpost / HAKO collecting, using and / or disclosing their Personal Data in the manner and for the purposes set forth in this Privacy Policy.
g) An individual who provides Toy Outpost / HAKO with Personal Data relating to a third party (e.g. information of his / her spouse, children, friends, siblings, partners, helpers) for any particular purpose, represents to Toy Outpost that he / she has obtained the consent of the relevant third party to Toy Outpost / HAKO collecting, using or disclosing such Personal Data for the relevant purpose. [By providing us with any Personal Data relating to any third party (“Third Party Personal Data”), you represent and warrant that you have ensured the accuracy of such Third Party Personal Data provided and have also obtained such third party’s consent for our collection, use and disclosure of such Third Party Personal Data. You also agree to keep us indemnified from and against any and all damages, losses, costs, legal fees (on a solicitor-client basis), penalties and proceedings, imposed or charges by any regulator or authority arising out of or in connection with your acts or omission, fault or negligence which results in our breach of relevant laws.]
Withdrawal of Consent
Any Individual who wishes to withdraw his/her consent to any use or disclosure of his/her Personal Data by Toy Outpost as set out in this Policy may do so by notifying Toy Outpost / HAKO at feedback@toyoutpost.sg. Toy Outpost / HAKO may require up to 2 weeks from the date of the Individual’s notification to respond and effect any change.
Depending on the extent to which an Individual withdraws consent to any or all use or disclosure of his or her Personal Data by Toy Outpost / HAKO, such withdrawal of consent may result in Toy Outpost / HAKO’s inability to provide services to the Individual and may be considered as a termination by the Individual of any agreement between Toy Outpost / HAKO and the Individual. Toy Outpost / HAKO’s legal rights and remedies are expressly reserved in such event.
In so far as an Individual’s data is being collected by cookies, the Individual may disable the use of cookies when accessing the Platforms. However, this may result in the loss of functionality, restrict the Individual’s use of the Platforms and/or delay or affect the way in which the Platforms operate.
Verification of Personal Data & Notification of changes
Where feasible, Toy Outpost / HAKO will take reasonable steps to verify the accuracy of Personal Data received at the point of collection but Individuals remain primarily responsible and liable to ensure that all Personal Data submitted by them to Toy Outpost / HAKO is complete and accurate. Information voluntarily by an Individual to Toy Outpost / HAKO shall prima facie be deemed complete and accurate.
Toy Outpost / HAKO will also take reasonable steps to periodically verify Personal Data in its possession, taking into account the exigencies of its operations, but Individuals are nonetheless required to notify Toy Outpost / HAKO, from time to time, of any applicable changes to such Personal Data.
Toy Outpost / HAKO shall not be held liable for any inability on its part to provide services to an Individual who fails to ensure that his/her Personal Data submitted to Toy Outpost / HAKO is complete and accurate or who fails to notify Toy Outpost / HAKO of any relevant changes to such Personal Data. In this regard, you should ensure that the Personal Data provided by you to Toy Outpost / HAKO is at all times correct, accurate and complete; and you agree to update Toy Outpost / HAKO in a timely manner of all changes to your Personal Data.
Policy on telephone numbers registered with the DNC Registry
Toy Outpost / HAKO is prohibited from sending unsolicited telemarketing messages to Singapore telephone numbers through voice calls, text or fax messages registered on the DNC Registry unless Toy Outpost / HAKO has obtained the relevant Individual’s clear and unambiguous consent in written or other accessible forms.
In compliance with the PDPA, Toy Outpost / HAKO will not send telemarketing messages to telephone numbers that appear on the DNC Registry unless the relevant Individual has given Toy Outpost / HAKO clear and unambiguous consent to do so.
Toy Outpost / HAKO will continue to contact Individuals at the telephone numbers provided to Toy Outpost / HAKO in the limited circumstances allowed under the DNC Registry even if these telephone number(s) are registered with the DNC Registry.
Activities undertaken prior to 2 July 2014
Toy Outpost / HAKO may use Personal Data of an Individual that was collected before 2 July 2014 for purposes for which the Personal Data was collected unless consent is withdrawn by that Individual.
