Privacy Policy - The Ring SG

Red Glove Management Pte. Ltd. and its affiliates (“we”, “us” or “our”) respect the privacy rights of our users (“you” or “your”) and are strongly committed to protecting your privacy.

This Privacy Policy aims to give you information on how we collect, process, use, disclose and retain your personal information through our website, or such other electronic services provided by us, your purchase of or signing up to our services (whether online or offline, including newsletters), or when you attend any of our events, courses or programs.

This Privacy Policy is based on the Personal Data Protection Act 2012 of Singapore (as may be amended, supplemented or otherwise modified from time to time, the “PDPA”) and all the associated regulations and guidelines as may from time to time be issued by the Personal Data Protection Commission of Singapore (the “PDPC”).

Notwithstanding the above, we will take steps to comply with all applicable laws with regards to data privacy, including where local laws are more stringent than this policy. For the purposes of this Privacy Policy, the term “applicable laws” shall mean applicable laws, regulations, codes of practice, guidelines, or rules as may be amended, supplemented or otherwise modified from time to time. If you are a European Union resident, please also refer to our General Data Protection Regulation Privacy Statement, which can be found here.

Please review this Privacy Policy in its entirety carefully before using our website, or otherwise providing us with any of your personal information. This Privacy Policy applies in conjunction with any other policies, notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal information by us. Specifically, this Policy supplements but does not supersede nor replace any other consents which you may have previously provided to us nor does it affect any rights that we may have at law in connection with the collection, use, disclosure and/or retention of your personal information.

Consent

We will notify you of the purpose for collection, processing, usage or disclosure of your personal information before we collect, process, use or disclose such personal information respectively, including through the use of this Privacy Policy. By using and continuing to use this website, you consent to the collection, processing, usage and disclosure of your personal data for the purposes set out in this Privacy Policy.

Under certain circumstances, we may deem that you have provided consent when you voluntarily provide your personal information for specific relevant purposes. For example, when you provide your name and contact information for the creation of an account, it is deemed that you have provided consent in relation to the creation of a profile linked to such account.

We may also rely on exceptions to the need for consent under certain circumstances such as the following:

Such personal information is publicly available;
Such personal information is required for debt recovery from you or another person to us;
Such personal data is disclosed to us or otherwise obtained directly or indirectly from a public agency; and
Such personal data is disclosed to us as part of another person’s or entity’s contractual obligations or otherwise by contractual necessity.

Information We Collect

We may collect and process certain types of personal information. “Personal information” is data that relates to you and can (on its own or in combination with other information) identify you as an individual, whether true or not. It does not include data that has been aggregated or made anonymous whereby you can no longer be identified using means reasonably available to us.

Personal information includes, among other things, personal information that you voluntarily provide on this website, which may include your:

Verification information: name; address; e-mail address(es); telephone number(s); date of birth; gender; race; nationality; and passport number;
Contact information: residential, mailing or billing address(es); e-mail address(es); and telephone number(s);

Payment information: credit or debit card numbers; and bank account, billing or other financial information;
Information relating to your use of the Services both offline and online (where relevant, through cookies, pixels, web server logs, web beacons or other similar technologies)

and any other types of information that you choose to upload, communicate or otherwise provide to us or that we may collect about you through our provision of any Services or your transactions with us in general, which may include any inquiries or feedback which we receive from you.

In addition, we may also collect personal information provided by other organisations such as your employer, company or third-party sources (including other entities we believe you have authorised to provide such personal information for and on your behalf, such as business partners, unaffiliated third-party social media companies, data brokers and analysts (via data analytics tools or otherwise), or other information providers, or other commercially and publicly available and legitimate sources as permissible by applicable law). We set out the privacy policies of certain relevant third-party websites for your reference – Kindly familiarise yourself with these and ensure that you are comfortable with them:

Google Analytics; and
WordPress.

We also may collect information about you that is not personal information, which may include anonymised or aggregated information, intellectual property or other company information shared with us, from your use of the Services or otherwise. Where necessary, we may combine this information with personal information or other information that we receive from or about you to provide the Services you require in the manner set out below, which combination of such information possibly could be used to identify you personally.

How We Collect, Use and Process Your Personal Information

We may collect, use and/or process your personal information for the following purposes:

providing you with our online or offline Services;

carrying out your instructions or responding to your enquiries, requests for information submitted by your or on your behalf;
checking or verifying your identity and/or suitability as a client for certain Services;
administering and managing our relationship with you;
for any promotion, business development, marketing or other communications, including that relating to newsletters or promotional material which may consist of texts, photographs, videos, or such other audio-visual content;
for any logistical or administrative purposes in connection with any of our Services, including informing you or any updates or changes to any Service;

contacting or corresponding with you through various means including voice calls, text messages, email, or post to administer and manage your relationship with us, including the processing of and attending or responding to any feedback, opinions or comments;
processing payment, billing, invoicing or other credit-related actions;
complying with applicable law or in response to a subpoena, court order, government request, or other legal process for or in connection with litigation, arbitration, mediation, adjudication, government, or internal investigations, or other legal or administrative proceeding;
protecting, enforcing and/or complying with our contractual, legal rights and/or obligations, as applicable;
operating and maintaining our systems and carrying out our business operations or internal protocols and policies properly including to ensure the safety and security of our users, representatives and all relevant persons in both physical and online environment, including the prevention of fraud, abuse, or other illegal or prohibited activities; and

for any other incidental or ancillary purposes related to or in connection with the above, including audit requirements and carrying out market-related, evaluative, or similar research and analysis to review, develop, improve or enhance our Services.

