PRIVACY POLICY (NSRCC)

The National Service Resort & Country Club (“NSRCC”) respects your privacy. This Privacy Policy informs you of how NSRCC manages the personal data collected will be processed in accordance with the Singapore Personal Data Protection Act 2012 (“PDPA”), its associated regulations and subsidiary legislation, and guidelines issued by the Singapore Personal Data Protection Commission (“PDPC”).

Please read through the following before providing us with any of your personal data. Your membership and continued use of our website constitutes your acknowledgement and understanding of, and agreement with, our Terms of Use and this Privacy Policy.

What this Privacy Policy covers

This Privacy Policy applies to personal data which we may collect when you interact with us, submit information to us, access and/or use our services, including but not limited to, all online and mobile website, social media platforms, rental of our bungalows, using our golf courses, the sports and recreational activities and facilities, food and beverage outlets available at NSRCC, and other services belonging to NSRCC (collectively, the “NSRCC Services”).

This policy does not apply to the practices of companies that NSRCC does not own or control, or to people that we do not employ or manage. NSRCC Services may contain links to other websites, social media platforms, applications and other services. Please note that we are not responsible for the privacy practices of such other websites, social media platforms, applications and other services and we advise you to read the privacy statements of such websites, social media platforms, applications and other services you visit which collects personal information.

This Privacy Policy shall be read in conjunction with NSRCC’s Terms of Use in respect of the use of its website and/or social media platforms, and any other policies, rules and regulations which NSRCC may impose from time to time (collectively referred to as the “Agreements”).

Collection of Personal Data

Depending on the services you use, we collect different kinds of personal data from or about you.

Generally, we collect personal data in the following non-exhaustive ways:

When you submit to us any form, including but not limited to, any application, registration or other forms for purposes of using NSRCC Services (e.g. when you sign up to be a member of NSRCC);

When you sign up for an online account with NSRCC for purposes of using NSRCC Services, including but not limited to the booking of golf sessions, golf tournaments, events, facilities, or the submissions of score with third parties (e.g. the Singapore Golf Association);

When you provide any documentation or information to us containing your personal data;

When you interact with our staff, including our customer service officers, through telephone calls, letters, emails, face-to-face meetings, social media platforms and/or other modes of communication;

When you request that we contact you and/or when you request that you be included in an email or any other mailing list;

When you respond to our promotions, initiatives or any of our request for additional personal data;

When you submit an employment application form and/or when you provide documents or information which contains your personal data;

When your images are captured by us via CCTV cameras or bodycams or similar equipment within our premises, or via photographs or videos taken by us and/or our representatives when you attend events at NSRCC;

When you submit your personal data to us for any other reason.

If you visit our online and mobile websites, social media platforms and/or access our applications and other digital services, such as registering for online golf tournaments, events, and booking your golf sessions, we may collect information about you, the type of device you use, your device’s unique identifier, the IP address of your device, your operating system, the type of internet browser that you use, usage information, diagnostic information, browsing information, session summary information, file attributes (including attributes for photos, videos, music and documents), and local information from or about the computers, phones, or other devices on which you install or access our products or services (as the case may be).

We may also collect information from third parties, including business partners and marketing agencies. This includes your contact information from marketing partners when we engage in joint marketing or co-branding activities, your IP address or location information from service providers to offer certain products and/or services relevant to your location, and data from your social networks to authenticate your product and/or services use with us, or that you grant permission to our services to access.

We may also collect personal data relating to any other individuals, such as your spouse, children and parents. By submitting such information to us, you also confirm that you have obtained the consent of these individuals to provide to us with their personal data for the respective purposes.

What is the information used for?

Your personal data will be collected, used, disclosed and/or processed by us or our agents for the following purposes:

Members of NSRCC

To send you notices, information, promotions and updates, including marketing and advertising materials in relation to our services and those of third-party organizations selected by us;

To allow you access to use the NSRCC Services;

To respond to queries, requests, and to provide the NSRCC Services by us or by our designated representatives and/or business partners to you or to parties designated by you and matters ancillary thereto;

For verification and record of your personal particulars, including comparing it with information from other sources and using the information to communicate with you, and processing your application for membership and assessing your suitability as a member of NSRCC (including publishing your name and picture on our notice boards, emails, updates, newsletters, magazines);

To manage the administrative and business operations of NSRCC, complying with our bye-laws, club rules, internal policies, procedures, including, but not limited to the following:

Providing members with the NSRCC Services, including but not limited to, the facilities available at NSRCC, the online booking of golf sessions, tournaments, events, facilities and/or any other facilities and services extended by NSRCC; and

Security measures undertaken at NSRCC, including but not limited to health measures, security measures for NSRCC’s slot machines, documenting any payouts for the slot machines

Requesting for feedback and/or participation in surveys, conducting market research and/or analysis for profiling purposes for us to review, develop and improve the quality of NSRCC Services

Employees, including potential employees

Assessing the suitability of the employee for the job duties and/or position applied for, including but not limited to verifying and contacting past employers of potential employees;

To contact employees and/or potential employees for any purpose;

General administration and record keeping of employees;

Audit, risk management, security and/or compliance purposes;

Will your personal information be shared with anyone?

