Z.com Data Protection Policy
Z.com's commitment to protecting your personal data
Z.com is committed to protecting your Personal Data (as defined below), and seeks to be in compliance with the applicable legislation and rules pertaining to the collection, use, disclosure and retention of Personal Data in Singapore. This includes the Personal Data Protection Act 2012 (No. 26 of 2012) (the "PDPA"), and the provisions pertaining to the Do Not Call Registry (the "DNC") set out therein.
This Z.com Data Protection Policy (the "Policy") aims to keep you, the customer, informed on how Z.com manages your Personal Data. You are advised to read this Policy carefully before using any of our products or services (hereinafter referred to as "Services") or creating an online account with Z.com (the "Account").
This Policy is expressly referred to in the Z.com Master Service Agreement (the “MSA”), the Z.com Pre-Pay Terms and Conditions (the “Pre-Pay Terms”) and the Z.com Domain Name Registration Service Order, Z.com Hosting Service Order and Z.com SSL Service Order.
This Policy governs the rights and obligations vis-à-vis Z.com and yourself in relation to the collection, use, disclosure and retention of your Personal Data, and supplements (but does not supersede or replace) the MSA, Pre-Pay Terms and Orders.
By using any of the Services provided by Z.com, or by creating an Account with Z.com or entering into the MSA, Pre-Pay Terms or any relevant Order(s) with Z.com, you hereby consent to the retrieval, collection, use, disclosure and/or retention of your Personal Data in accordance with the terms set forth in this Policy.
Your further represent, warrant and acknowledge that should any Personal Data of a third-party be disclosed to us by you, the consent of such third-party has been obtained for the retrieval, collection, use, disclosure and/or retention of his/her Personal Data in accordance with the terms set forth in this Policy. In the event that such consent has not been obtained, you shall indemnify us for all claims, losses, damages and/or liabilities howsoever arising from such failure to obtain consent. Any consent given in accordance with this Policy shall also constitute consent for the purposes of the Spam Control Act (Cap 311A, 2008 Rev. Ed. Sing.) or any other applicable legislation.
Z.com expressly reserves the right to amend this Policy at any time, in its sole and absolute discretion, in order to meet the changes in business demands, industry trends or changes in legal or regulatory requirements (as the case may be). The Policy, as amended from time to time, shall be made available on this page at the following link : https://cloud.z.com/ph/privacy/ . You are advised to refer to this page regularly to be apprised of the updates to this Policy.
1. Personal Data covered under this Policy
Personal Data is defined under the PDPA as "data, whether true or not, about an individual who can be identified
- (a) from that data; or
- (b) from that data and other information to which the organisation has or is likely to have access"
The Personal Data collected by Z.com varies with the kind and nature of the Service provided. Examples of such Personal Data include (but is not limited to) the following:
- (a)information pertaining to your identity, including your name, NRIC, FIN or Passport Number and date of birth;
- (b)your personal details, including your address, occupation, telephone number, email address, bank and credit card details and IP address;
- (c)your preferences, including your hobbies, interests, lifestyle choices, preferred modes of communication; and
- (d)information pertaining to your Account, including your usage of the Services provided.
2. How is Personal Data collected?
Personal Data is generally collected via the following means:
- (a)when an Account is set up with Z.com, including any personal details or documentation provided in pursuance thereof;
- (b)when an application is made to request for an increase in the maximum balance that can be held in the Z.com Pre-Pay account, in accordance with the Z.com Pre-Pay Terms and Conditions;
- (c)when you engage Z.com in the provision of any Services or make payment for such Services;
- (d)when you interact with Z.com or any employees of Z.com via telephone calls, mobile messages, letters, emails, face-to-face meetings, social media platforms or other means;
- (e)when you send any feedback and/or emails to Z.com;
- (f)when you respond to our requests for further information or data;
- (g)when you sign up to our newsletters or other promotional email, or offer to be included in our mailing list;
- (h)when you participate in any of our surveys or lucky draws;
- (i)when you are referred to us by business partners or other third parties; and/or
- (j)when you submit your Personal Data to us or to our related companies, business partners and/or third party agents for any other reason.
We do not automatically collect Personal Data when you browse our websites, unless you have logged into your account with your account details or provided us with such Personal Data on your own volition.
You shall ensure that all Personal Data provided by you is true, correct, accurate, complete and up to date, and we are entitled to rely on the accuracy, veracity, correctness, completeness and contemporaneousness of all such Personal Data provided to us. A failure on your part to do so may affect our provision of Services to you and may attract civil and/or criminal liabilities under the law. In such an event, by utilising our Services, you are deemed to have consented to the release of any information to any governmental authorities upon their request.
