INTRODUCTION

1.1 ATHLEE Pte Ltd (collectively referred to as “ATHLEE”, “we”, “us”, “our”) is committed to protecting the personal data of individuals entrusted to us, including those information provided through our website1.

1.2 ATHLEE manages personal data in accordance with the Personal Data Protection Act 2012 (No. 26 of 2012) (the “PDPA”).

1.3 This PDPA Policy sets out the principles, practices and manner in which ATHLEE collects, uses, discloses, secures and disposes of personal data. Please read this PDPA POLICY so that you understand the purposes for which we collect, use and disclose your personal data.

APPLICATION AND DEFINITIONS

2.1 This PDPA Policy is effective from 1 June 2018.

2.2 Definitions

2.2.1 “Data Protection Officer” means the person referred to in Paragraph 7.1 of this PDPA Policy.

2.2.2 “Individual” means a natural person, whether living or deceased.

2.2.3 “Notice of Withdrawal” means the notice referred to in paragraph 3.4 of this PDPA Policy.

2.2.4 “Personal Data” means data, whether true or not, about an individual who can be identified (i) from that data, or (ii) from that data and other information to which the organisation has or is likely to have access. This includes:

(a) Any data that relates to the individual (e.g. educational and employment background);

(b) Data about an individual who can be identified from that data on its own (e.g. full name, NRIC number, mobile phone number, fingerprint); and

(c) Data in (b) above and other information to which ATHLEE has or is likely to have access (e.g. gender, nationality).

2.2.5 “Processing”, in relation to personal data, means the carrying out of any operation or set of operations in relation to the personal data, and includes any of the following:

(a) recording;

(b) holding;

(c) organisation, adaptation or alteration;

(d) retrieval;

(e) combination;

(f) transmission;

(g) erasure or destruction.

2.2.6 “Purpose” means the situations and purposes set out in Paragraph 4 of this PDPA Policy.

COLLECTION OF YOUR PERSONAL DATA

3.1 ATHLEE will generally collect your Personal Data in the following ways:

3.1.1 Through this website

3.1.2 Over the phone

3.1.3 By Email

3.2 You are deemed to consent to the collection, use or disclosure of his Personal Data by ATHLEE for a particular Purpose if you voluntarily provide your Personal Data to ATHLEE for that Purpose.

3.3 By providing ATHLEE with the Personal Data of a third party, you are representing to us that you have obtained the consent of that third party to you providing us with the third party’s Personal Data for the Purpose.

3.4 You may at any time withdraw any consent given, or consent deemed to have been given under the PDPA, in respect of the collection, use or disclosure by ATHLEE of your Personal Data for any purpose by giving reasonable notice in writing to ATHLEE (the “Notice of Withdrawal”). Please contact our Personal Data Protection Officer to obtain a copy of this Notice of Withdrawal.

PURPOSE

4.1 ATHLEE shall use your Personal Data only for purposes that a reasonable person would consider appropriate in the circumstances (the “Purposes”).

4.2 The Purposes include, but are not limited to, the following:

4.2.1 Employment matters and human resource administration;

4.2.2 Event organisation and management;

4.2.3 Advertising and marketing;

4.2.4 Sales;

4.2.5 Research and development; and

4.2.6 Any other purpose which ATHLEE has informed the individual.

ACCESS, ACCURACY AND CORRECTION OF PERSONAL DATA

5.1 Access to the Individual’s Personal Data

5.1.1 If you wish to obtain access to your Personal Data records held by ATHLEE, please contact our Personal Data Protection Officer to make a request.

5.1.2 Please note that ATHLEE may need to verify your identity before processing your request for access to your Personal Data.

5.2 Accuracy of the Individual’s Personal Data

5.2.1 ATHLEE shall make reasonable efforts to accurately record your Personal Data as provided to ATHLEE by you or your representatives.

5.2.2 You should make all reasonable efforts to ensure that your Personal Data given to ATHLEE is accurate, true and complete.

5.2.3 Please inform ATHLEE in writing of any changes to your Personal Data. You may contact ATHLEE’s Personal Data Protection Officer to notify ATHLEE about any changes to your Personal Data.

5.3 Correction of the Individual’s Personal Data

5.3.1 You are entitled to request that ATHLEE correct an error or omission in your Personal Data that is under ATHLEE’s possession or control. Such requests are to be made in writing to ATHLEE’s Personal Data Protection Officer.

5.3.2 Please note that ATHLEE may need to verify your identity before processing your request for the correction to your Personal Data.

RETENTION AND PROTECTION OF PERSONAL DATA

6.1 ATHLEE shall retain your Personal Data for as long as it is reasonably necessary to fulfil the Purposes for which your Personal Data was collected, or as required by law.

6.2 ATHLEE shall not retain documents containing your Personal Data, or remove the means by which your Personal Data can be associated with you, as soon as it is reasonable to assume that:

6.2.1 the Purposes for which the Personal Data was collected is no longer served by retaining the Personal Data; and

6.2.2 the retention of your Personal Data is no longer necessary for legal or business purposes.

6.3 ATHLEE shall not retain any document containing your Personal Data where you have withdrawn consent for the collection, use or disclosure of your Personal Data.

THE DATA PROTECTION OFFICER AND THE GOVERNING LAW

7.1 ATHLEE’s Data Protection Officer’s details are as follows:

NAME: Yoshinori Washizu
EMAIL: dpo@athlee.sg

7.2 ATHLEE reserves the right to amend this PDPA Policy to reflect changes in legislation or other operational requirements.

7.3 This PDPA Policy is governed by the laws of the Republic of Singapore.

1 Website has a “contact us” page where personal info such as name, email and phone number are collected.B