Last Updated: 21 July 2015
Your privacy is important to us. Neo Group Limited and its subsidiaries (“Neo Group” or as appropriate in the context, “we”, “us” or “our”) take a serious approach to comply with the Singapore Government’s Personal Data Protection Act 2012 (“PDPA”).
Please read this Policy to understand how Neo Group uses the Personal Data collected. If you provide Personal Data to us or continue to interact with us, you are consenting to the collection, use, and disclosure of information in accordance with this Policy. Please review this Policy carefully before visiting or using our website, or otherwise providing us with any of your Personal Data. When you give us Personal Data about other individuals, you confirm that you are authorized to disclose and consent, on their behalf, to the collection, use, and disclosure of information in accordance with this Policy.
We strive to have your confidence and assure you of Neo Group’s capability as a provider of service excellence. Should you have any queries or comments about this Policy, please contact the Data Protection Officer:
Name: Jessie Ong
Address: 1 Enterprise Road Singapore 629813
Telephone Number: 6833 7922
For more information about PDPA generally, please visit the Personal Data Protection Commission’s website at http://www.pdpc.gov.sg
Section 1: Purposes For Collection, Use, Disclosure And Processing Of Personal Data
1.1 What Personal Data We Collect
Neo Group may request some or all of the following information from its members, employees, customers, vendors and visitors to Neo Group’s events, websites and pages on various social media. Some examples of Personal Data that we may collect are:
- personal particulars (e.g. name, NRIC number / FIN number / passport number, contact details, residential address, age, gender, date of birth, nationality, race and religion);
- contact information (e.g. postal address, telephone and mobile numbers, email address and user names on various social media websites);
- your photos;
- your payment related information, such as your bank account or credit card information, and your credit history;
- personal opinions made known to us (e.g. marketing preferences, feedback or responses to surveys);
- information and interactions with us pertaining to your order (e.g. telephone recordings, order details);
- your employment history;
- information relating to a related third party (e.g. information of your next of kin, spouse, children, parents, and/or employees); and
- Information about your usage 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.
1.2 How and When We Collect Your Personal Data
Generally, Neo Group collects your Personal Data in the following ways:
- when you submit forms relating to any of our products or services;
- when you register for or use any of our services on websites owned or operated by us or when you register as a member of websites owned and/or operated by us, or use services on such websites, including performing any online transactions;
- when you interact with any of our employees, including our customer service officers;
- when you use any of our services;
- when you establish any online accounts with us;
- when you request that we contact you;
- when you respond to our request for additional Personal Data
- when you ask to be included in an email or other mailing list;
- when you respond to our promotions and other initiatives;
- when you submit a job application;
- when we receive references from business partners and third parties, for example, where you have been referred by them; and
- when you submit your Personal Data to us for any other reason.
When you browse our website, you generally do so anonymously, but please see section 2 below on cookies and related technologies.
1.3 Purposes for the Collection, Use and Disclosure of Your Personal Data
Generally, we may use your Personal Data for one or more of the following purposes:
If you are a Customer:
- processing your orders;
- processing purchase transactions;
- recording and tracking of order and purchase history;
- communicating with you, including providing you with updates on changes to Neo Group’s policies or terms and conditions;
- responding to queries or feedback on Neo Group’s products and services;
- compiling data and conducting statistical or demographic analysis;
- addressing or investigating any complaints, claims, commercial risks or disputes;
- improving the content and navigability of our website;
- informing you of developments on our new products and services, special offers and/or promotions;
- to verify and process your personal particulars and payments in relation to the provision of any of our products or services to you;
- informing you of invitations to events / functions and seeking your feedback and comments on your attendance of the events / functions; and
- for purposes ancillary to or in furtherance of the above purposes.
Additionally, if you are a Member:
- to process your application for any of our services;
- to maintain your account with us;
- to verify and process your personal particulars and payments in relation to the provision of any of our products or services to you; and
- for purposes ancillary to or in furtherance of the above purposes.