You shall ensure that in the event any Personal Data of a third-party is provided to the Company (for example the Personal Data of your family members and/or employees), you have obtained the consent of such third-party to the retrieval, collection, use, disclosure and retention by and on behalf of the Company, of such Personal Data of the third-party in accordance with this Policy.
3. Purposes for which your Personal Data is collected, used, disclosed and/or retained
Z.com collects, uses, discloses and/or retains your Personal Data for the following purposes:
- (a)verifying your identity;
- (b)providing any of the Services to you;
- (c)carrying out any of Z.com's obligations under the MSA, Pre-Pay Terms and/or relevant Orders;
- (d)monitoring our interactions between you for the purposes of customer service quality controls, employee training and performance evaluation;
- (e)responding to your enquiries, feedback or comments;
- (f)conducting any market research and/or analysis;
- (g)carrying out any surveys;
- (h)reviewing our internal processes and policies with a view to improving upon such processes and policies;
- (i)opening and maintaining an Account or Z.com Pre-Pay account;
- (j)authenticating the operation of an Account or Z.com Pre-Pay account, and any transactions carried out thereon as emanating from a registered or authorised user of Z.com's Services;
- (k)investigating any suspected instances of fraud, forgery, unauthorised access or use pertaining to or arising out of the provision of Services by Z.com, the operation of any Account or Z.com Pre-Pay account or any transaction entered into;
- (l)monitoring the transactions carried out for any suspected money-laundering, terrorism financing activities and/or other related risks;
- (m)meeting any legal, regulatory or compliance obligations on the part of Z.com, including such disclosures to the relevant government agency or regulatory authority as the case may be;
- (n)the conduct or defence of any legal proceedings, claims or actions, including but not limited to the procurement of legal advice, drafting of documents and facilitation of dispute resolution, and the enforcement of our rights and/or performance of our obligations in relation thereto;
- (o)marketing our Services;
- (p)providing you with information on promotions or rewards;
- (q)any other purpose permitted by any relevant law, regulation, notice or government authority; and
- (r)any other purposes arising out of or connected to the abovementioned purposes.
Unless required or permitted by any relevant law, regulation, notice or government authority, and subject to paragraph 3.3 below, we will not collect, use, disclose or retain your Personal Data for any other purpose other than those listed above.
We may collect, use, disclose or retain your Personal Data for any other purpose other than those listed above, if we have disclosed to you such other purpose and obtained your consent for the collection, use, disclosure or retention of your Personal Data for that purpose.
Z.com will cease to retain your Personal Data if it is reasonable to assume that:
- (a)the purpose for which that Personal Data was collected is no longer being served by retention of the Personal Data; and
- (b)retention is no longer necessary for legal or business purposes.
4. Disclosure of your Personal Data
Z.com shall take reasonable measures to prevent the unauthorised disclosure of your Personal Data to any third parties.
Subject to the provisions of any applicable law, Z.com may disclose your Personal Data to the following parties in connection with the purposes listed under paragraph 3 above:
- (a)any related companies of Z.com;
- (b)any business partners of Z.com;
- (c)any third party vendors or suppliers with whom we collaborate in the provision of Services to you;
- (d)any third party agents of Z.com; and
- (e)any research bodies or institutions who carry out market research and analysis on our behalf,
provided that, in any case where your Personal Data is transferred to any of the aforementioned parties outside of Singapore, we will ensure that such parties provide a standard of protection to Personal Data so transferred that is comparable to the protection under the PDPA, unless such requirement is waived by the Personal Data Protection Commission (the "Commission") in accordance with the PDPA.
5. Protecting your Personal Data
Z.com shall take reasonable security arrangements to prevent any unauthorised access, collection, use, disclosure, copying, modification or disposal of your Personal Data, as well as to guard against such similar risks.
These measures include the setting up of firewalls, establishing internal controls and data management policies, training and vetting employees who handle Personal Data and regular independent checks by security professionals.
Whilst we strive to protect your Personal Data, we cannot guarantee the security of such Personal Data transmitted to us over the Internet or collected by us in connection with the provision of Services, or that our websites will be impervious to malicious codes or attacks. We urge that you take steps to protect your Personal Data, including utilising a strong alphanumeric password, changing your passwords often, and ensuring that your browser(s) and computing device(s) are secured against network-based threats.
You shall undertake to keep your username and password confidential at all times and not to disclose or permit the same to be disclosed to any unauthorised party. You further undertake to inform us as soon as reasonably practicable, should you know or suspect that the confidentiality of your username and/or password has been compromised in anyway whatsoever, or if there has been any unauthorised or fraudulent access to or use of your Account.
