Legal Notice

Disclaimer

All content contained herein is correct as at 01 October 2019. The contents of the website are intended only for general information and should not be treated as a substitute for specific professional advice for any particular course of action. While great care has been taken to ensure the accuracy and reliability of the content herein, interested parties are always encouraged to contact Senoko Energy Pte Ltd to make further enquiries.

Senoko Energy Pte Ltd shall not be responsible for any losses incurred or damage as a result of reliance on the contents herein.

No part of the contents herein may be reproduced or transmitted in any form or by any means, electronic or mechanical, including photocopy, recording or through any information storage and retrieval system, without the prior written permission and consent from Senoko Energy Pte Ltd.

Cookies Policy

i. Our web site(s) and mobile application(s) use cookies to monitor browsing preferences and help analyse data about webpage traffic in order to make web site improvements based on your needs and to enhance web site efficiency. We generally use such information for statistical analysis but may use it for other reasons in aggregated form or where we are not aware of your identity.

ii. When you visit our web site(s) and/or mobile application(s), our servers will automatically record information that is sent whenever you visit a web site or mobile application. This data may include: (a) your computer’s IP address; (b) your browser type; (c) the webpage you were visiting before you visited the relevant web site; (d) the pages within the web site or mobile application which you visit; and/or (e) the time spent on such pages, item and information searched for in the web site or mobile application, access time and dates, and other statistics.

iii. A cookie does not give us access to your computer. Most internet browsers automatically accept cookies, but you can usually modify your browser settings according to your preference. If you choose not to accept cookies, you may not be able to experience all of the features of our web site(s) and mobile application(s).

Personal Data Protection Policy

This policy (“Privacy Policy”) specifies the responsibilities of Senoko Energy Pte Ltd and its subsidiaries, its agents, data intermediaries and third party service providers authorized by Senoko Energy Pte Ltd (collectively referred herein as “Senoko”, “we”, “us” or “our”) in handling, collection, usage and disclosure of personal data provided to the company by individuals.

You agree and consent to us, the Organisation, and our authorised service providers and third parties to collect, use and disclose and/ or retain your Personal Data in the manner set forth in this Personal Data Protection Policy (also known as “Privacy Policy”). For the avoidance of doubt, in the event that Singapore’s personal data protection law permits an organisation such as us to collect, use or disclose your personal data without your consent, such permission granted by the law shall continue to apply.

This Privacy Policy is governed by and shall be construed in accordance with the laws of Singapore.

1. Your Personal Data

In this policy, “Personal Data” refers to personal data as defined by section 2 of the Personal Data Protection Act 2012, i.e., data, whether true or not, about an individual who can be identified from that data; or data, whether true or not, about an individual who can be identified from that data and other information to which the organisation has or is likely to have access.

2. Personal Data Collection

2.1 Senoko collects information about you when you use our website(s), website/IT portal(s)/mobile application(s), forms, surveys, and/or other channels and throughout other interactions, communications and services you have with us.

Information you provide to us: we collect personal data you provide directly to us. This includes, but not limited to, the following:
a. your full name and contact information, passport and visa information;
b. your credit card, mobile payment and other payment details;
c. your membership information, account details, profile or password details and any partner programme affiliation;
d. any information necessary to fulfill special requests (for example, billing preferences);
e. your reviews, feedback and opinions about our products and services;
f. information collected through the use of closed-circuit television systems and other security systems; and
g. any other personal data you choose to provide to us.

Information We collect automatically when you use this website (“Site”): when you access or use this Site, we automatically collect personal data about you, without limitation:
h. Log Information: we may collect system log information about your use of this Site, including the type of browser you use, access times, pages viewed, your IP address and the page you visited before navigating to our Site.
i. Device Information: we may collect information about the computer or mobile device you use to access our Site, including the hardware model, operating system and version, unique device identifiers (such as, IP address, IMEI number, the address of the device's wireless network interface, or mobile phone number used by the device) and mobile network information.
j. Location Information: we may collect information about the location of your device each time you access or use one of our mobile applications or otherwise consent to the collection of this information. You can turn off location services for a device at any time, but this may turn off some useful features.
k. Information Collected by Cookies and Other Tracking Technologies: we and our service providers use various technologies to collect information, including cookies and web beacons. Cookies are small data files stored on your hard drive or in device memory that help us improve our Site and your experience, see which areas and features of our Site are popular and count visits. Web beacons are electronic images that may be used in our services or emails and help deliver cookies, count visits and understand usage and campaign effectiveness.

