STC’s Personal Data Privacy Notice

1. Privacy Commitment

   We at Singapore Theatre Company Ltd (STC), formerly Singapore Repertory Theatre and its various divisions (The Little Company, The Young Company, Centre for Creative Learning and KC Arts Centre – Home of SRT) are committed to safeguarding the personal data you have provided us and it is our responsibility to properly manage, protect and process your personal data. We have developed the following Privacy Notice to deal with issues which may concern you.

   This Data Protection Notice (“Notice”) sets out the basis which Singapore Theatre Company (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of our customers in accordance with the Personal Data Protection Act (“PDPA”). This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.

2. Personal Data

"Personal Data" is defined under PDPA to mean data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access.

We may collect additional personal data about you that you knowingly and voluntarily provide in connection with certain activities at and/or transaction with SRT or our website.

We will collect your personal data in accordance with the PDPA either directly from you or your authorised representatives, and/or through our third party service providers (e.g. ticketing agents or survey companies). We will notify you of the purposes for which your personal data may be collected, used, disclosed and/or processed, as well as obtain your consent for the collection, use, disclosure and/or processing of your personal data for the intended purposes, unless an exception under the law permits us to collect and process your personal data without your consent. 

1. As used in this Notice:

“customer” means an individual who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us; and

“personal data” means data, whether true or not, about a customer 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.

2. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include name, email address, nationality and any other key information that is required for the ease of communications.

3. Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits)

3. Collection, Use and Disclosure of Personal Data

We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).

We may collect and use your personal data for the purposes of managing your relationship with us.

(collectively, the "Purposes")
As for other purposes for which we may use, disclose or process your personal data that has not appeared above, we will notify you of such other purpose at the time of obtaining your consent, unless processing of your personal data without your consent is permitted by the PDPA or by law.
In order to conduct our business operations more smoothly and to fulfil the above-said Purposes, we may also be disclosing the personal data you have provided to us to our third party service providers, agents and/or our affiliates or related corporations and/or sponsors, and/or other third parties whether sited in Singapore or outside of Singapore, for one or more of the above-stated Purposes. Such third party service providers, agents and/or affiliates or related corporations and/or sponsors and/or other third parties would be processing your personal data either on our behalf or otherwise, for one or more of the above-stated Purposes.

• Communicating with you on your enquiries, sending marketing, advertising and promotional information and materials relating to products, events, productions, shows, concerts, and/or services that we, our partners and/or third party organisations with whom we are collaborating, may be selling or marketing.
• Administrative matters on your ticket purchases, managing your status as a Friend of SRT and/or processing your sign-ups/registrations for workshops, events, activities, mailing lists, etc.
• Conducting market research, data analytics, data mining, data profiling and customer satisfaction surveys to enable SRT to improve our products, services and customer service, to develop new products and services, and to provide customized and personalised products and services to you; and
• Any other purposes that we notify you of at the time of obtaining your consent.

4. Specific Issues for the Disclosure of Personal Data to Third Parties

We may disclose your personal data where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods and services requested by you.

• Cases in which the disclosure is required or authorised based on the applicable laws and/or regulations
• Cases in which the purpose of such disclosure is clearly in your interests, and if consent cannot be obtained in a timely way;
• Cases in which the disclosure is necessary to respond to an emergency that threatens the life, health or safety of yourself or another individual;
• Cases in which the disclosure is necessary for any investigation or proceedings;
• Cases in which the personal data is disclosed to any officer of a prescribed law enforcement agency, upon production of written authorisation signed by the head or director of that law enforcement agency or a person of a similar rank, certifying that the personal data is necessary for the purposes of the functions or duties of the officer;
• Cases in which the disclosure is to a public agency and such disclosure is necessary in the public interest; and/or
• where such disclosure without your consent is permitted by the PDPA or by law.

We respect the confidentiality of the personal data you have provided to us. In that regard, we will not disclose your personal data to third parties without first obtaining your consent permitting us to do so. For more information on the exceptions, you are encouraged to peruse the Second, Third and Fourth Schedules of the PDPA which is publicly available at https://sso.agc.gov.sg/Act/PDPA2012
Where we disclose your personal data to third parties with your consent, we will employ our best efforts to require such third parties to protect your personal data.

5. Access To and Correction of Personal Data

You have the right to be informed about how we use your data. We cover all of the important points in this privacy notice but if you have any questions, then don’t hesitate to email us at ooffice@singaporetheatrecompany.sg.

If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer by submitting a written request to office@singaporetheatrecompany.sg. Please note that we will need enough information from you in order to ascertain your identity as well as the nature of your request.

Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.

We will respond to your request as soon as reasonably possible. In general, our response will be within three (3) business days. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

6. Withdrawing Your Consent

The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer. To make a request for any of the above, please email us at office@singaporetheatrecompany.sg.

Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within three (3) business days of receiving it.

Paper Disposal (Physical): For personal data stored on physical media and in paper form, PDPC’s Advisory Guidelines on the Key Concepts in the PDPA, advises organisations to ensure proper disposal of the documents that are no longer needed, through shredding or other appropriate means.  SRT disposes of personal data stored on by putting the paper through a paper shredder that produces a resultant shredded piece size of 175mm² .

Electronic Disposal: Data erasure is associated with electronic media. SRT takes into account the disposal method where data cannot be recovered (partially or fully). SRT also works with an external IT solutions company that supports necessary erasure/reformatting of hardware for the disposal of electronic data.

While we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described above.

Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

7. Protection of Personal Data

To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as minimised collection of personal data, authentication and access controls (such as good password practices, need-to-basis for data disclosure, etc.), encryption of data, up-to-date antivirus protection, web security measures against risks, usage of one time password(otp)/2 factor authentication (2fa)/multi-factor authentication (mfa) to secure access, and security review and testing performed regularly.

You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

8. Accuracy of Personal Data

We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.

9. Retention of Personal Data

We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.

We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.

10. Transfers of Personal Data Outside of Singapore

We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.

11. Our Contact Details

You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:

Name of DPO: Zach Ng
Contact No.: 6221 5585
Email Address: office@singaporetheatrecompany.sg

12. Effect of Notice and Changes to Notice

This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.

We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.

 

Effective date: 17 Aug 2023

Last Updated: 17 Aug 2023

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