At Clipped Assist, the privacy and confidentiality of the personal data of our members who have participated in our membership are important to us. We are committed to implementing policies, practices and processes which will safeguard the collection, use and disclosure of the personal data you provide us.

This Policy sets out the manner in which Clipped Assist collects, uses, manages and protects Personal Data (as defined below) in compliance with the provisions of the Personal Data Protection Act 2012.

This Policy supplements but does not supersede or replace any previous consent which members may have provided to Clipped Assist, and nothing in this Policy shall affect any rights or exemptions that Clipped Assist may have at law in connection with the collection, use and/or disclosure of member’s Personal Data.

Subject to Singapore laws, the prevailing terms of the Policy from time to time shall apply. By continuing your relationship with Clipped Assist after any amendments have been introduced and published, you shall be deemed to have accepted the Policy as amended and given your consent for Clipped Assist to use your Personal Data in the manner described. For the avoidance of doubt, this Policy forms part of the terms and conditions, if any, governing an members’s relationship with Clipped Assist (“Terms and Conditions”) and should be read in conjunction with such Terms and Conditions. In the event of any conflict or inconsistency between the provisions of this Policy and the Terms and Conditions, the provisions of the Terms and Conditions shall prevail to the fullest extent permissible by law.

1. Definitions

“Event Participants” means persons (whether or not Members) who participate in contests, competitions, lucky draws or campaigns or attend events, programmes or activities organised or sponsored by Clipped Assist, whether on its own or together with other organisers from time to time.

“PDPA” means the Personal Data Protection Act 2012 as may be amended from time to time.

“Personal Data” means data (whether true or not) that is capable of identifying a natural person, whether on its own or in conjunction with other data that is accessible to Clipped Assist. Such Personal Data shall also refer to data which is already in the possession of Clipped Assist or that which shall be collected by Clipped Assist in the future.

“Personnel” shall include any person engaged under a contract of service with Clipped Assist, management personnel, permanent or temporary employees, as well as volunteers engaged by Clipped Assist from time to time (and, where appropriate, shall also include memberss who provide services to Clipped Assist as sole proprietors under a contract for services, and memberss employed by a third party but who perform services for Clipped Assist pursuant to a contract for services entered into between his or her employer and Clipped Assist).

“Platforms” mean the websites (including but not limited to https://clippedassist.sg/), application software (including but not limited to the Clipped Assist mobile App), computer systems, computer networks and any other digital platforms operated by or on behalf of Clipped Assist from time to time, and which may include third party platforms used by Clipped Assist (including but not limited to Facebook & Instagram).

“Potential Personnel” shall include any members who has submitted an application to be engaged by Clipped Assist as Personnel.

2. Personal Data Collected by Clipped Assist

Clipped Assist will only collect, use or disclose Personal Data which it reasonably considers necessary for the relevant purposes underlying such collection, use or disclosure. Depending on the specific nature of an members’s interaction with Clipped Assist, Personal Data which Clipped Assist collects, uses or discloses may include the following (Note: the list below may not be exhaustive): personal particulars such as name, car plate number, and contact particulars, including telephone number(s), residential/mailing address(es) and email address and applicable visa or permits (such as employment pass, work permit, permanent residency status).

Network usage data and other data and information, submitted by the members or gathered automatically by our Platforms, including computer IP address, links visited and other activities conducted online or using our Platforms and any other information which an members may provide to Clipped Assist, from time to time, in the course of such member’s interaction with Clipped Assist or that may be received from a third party providing such information to Clipped Assist

3. How Clipped Assist collects Personal Data

Generally, Clipped Assist may collect Personal Data about members in one or more of the following ways:

1. Directly from members:
2. through correspondence, emails, electronic messages or other forms of communications with Clipped Assist or its representatives or information that may be posted on the Platforms;

1. through member’s verbal interactions with Clipped Assist (including voice or video calls or face-to-face interactions)

iii.   through registration for an online account with Clipped Assist (as online Clipped Assist account holder)

1. through information obtained from the mobile devices of members with consent

1. From a third party and affiliated organisations
2. through third party business partners or associates of Clipped Assist including but not limited to transactions carried out by members at points of sale at repairer premises.