Information We Collect From Other Sources: we may also obtain personal data from our program partners, and from our third party service providers (such as information relating to the credit ratings of customers) and from public sources and combine that with information we collect through our Site where we believe that it is necessary to help manage our relationship with you.

Where you provide personal data of third parties (for example, names and contact details of your family members or friends), you confirm that you have their consent to provide their personal data to us. We recommend you show them this Privacy Policy.

3. Use of Personal Data

3.1 Business Purposes
We may collect, use, disclose and/or retain your Personal Data for purposes, without limitation:
i. To provide you with product or services that you signed up for;
ii. To process payment or renewal of your subscription or agreement you have with us;
iii. To conduct research, surveys and interviews;
iv. To understand how our products and services impact you, provide you with a better, more personalised level of service, and further develop our products and services, including linking or combining with information we get from others to do so;
v. To provide privileges, benefits and services to you, process applications for and verify and validate your ability to access and use certain products, services and information, including rewards and redemption;
vi. To send customer service notices or/and other service related notices;
vii. To anticipate and resolve problems with any product or service supplied to you;
viii. To comply with applicable laws and regulations;
ix. For general management and reporting purposes for account management;
x. To provide you with access to the content on our Site, and respond to your enquiries and requests for information and services;
xi. To monitor your use of our Site and your bookings, and conduct analysis of the use of our Site in order to operate, evaluate and improve our Site and our services, understand your preferences, display customised content to you on our Site which may be of interest to you and troubleshoot any problems;
xii. To fulfill contractual obligations to you, anyone involved in the process of providing you with the services (e.g. SP) and vendors (e.g. credit card companies, credit ratings agencies and other loyalty programmes operators); or
xiii. All other purposes related to our business and provision of service to you.

3.2 Marketing or optional purposes
i. Upon your consent to using your personal data for direct marketing, we may contact you via mail, electronic mail, telephone (call or SMS), facsimile, mobile application or social media platforms to inform you about our promotions, services and events that we think may be of interest to you.
ii. You may inform us at any time if you no longer wish to receive marketing materials by unsubscribing from the mailing list with the option provided in our marketing materials or email us and we will remove your details from our direct marketing database.
iii. We may use your personal data to administer and disclose the winner of contests and lucky draw competitions conducted by us or on our behalf.
iv. We conduct market analysis, market research, customer satisfaction and quality assurance surveys to improve our products and services.

3.3 Employment purposes
For employment, we may collect, use, disclose and/or retain your Personal Data for the following purposes, without limitation:
i. To manage your application for employment;
ii. To evaluate your suitability for a position which may include passing your personal data to assessment centers or third parties to conduct assessment tests, background checks and likes;
iii. To clear regulatory security vetting;
iv. To evaluate and manage your work performance;
v. For provision of benefits which may include medical, insurance, training/education benefits etc;
vi. For our internal records and communication purposes;
vii. For events organized by us or other persons which you are required or invited to attend;
viii. To manage your employment;
ix. Conducting statistical analyses on demographic of recruitment activities and candidate sourcing channels; or
x. All other purpose(s) which you have provided consent to reveal.

4. Disclosure of your Personal Data

4.1 Your personal data may be disclosed to agents, data intermediaries or third-party service providers whom we have engaged specifically to assist with Senoko’s activities. All such parties will be bound contractually to keep all information in accordance with the Personal Data Protection Act 2012. Information will not be disclosed to other third parties except when required by law, or when we have your consent.

4.2 We may share your personal data:
4.2.1 between and amongst Senoko and a limited number of our affiliates as are relevant for the above purposes and to facilitate the operation of our business, but we shall only do so on a need to know basis;
4.2.2 with third-party payment processors, payment service providers, IT and marketing support service providers and other consultants, vendors and service providers who need access to such information to carry out work or provide services on our behalf or who help us to provide the Site to you;
4.2.3 with anyone involved in the process of fulfilling our contractual obligations to you;
4.2.4 with any law enforcement, courts, Government or regulatory bodies (in whatever jurisdiction), or otherwise in response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law, regulation, court order or legal process;
4.2.5 if we believe your actions are inconsistent with our agreements or policies, or to protect the rights, property and safety of Senoko, our affiliates or others;
4.2.6 in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company, or any change of management or shareholding of Senoko;
4.2.7 with our advisors, which includes our accountants, auditors, lawyers, other professional advisors and business contacts for the purpose of assisting us to better manage, support or develop our business and comply with our legal and regulatory obligations;
4.2.8 with any other party at your consent or at your direction; and
4.2.9 otherwise as permitted or required by applicable laws and regulations.

