[HIGHLIFE ADVISORY PTE LTD] cares deeply about the privacy of its guests and members, and is fully committed to protect their personal information and use it properly in compliance with data privacy laws. This policy describes how we may collect and use personal information, and the rights and choices available to our Guests and Members regarding such information.
We strongly urge you to read this policy and make sure you fully understand it, before you access or use any of our services.
1. What information do we collect?
1.1. Guest and Member Information
The data HIGHLIFE ADVISORY PTE LTD collects from our Guest and Member will be stored and processed by HIGHLIFE ADVISORY PTE LTD’s personnel, third party service providers and law enforcement/legal requests. These persons may also be engaged in order to provide the Services to the User, including but not limited to:
feedback, ratings and compliments;
transaction information (such as payment method and distance travelled);
information about how the User interacted with the App (such as features used and content viewed); and
device information (such as hardware model and serial number, IP address, file names and versions and advertising identifiers, or any information that may provide an indication of device or app modification).
1.2. Users-of-users’ information
HIGHLIFE ADVISORY PTE LTD may collect, store and process certain Non-personal and Personal Information of Users-of-Users (“Users-of-Users Information”), solely on our Users’ behalf and at their direction. For example, each of our Users is able to import their e-mail contacts from third party services like Gmail, or otherwise collect and manage contacts via their User Website. Such contacts are then stored with HIGHLIFE ADVISORY PTE LTD, on the User’s behalf.
For such purposes, HIGHLIFE ADVISORY PTE LTD serves and shall be considered as a “Processor” and not as the “Controller” of such Users-of-Users Information. The Users controlling and operating such User Websites shall be considered as the “Controllers” of such Users-of-Users Information, and are responsible for complying with all laws and regulations that may apply to the collection and control of such Users-of-Users Information, including all privacy and data protection laws of all relevant jurisdictions.
You are responsible for the security, integrity and authorised usage of your Users-of-Users’ Personal Information, and for obtaining consents, permissions and providing any fair processing notices required for the collection and usage of such information.
If you are a visitor, user or customer of any of our Users, please read the following: HIGHLIFE ADVISORY PTE LTD has no direct relationship with the individual Users-of-Users whose Personal Information it processes. If you are a visitor, user or customer of any of our Users, and would like to make any requests or queries regarding your Personal Information, please contact such User(s) directly. For example, if you wish to access, correct, amend, or delete inaccurate information processed by HIGHLIFE ADVISORY PTE LTD on behalf of its Users, please direct your query to the relevant User (who is the “Controller” of such data). Unless otherwise instructed by our User, we will retain their Users-of-Users’ Personal Information.
1.3. Retention of Personal Data
HIGHLIFE ADVISORY PTE LTD shall endeavour reasonable efforts that the protection of your personal data, both in storage and in transit, remains secure.
Should the User have any queries about your personal data protection, please contact the Data Protection Officer at [email@example.com].
1.4 Do Not Call (DNC) Provisions
The DNC provisions in the PDPA came into effect in 2014. HIGHLIFE ADVISORY PTE LTD will not send you any marketing messages or make any marketing calls if you have registered your Singapore telephone number with the respective DNC registries, unless we are allowed to do so under DNC provisions, or other applicable laws and regulations. Do also note that if you have given us consent to send you marketing messages to your Singapore telephone number, we may continue to do so until you withdraw your consent.
1.5. Withdrawal of Consent
Should you wish to withdraw your consent for our use of your Personal Data, you may do so in the following ways:
To unsubscribe from our electronic mailing list, follow the unsubscribe instructions in our emails or other electronic marketing materials; or
If you have an online subscription or membership account with us, you may access your account(s) with us to change your settings; or
For any other queries regarding our handling of your personal data, you may contact our Data Protection Officer at [firstname.lastname@example.org].
Do note that the withdrawal of consent is subject to all applicable laws and applicable terms and conditions.
2. Updates and interpretation