1. Who we are
1.2 You have been directed to this Policy because a company within the SBC group is collecting, using or disclosing your personal data.
1.3 In this Policy, when we use “we“, “us” or “our“, we refer to the companies (within the SBC Group) which is/are collecting, using, disclosing or processing your personal data (it will/may be the SBC Group of companies), or which is operating the Website which you are accessing or using.
1.4 We own and/or operate website(s) such as “spartansboxing.com” and/or any mobile apps that may be published by us (the said website and mobile apps may be collectively or individually referred to as the “Website”).
2. What is the purpose of this Policy?
2.2 We are committed to safeguarding the privacy and security of your personal data. We take our responsibilities under Singapore’s Personal Data Protection Act (the “PDPA”) seriously. We also recognize the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data.
3. What personal data is collected
3.1 “Personal data” is defined under the PDPA to mean data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access.
3.3 The SBC Group collects information about you, such as when you provide your information to us, when you use our Website, when you interact with us and/or when you enter into a transaction with us. Without limiting the generality of the foregoing, we collect and hold data that you have provided to us about yourself, and information about your use of our services such as membership information and information about your use of our academies and facilities. The information that we collect will depend on how you use the services offered by the SBC Entity you are interacting with, or the circumstances or the nature of the transaction with you. Personal data which we may collect include :
Location Information of yourself and/or your computer or device
Usage and Preferences
Your purchase and/or your transactions with us
Your personal data you provide in applying for Spartans Boxing Club memberships – for example, your name, postal address, date of birth, contact details and credit card details
personal data you provide as part of your use of the SBC Group academies and facilities – for example, the frequency with which and the times at which you use an SBC Group academy including the classes that you attend
personal data you provide as part of your use of our Website and web services – for example, the email address you provide to participate in specific promotions and offers, information you provide about your use of our academy and your fitness
personal data relating to your health – for example, the existence and nature of a medical condition disclosed to us in completing our pre-exercise questionnaire.
We will collect your personal data in accordance with the PDPA.
3.4 We may collect data by automated means. Various technologies may be used on our Website and our mobile and web-based applications in order to make them more user-friendly, effective and secure. Such technologies may lead to data being collected automatically by us or by third parties on behalf of us. This data does not always, but may, contain a user’s personal data or comprise of personal data. Examples of such technologies include:
(a) Click-stream data. A visit to one of our Website results in data that is transmitted from your browser to our server being automatically collected and stored by us or by third parties on behalf of us. This data can include, in particular, the following:
the visitor’s IP address
the date and time of the visit
the referral URL (the site from which the visitor has come)
the pages visited on our website
information about the browser used (browser type and version, operating system, etc).
(c) Flash cookies. A particular form of cookie is the flash cookie. In contrast to normal cookies, these cookies are not created and saved by the web browser but are governed by the Adobe Flash plug-in. These can contain more information than normal cookies and cannot be deleted or disabled via the browser; this is only possible if you follow instructions available from the Adobe Flash Player website. You can also obtain more information about these cookies on that website.
(d) Web beacons and tracking links. Web beacons (also known as pixel tags and clear GIFs) involve graphics that are not apparent to the user. Tracking links and/or similar technologies consist of a few lines of programming code and can be embedded in our Website or our (mobile) applications. In conjunction with cookies, these are primarily used for statistical analysis purposes. This technology can also be used for tracking traffic patterns on websites, as well as finding out if an e-mail has been received and opened and to see if there has been any response.
(e) Web analytics. Web analytics is the term given to a method for collecting and assessing the behaviour of visitors to websites and (mobile) applications. This includes the analysis of traffic patterns in order, for example, to determine the frequency of visits to certain parts of a website or (mobile) application, or to find out what information and services our visitors are most interested in. For these purposes, we primarily make use of click-stream data and the other techniques listed above. Web analytics are carried out by Google Analytics and/or other selected parties. You can find out more information about the processing of web analytics data by Google Analytics in paragraph 6 below.
