The purpose of this document ("Data Protection Policy") is to inform you how SMRT Corporation Ltd manages Personal Data (as defined below) in accordance with the Singapore Personal Data Protection Act 2012. Please take a moment to read this Data Protection Policy so that you are aware of and understand the purposes for which we collect, use and disclose your Personal Data.
By interacting with us, submitting information to us or signing up for any promotions or services offered by us, you agree and consent to SMRT Corporation Ltd and its related corporations (collectively, the "Companies"), as well as our respective representatives and/or agents ("Representatives") (collectively referred to herein as "SMRT", "us", "we" or "our") collecting, using, disclosing and sharing your Personal Data amongst ourselves, and disclosing such Personal Data to our authorised service providers and relevant third parties in the manner set forth in this Data Protection Policy.
This Data Protection Policy supplements but does not supersede nor replace any other consents you may have previously provided to SMRT in respect of your Personal Data, and your consents herein are cumulative and additional to any rights which we may have under applicable law to collect, use or disclose and/or otherwise process your Personal Data.
We may from time to time update this Data Protection Policy to ensure that this Data Protection Policy is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements, and may notify you of updates in any form we deem appropriate or, where required by applicable law, by posting a notice or reaching you via other forms of communication (e.g. sending you a SMS message or email or giving you a phone call) according to such contact particulars that we may have for you in our records from time to time. To the maximum extent permissible under applicable law, you agree to be bound by the prevailing terms of the Data Protection Policy as updated from time to time on our website and/or as you may be notified. Hence, please check back regularly for updated information on the handling or processing of your Personal Data.
Use of our electronic services (including without limitation our websites, platforms, and applications) is also subject to our Terms of Use, available at https://www.smrt.com.sg/terms-of-use/ or via such other means as we may specify from time to time. For more information about our use of cookies, please refer to our Terms of Use.
1.1 In this Data Protection Policy, "Personal Data" refers to any data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which we have or are likely to have access, including data in our records as may be updated from time to time.
1.2 Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us) your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address, transactional data, and any other information relating to any individuals which you have provided us (including in the form of biometric data), or via other forms of interaction with us.
2.1 Generally, we collect Personal Data in the following ways:
(a) when you submit any form, including but not limited to registration, application, or declaration forms;
(b) when you enter into any agreement or provide other documentation or information in respect of your interactions and transactions with us, or when you use our services;
(c) when you interact with our staff and Representatives, including our customer service officers and other representatives, for example, via telephone calls (which may be recorded), letters, fax, face-to-face meetings, email, and/or via our electronic services;
(d) when your images are captured by us via CCTV cameras while you are within our premises or photographs or videos taken by us or our Representatives when you attend events hosted by us;
(e) when you interact with us or use our services provided through online and other technology platforms, such as websites, social media platforms and mobile application software;
(f) when you share comments or feedback with us, such as through our electronic services or social media platforms, by contacting our Representatives;
(g) when you request that we contact you, that you be included in an email or other mailing list; or when you respond to our requests for additional Personal Data, our promotions, and/or other initiatives;
(h) when you are contacted by, and respond to, our marketing Representatives, agents, and/or other service providers;
(i) when you submit an employment application, and/or your details in connection with an independent contractor engagement or when you provide documents or information (including without limitation your resume, your track records and expertise, employment history, and/or curriculum vitae) in connection with any appointment, engagement, or position with us, or when you attend interviews with us;
(j) when we receive your Personal Data from business partners, public agencies, your employer or other third parties;
(k) where allowed under applicable law, when we seek information from third parties about you in connection with your relationship with us, including without limitation in connection with our services and/or employment applications submitted to us, for example, from business partners, public agencies, your ex-employer, and/or the relevant authorities; and/or
(l) when you submit your Personal Data to us for any other reasons.
2.2 If you provide us with any Personal Data relating to a third party (e.g. information of spouse, minors, children, parents, employees and/or authorised persons), by submitting such information to us, you represent to us that you have obtained the consent of such third party to you providing us with their Personal Data, and for the collection, use and disclosure of their Personal Data for all purposes set out in our herein and by or for the benefit of the persons referenced herein.
2.3 You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure to do so on your part may result in our inability to provide you with the products and/or services which you have requested.