Z.com shall not be liable for any losses, damages, claims or liabilities arising out of any security breaches and/or unauthorised or fraudulent access to or use of your Account or Personal Data.
A cookie is a small piece of data that is stored in your web browser when your browse certain websites. This data can then be retrieved by the owner of the website the next time you visit the website.
Cookies are used by Z.com on its websites for the following purposes:
- (a)tailoring our provision of Services to you in order to suit your needs and preferences;
- (b)enabling certain functionalities on our website, such as remembering your username and/or password for ease of log-in and the automatic filling-out of personal details when placing an order for any of our Services;
- (c)collating usage patterns in order to improve the efficiency of our websites; and
- (d)providing services to advertisers
7. Third-Party Advertisements and Websites
The Z.com websites may also contain links to third-party websites. These third-party websites may collect, disclose, use or retain your Personal Data for such purposes and in accordance with such privacy policies as may be determined by the relevant third-parties.
8. The Do Not Call Registry (the "DNC")
The DNC established under the PDPA allows individuals to opt out of receiving marketing or promotional phone calls, text messages or faxes ("Marketing Messages") on their Singapore telephone numbers.
This does not apply to information or service-related messages which Z.com may, from time to time, send to you in connection with the provision of our Services.
Z.com respects your choice and seeks to comply with the PDPA and the regulations pertaining to the DNC therein. If you have registered your Singapore telephone number with the DNC, Z.com will not send you any Marketing Messages. Please note that the effective date of registration with the DNC is thirty (30) days from the date of registration. You may continue to receive Marketing Messages from Z.com in the interim period.
Additionally, if you have given Z.com prior consent to the receipt of Marketing Messages, Z.com may still send you such Marketing Messages, until you have withdrawn your consent.
If you have registered your Singapore telephone number with the DNC but would like to be kept up to date on the latest promotions and offers available from Z.com, you may indicate your consent to the receipt of Marketing Messages by signing up to our newsletter at email@example.com. Examples of such Marketing Messages include:
- (a)exclusive offers, promotions, rewards or discounts in relation to the Services;
- (b)offers or discounts that are limited to a particular time period or a specific quantity;
- (c)offers or discounts in relation to the renewal of the provision of Services; and
- (d)invitations to events or exclusive activities;
9. Contacting us - Your Rights Under the PDPA
I. Withdrawal of consent
You may, at any time and upon the giving of Reasonable Notice to us (as defined below), withdraw your consent given in accordance with this Policy, the MSA, the Pre-Pay Terms or any relevant Order in relation to the collection, use, disclosure and/or retention of your Personal Data.
Reasonable Notice shall be given in writing via email or by letter setting out clearly your intention to withdraw your consent to the collection, use, disclosure and/or retention of your Personal Data in relation to any or all of the purposes listed in paragraph 3 or to any or all of the persons listed in paragraph 4.
Upon your withdrawal of consent, Z.com will assess the implications, if any, of such withdrawal on the performance of its obligations under the MSA, Pre-Pay Terms and/or any relevant Orders. In the event that Z.com is of the opinion that the performance of its obligations under the MSA, Pre-Pay Terms and/or any relevant Orders or provision of Services to you is affected owing to your withdrawal of consent, Z.com shall be entitled to terminate the provision of any part of or all of its Services to you. In such event, our rights and remedies in law and in equity are expressly reserved.
II. Access to and Correction of Personal Data
Subject to the provisions of the PDPA, you may:
- (a)request for us to provide you with information pertaining to your Personal Data that is in our possession or under our control, and the manner in which your Personal Data has been or may have been used or disclosed within the period of a year before the date of your request; and/or
- (b)request for us to correct an error or omission in your Personal Data that is in our possession or under our control
Please contact us via email or letter at our contact details set out below, in relation to any withdrawal of consent or request for access to or correction of Personal Data
Address: 23/F Zuellig Building, Makati Avenue corner Paseo de Roxas, Makati City 1226
III. Queries and Feedback
You may also contact us if you have any other queries, require further clarification or wish to give us your feedback with regards to the terms set out in this Policy.
10. Governing Law
This Policy and your use of the Services and Z.com's websites shall be governed in all respects by the laws of the Republic of Singapore.
Last updated on 6 October 2015
Capitalised terms in this Policy have the meanings given to them in the Z.com Master Service Agreement unless otherwise defined. "We", "our" and "us" refer to all GMO INTERNET GROUP