3.5 In many circumstances, we need to use your personal data in order for us to provide you with products or services which you require or have requested. If you do not provide us with the required personal data, or if you withdraw your consent to our use and/or disclosure of your personal data, it may not be possible for us to continue to serve you or provide you with the products and services that you require or have requested.
3.6 We may receive information about you from third parties such as if you use any websites or social media platforms operated by third parties (for example, Facebook, Instagram, Twitter etc.) and, if such functionality is available, you have chosen to link your profile on our Website with your profile on those other websites or social media platforms.
4. The purposes for which we collect, use or disclose your personal data
4.1 SBC and the SBC Group of companies, will/may collect, use, disclose and/or process your personal data for one or more of the following purposes:
(a) processing and/or dealing with your interest in our products and/or services;
(b) considering, processing, dealing with and/or managing, your booking, reservation, request/application for, of or your purchase of, our membership, products and/or services (the “Transaction”);
(c) facilitating, processing, dealing with, administering and/or managing Transaction(s) by or with you;
(d) administering, facilitating, managing, processing and/or dealing with your relationship with us, your transaction(s) with us, your being our member or loyalty card member, any transactions or activities carried out by you on the Website or at our premises/establishments or with us, your requests, including but not limited to dealing with your adhoc queries, requests or bookings, dealing with your preferences, dealing with your membership needs, dealing with your delivery needs, processing orders and payment transactions, implementing transactions and the supply of products and/or services to you that you have requested. Without limiting the generality of the foregoing, should you make a reservation or transaction that includes third party individual(s) or on behalf of third party individual(s) or for third party individual(s), you consent to us disclosing personal data that identifies you, to the said third party individual(s) (such as but not limited to your name). Further, if any of our classes, services, products and/or programmes that you sign up for or indicate an interest in, is run by a third party service provider, you consent to us disclosing personal data that identifies you, to the said third party individual(s) (such as but not limited to your name);
(e) administering, facilitating, processing and/or dealing in any matters relating to your use or access of the Website, including identifying you for login to the Website, our portals and other online services provided by or on behalf of us. Without limiting the generality of the foregoing, if you:
(i) gain access to or sign in to the Website, using your login credentials of a Social Networking Site, or
(ii) use any features of a Social Networking Site such as its widgets, plug-ins and browser push notifications, made available to you on our Website,
it may result in information or your personal data being collected or shared between us and the third party. For example, if you use Facebook’s “Like” feature, Facebook may register the fact that you “liked” a product and may post that information on Facebook. (“Social Networking Site” refers to an online or digital platform owned or operated by a third party, that is used by people to build social networks or social relations, or to interact, with other people, such as but not limited to Facebook, Instagram, Twitter). By your proceeding pursuant to (i) or (ii) above, you consent to such collection, use or disclosure of your personal data;
(f) monitoring, processing and/or tracking your use of the Website in order to provide you with a seamless experience, facilitating or administering your use of the Website, and/or to assist us in improving your experience in using the Website;
(g) administering, facilitating, processing and/or dealing in any transactions, payments, or activities carried out by you on the Website or at our premises or with us;
(h) providing services to you as our customer, as a member of our loyalty programme(s)/card programme(s)/rewards programme(s)/member programme(s) or when requested by you; dealing with or administering your participation in contests, gamification, social events organized by us;
(i) registering you as a customer of any of our products or services, and/or to deal with, process and/or administer the account that you may open with us, whether a membership account or otherwise, including to facilitate your transactions or activities at our premises, the Website, or your transactions or activities with us;