3.1 Generally, SMRT collects, uses and discloses your Personal Data for the following purposes:
(a) responding to, processing and handling your complaints, queries, requests, feedback and suggestions or otherwise providing customer support;
(b) managing the administrative and business operations of the Companies and complying with our internal policies and procedures;
(c) facilitating business asset transactions (which may extend to mergers, acquisitions, debt or asset sales) involving any of the Companies;
(d) matching any Personal Data held which relates to you for any of the purposes listed herein;
(e) verifying your identity and/or facilitating and carrying out due diligence checks;
(f) requesting feedback or participation in surveys, as well as conducting market research and/or analysis for statistical, profiling or other purposes for us to design our products, understand commuters' behaviour, customer behaviour, preferences, and market trends, and to review, develop and improve the quality of our products and/or services;
(g) preventing, detecting, and investigating crime (including fraud and money-laundering or terrorist financing), analysing and managing the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances);
(h) project management, conducting audits, reviews and analysis of our internal processes, action planning, analysing and managing commercial risks and managing and preparing reports on incidents and accidents;
(i) providing media announcements and responses;
(j) organising promotional events;
(k) in connection with any claims, actions or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution), and/or protecting and enforcing our contractual and legal rights and obligations;
(l) meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies, and/or assisting with any enquiries, requests, or investigations by relevant authorities (including but not limited to disclosures to regulatory bodies or conducting audit checks, surveillance, investigation, and/or due diligence); and/or
(m) any other purpose relating to or reasonably necessary for any of the above.
These purposes may also apply even if you no longer utilise any of our services.
3.2 In addition, SMRT collects, uses and discloses your Personal Data for the following purposes, depending on the nature of our relationship:
(a) If you are a customer or prospective customer of SMRT (for example, if you are a passenger on our trains, buses or taxis):
(i) processing taxi bookings;
(ii) providing customer service and administering benefits (including but not limited to fare ticketing and providing rewards, rebates and other promotions);
(iii) verifying and processing your personal particulars and payment in relation to the purchase or provision of goods and/or services;
(iv) providing you with goods and/or services which you have purchased or requested to receive, and to provide content to you which may be relevant to you (including to personalise and customise your experience based on your interactions with us), your profile information and preferences, and other content you submit from time to time;
(v) communicating with you and informing you of changes and development to our policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to the products and services offered to you;
(vi) managing and preparing reports on incidents, offences and accidents; and/or
(vii) investigating and processing compensation claims;
(b) If you are an employee, business partner, director or representative of an organisation that is a corporate customer, business partner or otherwise has a corporate relationship with SMRT:
(i) conducting background screenings and due diligence checks; and/or
(ii) facilitating the bidding of tenders;
(c) If you are a taxi partner with SMRT:
(i) administration in relation to the leasing of taxis (including but not limited to processing taxi licenses and rental payments);
(ii) facilitating the continuation or termination of the leasing relationship (including but not limited to maintenance of records, processing lease renewals and providing regular updates and communications);
(iii) administering programmes and benefits;
(iv) facilitating the advertising of our taxi services;
(v) processing claims;
(vi) management of vehicle servicing;
(vii) facilitating training, learning and talent development;
(viii) facilitating the enforcement of repayment obligations and approval of bad debts; and/or
(ix) enabling us to respond to emergencies;
(d) If you are a tenant at our retail premises:
(i) facilitating the leasing of properties;
(ii) administration in relation to the leasing of properties (including but not limited to handing and taking over of properties and processing payments); and/or
(iii) facilitating the continuation or termination of the leasing relationship (including but not limited to maintenance of tenant records, processing tenancy renewals and providing regular updates and communications);
(e) If you are an existing or prospective external service provider, vendor, contractor, subcontractor or consultant or an employee thereof (where applicable) of SMRT:
(i) providing information on upcoming tenders;
(ii) procuring, awarding and managing project tenders (including but not limited to procuring approval from relevant government regulators, government ministries, statutory boards or authorities);
(iii) managing the outsourcing relationship;
(iv) facilitating training, learning and talent development;
(v) processing and payment of invoices and claims;
(vi) managing project developments and communications;
(vii) supervising operational matters; and/or
(viii) managing the security of the premises (including but not limited to conducting security screening and issuing contractor access passes);
