Privacy Policy

April 7, 2023

GROWING NEEDS PTE LTD PRIVACY AND DATA PROTECTION POLICY (“POLICY”)

Welcome to Growing Needs Pte Ltd Website.

We value your privacy and want to let you know how we handle personal data in accordance with the Personal Data Protection Act 2012. As Growing Needs and its related entities, affiliates, and subsidiaries, we are collectively referred to as “Growing Needs,” “us,” “we,” or “our.” Please take the time to read this Policy to understand how we collect, use, and disclose your Personal Data, and to help you make an informed decision before sharing your Personal Data with us. It’s important to note that this Policy does not apply to European Union Data Subject or EU General Data Protection Regulation since our Site and Services are not intended for individuals residing in the European Union.

When you interact with us or our websites, such as signing up for promotions or services or submitting information, you agree and give your consent to Growing Needs Pte Ltd, our related corporations, and affiliates (collectively referred to as “Growing Needs,” “us,” “we,” or “our”), as well as our representatives, to collect, use, disclose, and share your Personal Data among ourselves. We may also disclose your Personal Data to authorized service providers and relevant third-parties, in accordance with the guidelines outlined in this Policy.

This Policy is an addition to any other consents you may have given to Growing Needs, and it does not replace or compromise them. It also doesn’t affect any legal rights Growing Needs may have regarding the collection, use, or disclosure of your Personal Data. We may update this Policy periodically to align with our future developments, industry trends, or changes in legal or regulatory requirements. By continuing to interact with us or our websites, you agree to be bound by the prevailing terms of this Policy, as updated from time to time. Please check our websites regularly for any updates on how we handle your Personal Data. If you have any queries related to how we manage, protect, or process your personal data, please feel free to contact us and address your concerns to our Data Protection Officer. Details on how to contact our Data Protection Officer are provided in this Policy.

For the avoidance of doubt, this Policy forms a part of the Website Terms and Conditions. If any conflict, inconsistency, or conflict arises between this Policy and the Website Conditions, this Policy shall take precedence. Unless otherwise specified, all defined terms mentioned in the Website Terms and Conditions apply to this Policy as well.

1) YOUR PERSONAL DATA

1.1 In this Policy, the term “Personal Data” refers to any information or data about you that can be used to identify you, either alone or in combination with other data to which we have or are likely to have access. Examples of Personal Data that you may provide to us, depending on how you interact with us, include:

(a) your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address, and any other information you have provided us through forms or other interactions with you;

(b) information about your use of Growing Needs’s website and services, such as cookies, IP address, subscription account details, and membership details, but only to the extent that Growing Needs can identify you from such information;

(c) your employment history, education background, and income levels;

(d) your payment-related information, such as your bank account or credit card information, and your credit history; and

(e) information about your use of and interaction with our website and/or services, including computer and connection information, device capability, bandwidth, statistics on page views, and traffic to and from our website.

2) COLLECTION OF PERSONAL DATA

We don’t collect your Personal Data unless you (a) provide it voluntarily either directly or through an authorized third party who has notified you of the purpose for which the data is being collected, and you have given written consent for such collection and usage, or (b) collection and use of personal data without consent is permitted or required by the law. Before collecting any additional Personal Data or using it for a new purpose, we seek your consent, except where the law permits or authorizes such collection or usage. We collect your Personal Data through various means, including when you submit forms, register for our services, interact with our staff, use our services, establish online accounts, respond to our promotions and initiatives, submit job applications, and in other situations where you provide your Personal Data to us.

3) PURPOSES FOR THE COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL DATA

3.1 We typically gather utilize, and disclose your personal information for the subsequent objectives:

(a) responding to your queries and requests and responding to complaints;
(b) managing the infrastructure and business operations of Growing Needs and complying with internal policies and procedures;

(c) facilitating business asset transactions (which may extend to any merger, acquisition or asset sale);

(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 analysing 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) processing payment or credit transactions.

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

(l) publishing your feedback at our internal and external events, feedback exercises and/or as part of our marketing and promotional activities;

(m) processing, storing, and/or performing internal administrative, operational and technology tasks to facilitate, administer or manage information related to your relationship with Growing Needs;

(n) any other purpose relating to any of the above.

