We take our data protection and privacy responsibilities seriously. We also recognize the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data.
If you, at any time, have any queries on this policy or any other queries in relation to how we may manage, protect and/or process your personal data, please do not hesitate to contact our Data Protection Officer (the “DPO”) using the contact details set out in paragraph 9 below.
1.1 “Personal data” means data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access. Common examples of personal data could include names, identification numbers, contact information, photographs and video images.
1.2 Whether you provide us with Personal Data is your choice, however in many instances, this type of information is required to participate in a particular activity, obtain a benefit we may offer, or gain access to certain content on our Websites.
1.3 One of your friends, family or other persons may also share your email address with us for certain content on our Websites (e.g. recipes) to be sent to you. We will only use your email address for such purpose unless you subsequently sign up or have already signed up for a newsletter (if available on any of the Websites).
2 PURPOSES FOR COLLECTION, USE, DISCLOSURE AND PROCESSING OF PERSONAL DATA
2.1 General Purposes. Generally, we collect, use, process and/or disclose your personal data for the following purposes (depending on the circumstances):
(a) in relation to any service, activity or online content that you have signed up for, in order to ensure that we can deliver the services to you (e.g. where you have signed up to receiving a newsletter, if available);
(b) in relation to any communication you send to us, in order to respond to your enquiries;
(c) to provide you with the products and services made available through the Websites, including but not limited to communicating with you, assisting and improving our products and services and to measure audience statistics;
(d) to assist you with your enquiries, and respond to your feedback, complaints and requests;
(e) to run contests on our Websites and any of our social media platforms, whether solely run by us or with our partners, affiliates, clients, sponsors and advertisers;
(f) to ensure that content on our Websites is presented in the most effective manner;
(g) to make suggestions and recommendations to you and other users of our Websites about content, goods and services that may interest you or them;
(h) to help analyse site traffic, understand customer needs and trends, carry out targeted promotional activities, personalize content and to improve our services;
(i) to understand or measure the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
(j) to notify of changes to our Websites;
(k) in relation to our corporate governance, audit, operational or business protocols;
(l) to process your job application and assessing your suitability for the position applied for;
(m) to resolve disputes;
(n) to manage the safety and security of our premises and event premises (including but not limited to carrying out CCTV surveillance and conducting security clearances); and
(o) any other purposes which we notify you of at the time of obtaining your consent, and any other reasonable purposes related to the aforesaid.
As the purposes for which we may/will collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of your personal data without your consent is permitted by applicable data protection laws.
2.2 Business purposes. We may also use your personal data for purposes connected or relevant to our business, such as:
(a) complying with our legal obligations and requirements;
(b) enforcing contractual terms and conditions, and legal obligations owed to us;
(c) accounting, risk management and record keeping;
(d) carrying out research, planning and statistical analysis;
(e) staff training; and
(f) any other reasonable purposes related to the aforesaid.
2.3 Additional purposes. If you have consented, we may use your personal data, from time to time, for additional purposes such as:
(a) to inform you of the latest activities, products, services, programs, special offers and promotions offered by us and/or our related entities, sponsors, strategic business partners and associates; and
(b) to use your photographs on our Websites and/or in publicity materials.
2.4 When using your personal data to contact you for the above purposes, we may contact you via regular mail, fax, e-mail, SMS, telephone or any other means.
2.5 You may opt-out of receiving future promotional communications from us by following the unsubscribe instructions provided in our communications.
3 NON-PERSONAL DATA
3.1 Non-personal data is data that does not personally identify you. Non-personal data can include certain personal data that has been anonymised. We obtain non-personal data from information you provide us and automatically when you access our Websites.
3.2 We use non-personal data in a variety of ways, including helping to analyse traffic on our Websites, understand customer needs and trends, carry out targeted promotional activities and to improve our services. We may use your non-personal data by itself or aggregate it with information we obtain from others. We may share your non-personal data with our affiliated companies and third parties for such purposes. Please remember that non-personal data is anonymous and does not personally identify you.
4 COOKIES, LOG DATA AND OTHER TECHNOLOGIES
4.1 When you visit our Websites, our servers automatically record information that your browser sends whenever you visit a website (“Log Data”). This Log Data may include information such as your IP address, browser type or domain from which you are visiting, the websites you visit, your search terms and any advertisements you click on. We use Log Data to monitor use of our Websites and of our services, and for the respective Website’s technical administration.
4.3 If you want to delete or disable any cookies and similar technologies which are already on your computer, please refer to the instructions of your file management software to locate the file and directory that stores cookies. You may not be able to take advantage of all the features of our Websites if you delete or disable cookies. For more information on how to see what cookies have been set and how to manage and delete them, please visit: http://www.allaboutcookies.org/.
4.5 Certain third parties also provide cookies or similar technologies on our Websites. These cookies or similar technologies are not within our control and are set by the third parties noted below. Please visit their websites to understand how their cookies are used.
5 SPECIFIC ISSUES FOR THE DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES
5.1 We may share your personal data with any of our affiliated companies and with selected third parties (for the purposes described in Paragraphs 2.1, 2.2 and 2.3) including:
(a) our third party vendors performing functions on our behalf (or on behalf of our affiliated companies) e.g. vendors that administer our promotion and competitions, provide us with marketing or promotional assistance, analyse data, assist us with customer service, our partners, clients, sponsors and advertisers to a program, promotion or contest you enter via our Websites, and with third parties who assist us in using the content or other information you have posted or shared with us via our Websites, including but not limited to production companies we may use;
(b) advertising networks, analytics companies and other vendors for advertising purposes, such as monitoring the effectiveness of advertisements and making advertisements more relevant to you;
(c) analytical and search engine providers that assist us in the improvement and optimsation of our Websites; and
(d) selected third parties such as partners, clients, sponsors and advertisers
5.4 You agree that we may disclose or share your personal data with our consultants and professional advisors (such as accountants, lawyers, auditors) for the purposes of obtaining advice.