(f) If you submit an application to us as a candidate for employment / your engagement as an independent contractor:
(i) conducting interviews;
(ii) processing your application / engagement which includes pre-recruitment / pre-engagement checks involving your qualifications and facilitating interviews;
(iii) providing or obtaining employee / customer references and for background screening;
(iv) assessing your suitability for the position or engagement applied for; and/or
(v) managing and/or processing referrals; and/or
(vi) verifying your identity and accuracy of your personal details and other information provide;
(g) if you are our employee, independent contractor, temporary staff, intern, or trainee:
(i) administrative, human resources related and support processes relating to your employment or relationship with us, including managing and terminating your employment or appointment, staff benefits (including travel, manpower, business continuity and logistical management or support), processing expense claims, administering insurance applications, leave administration, training, learning and talent development, resolving grievances, and planning and organising corporate events;
(ii) investigating any acts or defaults (or suspected acts or defaults), or contraventions of our internal or external compliance obligations;
(iii) providing you with tools and facilities to enable or facilitate the performance of your duties, and monitoring your use of such tools and facilities;
(iv) ensuring business continuity, including compiling and publishing internal directories and emergency contact lists;
(v) ensuring that our operations function in a secure, efficient and effective manner (including examining or monitoring any computer software and hardware installed by us, located in our premises, or under our control, your activities on such computer software and hardware, your internet access, your work emails and personal digital and storage devices); and/or
(vi) performing obligations under or in connection with your contract of employment or relationship with us, such as payment of remuneration and tax;
(h) If you are a SMRT shareholder:
(i) maintaining statutory registers and managing the publication of shareholder statistics on annual reports and circulars; and/or
(ii) facilitating shareholder analysis (including but not limited to profiling shareholders, identifying investors and scheduling shareholder meetings);
(i) If you sit on the SMRT Board of Directors:
(i) facilitating appointment to the Board (including but not limited to managing the publication of directors' statistics on annual reports and circulars); and/or
(ii) facilitating the execution of duties and administrative matters (including but not limited to maintaining statutory registers, delivering meeting agendas, processing both local and overseas tax filing and organising corporate events); and/or
(j) processing of your Personal Data in relation to any of the purposes stated above.
3.3 In addition, where permitted under applicable law, we may also collect, use and disclose your Personal Data for the following purposes (which we may describe in our documents and agreements as "Additional Purposes" for the handling of Personal Data):
(a) providing or marketing promotions, products, services and/or benefits to you, including loyalty and reward programmes as well as joint marketing and/or cross-promotions with third parties;
(b) matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision or offering of promotions, products and services, whether by SMRT or other third parties;
(c) organising marketing and promotional events, administering contests and competitions, and personalising your experience at SMRT's touchpoints;
(d) sending you details of promotions, services, special offers and rewards, either to our customers generally, or which we have identified may be of interest to you;
(e) conducting market research, understanding and analysing customer behaviour, location, preferences and demographics for us to offer you products and services as well as special offers and marketing programmes which may be relevant to your preferences and profile; and/or
(f) recommending, identifying and/or contacting you to inform you of products, services, special offers and rewards, either to our customers generally, or which we have identified may be of interest to you, or that are or may be relevant to you, in any case including on behalf of third parties, or sharing your Personal Data with such third parties or their service providers for them to collect, use, disclose or process your Personal Data for any of such purposes.
3.4 If you have provided your Singapore telephone number(s) and you have (i) indicated that you consent to receiving marketing or promotional information via your Singapore telephone number(s), (ii) not registered with the Do Not Call Registry, or (iii) the sending of such marketing or promotional information is permissible under applicable laws and regulations, then from time to time, SMRT may contact you using such Singapore telephone number(s) (including via voice calls, text, fax or other means) with information about our promotions, products and services (including discounts and special offers). You have the right to withdraw your consent regarding the marketing or promotional information you receive at any time by contacting the appropriate Representative. Such requests will be processed within 21 days. Please note that after opting out, you may still continue to receive non-marketing messages, such as product updates and service notices as permitted under applicable laws and regulations.
3.5 In relation to particular products or services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we may collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.