1. Other monitoring
2. through the member’s access to and/or use or navigation of the Platforms and the use of cookies.
3. through recordings taken via security cameras or other forms of photography or video or sound recording at Clipped Assist’s business partner’s premises.

4. Purposes for which Clipped Assist may collect, use and/or disclose Personal Data

In addition to the statutorily provided situations in which Personal Data may be collected, used or disclosed without consent, generally, Clipped Assist may collect, use and/or disclose Personal Data for one or more of the following purposes and any purposes reasonably related and/or ancillary to any of the below-mentioned purposes:

1. Members:
2. administering and managing Member relationships with Clipped Assist, including but not limited to verification of member’s eligibility to be a Member of Clipped Assist, the provision of services to Members, and providing Members with information regarding the expiry and renewal of their membership and other service-related announcements.
3. providing Members with information and updates concerning repair services, and/or other benefits or promotions being offered or made available by Clipped Assist to Members and where applicable.

iii.        providing Members with information about third party and/or external repair promotions, benefits, deals and/or other services being offered or made available to Members, through partnerships, associations and/or other collaborations involving such third parties or external repairer and Clipped Assist

1. Visitors and users of Clipped Assist services
2. recording and verifying the identity of visitors to Clipped Assist’s repairer premises for safety, health and security purposes
3. monitoring the activities of visitors to Clipped Assist’s repairer premises to ensure compliance with Clipped Assist’s rules and regulations.

1. Non-members
2. providing Non-members with information and updates concerning our repair services, and/or other benefits or promotions being offered or made available by Clipped Assist to Non-members and where applicable, allowing the Non-members to book, subscribe and/or purchase the same (this may require Clipped Assist to share Personal Data with the merchants to establish a Non-member’s eligibility for a benefit or promotion)

1. providing Non-members with information about third party and/or external repairer promotions, benefits, deals and/or other services being offered or made available to Non-members, through partnerships, associations and/or other collaborations involving such third parties or external Repairer with Clipped Assist.

1. Personnel
2. administering and managing Personnel relationships with Clipped Assist, including but not limited to making payment to Personnel (whether via VISA/MASTER, Paynow or through other payment platforms where Personal Data is submitted) and evaluating the performance of Personnel
3. monitoring performance and compliance with Clipped Assist rules and regulations and the terms of the Personnel’s contract with Clipped Assist

iii.   Organizing and undertaking training and quality assurance activities

1. providing Personnel with information about services, and/or other benefits being offered or made available by Clipped Assist.

1. Potential Personnel
2. evaluating the suitability and eligibility of Potential Personnel to be engaged by Clipped Assist, including but not limited to conducting interviews and assessing suitability for the position applied for processing your application (including but not limited to pre-recruitment checks involving qualifications, obtaining employee references to conduct background screening and facilitating interviews)
3. attending to the enrolment of successful applicants

In addition to the above mentioned purposes, Clipped Assist may also use Personal Data for the purposes below:

1. Marketing
2. sending marketing, advertising and promotional information concerning Clipped Assist and its affiliated organisations, interest groups, membership club and third party service providers engaged by or working in collaboration with Clipped Assist in relation to promotions, Events, deals and/or services being offered or made available to you

1. General business purposes
2. managing the administrative and business operations of Clipped Assist (which may include collection, use and disclosure of Personal Data in order to comply with governmental directions or other rules, regulations and advisories relating to the management of the COVID-19 situation.)

1. responding to complaints, queries and/or requests

iii.        safety and security purposes, including but not limited to preventing, detecting or investigating any actual or potential crime, fraud, misconduct, unlawful action, breach or dispute.

