This is the Data Protection Policy of the Copyright Licensing & Administration Society of Singapore (“we” or “our” or “us”).
We are committed to respecting and protecting the personal information that we collect. The following is our Data Protection Policy. When we gather and use information from you, we will comply with this Data Protection Policy as well as the requirements of the Singapore Personal Data Protection Act 2012 (“PDPA”). We hope the following Data Protection Policy will help you understand how we collect, use and/or disclose and safeguard the information that is collected on our website (accessible at https://class-singapore.com/) (“Website”), electronic mail (at email@example.com or any of our other affiliated emails), (“Email”) or at our physical premises (at 1 Wallich Street #14-01 (Guoco Tower), Singapore 078881) (“Premises”) or is otherwise in our possession or under our control. It also sets out your rights in relation to your information, and who you can contact for more information or queries.
CLASS is a not-for-profit organisation committed to protecting and enabling easy access to copyright material belonging to its members through licensing of academic works, newspaper articles, journals, novels, photos and illustrations, and especially for digital uses. CLASS seeks to provide rights and licenses in order to simplify the management of copyright material. CLASS may collect and use personal data from time to time in order to fulfil its purpose.
This Data Protection Policy does not apply to any unsolicited information that you provide to us. This includes, but is not limited to, any information posted to the public forums (such as social networking services, industry directories, industry guides, and the Internet), as well as any other unsolicited submissions. Such information shall be deemed to be non-confidential. You agree that we will be free to reproduce, use and exploit such information without limitation and/or any attribution to you.
We may amend and update this Data Protection Policy in our sole discretion from time to time. If we make any significant changes, we will inform you via email, so that you are able to review the changes before you continue to use our services.
If we intend to use, disclose and/or process personal data in any manner that is inconsistent with the terms of this Data Protection Policy, we will publish a notification on our Website to notify you of the same. You will be deemed to have consented to such variation should we not receive any objection from you within seven (7) days from the date of the said notice.
By accepting this Data Protection Policy, or continuing to access and use our Website, corresponding with us, or using any of our services, you are deemed to have agreed and consented to allow us, our subsidiaries and/or our affiliates to:
- collect, use, disclose and/or process information about you that you have provided or may in the future provide to us, our partners and/or our affiliates for the purposes set out in this Data Protection Policy; and
- disclose information about you in accordance with this Data Protection
If you do not agree with this Data Protection Policy, please do not access or use our Website, correspond with us and/or use any of our services.
I. General Principles
As a matter of principle, we try to minimise the amount of personal data we collect from you. We do not ask for more than that which is required to service your account and provide the services you require.
For the purposes of this Data Protection Policy, “personal data” shall have the meaning ascribed to it under the PDPA. This refers to any data, whether true or not, about an individual who can be identified:
- from that data; or
- from that data and other information to which we have or are likely to have access, including data in our records as may be updated from time to time.
II. Collection of Data
The Types of Data We Collect from You
We may collect, use and disclose the following personal data about you:
- Identity data. This may include your names, pseudonyms, NRIC/passport number, contact number, signature, residency status
- Profile data. This may include your username, password, interests, preferences, feedback, and survey responses
- Contact This may include your billing address, delivery address, email address and telephone/mobile number.
- Financial data. This may include details of your bank account details, payment card details and related payment verification information.
- List of Works and the Copyright owners of these works.
- Details of memberships, associations, and of licence schemes in which members operate.
- Transaction This may include details about payments to and from you.
- Support data. This may include information you provide through our support channels when you report a problem to us or communicate with us, including any contact information and
- Technical data. We may use “cookies”, web beacons, and other technologies to collect this information, which may include, for example, your internet protocol address, your login data, browser type and version, time zone, location, operating system and any other technology on the devices that you use to access our Website.
- Usage This may include information on how you use our Website and services.
- Online user This may include information such as links to your public social media pages and other online materials that may be related to you.
- Marketing and communication data. This may include the preferences you indicate in receiving marketing materials from us and our subsidiaries or affiliates and your communication
We may also collect, use and disclose aggregated data from time to time. Such data may be derived from your personal data, but will not be considered personal data at law as it will not be linked to you personally and cannot be used to identify you. For example, we may aggregate information we collect when you use our Website to measure usage rates of our Website, amongst others. These measurements, in turn, help us to improve our Website, and/or services for us to serve you and other users better. Such information may be stored in databases owned and maintained by our affiliates, agents or service providers. We may also disclose aggregated user data in order to describe our Website and/or services to current and prospective business partners, and to other third parties for other lawful purposes. We may also conduct research on our customer demographics and customer behaviour based on such information.
You agree that the personal data you provide to us, our subsidiaries and/or our affiliates is current, accurate, complete and unequivocal.
How We Collect Your Data
We collect the aforementioned data directly from you when you access and use our Website, or when you contact us in connection with our services (for example: when you provide us with a duly completed copy of the Membership Application Form). We may also collect the aforementioned data from third party sources, for example, among others, your name, mobile number and email addresses, our affiliates, and identity verification and compliance service providers.
