Last updated: January 14th 2019

This Data Protection Notice (“Notice”) sets out the basis which Pure-Commerce (“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”) and the General Data Protection Regulation (GDPR) for our guests from the European Union. 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.

PERSONAL DATA

1. As used in this Notice:

“guest/data subject” 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 your name and identification information such as your contact information such as your email address, nationality and financial information such as credit card numbers, debit card numbers or bank account information.

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

1. Collection of Personal Information

Personal Information refer to any piece of information that can be used to identify a data subject / guest. Example: Name, Address, Telephone Number, Date of Birth, Personal Identification Numbers (SSN, Passport, Taxpayer Identification number etc.), Photographic Images, log in details etc.

Pure-Commerce collects and stores the following information when data subject/guests uses the platform:

Type of Information collected Purpose
Full Name (First Name + Last Name) To provide guests with service
Truncated Card Number For payments
Email Used by hotels to send payment links to the guests
Description Description of the services availed by the guests

Information that Pure-Commerce collect through automatic data collection technologies:

Type of Information collected Purpose
Full Name (First Name + Last Name) For fetching geo-location of the guest to provide with their local currency option. We do not store your geo-location/IP address. However, your choice of payment (i.e. opted currency) will be recorded in our backend.

2. Use of Personal Information

We generally do not collect your personal data unless it is provided to us voluntarily by you. We shall seek your consent before collecting and processing 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 any or all of the following purposes:

  • Performing obligations during or in connection with our provision of the goods and/or services requested by you;
  • verifying your identity;
  • Responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
  • Processing payment or credit transactions;
  • Complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
  • For performing analysis and providing report to our merchants through our NetReport Tool (i.e. provide our merchants a daily report on number of successful and failed transactions, transactions coming from different countries etc)
  • Help diagnose problems with the platform, improve platform content, to administer the platform, and to enhance the platform for optimal user experience.
  • Monitor the usage and performance of the platform, and to determine aggregate information about our users and usage patterns.
  • Customize content and services that may be of interest to our users.

Pure-Commerce is not involved in processing of personal data relating to criminal convictions and offences or related security measures

3. Sharing of Information

Pure-Commerce does not sell or rent or any of guests/data subject’s personal information. However, we share your information like name, email, masked card number and whether transaction was successful or not with the payment merchants. We have contracts in place with the merchants which clearly define the level of protection they ensure for holding your information. Please note that they may hold your information as per their data retention policy.

4. Children’s under the age of 13

The Platform is not meant for or targeted to children and should not be used by children under 13. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this platform or on or through any of its features/register on the platform, make any purchases through the platform, use any of the features of this platform or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at dpo@pure-commerce.com

5. Access to your information and correction

Pure-Commerce can provide data subjects with the copy of information they hold. If the guests/data subjects would like a copy of some or all the personal information, please email or write to Pure-Commerce at the following address: dpo@pure-commerce.com

Before providing the copy of personal data that we hold, we may verify your identity.

Please note that Pure Commerce may charge a reasonable fee for repetitive requests as a service for providing the information.

6. How we protect personal information

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. All transactions, regardless of their nature, are encrypted using TLS technology.

7. How long do we keep personal information for?

Pure-Commerce will purge data once it’s verified to not be required from a business requirement perspective.

8. How can you access, amend or take back the personal data you’ve given to us?

For any of the following you may send us an email at dpo@pure-commerce.com :

  • If you want to erase your data
  • If you want to withdraw consent
  • If you want to restrict the processing of personal information
  • Pure-Commerce provides guests/data subjects an option for porting their personal data.
  • Pure-Commerce provides guests/data subjects with an option for opting-out of automated individual decision-making, including profiling.

9. 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 using and/or disclosing your personal data for any or all the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.

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 ten (10) business days of receiving it.

10. Effect of notice and change 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.

11. Transfer of data outside 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.

Annexure – 1

How to contact Pure Commerce:

152 Beach Road, Gateway (East) #19-01, Singapore 189721

Annexure – 2

Data Protection Officer Details

Name: Shashi Kumar

Email: dpo@pure-commerce.com

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