Keppel Electric - Privacy Statement

Introduction

This privacy policy (“Policy”) describes how Keppel Electric Pte Ltd subscribes to the principles, guidelines and requirements of the Singapore Personal Data Protection Act (“PDPA”) and in particular the practices which Keppel Electric Pte Ltd adopts in relation to the protection of your personal data, in connection with the operation of our website(s) and mobile application(s), and/or the provision of services by Keppel Electric Pte Ltd to you.

Definitions

For the purposes of this Policy, the following capitalised terms, unless elsewhere defined in this Policy, shall have the following meanings:

Act” means the Personal Data Protection Act 2012 of Singapore, as amended from time to time;

Group” means Keppel Corporation Limited and/or its subsidiaries, including Keppel Electric Pte Ltd ; and

personal data” means any data, whether true or not, about an individual who can be identified (a) from such data; or (b) from such data and other information to which we have or are likely to have. This may include, for example, a person’s name, date of birth, gender, NRIC, passport number, photos, mailing addresses, telephone numbers, email addresses and network data.

Methods of Collection

Personal data may be collected from you in the following ways:

  1. when you disclose personal data to us or submit forms, including by way of registering for an account, on our website(s), mobile application(s), an online portal, email, physical collection or other methods;
  2. when you (or any person authorised by you) correspond(s) with our employees, sub-contractors (including any delivery personnel), customer service or marketing representatives via telephone, letter, email, face-to-face meeting etc;
  3. when you subscribe to our mailing lists or otherwise register your interest for any specific products or services;
  4. when you respond to our promotions;
  5. when you are referred to us from business partners, our corporate customers and other third parties;
  6. when we obtain it from other entities within the Group;
  7. when we lawfully seek information from third parties about you in connection with the products and services you have applied for;
  8. during recordings of calls when telephone contact is made (for example, via customer service hotlines) which may be recorded for training, quality control, business and/or other lawful purposes;
  9. during CCTV recordings when a person visits our outlets and our premises;
  10. when you generate data or link data to your account, e.g. account synchronization, sign-up authentication etc;
  11. automatically, when you visit our websites and other websites which we own or manage, using technologies such as cookies (either by us or a third party), contracts with us or with any third parties via our websites, or downloads and/or uses any of our application programs and/or software; and
  12. when you (or any person authorised by you) provide us with personal data for any other reason.

Purposes

The purposes for which we and/or our service providers may collect, use, disclose, process, manage and/or transfer your personal data are as follows:

  1. to provide you with our services (including to fulfil our obligations under our contract with you for such services);
  2. to facilitate the set-up, operation, maintenance and/or administration of such services or any account you may have with us, and provide related services and support (including for billing purposes or to process orders and applications for such services);
  3. to maintain, test and/or operate our (or any of our service provider’s) systems required for the provision of any of our services, or in connection with the web site(s) or mobile application(s);
  4. to facilitate interconnection and inter-operability between service providers in connection with providing services to you;
  5. to facilitate the operations of a retail electricity market or a wholesale electricity market;
  6. to respond and deal with enquiries or complaints and for other customer-care activities;
  7. to assess, process, respond or otherwise handle your enquiries, requests, feedback, questions, instructions or complaints and for other customer-care related activities;
  8. to verify your identity, and to process orders and applications for services;
  9. to carry out credit checks, for the preparation of credit reports and/or for the evaluation of creditworthiness;
  10. to market, promote (including offer to sell you any other products or services), improve and/or further the provision of services to you by us, or by our affiliates, partners, contractors or third-party service providers;
  11. to share with selected related entities, affiliates and business partners (including entities within the Group) to enable them to conduct market research, planning, customer surveys, trend analyses and/or other related forms of data analytics in order to better tailor offers, promotions and/or other direct marketing to you;
  12. to provide complementary or value-added services;
  13. to offer and administer customer loyalty benefits, reward benefits, promotional benefits, contests, lucky draws and other related benefits;
  14. to conduct market research, planning, customer surveys, trend analyses and/or other related forms of data analytics;
  15. to keep you informed of our services and products, and the services and products of our related entities, affiliates and partners;
  16. to conduct training and/or improve our service quality and/or marketing and advertising strategies;
  17. to improve your user experience and/or our product and service delivery to you;
  18. to establish, enhance and/or further improve payment systems, including the interface or interaction of such payment systems with the payment systems of other financial institutions, merchants and/or payment organisations;
  19. to seek professional advice, including legal advice, or enforce your obligations or enforce our rights, including, without limitation, collection of amounts owed by you or by any other person, or defending our rights, the rights of any related corporations, partners, contractors and/or third party service providers;
  20. to conduct investigations or take action in relation to bad debts, crime and fraud prevention, detection of prosecution, risk management, violation of our terms and conditions for services, or to prevent any individual from harm, illegal or unlawful activities;
  21. for internal / external audit or compliance purposes;
  22. to comply with regulatory, compliance, or legal obligations and/or requirements; (including, but not limited to, for the purposes of transferring your electricity supply arrangements in accordance with the terms of any contract entered into by us with you);
  23. as permitted or required by applicable law, regulations, industry codes or market rules; (including in connection with investigations and to assist law enforcement and government authorities (in Singapore or elsewhere);
  24. for any other purposes necessary, ancillary or consequential to the above specified purposes.