(j) carrying out your instructions or responding to any enquiry or complaint given by (or purported to be given by) you or on your behalf including responding to your enquiries and complaints; or responding to or dealing with your interactions with us or your requests; or responding to or dealing with your feedback, comments or reviews. If you have contacted us with any complaints, feedback, comments, suggestions, we will use and disclose your personal data (including your contact history) to respond to you and provide you with the best service possible. If you are the complainant and you do not want us to disclose your identity to the party you are complaining about, you must let us know immediately. However, it may not always be possible to handle your complaint on the basis of anonymity;
(k) contacting you or communicating with you via phone/voice call, text message and/or fax message, email and/or postal mail for one or more of the Purposes stated herein. You acknowledge and agree that such communication by us could be by way of the mailing of correspondence, documents or notices to you, which could involve disclosure of certain personal data about you to bring about delivery of the same as well as on the external cover of envelopes/mail packages;
(l) sharing or disclosing (at our discretion) your suggestions, comments, feedback or content (including audio, video etc.) (collectively “Feedback”) that you provide, to Social Networking Sites, to the Website or to us (including at our premises), with other users of the Website or with the public, for publicity and/or promotion purposes with a view to marketing or showcasing the business, products or services of SBC (and/or of any member of the SBC Group), and/or to acquiring customers, and/or for the purpose of providing the public with your Feedback which may be useful for the public’s patronage decision or for the public’s information or otherwise. This includes us disclosing your name together with your Feedback. Without limiting the generality of the foregoing, in the above regard, your Feedback and name may/will be published or shared by us on public media platforms such as the newspaper, the Internet, in our (including our affiliates’) annual reports (if any) etc., and/or incorporated as part of SBC’s (and/or of the SBC Group companies’) marketing collaterals/materials or corporate video to be disclosed to the public, and you hereby consent to the same. Do not provide us with Feedback if you do not wish for such Feedback to be disclosed to the public. If you wish to give us your Feedback without it being disclosed to the public, please separately email our Customer Department at firstname.lastname@example.org and head the subject of your email with the word “Confidential”;
(m) understanding and/or managing your interests, concerns and preferences;
(n) carrying out due diligence, statutorily required activities or other screening activities (including background checks, anti-money laundering checks, know your client checks) in accordance with legal or regulatory obligations applicable to us or any SBC Group company (whether Singapore or other countries), the requirements or guidelines of governmental authorities which we determine are applicable to us (whether Singapore or other countries) or any SBC Group company, and/or our risk management procedures that may be required by law (whether Singapore or other countries) or that may have been put in place by us or our affiliates/associated companies;
(o) to prevent or investigate any fraud, unlawful activity or omission or misconduct, whether or not there is any suspicion of the aforementioned; dealing with conflict of interests; or dealing with and/or investigating complaints;
(p) complying with or as required by any applicable law, governmental or regulatory requirements of any jurisdiction applicable to us or our affiliates/associated companies, including meeting the requirements to make disclosure under the requirements of any law binding on us or our affiliates/associated companies, and/or for the purposes of any guidelines issued by regulatory or other authorities (whether of Singapore or other countries), with which we or our affiliates/associated companies are expected to comply;
(q) complying with or as required by any request or direction of any governmental authority (whether Singapore or other countries) which we or any SBC Group company are expected to comply with; or responding to requests for information from public agencies, ministries, statutory boards or other similar authorities. For the avoidance of doubt, this means that we may/will disclose your personal data to the aforementioned parties upon their request or direction;
(r) conducting research, (including customer research), surveys, market surveys, analysis and development activities (including but not limited to data analytics, and/or profiling), obtaining your feedback to our products, services or facilities, to :
(i) improve or develop our products, services and/or facilities in order to enhance any continued interaction between yourself and us connected or in relation to your relationship with us, the Website, or your Transaction(s);
(ii) improve any of our products or services or facilities, whether now or in the future; or
(iii) improve our understanding of your interests, concerns and preferences.
Without limiting the generality of the foregoing, we may/will in this regard send you surveys or request a face to face interview survey or request your feedback, by way of email or postal mail.