1. legal and record-keeping purposes (including but not limited to purposes of accounting or auditing or obtaining financial, or tax advice obtaining legal advice and dispute resolution) or the recovery of bad debts or damages and complying with laws, regulations, codes or guidelines binding on Clipped Assist, making disclosures to regulatory authorities or other public agencies

1. transmitting Personal Data to third parties engaged by or working in collaboration with Clipped Assist to facilitate any of the above-mentioned purposes (such as external consultants or outsourced service providers) or to such parties as may be directed by the relevant authorities or as may be required under applicable laws.

5. Consent

Unless otherwise permitted under the PDPA , Clipped Assist will not collect, use or disclose  member’s Personal Data without his/her consent or without notifying the members of the collection, use or disclosure of his or her Personal Data.

Where consent / notification is required to be obtained / provided to an members, Clipped Assist will take reasonable steps to highlight the relevant purposes, by appropriate means, at the point or time of collection of the Personal Data, which may include:

via notifications on or through the Platforms; and in the course of verbal communications. A members who provides Clipped Assist with Personal Data relating to a third party (e.g. information of his/her spouse or children) for any particular purpose, represents to Clipped Assist that he/she has obtained the consent of the relevant third party to Clipped Assist collecting, using or disclosing such Personal Data for the relevant purpose. By providing us with any Personal Data relating to any third party (“Third Party Personal Data”), you represent and warrant that you have ensured the accuracy of such Third Party Personal Data provided and have also obtained such third party’s consent for our collection, use and disclosure of such Third Party Personal Data. You also agree to keep us indemnified from and against any and all damages, losses, costs, legal fees (on a solicitor-client basis), penalties and proceedings, imposed or charges by any regulator or authority arising out of or in connection with your acts or omission, fault or negligence which results in our breach of relevant laws.

In so far as Clipped Assist collects Personal Data from any third party(ies), Clipped Assist will take reasonable steps to inform the relevant third party(ies) of Clipped Assist’s purposes for collecting the Personal Data and to verify that consent from the members has been obtained by the relevant third party(ies) to such disclosure for the intended purpose. If the third party is exempt from the provisions of the PDPA, and your consent is required, Clipped Assist shall take reasonable steps to contact you and confirm that you wish for your Personal Data to be used.

6. Cookies

When you visit our Platforms, we may send one or more cookies to your computer and/or other devices. The information obtained from such cookies may be used by us for storing user preferences and to enable Clipped Assist or third party advertising partners to display targeted advertisements which may be of interest to you.

We also collect information which is sent to us by your web browser. When you browse our Platforms, we automatically receive your computer’s Internet protocol (IP) address which provides us with information that helps us learn about your browser and operating system, such as the name of your operating system and the name and version of your browser.

In so far as an member’s data is being collected by cookies, the members may disable the use of cookies when accessing the Platforms. However, this may result in the loss of functionality, restrict the member’s use of the Platforms and/or delay or affect the way in which the Platforms operate.

7. Third party websites

Clipped Assist is not responsible in any way for the security and/or management of Personal Data shared by or collected from you through third party websites such as our partners which are not managed by Clipped Assist and accessible through links on the Platforms.

8. Retention of Personal Data

Your personal data is retained for a period of 5 years which it was collected remains and/or until your personal data is no longer necessary for any other legal or business purposes.

9. Protection of Personal Data

Clipped Assist shall make reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks to Personal Data in its possession. Subject to the foregoing and at all times the provisions of the PDPA, we cannot assume responsibility for any unauthorized use of your personal data by third parties which are wholly attributable to factors beyond our control.

Clipped Assist will ensure that third parties who receive Personal Data from Clipped Assist protect such Personal Data in a manner consistent with this Policy and not use such Personal Data for any purposes other than those specified by Clipped Assist, by incorporating appropriate contractual terms in its written agreements with these third parties.

