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Privacy Policy

Privacy Policy

1. PREAMBLE
This Privacy Policy (hereinafter the ‘Policy’) is hereby issued pursuant to the provisions contained in the Singapore Personal Data Protection Act 2012 (hereinafter the ‘Act’) and sets out inter alia Enterprise Sports Group Pte Ltd. (hereinafter ‘ESG’) collects, uses, discloses and protects information, including ‘personal data’ and ‘statistical data’ [hereinafter collectively referred to as ‘personal information’, and as defined in Paragraph (4) hereinbelow] that we learn about you (hereinafter interchangeably used with the term ‘Participant’) as a result of your interaction with us (hereinafter interchangeably used with ‘ESG) whether through the website www.kidsrun.com.sg (in which this Policy has been posted) or pursuant to any transaction offline (or of a similar nature) in relation to the Cold Storage Kids Run (hereinafter ‘CSKR’). The Policy also stipulates ESG’s responsibilities in relation to the collection, use, disclosure and protection of personal information.

2. CONSENT
By continuing to use ESG’s services, accessing any part of the website www.kidsrun.com.sg, registering for the CSKR, submitting information to ESG (and/or its related entities) whether for the purpose of registering for the CSKR or otherwise, as well as using any features of the aforementioned website, you signify that you have read, understood and agree to be bound by this Policy (as amended from time to time) in respect of ESG’s collection, use and disclosure of your personal information.

Furthermore, you hereby agree and consent to ESG’s (including its related entities, as well as their respective Agents’), collection, use and disclosure of your personal information, in the manner set forth in this Policy.

3. THIS POLICY SERVES AS A SUPPLEMENT
1. This Policy is meant to supplement any Agreements governing your relationship with ESG (and its related entities), and should be read in conjunction with those Agreements.

2. Furthermore, all consent provided pursuant to this Policy is meant to supplement and not supersede or replace any other consent you may have previously provided to ESG (and its related entities) in respect of your personal information.

4. PERSONAL INFORMATION
The types of personal information collected by ESG broadly fall within the ambit of the following categories:

a. Personal Data
This includes the following:

i. Information which can be linked back to the Participant. For example, the name, gender, date of birth, Passport No., and NRIC No.
ii. The Participant’s contact information. For example, the mailing address, the area of residence, telephone number, and email address.
iii. The Participant’s payment information. For example, the credit card number, the debit card number, the name of the card holder, the card number, the billing address, and the expiration date of the credit/ debit card.
iv. The Participant’s health information. For example, whether the participant has any known allergies, or any known medical conditions.
v. The participant’s technical information. For example, the IP address from which the registration form is accessed completed and submitted.

b. Statistical Data
This includes the following:

i. The number of Participants;
ii. The number of hits to the website www.kidsrun.com.sg.
iii. The number of hits to the CSKR Facebook group.
iv. Survey Results.
For the avoidance of doubt, Statistical data is stored purely for analytical purposes, and is entirely anonymous. Statistical data will not be tied to the Participant record, and will only be aggregated for statistical analysis so that ESG can better understand the Participant’s profile and improve the service offering. Statistical data may also be shared with the sponsors or potential sponsors of the event, as and when how ESG deems fit for presentation.

5. COLLECTION OF PERSONAL INFORMATION
a. Generally, ESG collects personal information in the following ways:

i. When you contact ESG (and/or any of its related entities);

ii. When you submit forms or applications to ESG (and/or any of its related entities) (including but not limited to the Registration Form for the CSKR);

iii. When you submit queries or requests to ESG;

iv. When you submit complaints;

v. When you provide feedback;

vi. When you respond to ESG’s request to provide further information;

vii. When you visit the website www.kidsrun.com.sg;

viii. When you purchase any form of product or merchandise through www.kidsrun.com.sg website;

ix. When you visit the website CSKR Facebook group;

x. When you submit your personal information to ESG, for any other reasons.

1. If and when you provide ESG (and/or any of its related entities) with any personal information relating to a third party (including but not limited to that of a dependant and/or spouse), by submitting such information to us, you warrant and represent to ESG that you have obtained the consent of that third party, to your providing ESG with their personal information, for the respective purposes.

2. By providing personal information to ESG (and/or any of its related entities), you confirm that the information is complete, and accurate, to the best of your belief, and knowledge. Failure to abide by the said requirement may result in ESG’s inability to fulfil your requests and/or applications.