4.1 SMRT will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, your Personal Data may be provided, for the purposes listed above (where applicable), to the following entities or parties, whether they are located overseas or in Singapore:
(a) SMRT's related corporations;
(b) companies or brokers providing services relating to insurance and/or reinsurance to SMRT;
(c) agents, contractors or third party service providers who provide operational services to SMRT, such as vehicle servicing and towing, courier services, telecommunications, information technology, advertising, payment, payroll, processing, training, market research, storage, archival, customer support investigation services or other services to SMRT;
(d) vendors or other third party service providers in connection with promotions and services offered by SMRT;
(e) any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to merger, acquisition, debt or asset sales) involving any of the Companies;
(f) banks, credit card companies, financial institutions, and their respective service providers;
(g) third party referrers;
(h) our co-brand and other business partners;
(i) our professional advisers such as our consultants, auditors and lawyers;
(j) relevant government regulators, government ministries, statutory boards or authorities and/or law enforcement agencies, whether local or overseas, including the Land Transport Authority, to comply with any directions, laws, rules, guidelines, regulations or schemes issued or administered by any of them;
(k) external business and charity partners in relation to corporate promotional events; and/or
(l) any other party to whom you authorise us to disclose your Personal Data to.
4.2 We may also share information about you in aggregate or anonymised form (such as generic aggregated demographic information regarding visitors and users) with the abovementioned parties.
5.1 In addition to the matters set forth above, subject to and in accordance with applicable law, you shall be deemed to have consented to us collecting, using, disclosing and sharing amongst ourselves your Personal Data, and disclosing such Personal Data to our authorised service providers and relevant third parties:
(a) where in response to a request for your Personal Data in connection with identified purposes, you voluntarily provide such Personal Data to us for such purpose(s) and it is reasonable that you would voluntarily provide such Personal Data; and
(b) where the collection, use and/or disclosure of your Personal Data is reasonably necessary for the conclusion and/or performance of a contract, between you and us or any other organisation entered into at your request, which may include recipients of your Personal Data not indicated in this Data Protection Policy.
6.1 In addition to and without limiting the consents you have provided to our collection, use and/or disclosure of your Personal Data for the purposes set out elsewhere in this Data Protection Policy, where permitted by applicable law, we may in accordance with the requirements thereof also collect, use and/or disclose your Personal Data as further detailed below including without consent, where we meet the requirements under applicable law:
(a) for our legitimate interests or the legitimate interests of another person (but not for sending you direct marketing messages unless you have otherwise provided your consent), including without limitation for the following purposes:
(i) any investigations or proceedings;
(ii) fraud detection and prevention;
(iii) entering into, managing or terminating an employment relationship or appointment;
(iv) to recover a debt owed by you to us or to pay a debt owed by us to you;
(v) to obtain legal services;
(vi) detection and prevention of misuse of services by users; and
(b) we may collect your Personal Data from any of the Companies, we may use your Personal Data, and any of the Companies may disclose your Personal Data to us, for improving our products, services, processes or business, understanding customer preferences and personalising experiences and recommendations (regardless whether you are an existing or prospective customer of any of the Companies).
7.1 If you:
(a) have any questions or feedback relating to your Personal Data or our Data Protection Policy (including without limitation our reliance on deemed consent or other bases for collecting, using, and/or disclosing your Personal Data);
(b) would like to withdraw your consent to any use of your Personal Data as set out in this Data Protection Policy; or
(c) would like to obtain access or make corrections to your Personal Data records,
please contact our data protection officer as follows: dpo@smrt.com.sg
7.2 Please note that if your Personal Data has been provided to us by a third party (e.g. a recruitment agency), you should contact such party directly to make any queries, feedback, and access and correction requests to us on your behalf.
7.3 If you withdraw your consent to any or all collection, use, and/or disclosure of your Personal Data, depending on the nature of your request, we may not be in a position to continue to provide our services to you and/or administer any contractual relationship in place. Such withdrawal of consent may also result in the termination of any agreements with you, and your being in breach of your contractual obligations or undertakings. Our legal rights and remedies in such event are expressly reserved. Please also note that withdrawing consent does not affect our right to continue to process Personal Data where such processing without consent is permitted or required under applicable laws.
8.1 This Data Protection Policy shall be governed in all respects by the laws of Singapore.