This Policy sets out the manner in which Alpine United Pte. Ltd. (UEN 201416050W) and its subsidiaries, including but not limited to, Auto Germany Pte. Ltd. (UEN 199601763M), Alpine Automobiles Pte. Ltd. (UEN 199409544M), Alpine Motors Pte. Ltd. (UEN 199206358D), Alpine Car Rental Pte. Ltd. (UEN 199003483E), 1st Autoworks Pte. Ltd. (UEN 200000274Z), Alpine Insurance Agency Pte. Ltd. (UEN 200207117D), Alpine Financial Pte. Ltd. (UEN 201900573K), Carzy Financial Pte. Ltd. (UEN 201007721R), and Polar Engineering Pte. Ltd. (UEN 202335924R) (collectively, “Alpine United”) collects, uses, manages and protects Personal Data (as defined below) in compliance with the provisions of the Personal Data Protection Act 2012.

This Policy applies to all Individuals (as defined below) who provide Alpine United with Personal Data or whose Personal Data is otherwise collected, used and/or disclosed by Alpine United in connection with and/or for the purposes of its operations.

This Policy supplements but does not supersede or replace any previous consent which an Individual may have provided to Alpine United, nor does it affect any rights that Alpine United may have at law in connection with the collection, use and/or disclosure of any Individual’s Personal Data. Subject to that, Alpine United will not collect any Personal Data from an Individual unless the Individual has voluntarily chosen to provide us with it.

Alpine United may from time to time update this Policy to ensure it is consistent with its future developments or business purposes or to accommodate future changes to applicable legal or regulatory requirements. All updates to this Policy will be published at alpineunited.com.sg and appropriate notifications of any material revisions will be issued to the relevant persons. Subject to an Individual’s rights at law, the prevailing terms of the Policy from time to time shall apply. By continuing their relationship with Alpine United after any amendments have been introduced and published, Individuals shall be deemed to have accepted the Policy as amended.

For the avoidance of doubt, this Policy forms part of the terms and conditions, if any, governing an Individual’s specific relationship with Alpine United (“Terms and Conditions”) and should be read in conjunction with such Terms and Conditions. In the event of any conflict or inconsistency between the provisions of this Policy and the Terms and Conditions, the provisions of the Terms and Conditions shall prevail to the fullest extent permissible by law.

Table of Contents

Definitions

“Data Protection Officer” means the person designated to be responsible for ensuring that Alpine United complies with the PDPA;

“DNC Registry” means the Do-Not-Call registry maintained by the Personal Data Protection Commission, pursuant to the PDPA;

“Individuals” means natural persons, whether living or deceased, and “Individual” means any of them;

“Customers” mean the customers of Alpine United from time to time;

“PDPA” means the Personal Data Protection Act 2012;

“Personal Data” means data that is capable of identifying a natural person, whether on its own or in conjunction with other data that is accessible to Alpine United;

“Personnel” shall include any person engaged under a contract of service or contract for service with Alpine United, management personnel, permanent or temporary employees, as well as trainees, interns and volunteers engaged by Alpine United from time to time; and

“Potential Personnel” shall include any Individual who has submitted an application to be engaged by Alpine United as Personnel.

Personal Data Collected by Alpine United

Alpine United will only collect, use or disclose Personal Data about an Individual which it reasonably considers necessary for the relevant purposes underlying such collection, use or disclosure. Depending on the specific nature of an Individual’s interaction with Alpine United, Personal Data which Alpine United collects, uses or discloses concerning an Individual may variously include the following:

  1. the Individual’s name, gender and contact particulars, including telephone number(s), residential/mailing address(es) and email address;
  2. details of the Individual’s identification documents (such as, NRIC or passport numbers), and applicable visa or permits (such as employment pass, work permit, permanent residency status);
  3. details of the Individual’s employment history and academic qualifications;
  4. details of the Individual’s CPF, credit card or bank account;
  5. the name and contact particulars of the Individual’s next-of-kin;
  6. details of the Individual’s hobbies or special interest areas;
  7. the Individual’s network usage data and other information gathered automatically by our computer systems, including the Individual’s computer IP address, links visited and other activities conducted online or using our computer systems;
  8. photographs and video or CCTV recordings of the Individual; and
  9. other information which the Individual may provide to Alpine United, from time to time, in the course of such Individual’s interaction with Alpine United.

How Alpine United Collects Personal Data

Generally, Alpine United may collect, use and/or disclose Personal Data about an Individual for one or more of the following purposes:

Customers

  1. administering and managing customer relationships with Alpine United, including the provision of services to Customers;
  2. providing Customers with information about services, facilities and/or other benefits being offered or made available by Alpine United to Customers;
  3. providing Customers with information about third party and/or external vendor/supplier promotions, deals and/or other services being offered or made available to Customers, through partnerships, associations and/or other collaborations involving such third parties or external vendors/suppliers and Alpine United;
  4. organising and/or facilitating events or programmes involving Customers and/or verifying the eligibility of such Customers to participate in such events or programmes;
  5. tailoring activities or services available to match Customers’ preferences; and
  6. transmitting Personal Data to third parties engaged by or working in collaboration with Alpine United to facilitate any of the above-mentioned purposes.

Personnel

  1. administering and managing Personnel relationships with Alpine United, including the provision of services to Personnel;
  2. evaluating the performance of Personnel;
  3. undertaking staff training and quality assurance activities;
  4. providing Personnel with services, facilities and/or other benefits being offered or made available by Alpine United to such Personnel as well as information about such services, facilities and benefits; and
  5. transmitting Personal Data to third parties engaged by or working in collaboration with Alpine United to facilitate any of the above-mentioned purposes.