6. PURPOSES FOR COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION
a. Generally, ESG collects, uses, and discloses your personal information for the following purposes:

i. To facilitate your registration for the CSKR;

ii. To verify your identity;

iii. To communicate with you;

iv. To respond to your queries;

v. To respond to your requests;

vi. To manage administrative and business operations of ESG, and to comply with ESG’s internal policies and procedures;

vii. To match any personal information held by ESG (and/or any of its related entities) which relates to you, for any of the purposes specified;

viii. To facilitate maintenance of security during the CSKR;

ix. For planning, research, data-planning, and data-processing activities;

x. For statistical and/ or risk assessment and analysis;

xi. For fund-raising;

xii. For analysing the effectiveness of our advertisements, competitions and promotions;

xiii. To comply with any applicable laws, rules, regulations, and guidelines (which may be issued by the concerned authorities);

xiv. For record keeping purposes (where there are legal and/or business reasons for retaining the said records);

xv. For legal purposes (including but not limited to the obtaining of legal advice; to facilitate dispute resolution; and to investigate suspected unlawful activities including intellectual property infringement);

xvi. For purposes which are reasonably related to the aforesaid.

b. Further, ESG may collect, use and disclose your personal information, under the following circumstances:

i. If you are a media representative: To facilitate the granting of any access pass to any of the media centres, during the CSKR; and for any purposes which are reasonably related to the aforesaid.

ii. If you are participating in a Community Engagement Programme (including but not limited to any donations specified in the Registration Form): To meet the relevant requirements stipulated by the applicable laws, rules and regulations; and as part of voluntary opt-in via participation by filling in the relevant details in the appropriate section of the Registration Form, inclusion of personal information for electronic direct mailers; and for any purposes which are reasonably related to the aforesaid.

iii. If you are a contractor or service provider, providing products and services (including but not limited to the provision of hospitality, and food & beverage services) in connection with the CSKR: To meet the relevant requirements stipulated by the applicable laws, rules and regulations; To facilitate the granting of any access pass to any of the relevant centres, during the CSKR; and for any purposes which are reasonably related to the aforesaid.

c. Further, to the extent permitted by applicable law, ESG may collect, use and disclose your personal information, for the following:

i. For conducting analytics of services;

ii. For organising promotional events;

iii. For organising corporate events;

iv. For sending you newsletters/ e-newsletters (only when you have subscribed to them);
v. For sending you updates about upcoming events, promotions, rewards, including those which we have identified may be of interest to you (including but not limited to via telemarketing to such numbers are you may have provided to us, subject to your unambiguous consent) (only when you have opted in to receive such updates);

vi. For market research purposes (information is collected anonymously);

vii. For purposes which are reasonably related to the aforesaid;

viii. For any other purposes for which ESG may notify you and obtain your express consent.

7. DISCLOSURE OF PERSONAL INFORMATION
a. We have identified the nature of personal information which may be collected, in the preceding paragraphs, as well as the specific purposes for the collection, use and/ or disclosure of the personal information. To the extent feasible, generally, your personal information held by us shall be kept confidential.

In order to provide you with effective and quality services, and for the purposes listed in the preceding paragraphs (where applicable), your personal information may be disclosed to the following:
i. ESG’s related entities;

ii. Agents, contractors and/ or third party service providers who provide operational services in relation to the CSKR;

iii. Any business partner, investor, assignee and/or transferee (actual or prospective);

iv. Our advertising, marketing and promotional agencies, to help us inter alia deliver and analyse the effectiveness of our campaigns and promotions;

v. External banks, credit card companies and their respective service providers;

vi. ESG’s professional advisers (including but not limited to its legal advisors, auditors and financial advisors);

vii. Appropriate government authorities, statutory boards and law enforcement authorities, to comply with the applicable laws, rules and regulations;

viii. Counterparties, billing organisations and their respective banks, in relation to fund transfers and payments; and

ix. Any other party to whom you authorise us to disclose your personal information.

b. To the extent feasible, ESG shall endeavour to ensure that its employees who are involved in the collection, use and disclosure of any personal information, will adhere to the stipulations contained in this Policy.

8. WITHDRAWAL OF CONSENT, ACCESS TO AND CORRECTION OF PERSONAL INFORMATION
a. ESG recognizes the need to maintain accuracy, currency and completeness of personal information collected. If you wish to have access to, review, incorporate amendments, and update your personal information, please follow the instructions specified hereinbelow:

b. If you wish to:

i. Withdraw your consent to any use of your personal information as set out in this Policy; and/or

ii. Have access to and/or incorporate amendments/updates to your personal information; and/or

iii. Have any queries or feedback pertaining to your personal information; you can contact ESG, through any of the following modes:

BY AR REGISTERED MAIL/ COURIER ESG Endurance Sport Pte Ltd.
2 Alexandra Road,
#08-00 Delta House,
Singapore 159919Mr Ryan Quek
BY EMAIL ryan@enterprisesg.com
BY TELEPHONE 6272 2911 (ext 204)

For the avoidance of doubt, the aforementioned request will be deemed to have been formally made and will be taken on record, only if received in a written form (either by AR Registered Mail and/ or via email).

c. ESG will, upon receipt of your aforementioned written request, allow you to view your stored personal information. To the extent permitted by law, ESG reserves the right to charge a reasonable administrative fee for the said service.