5.5 We may also disclose your personal data as required or permitted by law. We may disclose your personal data to regulatory authorities, statutory bodies or public agencies for the purposes of complying with their respective requirements, policies and directives.
5.6 The instances listed above are not intended to be exhaustive. For more information on the exceptions, you are encouraged to peruse your local data protection laws for any instances allowed under the law.
6 REQUEST FOR ACCESS AND/OR CORRECTION OF PERSONAL DATA
6.1 You may request to access and/or correct the personal data currently in our possession or control by submitting a written request to us. We will need enough information from you in order to ascertain your identity as well as the nature of your request, so as to be able to deal with your request. Hence, please submit your written request to our DPO by email to firstname.lastname@example.org.
6.2 For a request to access personal data, once we have sufficient information from you to deal with the request, we will seek to provide you with the relevant personal data as soon as reasonably possible. Otherwise, we will notify you of the soonest possible time within which we can provide you with the information requested. Please note that some data protection laws exempt certain types of personal data from being subject to your access request.
6.3 For a request to correct personal data, once we have sufficient information from you to deal with the request, we will correct your personal data as soon as practicable. Otherwise, we will notify you of the soonest practicable time within which we can make the correction. Note that some data protection laws exempt certain types of personal data from being subject to your correction request as well as provides for situation(s) when correction need not be made by us despite your request.
6.4 We will also be charging you a reasonable fee for the handling and processing of your requests to access your personal data. We will provide you with a written estimate of the fee we will be charging. Please note that we are not required to respond to or deal with your access request unless you have agreed to pay the fee.
7 REQUEST TO WITHDRAW CONSENT
7.1 You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control by submitting your request to our DPO via one of the contact methods listed in paragraph 9 below.
7.2 We will process your request within a reasonable time from such a request for withdrawal of consent being made, and will thereafter not collect, use and/or disclose your personal data in the manner stated in your request.
7.3 However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal. In this regard, depending on the extent of your withdrawal of consent for us to process your personal data, it may mean that we may not be able to provide some of our products, services or functionalities.
8 ADMINISTRATION AND MANAGEMENT OF PERSONAL DATA
8.1 If there are any changes to the personal data you have provided to us, we must rely on you to notify us of any such changes. We will not be responsible for relying on inaccurate or incomplete personal data arising from you not updating us of any changes in your personal data that you had initially provided us.
8.2 We will also put in place reasonable security arrangements to ensure that your personal data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorized access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data. Unfortunately, transmission and transfer of information via the internet is not completely secure. We cannot assume responsibility for any unauthorized use of or access to your personal data by third parties which are wholly attributable to factors beyond our control.
8.3 We will also put in place measures such that your personal data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes.
8.4 Your personal data may be transferred to and stored in a country where we have facilities in or in which we engage service providers, outside the country of your residence, and/or outside of Singapore (“relevant countries”). It may also be processed by staff (operating outside the relevant countries) who work for us, or for one of our affiliated companies or service providers. You consent to the transfer to, storage and processing of your personal data in relevant countries. We will take all reasonable steps which are necessary to ensure that your personal data is accorded a standard of protection that is comparable to the protection which your personal data enjoys under the laws of the relevant countries. Where these countries or territories do not have personal data protection laws which are comparable to that in the relevant countries, we will enter into legally enforceable agreements with the recipients to ensure that they protect your personal data to the same standard as required under the laws of the relevant countries.
9 CONTACT DETAILS
(a) Singapore telephone number:
+65 6835 8838
Attention it to the ‘Data Protection Officer’.
(c) Office address:
Scripps Networks Interactive (Asia) Pte Ltd.
3 Fusionopolis Way
#12-21 Symbiosis Tower
Attention it to the ‘Data Protection Officer’
9.2 We endeavor to respond to you, and, if applicable and appropriate, make the requested change in our active databases as soon as reasonably practicable. Please note that we may not be able to fulfil certain requests while allowing you access to certain benefits and features of our Websites.
10 THIRD PARTY LINKS AND MATERIALS
10.1 Our Websites may contain links to third party websites. The fact that we provide links to a website is not an endorsement, authorisation or representation of our affiliation with the third party. We do not exercise control over third party websites nor are we responsible for the privacy practices employed by third party websites. These websites may place their own cookies or other files on your computer, collect data or solicit personal data from you. We encourage you to note when you leave our Websites and to read the privacy policies of the other websites you visit to ensure that you are aware of their data protection policies before submitting any person data to such third party websites.
11.1 The features, programs, promotions and other aspect of our Websites requiring the submission of personal data are not intended for persons under 18 years of age. If you are a parent or legal guardian of a minor and believe that your child has provided us with personal data without your consent, please contact us at email@example.com.
12.1 As part of our efforts to ensure that we properly manage, protect and process your personal data, we will be reviewing our policies, procedures and processes from time to time.
13.1 Materials on our Website are for information purposes only. Despite our best efforts to provide accurate information, there may be errors. Please verify any and all information that is vital to your decision before acting on information you have obtained from our Website. SNI ASIA will not be liable for any damages of any nature relating to the use of the Website or any hyperlinked websites.
Last Updated on 4 December 2017