(s) the conduct of training or training purpose, so as to develop or improve our products or services and/or our staff’s and agents’ services and/or service quality. Without limiting the generality of the foregoing, such training may involve collection, use, disclosure or processing of your personal data including your feedback or comments or reviews;
(t) to facilitate and/or ensure the safety and security of our premises, our customers, our staff and/or visitors to our premises; to deal with, handle and/or conduct disciplinary, security, crime prevention and/or quality assurance processes, matters and/or arrangements. Without prejudice to the generality of the aforesaid, we wish to bring to your attention that there are surveillance cameras / CCTVs installed throughout our premises and/or our offices, for security, crime prevention, safety and training reasons and you acknowledge that your personal data (including your video image and/or audio) will be collected by such cameras and processed by us consequently;
(u) to identify you as a member and without prejudice to the generality of the latter, we may issue you a photo id which has your photograph on such id and you consent to us placing your photograph on such id;
(v) for marketing purpose and in this regard, SBC (and/or any member of the SBC Group) would be providing you with marketing, advertising and promotional information, materials and/or documents relating to products, contests, services and/or events (including products, services and/or events of third party organisations with which SBC (and/or any member of the SBC Group) may collaborate with) that we (including any member of the SBC Group) or such third party organisations may be selling, marketing, offering, organizing, involved in or promoting, whether such products, services and/or events exist now or are created in the future, :
(ii) if you have separately expressly consented to one or more of the following 3 DNC Modes, by way of the 3 modes of communications of voice calls, text messages or faxes (the “3 DNC Modes”) to your Singapore telephone number, in compliance with the requirements of the PDPA; and/or
(iii) Notwithstanding (ii) above, regardless that you have not separately provided express consent as aforementioned in (ii) above, SBCor an SBC Entity, as the case may be, reserves its right to send a specified fax message (as defined in Singapore’s Personal Data Protection (Exemption from Section 43) Order 2013) (the “Exemption Order”) and/or a specified text message (as defined in the Exemption Order) (i.e. a marketing fax message or marketing text message) to your Singapore telephone number, if:
(1) there is an ongoing relationship between SBC (or the SBC Entity, as the case may be), and you, and the purpose of the message is related to the subject of the ongoing relationship, pursuant to the requirements and conditions of the Exemption Order; or
(2) the law permits.
For the avoidance of doubt, this subparagraph is without prejudice to subparagraph (r) above for which you have hereby consented to us contacting you for a survey, which you may subsequently opt out of by sending our Data Protection Officer notice;
(w) storing, hosting, backing up (whether for disaster recovery or otherwise) of your personal data, whether within or outside Singapore;
(x) maintaining and/or developing our IT or business systems and infrastructure including testing and upgrading of these systems;
(y) creating reports with respect to your Transaction(s) and/or transactions that we have with our customers;
(z) facilitating, dealing with and/or administering external audit(s) or internal audit(s) of the business of SBC and/or of the SBC Group, Transaction(s), and/or our transactions with our customers;
(aa) anonymization of your personal data. In this regard, you acknowledge that personal data that has been anonymized is no longer personal data and the requirements of the PDPA would no longer apply to such anonymized data;
(bb) dealing with and/or facilitating a business asset transaction or a potential business asset transaction, where such transaction involves SBC as a participant or involves only a related corporation or affiliated company of SBC as a participant or involves SBC and/or any one or more of SBC’s related corporations or affiliated companies as participant(s), and there may be other third party organisations who are participants in such transaction. “business asset transaction” means the purchase, sale, lease, merger or amalgamation or any other acquisition, disposal or financing of an organisation or a portion of an organisation or of any of the business or assets of an organisation;
(cc) record-keeping purposes and producing statistics and research for internal and/or statutory reporting and/or record-keeping requirements, of SBC or of its affiliates/related corporations;
(dd) SBC’s or SBC Group’s reporting purposes including but not limited to reporting on SBC’s business performance; and
(ee) to deal with the or as part of a bankruptcy, winding up, reorganization, restructuring, insolvency, receivership or an assignment for the benefit of creditors, of SBC;
(ff) to manage and/or deal with any monies or outstanding fees owed by you to us;
(the purposes set out in this paragraph 4.1 above shall be collectively referred to as the “Purposes”)
4.2 You may withdraw your consent for us to process your personal data for marketing purpose mentioned at paragraph 4.1(v) above at any time via one of the following relevant methods:
clicking the Unsubscribe button located at the bottom of our emailers.
contacting us or our Data Protection Officer through email (please refer to the contact details below).
speaking to a Membership Executive at any SBC locations who will provide you with further simple instructions on how to effect such withdrawal.
