Data Protection Policy

This Data Protection Policy (the “Policy”) applies to the collection, use and disclosure of an individual customers Personal Data (hereinafter defined) arising from goods and/or services offered by Geewax Technology Pte Ltd (“Geewax Technology”), including, but not limited to the WePass group of apps (e.g., WePass Singapore BTT, WePass Singapore FTT, etc).

1. General

1.1 This Policy statement provides information on the obligations and policies of Geewax Technology in respect of an individual customers Personal Data. Geewax Technology undertakes to use reasonable efforts in applying, where practicable, those principles and the processes set out herein to its operations.

1.2 Geewax Technology’s officers, management, and members of staff shall use reasonable endeavours to respect the confidentiality of and keep safe any and all Personal Data collected, stored, disclosed, and/or used for, or on behalf of, Geewax Technology, shall use reasonable endeavours to ensure that all collection, storage, disclosure, and/or usage of Personal Data shall be done in an appropriate manner and in accordance with the Act and this Policy.

1.3 By interacting with us, submitting information to us, or signing up for any products or services offered by us, you agree and consent to Geewax Technology as well as to its respective representatives and/or agents (“Representatives”) (collectively referred to herein as “Geewax Technology”, “geewax.tech”, “us”, “we” or “our”) collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to Geewax Technology authorised service providers and relevant third parties in the manner set forth in this Policy Statement.

1.4 This Policy supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your Personal Data, and your consents herein are additional to any rights which we may have at law to collect, use or disclose your Personal Data.

1.5 For the purposes of this Policy, in line with the provisions under the Singapore Personal Data Protection Act 2012 (No. 26 of 2012) (the “Act”), “Personal Data” shall mean data, whether true or not, about an individual customer who can be identified from that data; or from that data and other information which an organisation has or is likely to have access. Such Personal Data shall also refer to that which is already in the possession of Geewax Technology or that which shall be collected by Geewax Technology in future.

2. Contacting the Data Protection Officer

2.1 Where you legitimately request access to and/or correction of Personal Data relating to you, such Personal Data which is in the possession and control of Geewax Technology, Geewax Technology shall provide and/or correct that data in a reasonable time and manner in accordance with its standard procedures as stated hereinafter.

2.2 In accordance with the Act, Geewax Technology has established a process for receiving and responding to any query or complaint that may arise with respect to the application of this Act. To ensure that Geewax Technology receives your complaints and enquiries, please send the same via email to the Data Protection Team of Geewax Technology at the following email address: privacy -at- geewax.tech

2.3 Please note that if your personal data has been provided to us by a third party (e.g. a member via a referral process), you should contact that individual to make such queries, complaints, and access and correction requests to Geewax Technology on your behalf.

2.4 Should you not wish Geewax Technology to use your Personal Data for any of the purposes listed in Clauses 3.2 to 3.4, or not to receive promotional materials from Geewax Technology, you may opt out by sending a clearly worded email to the Data Protection Team via the email address provided in Clause 2.2. Your request shall be processed within a reasonable time.

3. Statement of Practices

3.1 As part of its day-to-day activity, Geewax Technology may collect from you, through various means, including via our websites, smart phone applications, and/or any forms used by Geewax Technology from time to time, some or all of the following Personal Data:

We may choose to use cookies on our websites to track website visitorship and experience. Most web browsers are designed to accept cookies. If you do not wish to receive any cookies, you may set your browser to refuse it.

3.2 The above Personal Data mentioned in Clause 3.1 is collected for any purposes in connection with the services provided by us from time to time and to ascertain if you are eligible for discounts, privileges or benefits or other related purposes; to conduct market research and analysis; for direct marketing through voice calls; text messages; email; direct mail and facsimile messages; for payment and/or credit control purposes; to notify you of any changes to our policies or services which may affect you; to respond to queries and feedback; for identification and club access; maintaining and updating your membership details; and informing you of new developments, services, promotions of Geewax Technology and other third parties which we are associated with.

3.3 In order to carry out the functions described above, Geewax Technology may, from time to time, disclose your Personal Data between the Geewax Technology collection of companies.

3.4 Without derogating from any of the above, Geewax Technology may also disclose your Personal Data to the following third parties:

3.5 Geewax Technology may disclose your Personal Data to the above mentioned parties also in the occurrence of any of the following events:

3.6 In some instances, you may also be requested to provide certain Personal Data that may be used to further improve Geewax Technology products and services and/or better tailor the type of information presented to you. In most cases, this type of data is optional although, where the requested service is a personalised service, or provision of a product or dependent on your providing all requested data, failure to provide the requested data may prevent Geewax Technology from providing the service to you. This type of data includes, but is not limited to:

3.7 Under certain circumstances, telephone calls made to any of Geewax Technology companies to order and/or service hotlines and/or inquiry telephone numbers are recorded for the purposes of quality control, appraisal, and/or staff management and development. In such an event, by agreeing to this Policy, you hereby give your clear and unambiguous consent for the collection, use and disclosure of such Personal Data in accordance to this Policy.

