1. Introduction

1.1. In line with its aim to comply with the requirements of the Personal Data Protection Act 2012 (“PDPA”) and to maintain the highest standards of confidentiality with respect to the personal data of our guests, visitors, members, customers, employees or affiliates, this document sets out the Personal Data Policy of the Singapore Turf Club (the “Club”).

1.2. The purpose of the PDPA is to govern the collection, use and disclosure of personal data by organisations in a manner that recognises both the right of individuals to protect their personal data and the need for organisations to collect, use or disclose personal data for purposes that a reasonable person would consider appropriate in the circumstances.

1.3. This Personal Data Policy applies to all information collected by the Club from our guests, visitors, members, customers, employees or affiliates.

1.4. Nothing in this Personal Data Policy is intended to derogate from any contract that you have entered into with the Club.

1.5. For the purpose of this policy, the terms “we”, “us” or “our” shall, unless otherwise indicated, refer to the Club.


2. What is personal data?

2.1. Personal data is personal information, whether true or not and whether in electronic or other form, about an individual who can be identified :

2.1.1. from that data; or

2.1.2. from that data and other information to which we have access to or are likely to have access to.

2.2. Examples of personal data are your name, address, NRIC number or FIN number, photograph or video image, telephone number and email address.

2.3. We will do our best to ensure that your personal data that we collect is accurate. However, we do encourage you to provide us with an update of any change in your personal particulars as soon as possible.


3. When is personal data collected from you?

3.1. When you apply to the Club to become a licensee, members, or Racing Gold Card account holder or when you update your personal particulars.

3.2. When your image is captured by our photographers or videographers.

3.3. When your image is captured on our CCTV system.

3.4. When you apply for a job at the Club.

3.5. When you visit the Club or attend our events or respond to our marketing campaigns.

3.6. When you rent the Club’s corporate boxes, rooms or event venues.

3.7. When you provide feedback or interact with the Club’s customer service officers e.g. via meetings, emails or telephone calls (the telephone calls may be recorded for training and quality control purposes).

3.8. When you agree that we contact you.

3.9. When you agree to be included in a mailing list.

3.10. When you take part in any of the Club’s contests, surveys or promotions.

3.11. In certain situations and with your consent, we may also obtain your personal data from third parties.

3.12. When you access our website.

3.13. When you provide the personal data of your family members or friends for purposes connected with your custom of, visit to or employment with the Club.


4. What is the information collected or used for?

4.1. To maintain a register of our members.

4.2. The general administration of membership applications.

4.3. To facilitate the use of our facilities and services and participation in our activities.

4.4. To respond to your requests and queries.

4.5. To communicate with you.

4.6. To enforce our rules and regulations, contractual and legal rights and obligations.

4.7. To send you information, promotions, updates and marketing and advertising material in relation to the facilities, services and activities offered by the Club and our affiliates.

4.8. To publicise events and activities of the Club in our publications.

4.9. From time to time, to conduct contests, surveys or promotions.

4.10. To maintain an appropriate level of security in the Club and its premises.

4.11. To facilitate the employment of staff by the Club.

4.12. To comply with the law, any requests from law enforcement and regulatory officials, or orders of court.

4.13. Towards any other purpose of use for which we have obtained your consent, express or implied.


5. Is your consent required and can it be withdrawn?

5.1. We will endeavour to obtain your consent to collect, use and disclose your personal data prior to or at the time we collect it. However, in certain situations you will be deemed to have consented to the provision of your personal data, e.g. where you provide your personal data voluntarily.

5.2. In respect of our CCTV system and the images that are recorded, the Club has placed signs at prominent locations to inform you of the operation of the CCTV system and its purpose which is to ensure and maintain the security in and around our premises.

5.3. You may at any time give us reasonable written notice of the withdrawal of your consent to collect, use or disclose your personal data. Within a reasonable time after we receive the notice of withdrawal of your consent, we will inform you of the consequences of your withdrawal of consent and when it will take effect.


6. Can I get access to or correct my personal data?

6.1. You can view your personal data which we have collected and stored at any time. In order to do so, you will need to submit a written request for access to view your personal data. We will respond to your request as soon as possible and, at the latest, within 30 days of receipt of your request and payment of the administrative fee of S$20.00. Please note that we reserve the right to revise our fee if the cost of retrieving your personal data exceeds our original estimation. If so, we will notify you of any such fee revision before processing your request.

6.2. Your right to view your personal data is limited to your personal data only. We are not permitted to reveal any personal data about any other individual to you. We reserve the right to refuse access to your personal data if it will reveal or lead to the revelation of another individual’s personal data, cause harm to you or another individual or is contrary to the national interest.

6.3. You can submit a written request to correct your personal data which we have collected and stored. We will consider your request and respond to it as soon as possible and, at the latest, within 30 days of receipt of your request. We will make the necessary corrections as soon as reasonably practicable provided we are satisfied that the corrections should be made. In the event that we feel the corrections should not be made, we will inform you.


7. Is my personal data secure?

7.1. The Club makes every effort to maintain the highest standards of confidentiality and security of your personal data. To this end, we have internal policies and procedures in place to ensure that your personal data is kept secure. These include the following:
Restricting access to your personal data;

7.2. Conducting regular briefings and trainings for our staff in relation to our data protection policies;

7.3. Imposing confidentiality obligations on our staff;

7.4. Conducting regular audits of our data protection policies; and

7.5. Devising procedures that will be implemented in the event of a breach of security.


8. How long do you retain my personal data?

8.1. The Club will retain your personal data for as long as the purpose for which your personal data was collected is still being served and as long as it is necessary for legal or business purposes.


9. Do you ever transfer my personal data out of Singapore?

9.1. Your personal data may be transferred to, stored by and / or processed by a party outside of Singapore.

9.2. The Club will ensure that the party receiving, storing and/or processing your personal data outside of Singapore protects your personal data at a standard at least comparable to the protection under the PDPA. The Club will ensure that the party coming into contact with your personal data outside Singapore:

9.2.1. complies with the PDPA, all applicable laws and regulations and this Personal Data Policy and will not do or permit anything to be done which might cause the Club to breach this Personal Data Policy; and

9.2.2. takes appropriate measures to ensure such compliance by implementing the necessary data protection and appropriate technical and organisational measures and providing a standard of protection for your personal data that is comparable to the protection under the PDPA.


 10. What to do if I have a complaint?

10.1.   If you have any concerns or problems with the way your personal data has been handled, please write in and clearly set out the nature of your concern.

10.2.   Upon receiving your complaint, we will confirm that your complaint will be investigated and provide you with an estimate of how long you should expect to wait to receive a full response. While Singapore Turf Club endeavours to respond as promptly as possible, response times will vary depending on the nature of the complaint.


11. Who can I contact about my personal data or this policy?

11.1. If you have any queries or doubts about the policies set out in this statement or about your personal data that we obtain, maintain, process, use and disclose, or if you would like to access or correct your personal data, you may contact Singapore Turf Club’s Data Protection Officer at DataProtectionOfficer@turfclub.com.sg

11.2. For more information about the PDPA, please visit Personal Data Protection Commission’s website at http://pdpc.gov.sg