When you provide data on behalf of another individual, you undertake and will ensure that the individual whose data is supplied to us has authorised the disclosure of his data to us, and is informed of and agrees to the terms of this Data Protection Policy. You agree to indemnify us from any claim that such authority does not exist. If the individual whose data is supplied to us have withdrawn such consent, you shall notify us immediately to enable us to stop processing said data.
If you prefer not to provide your personal data to us, you may opt not to do so. In addition, you have the right to withdraw your consent at any time by contacting our Data Protection Officer (at the address stated in Section XIII below). However, please note that by denying the provision of your personal data, you may not be able to utilise some of the services on our Website that require submission of your personal data and/or be able to benefit from the services that we provide which may require such personal information.
III. Use of Data
We use your data for the following purposes:
- opening and maintaining your account with us;
- verifying that you are a unique user of our Website;
- providing, maintaining, and updating our member or customer database;
- collecting and distributing payments for the use of copyright works;
- collecting and distributing payments for resale royalties to our members;
- confirming payment share entitlements to our members;
- assisting members to resolve disputes over entitlements to resale royalties;
- managing payments and fees, including the collection and recovery of money owed to us;
- providing you with a statement of accounts for royalty payments;
- providing you with our Website and services, including processing any transactions and payments;
- notifying you about changes to our services;
- communicating with you about our services, including to ask you to take any relevant surveys;
- providing customer support, including communicating with you with regard to any feedbacks or queries;
- improving the Website and ensuring that the content on the Website is presented in the most effective manner for you and your device;
- administering the Website, including internal operations such as trouble shooting, data analysis, testing, research, statistical and survey purposes;
- keeping the Website safe and secure;
- facilities management (including but not limited to maintaining the security of our premises);
- managing the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances);
- responding to your queries, requests or feedback;
- providing you with information on our services via email, telephone or in-person at our premises;
- enforcing our terms, conditions and policies;
- aggregating data into anonymised statistical data, which we will use for statistical analysis so that we can improve our service offering to serve you better;
- conducting research and development for analytics purposes;
- with your consent, sending you marketing and promotional materials in relation to services that we, our subsidiaries, affiliates, business partners and/or third-party providers offer;
- internal administration and management;
- conducting investigations regarding any complaints and/or potential breaches of any of our policies;
- supporting legal actions which assist creators in rights management;
- administering and organising competitions and marketing campaigns;
- personalising your customer experience with us;
- any other purposes that we may notify you from time to time; and
- any other purposes reasonably related to the
IV. Disclosure of Data
We may disclose your personal data in the following circumstances:
- when we obtain your permission;
- when we find it necessary to disclose your personal data to our subsidiaries and/or affiliates in order to respond to your queries, requests or feedback;
- when we find it necessary to disclose information to business partners and/or third-party service providers in order to provide you with our services; and
- when we find it necessary to disclose information to our legal advisors or other professional advisors, or as otherwise authorised or required by law.
The business partner(s) and/or third-party service provider(s) referred to in paragraph (3) above may be located within or outside of Singapore. In this regard, by accepting this Data Protection Policy or continuing to access or use our Website, you are deemed to have agreed and consented that such business partner(s) and/or third-party service provider(s) may, to the extent necessary to provide our services to you, collect, use, disclose and/or process information about you.
We also reserve the right to share your personal data as is necessary to prevent a threat to the life, health or security of an individual or corporate entity. Further, we reserve the right to disclose personal data, as is necessary, to law enforcement, governmental agencies, or authorised third parties, in response to a verified request relating to a criminal investigation or alleged illegal activity or any other activity that may expose us to legal liability.
V. Safeguards of Data
As part of our commitment to keeping your personal data (which is in our possession or control) secured, we have taken reasonable steps to protect the information you share with us in order to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. Such measures include, but are not limited to, setup of processes, equipment and software to avoid unauthorised access or disclosure of this information. We limit access to personal data only to our employees and the employees of our subsidiaries, affiliates, business providers and/or third-party service providers who are reasonably required to come in contact with that information in order to provide services to you or in order to do their jobs.
While we are committing to taking reasonable steps to protect the security of the information communicated through our Website and/or any other means, the Internet is not a secure method of transmitting information, and accordingly we do not assume any responsibility for the information you submit to or receive from us through the Internet or for any unauthorised access or use of that information. We also cannot and do not guarantee that information communicated by you to us or by us to you will be received or that it will not be altered before or after its transmission to us or to you, as the case may be. We cannot warrant the security of any information that you transmit to us via our Website and/or any other means, or guarantee that such information will not be accessed, disclosed, altered or destroyed by a breach of our physical, managerial, or technical safeguards. In any event, you agree to not hold us, our subsidiaries or affiliates, our past, present and future employees, officers, directors, contractors, consultants, suppliers, vendors, service providers, agents, representatives, predecessors, successors and assigns liable for any loss or damage of any sort incurred as a result of any misappropriation, interception, modification, deletion, destruction or use of the information provided through our Website and/or any other means.
The security of your personal data also relies on your protection of your personal data. In this regard, we kindly ask that you protect the password given or created by you for your use of our Website without sharing the same with anyone.
