PERSONAL DATA PROTECTION

Please read this Policy carefully and, should you have any questions on how we manage, protect or process your personal data, do not hesitate to contact our Data Protection Officer at the details below.

You undertake to keep your account details secure and confidential. Unauthorised access and use of the Channels by any third party through your account may result in suspension or termination of your account.

This Policy explains how we collect, use, disclose or process your personal data through your interactions with certain services: (i) this website, ssdcl.com.sg (the “Sites”); (ii) any official social media channels (the “Channels”); (iii) all associated service offerings; and (iv) all other services, systems, servers, software and applications provided or operated by us, our affiliates, the Government of Singapore or our service providers (collectively, the “Services”).

Personal data includes any information relating to an identified or identifiable natural person. It does not include data that cannot be linked to an individual (such as anonymised data).

Your privacy matters to us. SSDC follows certain privacy principles to comply with the Personal Data Protection Act 2012 of Singapore (“PDPA”) and other applicable laws, including:

• obtaining your consent to collect, use or disclose your personal data (unless otherwise required or permitted by law);
• only collecting and using personal data necessary to conduct our business, comply with legal obligations, pursue our legitimate interests and provide the Services;
• implementing reasonable technical and organisational measures to keep your personal data secure, accurate and up to date;
• retaining your personal data only for as long as necessary; and
• disclosing your personal data to the Government of Singapore, our service providers or other third parties in relation to certain Services offered.

We may collect, use, disclose or process your personal data for purposes including:

• establishing and maintaining any user or membership account with us;
• facilitating the provision of the Services, including enrolment, courses and the issuance of licences;
• communicating with you about changes in the Services or providing supporting services;
• monitoring and analysing how you and other users use the Services;
• improving and building features and offering other services;
• detecting and preventing fraud or misuse of the Services;
• verifying your identity, billing, membership or eligibility for courses, grants or subsidies; and
• complying with obligations, requirements or arrangements that apply to us, now and in future.

We may also rely on the legitimate interest exception to collect, use and disclose personal data — including for improving services and operations, understanding your preferences, customer segmentation, and CCTV and physical security purposes such as detection and prevention of crime and safety incidents.

The types of personal data we collect depend on the nature of the Services you seek, and include but are not limited to:

• contact information and personal details: full name, NRIC/FIN, date of birth, nationality, address, email and mobile number;
• billing, enrolment, insurance or licence information: payment details, billing name and address, eyesight test result, digital photograph and membership information;
• video and image for safety and training: CCTV and in-vehicle camera (outward-facing) audio and video recordings;
• your IP address and details of visits to the Sites and Channels; and
• your voice or video recording in phone calls for training, analytical and service-improvement purposes.

Personal data in our possession and control shall be kept confidential and private. To the extent necessary under the PDPA, we implement reasonable technical and organisational measures to prevent loss, misuse or alteration of your personal data, with policies and procedures designed to protect both your confidentiality and the security of your data.

Our Sites and Channels may include links to third-party websites, plug-ins and applications. We do not control these and are not responsible for their privacy notices; we encourage you to read the privacy notice of every website you visit.

SSDC may share your personal data with certain third parties for the purposes set out above, in compliance with the PDPA, including where third parties are located in a different country from the point of collection. Where data must be shared in circumstances not reasonably contemplated in the normal course of dealings, we will first seek your consent unless disclosure:

• is required or authorised by applicable laws or regulations;
• is clearly in your interests and consent cannot be obtained in a timely way;
• is necessary to respond to an emergency threatening life, health or safety;
• is necessary for any investigation or proceedings;
• is required by a law enforcement agency;
• is to a public agency and necessary in the public interest; or
• is otherwise permitted by law.

We take reasonable efforts to keep your personal data accurate and complete based on the information you provide — please keep us informed of any relevant changes. We have security arrangements to protect your data and will securely destroy personal data in our possession or control within seven (7) years from the date of collection, as soon as it is reasonable to assume the purpose is no longer served and retention is no longer necessary for any legal or business purpose, unless required by law, regulation or audit requirements.

If you have any complaint or feedback regarding how we handle or process your personal data, please contact us in writing with sufficient particulars:

As part of our efforts to properly manage, protect and process your personal data, we review our policies and may update the terms of this Policy from time to time at our absolute discretion. Any revised Policy will be posted on our Sites. You are encouraged to visit our Sites to access this Policy from time to time.