If you are a Vendor / Business Partner:
- to conduct due diligence / background checks that are mandated by legislation or Neo Group’s internal policies and practices;
- for the supply of products and services and support by vendors / business partners to Neo Group;
- to evaluate and improve Neo Group’s products and services;
- to evaluate the products and services provided by vendors / business partners to Neo Group;
- to facilitate attendance at our corporate events / functions or any events/functions that we are involved in; and
- for purposes that are ancillary to or in furtherance of the above purposes.
If you are a prospective employee / employee:
- processing your application including pre-recruitment checks;
- providing or obtaining employee references or other references where relevant for background screening/vetting;
- collecting information about your suitability for the position applied for, including the conduct of background / due diligence checks ;
- organising training and staff development programs;
- assessing your performance;
- administrating benefits and payroll processing;
- providing you with tools to facilitate your job or as required for you to do your job;
- communicating with you as required by Neo Group to comply with its policies and processes, including for business continuity purposes; and
- for purposes that are ancillary to or in furtherance of the above purposes.
1.4 Usage of Personal Data for Marketing Purposes
From time to time, we may use your Personal Data to offer you products our services, including special offers, promotions or contests that may be of interest to you or for which you may be eligible. Such marketing messages may be sent to you in various modes including but not limited to electronic mail, direct mailers, short message service, telephone calls, facsimile and other mobile messaging services.
If at any time, you would like to request that we stop contacting you for marketing purposes or if you wish to change the way we use your Personal Data for marketing purposes, please contact us at email@example.com.
Please note that we may still send you non-marketing messages such as surveys, customer-service notices and other service related notices.
1.5 Disclosure of Personal Data
Neo Group will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, this Personal Data may be disclosed, for the purposes listed above (where applicable), to the following third parties, whether they are located overseas or in Singapore:
- any entity within Neo Group and our affiliates;
- anyone to whom we transfer or may transfer our rights and duties, including our business partners, vendors, service providers, external contractors and agents;
- service providers who provide IT and outsourcing services such as data storage, electronic mail services;
- banks, credit card companies and their respective service providers;
- our professional, legal and financial advisors such as our auditors, lawyers, tax advisors and insurers; and
- any other party to whom you authorise us to disclose your Personal Data.
Neo Group requires that the parties to whom we transfer any Personal Data implement adequate levels of protection in order to protect Personal Data. We also require that these parties only process Personal Data strictly for purposes for which we engage them for and consistent with the purposes that we have described in Section 1.3 above or for other purposes for which consent has been sought and obtained.
In addition, we would disclose Personal Data in the following circumstances:
- when we are required to do so by law or by the listing rules of the Singapore Exchange Securities Trading Limited;
- in response to a request from law enforcement authorities or other government authorities;
- to comply with a court order or direction from any government agency or regulatory authority; and
- where such disclosure is necessary for investigations or legal proceedings.
Section 2: Cookies And Related Technologies
2.1 Servers & Cookies
Neo Group’s websites are hosted on third party servers. When you access our websites, the servers hosting our websites may automatically collect non-Personal Data (e.g. type of Internet browser and operating system used, domain name of the Web site from which you came, number of visits, average time spent on the site, pages viewed). This data may be used to monitor the information such as the number of users, their frequency of use, profiles of users and their online preferences and may help us to improve the performance or content of our websites.
When you view one of our websites, we may store some data on your computer in the form of a “cookie” to automatically recognize your PC next time you visit. 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 and may affect the functionality of our website(s).
2.2 Third-party Sites
Our website may contain links to other websites which are not maintained by Neo Group, such as those of our business partners. We are not responsible for the privacy practices of websites operated by third parties that are linked to our website. We encourage you to learn about the terms, conditions and privacy policies of such third party websites and to contact its owner or operator if you have any concerns or queries.