4.3 We may/will need to disclose your personal data to third parties, whether located within or outside Singapore, for one or more of the above Purposes, as such third parties, would be processing your personal data for one or more of the above Purposes. In this regard, you hereby acknowledge, agree and consent that we may/are permitted to disclose your personal data to such third parties (whether located within or outside Singapore) for one or more of the above Purposes and for the said third parties to subsequently collect, use, disclose and/or process your personal data for one or more of the above Purposes. Without limiting the generality of the foregoing or of paragraph 4.1, such third parties include :
(a) our associated or affiliated organisations or related corporations, or any member of the SBC Group;
(b) any of our agents, contractors or third party service providers that process or will be processing your personal data on our behalf including but not limited to trainers, fitness instructors, those which provide administrative or other services to us such as mailing houses, telecommunication companies, information technology companies, data centres, hosting and maintenance service providers, analysis services service providers, e-mail messaging services service providers, delivery service provider, handling of payment transactions service providers, marketing service providers, delivery services, debt collection services, handling of payment transactions, solvency check and address check;
(c) our professional advisers, for example, our auditors and lawyers, as well as our insurers;
(d) third parties to whom disclosure by us is for one or more of the Purposes and such third parties would in turn be collecting and processing your personal data for one or more of the Purposes. Without limiting the generality of the foregoing, such third parties to which we may/will disclose your personal data include payment, finance companies or banks including credit card companies; and
(e) any actual or proposed assignee or transferee of the business of SBC, or a merged entity in the event SBC is merged to create the said merged entity.
4.4 We may share your information with any member of the SBC Group, which may be based in countries other than Singapore, from time to time for one or more of the Purposes.
4.5 Should you provide us with personal data of your child or children, you confirm, declare and agree that you are the parent and/or legal guardian of such child/children, and that we may collect, use and/or disclose your child’s or children’s personal data for the Purposes set out at paragraph 4.1 above and in the manner as set out at paragraphs 4.1 to 4.4 above.
4.6 You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control by emailing us at email@example.com. We will process your request within a reasonable time from such a request for withdrawal of consent being made, and will thereafter not collect, use and/or disclose your personal data in the manner stated in your request, unless an exception under the law or a provision in the law permits us to. However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal, including us being unable to perform the transactions requested by you or the termination of your relationship with us (depending on the extent of your withdrawal), as the case may be.
4.7 We may collect, use, disclose or process your personal data for other purposes that do not appear above. However, we will obtain your consent before doing so and notify you of such other purpose at the time of obtaining your consent, unless processing of your personal data without your consent is permitted by the PDPA or by law.
4.8 To the extent permitted by law, we may/will also be collecting from sources other than yourself, personal data about you, for one or more of the above Purposes, and thereafter using, disclosing and/or processing such personal data for one or more of the above Purposes. We may combine information we receive from other sources with information you give to us and information we collect about you. We may use this information and the combined information for the Purposes set out above (depending on the types of information we receive).
4.9 We take reasonable steps to ensure that any personal data we collect, disclose and use is accurate and complete, if your personal data is likely to be used by us to make a decision that affects you, or disclosed to another organisation. However, it is important that you advise us of any changes to your personal data or if there are any errors in the personal data we hold about you. We will not be responsible for relying on inaccurate or incomplete personal data arising from your not updating us of any changes in your personal data that you had initially provided us with.