Who we might Disclose Personal Data to

Your personal data will be disclosed for the purposes indicated above to our officers and employees, affiliates, third parties, service providers, advisors, which includes without limitation, the following persons or entities:

  1. other entities within the Group;
  2. external service providers, contractors and third parties, for the purpose of providing our services to you;
  3. other business partners and vendors we work with to deliver products and services, including but not limited to courier services companies and other entities within the delivery chain;
  4. banks, credit card companies, payment vendors and other entities within the payment processing chain for the purposes of processing payment;
  5. debt collection agencies;
  6. credit information companies and credit bureaus;
  7. government bodies, including any ministry, department, agency (including law enforcement agencies), or organ of state, judicial or quasi-judicial body or disciplinary, arbitral or mediatory body, or any other statutory body;
  8. advisors, including auditors, accountants and lawyers who advise us;
  9. any data intermediaries; and
  10. any other party to whom you authorise us to disclose personal data to.

Transfer of Personal Data Overseas

We may, in the course of providing services to you, disclose, transfer, store, process and/or deal with your personal data outside Singapore. In doing so, we will comply with all applicable data protection and privacy laws, and take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the Act.

Withdrawal of Consent

You may subsequently withdraw your consent to our collection, use or disclosure of your personal data. However, should you choose to do so, we may not be able to provide you with our services, or perform any contract we may have with you. Accordingly, the Group may, insofar as such consent is integral to the provision of the services to you, cease to provide such services to you and will have the right to terminate any contract of service with you in its discretion, without liability to you. Notwithstanding any withdrawal of consent, unless otherwise agreed by the Group, you will still be bound by any contract of service with the relevant entity in the Group, and should you choose to terminate the relevant contract(s), early termination and other charges, liquidated damages or contractual consequences may apply in accordance with the relevant contract(s) or at law, and the Group reserves its rights thereof.

Please contact our Data Protection Officer by email (please see the “Contact Details and DPO” section below) to request for withdrawal.

We shall process your withdrawal request within a reasonable time (depending on the complexity of the request and its impact on our relationship with you), and in any event no later than within [ten (10) business days of receiving your request.

Retention of Personal Data

We will retain personal data for as long as it is necessary to fulfil the purpose for which it was collected, our legal or business purposes, or as required by relevant laws. We will usually keep your personal data for up to seven (7) years to ensure that any contractual disputes can be addressed. If you opt out or withdraw your consent to marketing, we will remove you from our marketing database.

Access, Update and Correction Requests

You must ensure that all personal data submitted to us is accurate, up-to-date and not misleading. Any submission of false or incorrect information may result in our failure to deliver the products and services you seek. We reserve the right to request for documentation to verify the information provided by you.

We encourage you to inform us when there are any changes to the personal data which you have provided to the Group, so as to ensure that we have the most current, accurate and complete information. Upon request by you, the Group may, in accordance with the Act, correct or complete any personal data found to be inaccurate or incomplete as soon as practicable.

You can access, update and correct your personal information anytime by accessing your account registered with us through the website or mobile application (if applicable). If you do not have an account with us, you may contact us (please see the “Contact Details and DPO” section below). We will respond to your update and/or correct request as soon as reasonably possible, an in any event no later than within ten (10) days of receiving such update and/or correct request. Subject to the Act, we will respond to access requests within a reasonable time (and in any event no later than within thirty (30) days of receiving such access request.

We may charge a fee for processing your request for access. Such a fee would depend on the nature and complexity of your access request.

Cookies

Our web site(s) and mobile application(s) use cookies to monitor browsing preferences and help analyse data about webpage traffic in order to make web site improvements based on your needs and to enhance web site efficiency. We generally use such information for statistical analysis but may use it for other reasons in aggregated form or where we are not aware of your identity.

When you visit our web site(s) and/or mobile application(s), our servers will automatically record information that is sent whenever you visit a web site or mobile application. This data may include: (a) your computer’s IP address; (b) your browser type; (c) the webpage you were visiting before you visited the relevant web site; (d) the pages within the web site or mobile application which you visit; and/or (e) the time spent on such pages, item and information searched for in the web site or mobile application, access time and dates, and other statistics.

A cookie does not give us access to your computer. Most internet browsers automatically accept cookies, but you can usually modify your browser settings according to your preference. If you choose not to accept cookies, you may not be able to experience all of the features of our web site(s) and mobile application(s).

Other Web Sites

Our web site(s) and mobile application(s) may contain links to other web sites which are owned or operated by third parties, and which are not under our control. We are not responsible for the content on any such web site, or the consequences of accessing or using any such web site (including the protection and privacy of any information which you provide whilst visiting such sites) and such sites are not governed by this statement. You agree that your access to or use of such web sites is entirely at your own risk. When visiting these third-party web sites, you should read their privacy policies which will apply to your use of the web sites.

Updates to this Policy

We will amend this Policy from time to time, and the updated versions will be posted on our website and/or mobile application; and date stamped so that you are aware of when the Policy was last updated. Please check back frequently to see any updates or changes to this Policy. If we make any material changes to this Policy, we will provide notice, for example, by way of a banner on our website. Subject to applicable laws, the English version of this Policy will prevail over any version of this Policy in another language.

Contact Details and DPO

If you have any enquiries, comments or suggestions about how we collect, use or disclose your personal data or this Policy, or would like to receive information about your personal data which we retain, please contact our Data Protection Officer by email at dpo@keppelelectric.com.