Privacy Policy SG

This privacy policy applies between you, the User of this Website and Cinos Pte Ltd, the owner and provider of this Website. Cinos Pte Ltd takes the privacy of your information very seriously. This privacy policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website.
Please read this privacy policy carefully.

2. In this privacy policy, unless the context requires a different interpretation:
   1. The singular includes the plural and vice versa;
   2. References to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy.
   3. A reference to a person includes firms, companies, government entities, trusts and partnerships.
   4. “including” is understood to mean “including without limitation”;
   5. reference to any statutory provision includes any modification or amendment of it;
   6. the headings and sub-headings do not form part of this privacy policy.

Scope of this privacy policy

3. This privacy policy applies only to the actions of Cinos Pte Ltd and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites.

Our use of Data

4. Any or all of the Personal Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Personal Data may be used by us for the following reasons:
   1. Internal record keeping;
   2. Improvement of our products / services;
   3. Transmission by email of promotional materials that may be of interest to you, including but not limited to notifying you of marketing events, initiatives and promotions, lucky draws, membership and rewards schemes and other promotions;
   4. Responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
   5. 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;
   6. Performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
   7. Managing your relationship with us;
   8. Upon request by a prospective purchaser of our business;
   9. Any other incidental business purposes related to or in connection with the above.
5. Unless we are obliged or permitted by law to do so, and subject to any third-party disclosures specifically set out in this policy, your Data will not be disclosed to third parties. This includes our affiliates and / or other companies within our group.

Data Collected

6. We may collect the following Data, which includes personal Data, from you:
   1. Name
   2. Date of Birth;
   3. Gender;
   4. Job Title;
   5. Profession;
   6. Contact Information such as email addresses and telephone numbers;
   7. Demographic information such as post code, preferences and interests;
   8. Financial information such as credit / debit card numbers;
   9. IP address;
   10. A list of URLs starting with a referring site, your activity on this Website, and the site you exit to (automatically collected);

Third Party Websites & Services

7. Cinos Pte Ltd may, from time to time, employ the services of other parties for dealing with certain processes necessary for the operation of the Website. The providers of such services have access to certain Personal Data provided by Users of this Website.
8. Cinos Pte Ltd shall disclose any Personal Data to such parties only to the extent required by such parties to perform the services that we request for the purposes stated at paragraph 4 above. Any use for other purposes is strictly prohibited. Furthermore, any Data that is processed by third parties will be processed within the terms of this privacy policy and in accordance with the PDPA.

Links to Other Websites

9. This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.

Changes of Business Ownership & Control

10. Cinos Pte Ltd may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of Cinos Pte Ltd. Personal Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Personal Data for the purposes for which it was originally supplied to us.
11. In the above instances, we will take steps with the aim of ensuring your privacy is protected to the same standard as that provided under the PDPA.

Controlling Use of Your Data

12. By using our Website, you are agreeing to us using your Personal Data for the purposes stated at paragraph 4 above. Wherever possible, you will be given options to restrict our use of your Personal Data. This may include the following;
    1. use of Personal Data for direct marketing purposes; and
    2. sharing Personal Data with third parties.
13. 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 of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided at paragraph 19 below.
14. 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. In general, we shall seek to process your request within ten (10) business days of receiving it. Whilst 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 shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform our Data Protection Officer in writing or via email at the contact details provided at paragraph 19 below.

Functionality of the Website

15. The Website’s functionality and features may not be fully available to you if you choose not to submit certain Personal Data.
16. You may restrict your internet browser’s use of Cookies. For more information see the clause below (Cookies).

Accessing Your Personal Data

17. You have the right to ask for:
    1. a copy of any of your Personal Data held by Cinos Pte Ltd (where such Personal Data is held) (“Access Request”); or
    2. information about the ways in which we use or disclose your Personal Data; or
    3. a correction request to correct or update any of your Personal Data which we hold about you.
18. If you wish to make an Access Request, we shall process it upon your payment of a small fee which will not exceed S$50.00.
19. You may submit your request in writing or via email to Cinos Pte Ltd’s Data Protection Officer (“DPO”) at the contact details provided below:
    • DPO’s business address: 212 Telok Kurau Road, #03-214, Singapore 423835
    • DPO’s business email address: rakesh.verma@cinos-pte.com
    • DPO’s business telephone number: +65 6904 3650
20. You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request regarding your Personal Data.

Retention of Your Personal Data

21. We may retain your Personal Data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
22. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.

Security

23. Data security is of great importance to Cinos Pte Ltd. To protect your Data, we have put in place reasonable physical, electronic and managerial procedures (such as up-to-date antivirus protection, encryption and the use of privacy filters) to secure all storage and transmission of personal data by us in order to prevent unauthorised access, collection, use, disclosure, copying, modification and/or disposal of Personal Data collected via this Website. We shall only disclose personal data internally and to our authorised third party service providers and agents on a need-to-know basis for the purposes stated at paragraph 4 above.
24. If password access is required for certain parts of the Website, you are responsible for keeping this password confidential.
25. We endeavour to do our best to protect your personal Data. However, transmission of information over the internet is not entirely secure and is done at your own risk. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information

Cookies

26. This Website may place and access certain Cookies on your computer. Cinos Pte Ltd uses Cookies to improve your experience of using the Website and to improve our range of products and services. Cinos Pte Ltd has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.
27. All Cookies used by this Website are used in accordance with the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011.
28. Before the Website places Cookies on your computer, you will be presented with a pop-up requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling Cinos Pte Ltd to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.
29. This Website may place the following Cookies:
30. Type of Cookie Purpose Analytical/performance cookies – They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily. Targeting cookies, these cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
31. You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.
32. You can choose to delete Cookies at any time; however, you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.
33. It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings

Transfers Outside Singapore

34. Data which we collect from you may be stored and processed in and transferred to countries outside of Singapore. For example, this could occur if our servers are located in a country outside of Singapore or one of our service providers is situated in a country besides Singapore. We also share information with our group companies, some of which are located outside of Singapore. These countries may not have data protection laws equivalent to those in force in Singapore.
35. If we transfer Data outside of Singapore in this way, we will take steps with the aim of ensuring that your privacy rights continue to be protected as outlined in this privacy policy. You expressly agree to such transfers of Personal Data for the purposes stated at paragraph 4 above.

General

36. You may not transfer any of your rights under this privacy policy to any other person. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.
37. If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.
38. Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.
39. This Agreement will be governed by and interpreted according to Singapore law. All disputes arising under the Agreement will be subject to the exclusive jurisdiction of the Singapore courts.

Changes to this privacy policy

40. Cinos Pte Ltd reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations.