In this policy, “we”, “us”, “our” means Strides International Business Pte Ltd and its related corporations, “you”, “your” or “yours” means the persons to whom this policy applies.
The purpose of this policy is to inform you of how we manage your personal data. Please take a moment to read this policy so that you are aware of and understand the purposes 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 us, as well as our respective representatives and/or agents to collecting, using, disclosing and sharing amongst ourselves your Personal Data, and disclosing such Personal Data to our authorised service providers and relevant third parties according to this policy.
This policy supplements but does not supersede nor replace any other consents you may have previously provided to us regarding your Personal Data. Your consents are additional to any rights that we may have at law to collect, use, or disclose your Personal Data.
We may from time to time, update this policy to ensure that it is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the latest version of this policy on our website. Please check back regularly for the updated policy on the handling of your Personal Data.
1. Personal Data
In this 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.
Examples of such Personal Data include your name, NRIC, passport or other identification number, telephone number, mailing address, email address, biometric information and any other information relating to any individuals which you have provided. The Personal Data may be provided through any form or medium or through your interaction with us.
2. Collection of Personal Data
Generally, we collect Personal Data in the following ways:
(a) when you submit any form, including but not limited to application or declaration forms;
(b) when you interact with our staff, including our customer service officers and other representatives, for example, via telephone calls (which may be recorded), letters, fax, physical or virtual meetings and email;
(c) when your images are captured by us via CCTV or body-worn cameras while you are within our premises or photographs or videos taken by us or our representatives when you attend events hosted by us;
(d) when you use our services provided through online and other technology platforms, such as websites, social media platforms and mobile application software;
(e) when you request that we contact you, be included in an email or other mailing list; or when you respond to our request for additional Personal Data, our promotions and other initiatives;
(f) when you are contacted by, and respond to, our marketing representatives and agents and other service providers;
(g) when you submit an employment application or when you provide particulars or information in connection with your appointment as an officer, director or other representatives;
(h) when we receive your Personal Data from business partners, public agencies, your employer or other third parties;
(i) when we seek information from third parties about you in connection with your relationship with us, for example, from your ex-employer and the relevant authorities in relation to employment applications or from a credit bureau in relation to a business transaction; or
(j) 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, children, parents, employees and/or authorised persons), by submitting such information to us, you represent to us that you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes.
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 services which you have requested.
3. Purposes for the Collection, Use and Disclosure of Your Personal Data
3.1 Generally, we collect, use and disclose your Personal Data for the following purposes:
(a) responding to, processing and handling your complaints, queries, requests, feedback and suggestions;
(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;
(f) requesting feedback or conducting market research and/or analysis for statistical, profiling or other purposes for us to understand commuters behaviour, preferences and market trends, and to review, develop and improve the quality of our services;
(g) facilitating and carrying out due diligence checks;
(h) preventing, detecting and investigating crime and managing the safety and security of our premises and services (including but not limited to carrying out surveillance through CCTV or body-worn cameras and conducting security clearances);
(i) conducting audits, reviews and analysis of our internal processes, action planning and managing commercial risks;
(j) project management;
(k) providing media announcements and responses;
(l) legal purposes (including but not limited to obtaining legal advice, drafting legal policies and contracts and facilitating dispute resolution);
(m) meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on us (including but not limited to disclosures to regulatory bodies or conducting audit checks, surveillance, investigation, or due diligence); or
(n) any other purpose relating to any of the above.
3.2 In addition, we collect, use and disclose your Personal Data for the following purposes depending on the nature of our relationship:
(a) If you are a customer of us (for example, if you are a passenger on our trains, buses or taxis):
(i) processing taxi or private hire bookings;
(ii) providing customer service and administering benefits (including but not limited to fare ticketing and providing rewards, rebates and other promotions);
(iii) processing and managing customer feedback;
(iv) managing and preparing reports on incidents, offences and accidents;
(v) investigating and processing compensation claims; or
(vi) any other purpose relating to any of the above.
(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 us:
(i) conducting background screenings and due diligence checks;
(ii) facilitating the bidding of tenders; or
(iii) any other purpose relating to any of the above.