Potential Personnel

  1. administering and managing Alpine United’s relationship with Potential Personnel; and
  2. evaluating the suitability and eligibility of Potential Personnel to be engaged by Alpine United;

Event Participants

  1. administering and managing the event participant’s relationship with Alpine United;
  2. verifying the identity and eligibility of event participants;
  3. promotional and publicity purposes, including recording videos or taking photographs of participants at events; and
  4. transmitting Personal Data to third parties engaged by or working in collaboration with Alpine United to facilitate any of the above-mentioned purposes.

Visitors and Users of Alpine United’s Facilities

  1. recording and verifying the identity of visitors to Alpine United’s premises and users of Alpine United’s facilities; and
  2. monitoring the activities of visitors to Alpine United’s premises and users of Alpine United’s facilities.

General Business Purposes

  1. managing the administrative and business operations of Alpine United;
  2. facilitating the completion of transactions with Individuals;
  3. responding to complaints, queries and/or requests;
  4. conducting market research for statistical profiling and other purposes in order to improve Alpine United’s services;
  5. safety and security purposes;
  6. preventing, detecting or investigating any actual or suspected crime, fraud, misconduct, unlawful action, breach or dispute;
  7. record-keeping purposes;
  8. accounting or auditing purposes;
  9. legal purposes (including but not limited to obtaining legal advice and dispute resolution); and
  10. complying with laws, regulations, codes or guidelines binding on Alpine United, including disclosures to regulatory authorities or other public bodies; and
  11. transmitting Personal Data to third parties engaged by or working in collaboration with Alpine United to facilitate any of the above-mentioned purposes.

Verification of Personal Data & Notification of Changes

Where feasible, Alpine United will take reasonable steps to verify the accuracy of Personal Data received at the point of collection but Individuals remain primarily responsible and liable to ensure that all Personal Data submitted by them to Alpine United is complete and accurate. Information voluntarily submitted by an Individual to Alpine United shall prima facie be deemed complete and accurate.

Alpine United will also take reasonable steps to periodically verify Personal Data in its possession, taking into account the exigencies of its operations, but Individuals are nonetheless required to notify Alpine United, from time to time, of any applicable changes to such Personal Data.

Alpine United shall not be held liable for any inability on its part to provide services to an Individual who fails to ensure that his/her Personal Data submitted to Alpine United is complete and accurate or who fails to notify Alpine United of any relevant changes to such Personal Data.

Policy on Telephone Numbers Registered with the DNC Registry

Alpine United is prohibited from sending unsolicited telemarketing messages (“specified messages”) to Singapore telephone numbers through voice calls, text or fax messages registered on the DNC Registers unless Alpine United has obtained the relevant Individual’s clear and unambiguous consent in written or other accessible forms.

In compliance with the PDPA, Alpine United will not send specified messages to telephone numbers that appear on the DNC Registry unless the relevant Individual has given Alpine United clear and unambiguous consent to do so.

Alpine United will continue to contact Individuals at the telephone numbers provided to Alpine United in the limited circumstances allowed under the DNC Registry even if these telephone number are registered with the DNC Registry. Individuals who do not wish to receive such messages may notify Alpine United’s Data Protection Officer at .

Activities Undertaken Prior to 02 July 2014

Alpine United may use Personal Data of an Individual that was collected before 02 July 2014 for purposes for which the Personal Data was collected unless consent is withdrawn by that Individual.Alpine United will continue to use Personal Data of Customers, which had been collected before 02 July 2014, for its general business purposes and purposes relating to Customers. Customers who wish to withdraw their consent to Alpine United’s use of their Personal Data may contact Alpine United’s Data Protection Officer at .

Protection of Personal Data

Alpine United shall make reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks to Personal Data in its possession.

If Alpine United transfers Personal Data outside Singapore, Alpine United will take reasonable steps to ensure that such Personal Data transferred receives a standard of protection comparable to the protection received under the PDPA.

Alpine United will ensure that third parties who receive Personal Data from Alpine United protect such Personal Data in a manner consistent with this Policy and not use such Personal Data for any purposes other than those specified by Alpine United, by incorporating appropriate contractual terms in its written agreements with these third parties.

Alpine United is not responsible in any way for the security and/or management of Personal Data shared by Individuals with third party websites accessible via links on Alpine United’s website.

Contacting Alpine United: Access and Correction of Personal Data

Any Individual who:

  1. has questions or feedback relating to this Policy;
  2. would like to obtain access to his/her Personal Data held by Alpine United;
  3. would like to obtain information about the ways in which his/her Personal Data held by Alpine United has been or may have been used or disclosed by Alpine United in the year preceding the request; and/or
  4. would like to update or make corrections to his/her Personal Data held by Alpine United,

should contact Alpine United’s Data Protection Officer at .

Individuals should note that Alpine United is not required, under the PDPA, to provide access and correction to Personal Data in certain situations.

The PDPA allows and Alpine United reserves the right to charge a reasonable fee for the handling and/or processing of access requests by an Individual pursuant to paragraphs (b) or (c) above.

Alpine United may require up to 3 weeks from the date of the Individual’s request to respond and effect any change.

Governing Law

This Policy shall be governed by and construed in accordance with the laws of Singapore. Any dispute arising out of or in connection with this Policy including any question regarding its existence, validity or termination, shall be referred to and finally resolved by the Courts of Singapore.

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