3.2 In addition, Growing Needs may collect, use and disclose your Personal Data for the following purposes, depending on the nature of our relationship with you:

(a) If you have a subscription or membership account with us:

(i) to process your application for Online Subscription Services and/or Print Subscription Services;

(ii) to maintain your account with us;

(iii) to verify and process your personal particulars and payments in relation to provision of Online Subscription Service and/or Print Subscription Services to you;

(iv) to provide you with the goods and services which you have signed up for, including the provision and delivery of newspapers and magazines requested;

(v) communicating with you to inform you of changes and development to Growing Needs policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you;

(vi) resolving complaints and handling requests and enquiries;

(vii) conducting market research for statistical, profiling and statistical analysis for the improvement of services provided to you; and

(viii) the processing of your Personal Data in relation to any of the purposes stated above.

(b) If you use download or use any of our Apps:

(i) where the App includes App Subscription Services, to process your application for these services;

(ii) to maintain your account with us and to ensure your access of the App is within the scope of your subscription;

(iii) to verify and process your personal particulars and payments in relation to provision of goods and services connected to the App;

(iv) to provide you with the goods and services which you have signed up for and to push articles to you which may be relevant to you;

(v) communicating with you to inform you of changes and development to Growing Needs policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you;

(vi) resolving complaints and handling requests and enquiries;

(vii) conducting market research for statistical, profiling and statistical analysis for the improvement of services provided to you; and
(viii) the processing of your Personal Data in relation to any of the purposes stated above.

(c) If you submit advertisements to us through any of our other online advertising portals:

(i) to verify and process your personal particulars and payments made for the posting of the advertisements;

(ii) communicating with you to inform you of changes and development to Growing Needs policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you;

(iii) resolving complaints and handling requests and enquiries;

(iv) conducting market research for statistical, profiling and statistical analysis for the improvement of services provided to you; and

(d) If you submit an application to us as a candidate for employment or an internship:

(i) processing your application including pre-recruitment checks;

(ii) providing or obtaining employee references or other references where relevant for background screening/vetting;

(iii) collecting information about your suitability for the position applied for;

(iv) organising training and staff development programs;

(v) assessing your performance;

(vi) administering benefits and payroll processing;

(vii) providing you with tools to facilitate or as required for you to do your job;

(viii) communicating with you as required by Growing Needs to comply with its policies and processes, including for business continuity purposes; and

(ix) any other purposes relating to the aforesaid.

3.3 In addition, where permitted under the Act, Growing Needs may also collect, use and disclose your Personal Data 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 Growing Needs 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 which may be of interest to you; and

(e) conducting market research, understanding and determining customer location, preferences and demographics for us to review, develop and improve our products, services and also develop special offers and marketing programmes.

3.4 If you have provided your Singapore telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your Singapore telephone number(s), then from time to time, Growing Needs may contact you using such Singapore telephone number(s) (including via voice calls, SMS, fax or other means) with information about our products and services (including discounts and special offers).

3.5 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 additional purposes as well, unless we have specifically notified you otherwise.

3.6 By using this website, you give your consent to Growing Need for the collection, usage, and sharing of your personal data in relation to any transaction involving the acquisition, sale, securitization, merger, listing, or any other corporate transaction of Growing Need, its assets or shares, including any assessments or due diligence associated with it. Additionally, you consent to the sharing of such information with the relevant counterparties for the same purposes and for the provision of goods and services by such counterparties after the transaction, if applicable.

4) DISCLOSURE OF PERSONAL DATA

4.1 Growing Needs will implement reasonable measures to safeguard your personal information from unauthorized disclosure. This personal data, subject to the provisions of any relevant law, may be shared with the following third-party entities, situated in Singapore or overseas, for the previously mentioned purposes (if relevant):

(a) Growing Needs affiliates;

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

(c) vendors or any third-party business partners who offer goods and services or sponsor contests or other promotional programs on Growing Needs’s sites, 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, credit card companies 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) USE OF COOKIES

5.1 When you engage with our websites, we may gather or examine anonymized data that does not identify individuals (“Aggregate Information”), including the quantity of users and their usage frequency, the number of page views (or impressions) on the website, and the typical entry and exit points of the website.

5.2 To collect and track Aggregate Information about you as you browse our websites, Growing Needs employs “cookies,” which are small data files sent to your browser. The cookies track details such as the number of users and their frequency of use, user profiles, and preferred sites.

