Privacy Policy

Privacy Policy

 

This privacy notice ("Notice") has been updated to clarify how Instant QR Menu ("we," "us," "our") collects, uses, discloses, or processes personal data of customers in accordance with the Personal Data Protection Act ("PDPA"). This Notice applies to personal data held or controlled by us, including personal data in the possession of the entities we have contracted with to collect, use, and disclose customer data for our purposes.

 

Personal Data

 

1. As used in this Notice:

   - "Customer" means an individual who contacts us by any means to learn more about the services we offer or who may have entered into a contract with us to provide any of the goods or services we offer; 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 your interactions with us, examples of personal data we may collect from you include name, residential address, email address, phone number, and other financial information.

 

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

 

Collection, Use, and Disclosure of Personal Data

 

4. We generally do not collect your personal data unless (a) it is provided to us voluntarily and directly by you or through an authorized third party acting on your behalf (your authorized representative) after (i) informing you (or your authorized representative) of the purposes of the data collection, and (ii) obtaining your written consent to collect and use your personal data for those purposes; or (b) collection and use of personal data is permitted or required without consent under the PDPA or other laws. We will seek your consent before collecting any additional personal data and before using your personal data for a purpose not notified to you (unless permitted or authorized by law).

 

5. We may collect and use your personal data for any of the following purposes:

   - Fulfilling obligations under or in connection with our provision of goods and/or services requested;

   - Verifying your identity;

   - Responding to inquiries and processing complaints and feedback from you;

   - Managing your relationship with us;

   - Processing payment or credit transactions;

   - Complying with any laws, regulations, business practices, guidelines, or rules applicable to us, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;

   - Any other purposes for which you have provided the information;

   - Disclosing it to any third party unrelated to us including service providers, our agents, relevant governmental and/or regulatory authorities, whether located in Singapore or overseas, for the purposes stated above; and

   - Any other incidental business purposes related to or in connection with the above.

 

6. We may disclose your personal data:

   - Where such disclosure is required to fulfill obligations under or in connection with our provision of goods and services requested by you; or

   - To third party service providers, agents, and other organizations with whom we have a relationship to perform any of the functions mentioned above.

 

7. The purposes mentioned in the preceding paragraphs may continue even in cases where our relationship with you has ended or changed (e.g., under contract) reasonably thereafter (including where applicable, a period enabling us to enforce our rights under a contract with you).

 

Relying on Legitimate Interests Exemption

 

In accordance with the PDPA, we may collect, use, or disclose your personal data without your consent for our legitimate interests or those of another person. By relying on the legitimate interests exemption under the PDPA, Instant QR Menu will assess the potential negative impacts on the individual and determine that the legitimate interests outweigh any negative impact.

 

8. Pursuant to the legitimate interests exemption, we may collect, use, or disclose your personal data for the following purposes:

   - Detecting and preventing fraud;

   - Detecting and preventing misuse of services;

   - Conducting network analysis to prevent fraud and financial crime, and conducting credit analysis.

 

The purposes mentioned in the above paragraph may continue even in cases where our relationship with you has ended or changed reasonably thereafter.

 

Withdrawal of Consent

 

10. The consent you provide for the collection, use, and disclosure of your personal data will remain valid until withdrawn by you in writing. You may withdraw your consent and request us to stop collecting, using, and/or disclosing your personal data for any of the purposes mentioned above by submitting your request in writing or via email to our Data Protection Officer using the contact details provided below.

 

11. Upon receipt of your written request to withdraw your consent, we may need a reasonable time (depending on the complexity of the request and its impact on our relationship with you) to process your request and inform you of the consequences of accepting it, including any legal consequences that may affect your rights and obligations towards us. In general, we will aim to process your request within twenty (20) working days from its receipt.

 

12. 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 will notify you before completing the processing of your request in such circumstances. If you decide to cancel the withdrawal of your consent, please inform us in writing as described in paragraph 8 above.

 

13. Please note that the withdrawal of consent does not affect our right to continue collecting, using, and disclosing personal data where permitted or required without consent under applicable laws.

 

Access and Correction of Personal Data

 

14. If you wish to request (a) access to obtain a copy of the personal data we hold about you or information on the ways we use or disclose your personal data, or (b) correction or update of any of the personal data we hold about you, you may submit your request in writing or via email to our Data Protection Officer using the contact details provided below.

 

15. Please note that reasonable fees may be charged for requests for access. If applicable, we will notify you of the fees before processing your request.

 

16. We will respond to your request as soon as reasonably possible. In general, our response will be within twenty (20) working days. If we are unable to respond to your request within thirty (30) days of receiving your request, we will notify you in writing within thirty (30) days of when we expect to be able to respond to your request. If we are unable to provide any personal data to you or make the correction requested by you, we will usually inform you of the reasons why we are unable to do so (unless requested under the PDPA).

 

Protection of Personal Data

 

17. To protect your personal data from unauthorized access, collection, use, disclosure, copying, modification, disposal, or similar risks, we have implemented appropriate administrative, technical, and physical measures such as limiting the collection of personal data, monitoring and controlling access (e.g., storing information in secure locations, encrypting sensitive data when necessary, restricting access to personal data to authorized personnel only).

 

18. We are committed to maintaining the security of your personal data and take all necessary measures to prevent unauthorized access, inappropriate use, or unauthorized disclosure of the personal data we hold. However, please be aware that 100% security of data over the internet cannot be guaranteed.

 

19. We retain personal data for no longer than necessary for the purposes for which it was collected, used, and as required under the PDPA or applicable laws. Upon expiry of the retention period, we will take appropriate steps to securely erase your personal data.

 

20. If you believe that we may have engaged in any unlawful collection or use of your personal data, please contact us immediately using the contact details provided below. We will work to address your complaint promptly and effectively.

 

Contact Us

 

21. For any questions or inquiries about this Notice or our privacy practices, or to submit a request for access to or correction of your personal data, please contact our Data Protection Officer by email at [email protected]

 

Changes to Privacy Policy

 

22. We may update this Notice periodically to ensure our compliance with current and changing privacy practices. We will publish any changes to this Notice on our website and notify you of any significant changes that may affect your rights and obligations under this Notice.

 

Version Date

 

Last Updated: 20/06/2024

 

---