(c) If you are a taxi or private hire partner with us:
(i) administration in relation to the leasing of taxis (including but not limited to processing taxi licenses and rental payments); 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);
(ii) administering programmes and benefits;
(iii) facilitating the advertising of our taxi services;
(iv) processing claims;
(v) management of vehicle servicing;
(vi) facilitating training, learning and talent development;
(vii) facilitating the enforcement of repayment obligations and approval of bad debts;
(viii) enabling us to respond to emergencies; or
(ix) any other purpose relating to any of the above.
(d) If you are a tenant at our retail premises or an advertiser at our stations or on our trains, buses and taxis:
(i) facilitating the leasing of properties or the advertisement that you place;
(ii) administration in relation to the leasing of properties (including but not limited to handing and taking over of properties and processing payments); 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); or
(iii) any other purpose relating to any of the above.
(e) If you are our existing or prospective external service provider, vendor, contractor, subcontractor or consultant or an employee thereof (where applicable):
(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;
(viii) managing the security of the premises (including but not limited to conducting security screening and issuing contractor access passes); or
(ix) any other purpose relating to any of the above.
(f) If you submit an application to us as a candidate for employment
(i) conducting interviews;
(ii) processing your application which includes pre-recruitment checks involving your qualifications and facilitating interviews;
(iii) obtaining employee references and for background screening;
(iv) assessing your suitability for the position applied for;
(v) managing referrals; or
(vi) any other purposes relating to any of the above.
(g) If you are our shareholder:
(i) maintaining statutory registers and managing the publication of shareholder statistics on annual reports and circulars;
(ii) facilitating shareholder analysis (including but not limited to profiling shareholders, identifying investors and scheduling shareholder meetings); or
(iii) any other purpose relating to any of the above.
(h) If you are a member of our Board of Directors:
(i) If you are a member of our Board of Directors:
(ii) facilitating appointment to the Board (including but not limited to managing the publication of directors’ statistics on annual reports and circulars);
(iii) 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); or
(iv) purposes which are reasonably related to the aforesaid.
3.3 In addition, we may also collect, use and disclose your Personal Data for the following purposes (which we may describe in our policies and agreements as “Additional Purposes” for the handling of Personal Data):
(a) providing promotions, services and benefits to you, including promotions, loyalty and reward programmes;
(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 us or other third parties;
(c) administering contests and competitions, and personalising your experience at our touchpoints;
(d) organising marketing and promotional events or marketing our services to you;
(e) 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; or
(f) conducting market research, understanding and analysing customer behaviour, location, preferences and demographics for us to develop special offers and marketing programmes.
3.3 In addition, we may also collect, use and disclose your Personal Data for the following purposes (which we may describe in our policies and agreements as “Additional Purposes” for the handling of Personal Data):3.4 If you have provided your Singapore telephone number(s) and have indicated that you consent to receive marketing or promotional information via your Singapore telephone number(s), then from time to time, we may contact you using such Singapore telephone number(s) (including via voice calls, text, fax or other means) with information about our promotions and services (including discounts and special offers).
3.5 In relation to particular 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.
4. Disclosure of Personal Data
4.2 We 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) Our related corporations;
(b) companies or brokers providing services relating to insurance or reinsurance to us;
(c) agents, contractors or third party service providers who provide operational services to us, such as vehicle servicing and towing, courier services, telecommunications, information technology, advertising, payment, payroll, processing, training, market research, storage, archival, customer support, investigation services, credit management or other services to us;
(d) vendors or other third party service providers in connection with promotions and services offered by us;
(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) external banks, credit card companies and their respective service providers;
(g) third party referrals;
(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.
5. Contacting Us – Withdrawal of Consent, Access, and Correction of your Personal Data
5.1 If you:
(a) have any questions or feedback relating to your Personal Data or this policy;
(b) would like to withdraw your consent to any use of your Personal Data as set out in this policy; or
(c) would like to obtain access or make corrections to your Personal Data records,
please contact us as follows:
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.
5.2 If you withdraw your consent to any or all use 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, administer any contractual relationship in place, may also result in the termination of any agreements with you, and your being in breach of your contractual obligations or undertakings, and our legal rights and remedies in such event are expressly reserved.
6. Governing Law
6.1 This Data Protection Policy shall be governed in all respects by the laws of Singapore.