Section 3: Request For Withdrawal Of Consent, Access And Correction Of Personal Data
3.1 Withdrawal of Consent of your Personal Data
You may withdraw your consent to our usage or disclosure of your Personal Data for a particular at any time. If you wish to withdraw consent to the usage or disclosure of your Personal Data or obtain access to or make corrections to your Personal Data records, please contact our Data Protection Officer. Once we receive your notice that you wish to withdraw consent, we will contact you within  days to acknowledge receipt of your withdrawal notice and within  days to inform you of the likely consequences of your withdrawal of your consent. We will cease to use and share your Personal Data within  days after our acknowledgement of receipt of your withdrawal notice. We will also inform any third parties to stop using and sharing your Personal Data. If we require more information from you in order to respond to your request for withdrawal of consent, we will contact you within  days after our acknowledgement of receipt of your withdrawal notice to obtain the necessary information from you.
If you withdraw your consent to any or all usage or disclosure of your Personal Data, depending on the nature of your request, Neo Group may not be in a position to continue to provide its products and services to you, or to administer any contractual relationship with you. However, please understand that your withdrawal of consent for purposes necessary to Neo Group to supply any products or services to you or to administer any contractual relationship with you may carry legal or practical consequences, which will continue to apply.
Please understand that after your withdrawal of consent, we will continue to retain your Personal Data for any legal purposes in accordance with any applicable laws.
3.2 Access to your Personal Data
You may request access to your Personal Data records, but we may charge an administrative cost to respond to your request for information, such as the printing or postage and any costs that we may incur in order to respond to your requests. We will inform you on the reasonable fee to be paid upon our receipt of your request for information. Once we receive payment of the administrative fee, we will respond to your request for information within  days from the date of our receipt of payment of the administrative fee. If we require more time to respond to your request for information or if we require more information from you in order to respond to your request, we will contact you within  days from the date of our receipt of payment of the administrative fee to inform you of our estimated time of response or to obtain the necessary information from you. We will use our reasonable endeavours to respond to your request as soon as possible.
3.2 Updates & Correction to your Personal Data
We take all reasonable measures to ensure that your Personal Data remains accurate, complete and up-to-date. If there is any change or update in your Personal Data, please write to our Data Protection Officer and provide your name and email address / postal address for us to contact you, the nature of our relationship with you and the Personal Data for which there has been a change, update or correction. As it is important for us that the Personal Data that we have about you is accurate and complete, we may contact you if we require supporting documentation from you.
Section 4: Security And Retention
Neo Group maintains a range of security safeguards and practices to ensure the integrity and confidentiality of your Personal Data and to protect it from loss, misuse, accidental or unauthorised access, collection, disclosure, copying, alteration or destruction of the Personal Data.
Some of the ways we protect Personal Data include:
- external and internal premises security;
- restricting access to Personal Data only to authorised persons who need it to perform their day to day functions; and
- maintaining technology products to prevent unauthorized computer access or damage to electronically stored information, such as requiring identifiers and passwords, firewalls and anti-virus software
Please be aware that no method of transmission over the Internet or method of electronic storage is fully secure. While we cannot guarantee 100% security, we strive to protect the security of your information and are constantly reviewing and enhancing our information protection measures.
For unsuccessful job applicants, Neo Group will retain your Personal Data for no longer than one (1) year for the purposes of evaluating your suitability for future job openings with Neo Group, unless you inform us otherwise.
Section 5: Governing Law
This Policy is governed by the laws of Singapore. You consent to submit to the exclusive jurisdiction of the Courts of Singapore in any dispute relating to this Policy.
Amendments and Updates of the Policy
We may amend this Policy from time to time to ensure that this Policy is consistent with any developments to the way Neo Group uses your Personal Data or any changes to the laws and regulations applicable to Neo Group. We will make available the updated Policy on our web site. All communications, transactions and dealings with us shall be subject to the latest version of this Policy in force at the time.