5.3 Growing Needs may use an independent company (the “Third-party Market Research Company”) to measure and analyse the Internet usage across Growing Needs websites. Growing Needs may use 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 Growing Needs websites;

(b) The number of unique visitors to Growing Needs websites;

(c) How long these unique visitors (on average) spend on Growing Needs websites when they do visit; and

(d) Common entry and exit points into Growing Needs websites.

5.4 This information is aggregated by the Third-party Market Research Company and provided to Growing Needs to assist in analysing the usage of Growing Needs websites.

5.5 Pages on Growing Needs websites may be coded with software which enables the Third-party Market Research Company to track visitors to our websites.

5.6 For more information about the cookies we use, please see our Cookie Policy. 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 website.

6) THIRD-PARTY SITES

6.1 Our website 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 website. We have no control over personal data that you submit to or receive from these third parties. 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 website, 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. As a reminder, you should always remain alert and exercise caution when accessing third-party sites.

6.2. In respect of Third Party Personal data of any individuals whatsoever which you may, from time to time, disclose to us, (“Third Party Personal Data”) you hereby represent, undertake and warrant to us that:

(i) in disclosing such information to us, you have obtained the appropriate, prior and informed consent from the individuals whose Third Party Personal Data are being disclosed;

(ii) that such Third Party Personal Data is accurate;

(iii) that if in the event such Third Party Personal Data is updated or changed as the case may be, the same to be notified in writing to us as soon as reasonably practicable,

(iv) should you become aware that such individual has withdrawn his/her consent as referred to in sub-clause (i) above, such withdrawal of consent to be notified to us in writing as soon as reasonably practicable.

7) WITHDRAWAL, ACCESS AND CORRECTION OF YOUR PERSONAL DATA

7.1 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 Growing Needs website.

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

7.3 Please note that if you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, Growing Needs 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 Growing Needs and your being in breach of your contractual obligations or undertakings, and Growing Needs’s legal rights and remedies in such event are expressly reserved.

8) WITHDRAWING YOUR CONSENT

8.1 The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.

8.2 Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the 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 ten (10) business days of receiving it. Notwithstanding, any necessary extension of time beyond ten (10) days shall remain at the sole and absolute discretion of Growing Needs.

8.3 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 goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described herein above.

8.4 Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

9) ACCESS TO AND CORRECTION OF PERSONAL DATA

9.1 If you want to request access to a copy of your personal data that we possess, or if you wish to receive information about how we use or disclose your personal data, please submit an access request in writing or by email to our Data Protection Officer. Similarly, if you need to update or correct any of your personal data that we have in our records, you can submit a correction request using the contact details provided below for our Data Protection Officer.

9.2 Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.

9.3 We will respond to your request as soon as reasonably possible. In general, our response will be within fourteen (14) business days. 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 PDPA).

10) PROTECTION OF PERSONAL DATA

10.1 To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption, use of privacy filters, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis.

10.2 You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

11) ACCURACY OF PERSONAL DATA

11.1 We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.

12) RETENTION OF PERSONAL DATA

12.1 We will hold onto your personal information for as long as it is essential to achieve the objective(s) for which it was gathered, or as permitted or required by relevant laws.

12.2 We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.

13) TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE

13.1 We generally do not transfer your personal data to countries outside of
Singapore. However, if we do so, we will obtain your consent for such transfer to be made and 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 PDPA.

14) DATA PROTECTION OFFICER

14.1 To inquire about or provide feedback on our personal data protection policies and procedures, or to submit a request, please contact our Data Protection Officer at:
Attention to: Growing Needs Data Protection Officer
Email: hello@growingneeds.sg

15) MODIFICATIONS

15.1 To ensure that we effectively manage, store, protect, preserve, and process your personal data, Growing Needs may modify, review, or amend this Policy at any time. We retain the right to amend this Policy at our sole discretion. In the event of any changes, the updated Policy will be posted on Growing Needs’s website and dated accordingly. It is recommended that you visit the website regularly to stay up-to-date with the latest policies concerning personal data protection.

16) GENERAL

16.1 Your consent that is given pursuant to this Policy is additional to and does not supersede any other consent that you had provided to Growing Needs with regard to the processing of your personal data.

16.2 For the avoidance of doubt, in the event that Singapore personal data protection law permits an organisation such as Growing Needs to collect, use or disclose your personal data without your consent, such permission granted by the law shall continue to apply. This also applies to foreign data protection laws for non-Singapore residents.

17) GOVERNING LAW

17.1 All aspects of this policy are subject to the laws of Singapore.