PRIVACY AND DATA PROTECTION POLICY

Hong Ye Group of Companies and our subsidiaries ((hereinafter collectively referred as“we”, “our”, “us”, “We”, “Our”, “Us”, "Hong Ye Group Pte. Ltd, "YY Life Pte. Ltd.” ) value the information you have provided us or permitted us to collect. We strive to protect your privacy while providing you with the best service and experience we can provide. All such personal information in our possession is collected, valued, used, disclosed and protected in accordance with the Singapore Personal Data Protection Act 2012 ("PDPA").

This Privacy and Data Protection Policy applies to all is intended to apply to all personal data submitted by you, third parties authorised by you via www.hongyegroup.com.sg, via its sub-domains, and any other websites, media platforms, applications including the YYCircle Mobile Application operated by us (hereinafter collectively referred to as the "Platforms") and any personal data that we receive from other third parties.

By visiting or using any of the Platforms, you are deemed to agree to the terms of this Privacy and Data Protection Policy. Please review this Privacy and Data Protection Policy carefully prior to visiting or using any such Platforms or otherwise providing any personal data.

INTRODUCTION TO THE PDPA

In Singapore, Personal data is protected under the Personal Data Protection Act 2012 (PDPA).

The PDPA establishes a data protection law that constitute various rules governing the collection, use, disclosure and handling of personal data. It acknowledges both the rights of individuals to protect their personal data, including rights of access and correction; and the requirements of organisations to collect, use or disclose personal data for legitimate and reasonable purposes.

In accordance to Advisory Guidelines on the Personal Data Protection Act (“PDPA”) for NRIC and Other National Identification Numbers (“NRIC Guidelines”), organisations are typically not allowed to collect, use or disclose an individual’s NRIC number (or copy of NRIC) from 1st of September 2019 unless:

a. required under the laws in Singapore (or an exception under the PDPA applies); or

b. necessary to accurately establish or verify the identity of the individual to a high degree of fidelity, where the failure to do so would pose a significant safety or security risk or significant impact or harm to an individual and/or organisation.

1. PERSONAL INFORMATION AND OTHER RELEVANT DATA COLLECTED

Personal data as defined in the PDPA refers to data whether genuine or not, about an individual who can be identified from either that particular data, or from that data and other information which we have or likely have access to. Personal data is collected where reasonably necessary for our functions and activities. Personal data that we may hold include the following:

2. USE OF YOUR PERSONAL DATA

We collect personal data for various purposes. Without limitation, these purposes include:-

3. SHARING YOUR PERSONAL DATA

In the course of providing our services and products to you, we may need to disclose your personal data with classes of internal stakeholders, external parties or individuals. The reasons for which we may disclose your personal data are set out under section 2 above. The possible classes of internal stakeholders, external parties or individuals we may share your personal data with include without limitations, to the following:-

4. THIRD PARTY LINKS

Our Platforms may, from time to time, contain links to and from the websites of our partner networks, advertisers, affiliates and third party service providers.

You may sign up with our Platforms through sign-in services such as Facebook connect or Google. This service will authenticate your identity and provide you the option to share personal information with us (such as your name and contact details) to pre-set our sign-up form.

Please note that these websites and any services that may be accessible through them have their own privacy policies and we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services. Please check these policies before you submit any personal data to these websites or use these services.

5. SECURITY

We will protect your personal data using industry standard precautions from theft, loss, misuse, disclosure, alteration and unauthorised access. While the transference of electronic data over the internet has inherent risks, we use reasonable precautions to ensure your personal data is not subject to unnecessary risks.

We although endeavor to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches over the internet, or any electronic storage methods. You have a personal responsibility to safeguard your passwords to the Platforms.

6. RETENTION

We will retain your personaldata for as long as necessary in order to fulfil the purpose for which it was collected, or as required for any legal or business purposes under relevant laws.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

7. ACCESS, UPDATE, WITHDRAWAL OF CONSENT

Understand that you may have different privacy concerns, you are entitled to be provided, upon request;

(a) access to some or all your personal data that is in our possession or control; or

(b) information about the ways in which that personal data has been or may have been used or disclosed by us within a year before the date of your request

You must submit a request to our data protection officer, whose contact details are set out in section 10 below, if you subsequently decide to request access to your personal data, update your personal data or withdraw your consent for us to collect, use and/or disclose your personal data, whether partial or in full. Please note that it may take up to 30 business days after receipt of your request to process your request. We may require further information from you to accurately verify your identity before processing your request. Kindly also take note that:-

a) your updated personal data, will also be sent to all relevant parties which we had originally disclosed to them within a year before the date of the update, unless the relevant parties have no more legal or business purposes for the personal data.

b) the PDPA exempts certain types of personal data from being subject to your access request.

c) Should your withdrawal of consent result in any legal consequences arising from such withdrawal, and depending on the extent of your withdrawal of consent, it may result in the discontinuation on your existing relationship with us.

8. RIGHTS TO AMEND THIS PRIVACY POLICY

We reserve the right to amend this Privacy and Data Protection Policy at any time. If material changes are made to this Privacy and Data Protection Policy, they will be posted on this page and date stamped. We encourage you to review this page periodically in order for you to stay notified of any changes.

Your continued use of the Platforms and acceptance of our services after any changes to this Privacy and Data Protection Policy constitutes your consent to any such changes, to the extent such consent is not otherwise provided.

9. COMPLAINT PROCESS

If you have any complaint or feedback regarding about how we handled your personal data or about how we are complying with the PDPA, feel free to contact us for clarifications at section 10 below via the company’s DPO.

We will certainly strive to deal with any complaint or feedback that you may have fairly and promptly.

10. CONTACT US

If you have comments or questions about this Privacy and Data Protection Policy statement, or wish to submit a request mentioned in paragraph 7 above, please contact our data protection officer at:

Email address: dpo@hongyegroup.com.sg
Telephone number: (+65) 66046896
Address: 60 Paya Lebar Road #05-43 Paya Lebar Square Singapore 409051

11. GOVERNING LAW AND JURISDICTION

Nothing in this Privacy and Data Protection Policy shall limit your rights under the Personal Data Protection Act 2012 of Singapore, or any other data protection or privacy related law that is applicable to you. This Privacy Policy shall be governed by the laws of the Republic of Singapore and you agree to submit to the exclusive jurisdiction of the Singapore courts.