5. Provision of third party personal data by you
5.1 Should you provide us with personal data of any individual other than yourself, you represent, undertake and warrant to us that :
(a) for any personal data of individuals that you disclose to us, you would have prior to disclosing such personal data to us obtained consent from the individuals whose personal data are being disclosed, to :
(i) permit you to disclose the individuals’ personal data to SBC and the SBC Group for the Purposes; and
(ii) permit SBC and the SBC Group to collect, use, disclose and/or process the individuals’ personal data for the Purposes;
(b) at our request, you will use such form(s) or document(s) provided by us in obtaining such consents from the individuals in question (for the avoidance of doubt, we are under no obligation to you to create any such form(s) or document(s));
(c) any personal data of individuals that you disclose to us are accurate; and
(d) for any personal data of individuals that you disclose to us, that you are validly acting on behalf of such individuals and that you have the authority of such individuals to provide their personal data to SBC and the SBC Group and for SBC and the SBC Group to collect, use, disclose and process such personal data for the Purposes.
6. Web analytics by Google Analytics
6.1 Our Website and mobile or web-based applications may contain web analytic services provided by Google Analytics. This means that when you visit our Website or use any mobile or web-based applications, a cookie will be stored on your computer or mobile device, except when your browser settings do not allow for such cookies.
6.2 This further means that when you visit our Website or use any mobile or web-based applications, your personal data including the “click-stream data”, the data from “web beacons and tracking links” and information stored in Google Analytics’ cookies – will be sent to Google Analytics for analysis for and on behalf of us. Please note that if you have created an online profile at our Website or mobile or web-based application and if you are logged on in this profile, a unique number identifying this profile will also be sent to Google Analytics in order to be able to match the web analytics data to this profile.
7. Security and how do we store personal data?
7.1 Security of your personal data is important to us. We will put in place reasonable security arrangements to ensure that your personal data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorized access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data. However, we cannot assume responsibility for any unauthorized use of your personal data by third parties which are wholly attributable to factors beyond our control.
7.2 We will put in place measures such that your personal data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes.
8.1 You have the right to access and/or correct personal data that we hold about you, subject to exceptions under the law. This right can be exercised at any time by emailing us at [insert email address]. We will need enough information from you in order to ascertain your identity as well as the nature of your request, so as to be able to deal with your request. With respect to your access request, we may charge a fee in order to process it.
8.2 For a request to access personal data, once we have sufficient information from you to deal with the request, we will seek to provide you with the relevant personal data within 30 days. Where we are unable to respond to you within the said 30 days, we will notify you of the soonest possible time within which we can provide you with the information requested. Note that the PDPA exempts certain types of personal data from being subject to your access request.
8.3 For a request to correct personal data, once we have sufficient information from you to deal with the request, we will correct your personal data within 30 days. Where we are unable to do so within the said 30 days, we will notify you of the soonest practicable time within which we can make the correction. Note that the PDPA exempts certain types of personal data from being subject to your correction request as well as provides for situation(s) when correction/s need not be made by us despite your request.
8.4 We hold and deal with your personal data in accordance with the PDPA.
9. Complaint Process
9.1 If you have any complaint or grievance regarding how we are handling your personal data or about how we are complying with the PDPA, we welcome you to contact us with your complaint or grievance.
9.2 Please contact us with your complaint or grievance by emailing us at firstname.lastname@example.org
9.3 Where you are sending an email in which you are submitting a complaint, your indication at the subject header that it is a PDPA complaint would assist us in attending to your complaint speedily by passing it on to the relevant staff in our organisation to handle. For example, you could insert the subject header as “PDPA Complaint”.
9.4 We will certainly strive to deal with any complaint or grievance that you may have speedily and fairly.
10.2 For the avoidance of doubt, in the event that Singapore personal data protection law permits an organisation such as us to collect, use or disclose your personal data without your consent, such permission granted by the law shall continue to apply.