Disclosure of Personal Information and Other Information

We may disclose your information, including personal information:

to our affiliated or related group companies, where they are directly or indirectly involved in the provision of Services;

to any entity to whom we assign, novate or otherwise transfer or may assign, novate or otherwise transfer our rights and obligations in connection with the Services, whether in relation to a merger, acquisition or sale of all or a portion of our assets or otherwise;
where swift disclosure is required to respond to an emergency threatening the life, safety or health of you or any other persons;
where applicable laws or regulations require such disclosure, such as producing relevant documents or information for compliance with a subpoena, court order, government request, or other legal process, whether in connection with litigation, arbitration, mediation, adjudication, government, or internal investigations, or other legal or administrative proceeding;
where such disclosure is required for performing obligations in the course of or in connection with our provision of the Services you require;
to third-party service providers, agents, professional advisors and other organisations we have engaged to perform any of the functions listed in the section above for us, including (a) referring websites and applications, (b) social media services where accessed through our website or applications, (c) payment, workspace management and other backend related systems, as well as their respective representatives; and

where you have created an account and have publicly disclosed any personal information through your profile.

Please review the privacy policies of any website or application that referred you to our website, or which you are accessing from our website as we are unable to place limitations on their use of personal information.

Accuracy and Security of Personal Information

Where personal information is submitted by you on behalf of another person or concerns another person other than yourself, you represent and warrant to us that all the necessary consents procured in accordance with applicable law, for such purposes stated in the relevant sections of this Privacy Policy have been obtained from the relevant person(s) and that you have retained proof of these consents, such proof to be provided to us upon our request.

Where we have an ongoing relationship with you, it is crucial that you update us on any changes or updates to your personal information. As such, we may from time to time do data verification exercises for you to provide us with any such updates.

We strive to protect the security of your information and are constantly reviewing and enhancing our information security measures. We make reasonable efforts to implement appropriate administrative, technical, personnel, and physical measures (a) to safeguard personal information against loss, theft, unauthorised use, copying, disclosure, or modification; and (b) to ensure the integrity of the personal information, as encapsulated in our internal data protection rules and PDPA compliance policies.

Retention of Data

Any personal information in our possession or under control will be destroyed and/or anonymised when:

the purpose for which the personal information was collected is no longer served by the retention of such personal information, including to address any complaints, and
the retention is no longer necessary for any audit, legal, regulatory, or business purposes, including the maintenance of business records in accordance with record retention requirements under applicable law or for business analysis purposes, as well as to make or defend against any legal claims.

Access, Correction and Withdrawal

The consent that you provide for the collection, use, disclosure and retention of all or any parts your personal information will remain valid until such time it is being withdrawn by you in writing.

You may request to access and/or correct the personal information currently in our possession or withdraw your consent for the collection, use, disclosure and/or retention of your personal information in our possession or under our control at any time by contacting us at info@thering.sg. Where appropriate, such request may be referred to the relevant data protection officer. To the extent possible, we may take steps to verify your identity before granting access or making any changes to your personal information to protect your privacy.

For a request to access personal information, we will process your request within a reasonable amount of time from when the request is made.

For a request to correct or update personal information, we will process your request as soon as practicable after the request has been made. Such correction or update may involve necessary verification, which may include sending the corrected or updated personal information to other organisations to which the personal information was disclosed within a year before the date the correction or update was made (unless that other organisation does not need the corrected personal information for any legal or business purpose), or if you so consent, only to specific organisations to which the personal information was disclosed by us within a year before the date the correction or update was made.

For a request to withdraw your consent to the processing of personal information, we will process your request within a reasonable amount of time from when the request is made. Our ability to provide Services to you after such withdrawal may be affected. We will notify you of any impact before processing your request.

Your Account

Where applicable, you may be required to create an account to use our site and/or the Services. If you choose, or you are provided with, a user identification code, password or any other piece of information as part of our security procedures, you must treat such information as confidential. You must not disclose it to any third party.

If you have created an account in connection with our service, we may also send you communications relating to the administration and management of your account. You will not be able to opt out of receiving such communications unless you close such account.

Questions or Feedback

If you have any questions about this Privacy Policy or any other queries in relation to how we manage, protect and/or process your personal information, please contact us at cinfo@thering.sg.

Updates

This Privacy Policy may be updated from time to time without any prior notice. As changes to this Privacy Policy take effect when they are posted on this website, you may determine if any such revision has taken place by referring to the date on which this Privacy Policy was last updated and should visit this website periodically to note any changes. Your continued use of any Service, including without limitation this website, constitutes your acknowledgement and acceptance of such changes.

Last Updated 10 July 2023