VI. Retention and Transfer of Data
We shall not retain your personal data in our possession and/or database if your personal data is no longer required to meet the purposes for which they were collected and/or no longer serves a legal and/or business purpose. Specifically, we may retain your personal data for a period of up to six (6) months after you close your account with us, in order to facilitate the restoration of your account in the event that you choose to re-open your account with us within this period. Thereafter, we will destroy or delete your personal data, or remove the means by which such data can be associated with you. We will review the personal data in our possession and/or database from time to time, and remove or anonymise such data when it is no longer required.
Some of the recipients of your personal data (for example, our business partners and/or third-party service providers) may be based in countries outside of Singapore. We are committed to adequately
protecting your personal data regardless of where the data resides and to providing appropriate protection for your data where such data is transferred outside of Singapore. We will use our best efforts to ensure that the business partners and/or third-party service providers engaged by us to provide the services to you will not transfer information about you to a place outside Singapore without our prior written consent. In the event that we provide such consent, we will use our best efforts to procure that the relevant business provider and/or third-party service provider provides a written undertaking to us that the information about you which is transferred outside of Singapore will be protected at a standard that is at least comparable to that under the PDPA.
If the relevant business partner and/or third-party service provider transfers information about you to any person overseas, we will use our best efforts to procure that such business partner and/or third- party service provider procures the same written undertaking from such person.
VII. Access and Correction of Data
You have the right to access personal data we hold about you and certain information about how we use it and who we share it with.
Where permitted by law, we reserve the right to charge a reasonable administrative fee for this service. Should an administrative fee be charged, we will provide you with a written estimate of the administrative fee that we will be charging.
In exceptional circumstances and where permitted by the applicable laws, we reserve the right to deny you access to your personal data and may provide an explanation as required by applicable laws.
You have the right to correct any personal data held about you that is inaccurate.
If you would like to inquire, make any corrections or request deletion of your personal data, please contact our Data Protection Officer (at the address stated in Section XIII below).
We will strive to respond to each request for access or correction as soon as reasonably possible or as soon as practicable. We strive to respond to each request within thirty (30) days. If more than thirty (30) days are required for our response, we will inform you in writing before the lapse of thirty (30) days from the date of your request, of the time by which we will respond to your request.
Additionally, we may need to request specific information from you in order for us to verify your identity and ensure that you have the right to access your personal data, or to exercise any other right. This is to ensure that personal data is not disclosed to any person who does not have a right to receive it. We may contact you to obtain such information in order to process your requests.
VIII. Accuracy of Data
We require your assistance to ensure that your personal data is accurate and complete. As such, please inform us of any changes to your personal data by contacting our Data Protection Officer (at the address stated in Section XIII below).
IX. Withdrawal of Consent
If you prefer not to provide your personal data to us, you may opt not to do so. In addition, you have the right to withdraw your consent for us to collect, use or disclose your personal data at any time by contacting our Data Protection Officer (at the address stated in Section XIII below). However, please note that by denying the provision and/or withdrawal of your personal data, you may not be able to fully use and/or benefit from our Website, and/or services which may require such personal data.
X. Social Sharing Features and links to other websites
Our Website may offer social sharing features, links to social media and other integrated tools. Depending on the settings you use with the entity that provides the social sharing feature or social media, your use of such social sharing feature or social media may enable the sharing of your information with your contacts or with the public. You are advised to visit the data policies of the entities that provide these social sharing feature or social media to obtain information about the way they collect, use and/or disclose your personal data.
In addition, we may, from time to time, provide you with links to other websites for your convenience and information, or other third-party websites may share links to our Website. If you follow a link to any of these websites and/or otherwise access third-party websites, please note that these websites have their own data policies and that we do not accept any responsibility or liability for these policies. You access these websites at your own risk and we are not responsible for these websites. Whilst we endeavour to protect your personal data on our Website, we cannot control or be responsible for the policies of other sites we may link to, or the use of any personal data you may share with them. Please note that this Data Protection Policy does not cover these other websites, and we would recommend that you are apprised of their specific policies.
XI. Monitoring and Checking
We may monitor and record any communications with you for quality management, fraud prevention and compliance purposes.
We may search the files of credit reference from fraud prevention agencies for the prevention of fraud and money laundering. Should you provide us with false or inaccurate information raising a suspicion of fraud, we may disclose information of your use of our Website to the relevant fraud prevention agencies. If required, we may also report the same to the relevant law enforcement authorities.
Should you wish to disable cookies, you may at any time adjust the settings on your browser to do so. However, if you choose to disable cookies, many of the features on our Website may not operate properly.
XIII. Contact Us
If you have any comments, questions, complaints about or requests relating to this Data Protection Policy, please contact our Data Protection Officer at the address stated below, referencing “Data Protection Policy”:
Copyright Licensing & Administration Society of Singapore
1 Wallich Street #14-01 (Guoco Tower)
Telephone: +(65) 6403 3970
Email address: firstname.lastname@example.org
Attention: Ms Monica Gupta, Data Protection Officer
— Updated as at September 2022