SFBI Internet Privacy Policy (Sun with Moon Japanese Dining & Café)

 

  1. What does this Policy cover?

This policy:

  • sets out the principles and practices SFBI (Asia-Pacific) Pte. Ltd (“SFBI”), the operator of Sun with Moon Japanese Dining & Café, follows when collecting, using, disclosing, retaining and removing personal data; and
  • describes other important topics relating to an individual’s privacy.

By sales transactions from SFBI, by communicating with SFBI through email, on telephone, in writing or via any of SFBI ‘s other services, including the Sun with Moon Japanese Dining & Café website or otherwise by providing personal data to us, you agree to the collection, use and disclosure of your personal data described in this policy.

  1. Collection Use and Disclosure of Personal Data

The type of personal data that SFBI may collect from individuals will depend upon the particular transaction and the dealing. Normally the personal data of an individual collected by SFBI may include that individual’s:

  • Name, title, address;
  • NRIC/FIN/Passport number;
  • Telephone Number;
  • Email address;
  • Records of communications with SFBI;
  • Responses to surveys and contests conducted by SFBI or on its behalf;
  • Credit card or debit card information;
  • Camera or video footage that identifies individuals (include CCTV footage); and
  • Website usage information.

SFBI only collects, uses and discloses personal data of an individual with the individual’s consent or deemed consent or as otherwise permitted under the PDPA or other applicable laws and regulations.

Personal Data will, generally, only be collected and used for the primary purposes of:

  • conducting, improving, maintaining and developing a business relationship.
  • processing, servicing or enforcing transactions and sending related communications;
  • identification and verification purposes in connection with any of the services or products that may be supplied to individuals;
  • responding to individual’s queries;
  • administering contests or market surveys conducted by SFBI or on its behalf
  • marketing (such as providing individuals with information about our products and promotional notices and offers); and
  • improvement of SFBI’s websites including the Sun with Moon Japanese Dining & Café website.

SFBI takes reasonable steps to ensure the individual is aware of:

  • the likely use of the information;
  • the means of requesting SFBI on the provision of the individual’s personal data that is in the possession of SFBI;
  • the means of withdrawing any consent in respect of the collection of the individual’s personal data or use or disclosure thereof that is in the possession of SFBI;
  • the identity and contact details of the organisation to whom the individual’s personal data is disclosed;
  • any law requiring collection, use or disclosure of the individual’s personal data; and
  • the main consequences of the individual’s failure to provide personal data to SFBI.
  1. How will SFBI disclose your Personal Data?

SFBI discloses personal data:

  • for the primary purposes for which it was collected;
  • for purposes that a reasonable person would consider appropriate in the circumstances;
  • where the individual has provided prior consent;
  • for direct marketing by SFBI where consent has been given provided that SFBI gives the individual an opportunity to opt out of such direct marketing; or
  • where permitted under the PDPA or other applicable law or if required by law.

SFBI does not disclose your personal data for any secondary purposes unless your consent has been given or if so permitted or required under the PDPA or other applicable laws and regulations.

SFBI will not sell or license any personal data that it collects from an individual.

  1. Accuracy and Correction of Personal Data

SFBI takes reasonable steps to ensure information is accurate and up-to-date by updating its records whenever changes come to its attention. SFBI disregards information which, on a reasonable basis, is inaccurate or out of date by reason of the time which has elapsed since it was collected or by reason of any other information in its possession.

If an individual has submitted personal data to SFBI electronically or otherwise, and would like it corrected, then a written request should be sent by email to the Data Protection Officer at [email protected] or to the address below.

SFBI will comply with an individual’s request to correct their personal data as soon as practicable.

If SFBI disagrees with any request to correct an individual’s personal data on reasonable grounds, SFBI shall annotate the personal data with the correction that was requested but not made.

  1. Withdrawal of Consent

An individual may withdraw his consent for the collection, use or disclosure of personal data by giving SFBI reasonable notice by sending a written request by email to the Data Protection Officer at [email protected] or to the address below. SFBI shall inform the individual of the likely consequences of the withdrawal of the consent. SFBI will cease to collect, use or disclose the personal data upon such withdrawal unless otherwise permitted or required by the PDPA or other applicable laws and regulations.

  1. Using our Website

As with most websites, when you visit or use an application on SFBI’s websites including the Sun with Moon Japanese Dining & Café website, SFBI may record anonymous information such as IP address (not used to identify a specific individual), time, date, referring URL, pages accessed and documents downloaded, type of browser and operating system.

SFBI’s websites including the Sun with Moon Japanese Dining & Café website also use “cookies”. A cookie is a small file that stays on your computer until, depending on whether it is a sessional or persistent cookie, you turn your computer off or it expires. Cookies may collect and store your personal data. You may adjust your internet browser to disable cookies. If cookies are disabled you may still use SFBI’s websites, but may be limited in the usage of some of its features.

  1. Security of your Personal Data

SFBI will take reasonable steps to ensure that personal data is securely stored.

SFBI protects personal data from misuse or loss by restricting access to the information in electronic and by appropriate physical and communications security.

  1. Retention and Removal of your Personal Data

SFBI will cease to retain personal data or remove the means by which the personal data can be associated with particular individuals as soon as the purpose for which that personal data was collected is no longer served by the retention or retention of the personal data is no longer necessary for legal or business purposes.

Any data removed is disposed of in a manner that protects the privacy of personal data in an appropriate manner.

  1. Dealing with Unsolicited Information

SFBI takes all reasonable steps to ensure that all unsolicited information is destroyed immediately.

  1. Access to Personal Data

If an individual wishes to be provided with information regarding their personal data that is in the possession or under the control of SFBI or the ways in which such personal data has been used or disclosed by SFBI in the year preceding such request, the individual needs to send a written request by email to the Data Protection Officer at [email protected] or to the address below. SFBI will handle such requests as soon as reasonably possible in accordance with the PDPA.

  1. Anonymity when dealing with SFBI

SFBI allows individuals the option to not identify themselves when dealing with it, where practical.

  1. Cross Border Disclosure

Any personal data provided to SFBI may be transferred to, stored by or disclosed to an overseas recipient. For example, SFBI may use a server hosted overseas to store data, which may include your personal data. SFBI ensures that the overseas recipient provides a standard of protection to personal data so transferred that is comparable to the protection under the PDPA.

  1. Sensitive Information

SFBI does not collect sensitive information without the individual’s consent and unless collection of such information is specifically relevant and necessary for SFBI’s primary purposes described in Article 2 of this policy or otherwise permitted or required by the PDPA or other applicable laws. All sensitive information is collected and used in accordance with this policy. SFBI does not use government identifiers to identify individuals.

  1. DNC Registry

SFBI complies with all provisions regarding the DNC Registry under the PDPA.

  1. Other Important Information

SFBI reserves the right to modify this policy at any time. A current version of this policy will be published on the Sun with Moon Japanese Dining & Café website or may be obtained free of charge upon request.

  1. Further Information

If you have any queries or concerns about SFBI’s personal data protection policies and practices, please contact:

Data Protection Officer

1 Coleman Street, #10-08/09 The Adelphi, 179803

Email: [email protected]

Updated on 15 October 2015