ESG will endeavour to respond to your written request within a reasonable timeframe.

In exceptional circumstances, ESG reserves its right to deny you access to your personal information, and may provide you with an explanation as may be required by applicable law. Some of these circumstances include:

i. Where an investigating authority/ statutory authority/ government body objects to ESG complying with a participant’s said request,

ii. Where the information may, in the exercise of ESG’s reasonable discretion, have a bearing on the life or security of an individual;

iii. Where the personal information is collected in connection with an investigation of a breach of contract, and/ or contravention of applicable laws, rules and regulations;

d. Kindly note that if you withdraw your consent to any or all use of your personal information by ESG, depending upon the nature of request, ESG may not be in a position to continue to provide its services to you, and the said action of withdrawal of consent (whether partial or total) may be deemed to be a termination by you of any contractual relationship which you may have with ESG. Further, under such circumstances, you may be in breach of your contractual obligations. In such an event, all of ESG’s (and its related entities) rights are hereby fully and expressly reserved.

9. TRANSFER OF PERSONAL INFORMATION OVERSEAS
ESG’s registered office is located at 2 Alexandra Road, #08-00 Delta House, Singapore 159919. Be that as it may, personal information may be transmitted to data storage facilities where ESG keeps its central records. Personal information may thus be transferred to other countries, in connection with the conduct of the CSKR and/or ESG’s performance of its obligations under any existing Agreement with you.

10. RETENTION OF PERSONAL INFORMATION
ESG will retain the personal information collected, for as long as it is necessary to fulfil the purpose for which it was collected, the legal and/ or business purposes of ESG, and/or as may be required by applicable law.
When destroying personal information, ESG will take commercially reasonable and technically feasible measures to make the personal information irrecoverable or irreproducible, as may be required by applicable law.

11. SECURITY SAFEGUARDS
a. ESG takes the security and protection of your personal information very seriously. As such, ESG has put in place appropriate reasonable security arrangements to protect your personal information against loss or theft, as well as against unauthorised access and undue disclosure. Some of the security arrangements include secure servers, firewalls, and encryption of credit card information.

b. Unfortunately, there is always a potential risk in sending information through any channel (more so through the internet) and/ or retaining information on any storage device, and ESG cannot guarantee that communications between you and ESG or information stored on ESG’s resources, including personal information, will be free from unauthorized access by third parties.

c. To the extent permitted by applicable law, ESG (and its related entities) will not be held responsible for:

i. for any unauthorized access and/or illegal or unauthorized use of information, including personal information; and

ii. if your information, including personal information, is accessed through unauthorized and/ or improper use of your account or login information or due to your failure to secure your username, password, or customer ID.Furthermore, if you do not take reasonable measures to ensure the continued confidentiality and accuracy of the personal information, to the extent permitted by applicable law, ESG will not be liable for any consequential misuse.
d. If you have any concerns about security of your personal information disclosed to ESG, you should contact ESG [please refer to the contact details specified in the preceding paragraph (8)].

12. UPDATES TO THE PRIVACY POLICY
ESG may from time to time update this Policy to ensure that the Policy is in compliance with any future developments, industry trends and/ or any changes in the legal and/ or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of the Policy as updated from time to time on the website www.kidsrun.com.sg. Please check back regularly for updated information on the handling of your personal information. This Policy was last updated on 02 January 2016.

13. USE OF COOKIES, CLICKSTREAM DATA AND LINKS TO OTHER WEBSITES
a. In order to enable certain parts of the website www.kidsrun.com.sg to function correctly, we employ cookies. Cookies are small data files that are transferred to your computer’s hard drive from your web browser, to recognise your preferences. The cookies do not contain your Personal Data (unless you specifically chose the “Remember Me” feature), but only Statistical Data which is entirely anonymous. Please refer to your browser’s documentation to check if cookies have been enabled on your computer or to request not to receive cookies.

b. In order to improve your online experience, ESG may track clickstream data to advance your use of the web pages and to track referrals from other websites. Such data will not be stored as part of your personal information. It will only be collected for statistical analysis.

c. The website www.kidsrun.com.sg may contain links to other websites. Your access to the said linked websites is at your own risk and to the extent permitted by law, ESG shall not be held responsible for your access to the said linked websites and the consequences which may flow therefrom. Whilst ESG will protect your personal information collected by it directly, ESG cannot control or be responsible for the policies of other websites that may be linked to it, or the use of any personal information which you may share with them. Please note that this Policy does not cover these other websites, and ESG would recommend that you are apprised of their specific policies.

14. TRADE MARKS DISCLAIMER
All trademarks specified in this Policy remain the property of their respective holders, and unless otherwise represented, their display on CSKR-related material are solely for the purpose of illustrating products, events businesses being discussed and in no way should be taken to indicate any relationship, affiliation and/ or sponsorship between the respective holders of trademarks and ESG.

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