We will not sell or rent your personal information to anyone. We will only share your personal details with a third party for the purposes and situations as described above, or for other purposes where we have your consent to do so.

For the avoidance of doubt, you consent to:

NSRCC collecting, using, disclosing and/or processing your personal data for the purposes and situations as described above;

NSRCC transferring your personal data out of Singapore to NSRCC’s third party service providers or agents for the purposes and situations as described above;

NSRCC disclosing your personal data to companies providing services to NSRCC, including but not limited to insurance companies, third party organizers of events, third party service providers to NSRCC such as, courier services, telecommunications, information technology, payment, printing, billing, technical services, training, market research, security, marketing or other services provided to NSRCC;

Our professional advisers, including our consultants, auditors and lawyers;

Relevant government ministries, regulatory, statutory boards, authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes.

Third Party Sites

The NSRCC Services may contain links to other websites, social media platforms operated by third parties. You agree that we are not responsible for the privacy practices of websites operated by third parties that are linked to our website/s, social media platforms or other digital platforms.

Can you opt out?

In the event that you wish for us to discontinue the collection, use, disclosure and/or processing of your personal data by us for any of the above purposes, you may also write in to us at dpo@nsrcc.com.sg to inform us of the same (the “Opt-out Email”). An acknowledgement email will be sent within fourteen (14) days upon receipt of the Opt-out Email and we shall process your request within one (1) month upon receipt of the Opt-out Email.

Please note that your personal information would only be deleted from our records after a reasonable time.

In addition, in the event you wish for us to discontinue the collection, use, disclosure and/or processing of your personal data, please note that you would not be able to access or use any of the NSRCC Services. Withdrawal of your consent may also affect your membership with NSRCC. For the avoidance of doubt, notwithstanding any withdrawal of consent herein, members shall terminate their membership(s) with NSRCC in accordance with NSRCC’s prevailing terms and conditions for such termination of membership accordingly.

Can you access or correct your personal data?

You may update your personal information at any time by accessing your registered account(s) with us or by writing in to us at dpo@nsrcc.com.sg to inform us of the same.

If you would like to request access to your personal data held by us, or you would like to contact us for any reason regarding our privacy policy or practices, please contact us at dpo@nsrcc.com.sg. Please note that we may charge a reasonable fee for processing any data access request.

How is your data protected?

We will take reasonable precautions to ensure that personal data are protected from unauthorized access and other similar risks. Access to your registered account(s) (if any) is password protected. Thus, no other party, including NSRCC’s employees, can change the information. However, you must remember to log off from your registered account and close the requisite application/s after use so that no unauthorized party can have access. You are responsible for the safe-keeping of your password. You must not, at any time, disclose your password to any third party, including NSRCC’s employees and/or representatives and/or contractors. We will not be responsible and you agree that we cannot be held liable for any losses or damage incurred by you whatsoever caused by your non-compliance to any of the foregoing. All information gathered by NSRCC is stored in systems that may only be accessed by authorised NSRCC’s staff using assigned user ids and passwords.

Technical measures are also undertaken by NSRCC, such as firewalls and other security software, to protect its servers and networks from unauthorized use, access and tampering of files and other information which we store. Employees of NSRCC are also required to handle the personal data securely and in accordance with our internal data protection policies.

While NSRCC shall endeavor to ensure that its vendors, third party service providers, consultants and professional advisors shall handle your personal data in compliance with the PDPA, you agree that NSRCC cannot assume responsibility for any unauthorized use of the personal data which are not attributable to NSRCC and/or beyond NSRCC’s control.

Changes to this Privacy Policy

NSRCC may from time to time update the terms of this Privacy Policy to ensure compliance with any legal and/or regulatory requirements. You agree to be bound by the prevailing terms of the Privacy Policy as may be updated from time to time.

Use of cookies, web beacons and other user and ad-targeting technologies

When you access, use and/or interact with NSRCC Services online, we or our authorized service providers may use "cookies", “web beacons” and other tracking technologies where small data files are sent to the app and/or browser, application or device to store and track information about you. The cookies, web beacons and other tracking technologies are used to track information such as the number of users and their frequency of use, online behavioural data, profiles of users and their preferred sites. They enable our own system to recognise you when you visit us again, enhance your web-viewing experience and allow for more effective online targeted advertising.

You may accept or decline cookies by modifying the settings in the app and/or browser, application or device, if the app and/or browser, application or device so permits. However, please note that you may not be able to use all interactive features if cookies have been disabled completely. While the cookies can tell us when you interact NSRCC Services and which pages you visit, it cannot access other data including from your computer or storage device and it does not contain information intended to identify you personally.

Governing Law

This policy is subject to any existing laws of the Republic of Singapore in relation to the protection of information and if required by any lawful authority for any legal purposes such as the enforcement of any laws or to prevent the breaching of any laws, we shall release all such information as is legally required by the requisite and lawful authority in accordance with the directions of the lawful court of the competent jurisdiction.