4. Transfer of Personal Data Overseas

Your Personal Data may be processed by Geewax Technology, its affiliates, agents and third parties providing services to Geewax Technology, in jurisdictions insire and/or outside of Singapore. In this event Geewax Technology will comply with the terms of the Act.

5. Accuracy of Personal Data

Where possible, Geewax Technology will validate data provided using generally accepted practices and guidelines. This includes the use of check sum verification on some numeric fields such as account numbers or credit card numbers. In some instances, Geewax Technology is able to validate the data provided against pre-existing data held by Geewax Technology. In some cases, Geewax Technology is required to see original documentation before we may use the Personal Data such as with Personal Identifiers and/or proof of address. To assist in ensuring the accuracy of your Personal Data in the possession of Geewax Technology, please inform us of any updates of any parts of your Personal Data by sending a clearly worded email to the DPO at the email address provided at Section 2.2.

6. Protection of Personal Data

Geewax Technology uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your Personal Data and will not knowingly allow access to this data to anyone outside Geewax Technology, other than to you or as described in this Policy. However, Geewax Technology cannot ensure or warrant the security of any information you transmit to Geewax Technology and you do so entirely at your own risk. In particular, Geewax Technology does not warrant that such information may not be accessed, altered, collected, copied, destroyed, disposed of, disclosed or modified by breach of any of Geewax Technology physical, technical, or managerial safeguards.

7. Access and Correction of Personal Data

7.1 In accordance with Clause 2.1 of this Policy, you have the right to:

7.2 Geewax Technology reserves the right to charge a reasonable administrative fee in order to meet your requests under Clause 7.1. Upon payment of the requisite fee, your request shall be processed within a reasonable time.

7.3 If you wish to verify the details you have submitted to Geewax Technology or if you wish to check on the manner in which Geewax Technology uses and processes your personal data, Geewax Technology security procedures mean that Geewax Technology may request proof of identity before we reveal information. This proof of identity will take the form of full details of name and/or membership number and NRIC or Passport or Fin number. You must therefore keep this information safe as you will be responsible for any action which Geewax Technology takes in response to a request from someone using your respective details.

8. Storage, Deletion and Retention of Personal Data

8.1 Geewax Technology will delete, as reasonably possible, or otherwise anonymise any Personal Data in the event that the Personal Data is not required for any reasonable business or legal purposes of Geewax Technology and where the Personal Data is deleted from Geewax Technology electronic, manual, and other filing systems in accordance with Geewax Technology internal procedures and/or other agreements.

8.2 To request an account be permanently deleted expresses your intention to fully remove both your user account and any existing information relevant to your user account via email at the following email address privacy -at- geewax.tech. Deletion of the personal data cannot be undone, and Geewax Technology won’t be able to recover any of your data in the future should you make such a request.

9. Contacting you

To the extent that any of the communication means which you have provided Geewax Technology with (which may include, your telephone number and fax number) is/will be listed on the Do Not Call Registry (the “DNC”), by agreeing to this Policy through your signing of any e-forms or by any other means of indication, you hereby grant Geewax Technology your clear and unambiguous consent to contact you using all of your communication means you have provided to Geewax Technology including using via voice calls, SMS, Whatsapp, MMS, fax or other similar communications applications or methods, for the purposes as stated above in Clause 3.2. This will ensure your continued enjoyment of Geewax Technology promotional rates and services.

10. Change Policy

Geewax Technology reserve the right to alter any of the clauses contained herein in compliance with local legislation and/or to meet its global policy requirements, and for any other purpose deemed reasonably necessary by Geewax Technology. You should look at these terms regularly. If you do not agree to the modified terms, you should inform us as soon as possible of the terms to which you do not consent. Pending such notice, if there is any inconsistency between these terms and the additional terms, the additional terms will prevail to the extent of the inconsistency.

11. Governing Law

This Policy is governed by and shall be construed in accordance with the laws of Singapore. You hereby submit to the non-exclusive jurisdiction of the Singapore courts.

12. Miscellaneous

12.1 This Policy only applies to the collection and use of Personal Data by Geewax Technology. It does not cover third party sites to which we provide links, even if such sites are co-branded with our logo. Geewax Technology does not share your Personal Data with third party websites. Geewax Technology is not responsible for the privacy and conduct practices of these third party websites, so you should read their own privacy policies before disclosure of any Personal Data to these websites.

12.2 Geewax Technology will not sell your personal information to any third party without your permission, but we cannot be responsible or held liable for the actions of third party sites which you may have linked or been directed to Geewax Technology website.

12.3 Geewax Technology does not target and are not intended to attract children under the age of 18 years old. Geewax Technology does not knowingly solicit personal information from children under the age of 18 years old or send them requests for personal data.

If party is under 18 years of age, parent or legal guardian MUST write in to privacy@geewax.tech to request for the obtaining of “CONSENT FORM (UNDER 18 YEARS OLD)”.