Privacy Policy


KALMS Personal Data Protection Policy (“Policy”)

KALMS (Singapore) Pte. Ltd. and its subsidiaries and joint venture companies (collectively referred to herein as “Kalms Group”, “us”, “we” or “our”) own and operate vending machines and provide automated retail solutions.

By interacting with us, submitting information to us, or signing up for any of our goods and/or services, you agree and consent to the use of collection, use, and disclosure of your personal data by the Kalms Group in the manner set forth in this policy.

This Policy supplements but does not supersede nor replace any other consent which you may have previously provided to us nor does it affect any right that we may have at law in connection with the collection, use, disclosure and/ or retention of your Personal Data.

We may update this Policy from time to time to ensure that it is consistent with our future developments and/ or any changes in legal or regulatory requirements. Should any revisions be made to this Policy, updates will be published on our site www.kalms.com/sg/pdppolicy. Subject to your legal rights in Singapore, you agree to be bound by the prevailing terms of the Policy as updated from time to time on our website.


PERSONAL DATA

Personal Data” refers to any personally identifiable information which you have provided to us in connection with the use of our Services, including but not limited to, when you create an account with us, make payments to us, or use any of our vending machines. Examples of such Personal Data include but are not limited to:

Personal information such as your name, NRIC, passport or other identification number, your mailing address, email address, mobile number, and information relating to payments, such as your bank account number or credit card information;

Non-personally identifiable information which is collected automatically when you interact with our site through the use of software or other automated processes that the site uses.


COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).

You agree that we may use your Personal Data for some or all of the following purposes and/or other purposes that we may notify you of in writing or as permitted by law (the “Purposes”):

2.2.1.To perform obligations in the course of or in connection with our provision of the goods and/or services requested by you;

2.2.2.To provide you with membership benefits and services;

2.2.3.To provide you with employment or employability services;

2.2.4.To send you marketing information about our goods and/or services including notifying you of our marketing events, initiatives and promotions, lucky draws, membership and rewards schemes and other promotions;

2.2.5.To process your payment and credit transactions;

2.2.6.To obtain feedback and assist you with your enquiries as part of our customer service programme;

2.2.7.For the provision, development and the improvement of the Services provided to you;

2.2.8.To monitor, track and analyze user activity and demographic data, including but not limited to trends and usage of our Services;

2.2.9.To conduct research, surveys and interviews;

2.2.10.To comply 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;

2.2.11.Any other incidental business purposes related to or in connection with the above

We may disclose your Personal Data:

2.3.1.Where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods or services requested by you; or

2.3.2.To third party service providers, agents and other organisations we have engaged to perform any of the functions listed in clause 2.2 above for us.

The Purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).


WITHDRAWING YOUR CONSENT

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 below. You may download the form for a withdrawal request here. [Note to Grace and Danny: When the user clicks on “withdrawal request”, FORM A should download automatically]

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 and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. 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 us in writing in the manner described in clause 3.1 above.

Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.


ACCESS TO AND CORRECTION OF PERSONAL DATA

If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below. You may download the forms for an access request and correction request here.

Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.

We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).


PROTECTION OF PERSONAL DATA

To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures 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, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis.

You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.


ACCURACY OF PERSONAL DATA

We take all reasonable measures to ensure that your Personal Data is accurate, complete and up-to date.

We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.


RETENTION OF PERSONAL DATA

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.

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.


TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE

We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.


DATA PROTECTION OFFICER

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 at:

Kalms (Singapore) Pte. Ltd.
16 Kallang Place, #03-02, Singapore 339156
enquiries@kalms.com.sg


EFFECT OF NOTICE AND CHANGES TO NOTICE

10.1 This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.

10.2 We may revise this Policy from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Policy was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.