Toy Outpost / HAKO will continue to use Personal Data of its members, which had been collected before 2 July 2014, for its general business purposes relating to members. Members who wish to withdraw their consent to Toy Outpost / HAKO’s use of their Personal Data may contact Toy Outpost / HAKO at feedback@toyoutpost.sg
Protection of Personal Data
Your Personal Data will be protected and kept confidential, but subject to the provisions of any applicable law, your Personal Data may, depending on the products or services concerned, be disclosed to third parties set out below. Such disclosure may be subject to additional legal requirements under applicable law, depending on the nature of such transfer to third parties. Your Personal Data will, in each case, only be disclosed to the extent necessary and proportionate.
The third parties are:
a) other divisions or entities within the Toy Outpost and HAKO Group;
b) our joint venture/ alliance partners;
c) our agents, contractors, third party service providers and specialist advisers who have been contracted to provide us with administrative, financial, research, operational or other services in pursuance of the purposes set out in this Policy, such as telecommunications, information technology, payment, payroll, processing, training, market research, storage and archival;
d) any third party business partners who offer goods and services or sponsor contests or other promotional programmes, whether in conjunction with us or not, and where permitted by applicable laws;
e) insurers or insurance investigators and credit providers;
f) the Credit Bureau, or in the event of default or disputes, any debt collection agencies or dispute resolution centres;
g) 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 the Toy Outpost and HAKO Group;
h) our professional advisors such as our auditors and lawyers;
i) relevant government regulators or authority or law enforcement agency to comply with any laws or rules and regulations imposed by any governmental authority;
j) anyone to whom we transfer or may transfer our rights and obligations, including, for example, where we obtain the services of a third party organisation to handle any aspect of the processing of your Personal Data for the purposes notified to you in accordance with this Policy;
k) banks, credit card companies and their respective service providers; and
l) any other party as may be consented to by you, as specified by you or as may be notified to you by us in subsequent notices.
Contacting Toy Outpost / HAKO – Access to and / or Correction of Personal Data
We will, to the best of our ability ensure the accuracy of data collected. In the event, that you may wish to rectify any error or omission we will assist to respond in the soonest way possible.
Any Individual who :
a) has questions or feedback relating to this Policy:
b) would like to obtain access to his / her Personal Data held by Toy Outpost / SAFRA
c) would like information about the ways in which his / her Personal Data held by Toy Outpost has been or may have been used or disclosed by Toy Outpost / HAKO in the year preceding the request ; and / or
d) would like to update or make corrections to his / her Personal Data held by Toy Outpost / HAKO should contact Toy Outpost at feedback@toyoutpost.sg
e) Individuals should note that Toy Outpost / HAKO is not required, under the PDPA, to provide access and correction to Personal Data in certain situations.
f) The PDPA allows and Toy Outpost / HAKO reserves the right to charge a reasonable fee for the handling and / or processing of access request by an Individual pursuant to the clauses (b) or (c) above
g) Toy Outpost / HAKO may require up to 3 weeks from the date of the Individual’s request to respond and effect any change.
We may retain an Individual Personal Data for as long as it is necessary for the purposes it has been collected, and (i) in most cases, up to 7 years; or (ii) in respect of our activities, up to 10 years, unless otherwise permitted by applicable law or in order to defend legal claims. Where we no longer require the Individual’s Personal Data for those purposes, we will cease to retain such Personal Data.
We have appointed Data Protection Officers to oversee our management of your Personal Data in accordance with this Policy and the applicable data protections law. We train our employees who handle your Personal Data to respect the confidentiality of your Personal Data, and we regard breaches of all applicable data protection laws very seriously.
If you have any questions regarding this Policy, you may send an email to our Data Protection Officer at feedback@toyoutpost.sg.
Governing Law
This Policy shall be governed by and construed in accordance with the laws of Singapore.
Any dispute arising out of or in connection with this Policy including any question regarding its existence, validity or termination, shall be referred to and finally resolved by the Courts of Singapore.