4.3 We may also disclose aggregate or de-identified data that is not personally identifiable with third parties, including our commercial and strategic partners.

5. Withdrawal of Consent

5.1 Upon reasonable notice, via the email address as stated below, being given by an individual of his withdrawal of any consent given or deemed to have been given in respect of our collection, use or disclosure of his personal data, we will cease (and cause any of our data intermediaries and agents to cease) collecting, using or disclosing the personal data unless it is required or authorised under applicable laws.

5.2 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.

5.3 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 in clauses above.

5.4 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.

6. Access to and Correction of Personal Data

6.1 Upon request, we will provide the individual with access to their personal data or other appropriate information on their personal data in accordance with the requirements of the PDPA.

6.2 Upon request, we will correct an error or omission in the individual’s personal data that is in our possession or control in accordance with the requirements of the PDPA.

6.3 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.

7. Protection of your Personal Data

7.1 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 and the use of privacy filters to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis.

7.2 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.

8. Accuracy

8.1 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 us in writing or via email as provided below.

9. Retention of Personal Data

9.1 We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.

9.2 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.

10. Transfer of Data to other Countries

10.1 The data we collect from you may be transferred to, processed, and stored at, different locations worldwide. Senoko will take all steps as required by the mandatory Singapore law in connection with any transfer of such data overseas.

10.2 Senoko will make reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar activities to protect your personal data in Senoko’s possession or under Senoko’s control.

10.3 Senoko will require these data protection standards to be observed by external parties who provide services to Senoko and/or to whom we disclose your personal data.

10.4 By submitting your personal data to us through our websites or otherwise, you are providing explicit consent to transborder transmission of data.

11. Use of Cookies

11.1 We may use, collect or analyse information from “cookies” stored on your computer or devices from which you use to access the website, applications or services (“e-services”) we provide to you. This information is used to assist us in analysing the usage of our e-services to improve your online experience with us.

11.2 Should you wish to disable the cookies, you may do so by changing the setting on your browser. However, this may affect the functionality of the e-service provided.

12 Your Responsibility

12.1 You shall be responsible for maintaining the confidentiality of the username and password and not share or authorise the use of the username and password by third parties. You shall be responsible for all activities undertaken using your username and password whether authorised or otherwise. You shall immediately notify us if it comes to your knowledge that your user ID and/or password has been compromised or there has been unauthorised use.

12.2 Senoko shall not be liable for any direct, indirect, special or consequential damages or loss of any kind as a result of any unauthorised use of your user ID, password.

12.3 This Site may contain links to other websites, apps, content, services or resources on the internet which are operated by third parties. If you access other websites, apps, content, services or resources using the links provided, please be aware they may have their own privacy policy, and we do not accept any responsibility or liability for these policies or for any personal data which may be collected through these sites. Please check these policies before you submit any personal information to these sites.

13. Changes to the Privacy Policy

13.1 This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use, disclosure, and retention of your personal data by us.

13.2 We may modify this Privacy Policy from time to time. Any changes to this Privacy Policy will be posted on this Site so that you are always informed of the way we collect and use your personal data, and we encourage you to review this Privacy Policy whenever you access the Site or otherwise interact with us to stay informed about our information practices and the ways you can help protect your privacy. Updated versions of this Privacy Policy will include the date of the revision at the end of this Privacy Policy so that you are able to check when the Privacy Policy was last amended. Any changes to this Privacy Policy will become effective upon posting of the revised Privacy Policy on the Site. Use of the Site following such changes constitutes your acceptance of the revised Privacy Policy then in effect but, to the extent such changes have a material effect on your rights or obligations as regards our handling of your personal data, such changes will only apply to personal data after the changes are applied.

14. Contacting us

If you have any question or feedback regarding this personal data policy, the usage or disclosure of personal data by Senoko, or if you have any question, feedback about your personal data being used by Senoko Energy, you may contact our Data Protection Office.