10. Overseas transfer of data

If Clipped Assist transfers or hosts Personal Data outside Singapore, Clipped Assist will take reasonable steps to ensure that the Personal Data that is transferred to the transferee or host overseas receives a standard of protection for personal data that is comparable to the protection received under the PDPA.

Where your personal data is to be transferred out of Singapore, we will comply with the PDPA in doing so. In this regard, this includes us obtaining your consent unless an exception under the PDPA or law applies, and taking appropriate steps to ascertain that the foreign recipient organisation of the personal data is bound by legally enforceable obligations to provide to the transferred personal data a standard of protection that is at least comparable to the protection under the Act. This may include us entering into an appropriate contract with the foreign recipient organisation dealing with the personal data transfer or permitting the personal data transfer without such a contract if the PDPA or law permits us to.

11. Withdrawal of Consent / Unsubscribing

Members / Online Clipped Assist account holders may unsubscribe from receiving electronic direct mailers (for marketing purposes) by altering their consent settings through logging into their accounts on the respective Platforms, such as my Clipped Assist. Alternatively, if Members/Online Clipped Assist account holders are unable to do so for technical reasons, they may write to Clipped Assist’s and clearly indicate their intention to withdraw their consent to the use, or disclosure of Personal Data by Clipped Assist.

Not consenting to or removal of consent to receiving marketing materials from Clipped Assist and its affiliates does not mean that you will not receive service-related messages and updates from Clipped Assist, including but not limited to notifications that your Clipped Assist membership is expiring or notifications of an amendment to Clipped Assist’s policies or Terms and Conditions.

By signing up as a Member, an online Clipped Assist account holder, you have consented to receiving service-related messages and updates. Depending on the extent to which you withdraw consent to any or all use or disclosure of your Personal Data by Clipped Assist, such withdrawal of consent may result in Clipped Assist’s inability to provide services to you and/or you having to cease participation in the Events and this may be considered as a termination by you of any agreement between Clipped Assist and you. Clipped Assist’s legal rights and remedies are expressly reserved in such event.

12. Accuracy of Personal Data & Notification of Changes

You agree that you shall be responsible for ensuring that all Personal Data submitted by you to Clipped Assist is complete and accurate, and that you shall update Clipped Assist in a timely manner of all changes to your, or your family members’ Personal Data.

Clipped Assist may take reasonable steps to periodically verify Personal Data in its possession, taking into account the exigencies of its operations but shall not be held liable for any inability to attend to or provide services to any person (including participation in an Event) who fails to ensure that his/her Personal Data submitted to Clipped Assist is complete and accurate or who fails to notify Clipped Assist of any relevant changes to such Personal Data.

13. Contacting Clipped Assist on Personal Data matters

If you have questions or feedback relating to this Policy, would like information about the ways in which your Personal Data held by Clipped Assist has been or may have been used or disclosed by Clipped Assist, or have other queries or concerns about your Personal Data, please contact Clipped Assist’s Data Protection Officer by email at [email protected] .

Please note that Clipped Assist is not required, under the PDPA, to provide access and correction to Personal Data in certain situations. Clipped Assist reserves the right to charge a reasonable fee for the handling and/or processing of access requests.

Depending on the complexity of the request, Clipped Assist may require up to 30 calendar days from the date of the request to respond and effect any change requested, and if additional time is required, Clipped Assist will notify you accordingly.

14. Amendments or Updates to this Policy

Clipped Assist reserves the right to amend or update this Policy to ensure it is consistent with its future developments or business purposes or to accommodate future changes to applicable legal, business or regulatory requirements. All amendments or updates to this Policy will be published at https://clippedassist.sg/ and appropriate notifications of any material revisions will be issued to the relevant persons (unless such persons have unsubscribed from our notification channels).

15. Governing Law

This Policy shall be governed by and construed in accordance with the laws of Singapore. Any dispute arising out of or in connection with this Policy including any question regarding its existence, validity or termination, shall be referred to and finally resolved by the Courts of Singapore.