1.1. www.21zoom.com is a website owned and managed by eLifeStyle 4 U (Pte.) Ltd, (herewith referred to as eLifeStyle 4 U). When you purchase products and services from the websites or use any mobile or web-based applications owned by eLifeStyle 4 U, and/or submit your information to us through our websites, you will be classified as a registered user.
1.2. As a registered user of websites or any mobile or web-based applications owned by eLifeStyle 4 U such as www.21zoom.com, you are required to read the contents of this document. This document spells out the way that eLifeStyle 4 U manages, collects, uses and discloses your Personal Data, which is subject to the Singapore Personal Data Protection Act (No. 26 of 2012) (“the Act”).
1.3. As a registered user, you agree and consent to eLifeStyle 4 U and its independent sales representatives / affiliates / agents, collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to its authorized service providers and relevant third parties in the manner set forth in this Personal Data Protection Policy.
1.4. eLifeStyle 4 U may update this Personal Data Protection Policy in our website 21zoom.com, to be in line with market norms and to comply with changes in legal or regulatory requirements. You agree that you are bound to the current terms of the Personal Data Protection Policy, and to any amendments, additions, changes and updates from time to time on our website www.21zoom.com
2. Personal Data
2.1. In this Personal Data Protection Policy, “Personal Data” refers to any 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 we have or are likely to have access, including data in our records as may be updated from time to time.
2.2. Some examples of Personal Data that you may provide to us include your name, NRIC, passport or other identification number, telephone numbers, mailing address, email address, network data and any other information relating to any individuals, provided to us in any forms, whether it is on-line or in physical forms or via other forms of interaction with you.
3. Collection of Personal Data
3.1. eLifeStyle 4 U collects Personal Data, either directly from you or from our authorized Sales Representatives or Affiliates or Agents or from your authorized representatives (i.e. persons whom you have authorized, persons who have been validly identified as being you or your authorized representative pursuant to our then-current security procedures), from third parties, or from publicly available sources or through our website in the following ways:
- when you subscribe to, purchase or use our products and/or services;
- when you submit an application form or other forms relating to our products and services;
- when you take part or respond to any contests, surveys, promotions or other initiatives conducted by us;
- when you participate in any of our radio, television or online programmes;
- when you visit our websites or use our mobile applications;
- when you interact with our customer service officers, for example, via telephone calls, letters, face-to-face meetings and emails;
- when you request we contact you;
- when you submit your personal data to us for any other reasons.
3.2. When you browse our website or use any of our mobile or web-based applications, you generally do so anonymously but please see the section below on cookies. We do not at our website automatically collect Personal Data unless you provide such information or login with your account credentials.
3.3. If you provide us with any Personal Data relating to a third party (e.g. information of your spouse, children, parents, and/or employees), by submitting such information to us, you represent to us that you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes.
3.4. You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with the Products and Services you have requested.
4. Purposes for the Collection, Use and Disclosure of Personal Data
4.1. eLifeStyle 4 U collects, may use and disclose your Personal Data for the following purposes:
- responding to your queries and requests;
- managing the administrative and business operations of eLifeStyle 4 U and complying with internal policies and procedures;
- facilitating business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving any of the Companies;
- matching any Personal Data held which relates to you for any of the purposes listed herein;
- resolving complaints and handling requests and enquiries;
- preventing, detecting and investigating crime and analyzing and managing commercial risks;
- providing media announcements and responses;
- monitoring or recording phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes;
- organising promotional events;
- legal purposes (including but not limited to obtaining legal advice and dispute resolution);
- conducting investigations relating to disputes, billing or fraud;
- meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on eLifeStyle 4 U (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies and conducting audit checks, due diligence and investigations); and
- purposes which are reasonably related to the aforesaid.
4.2. Furthermore, where permitted under the Act:
a) eLifeStyle 4 U may also collect, use and disclose your Personal Data for the following “eLifeStyle 4 U Additional Purposes”:
- analytics and tracking, including facilitating the sale of analytical data
- conducting market research and surveys to enable us to understand and determine customer location, preferences and demographics to develop special offers and marketing programs in relation to eLifeStyle 4 U’s Products and Services, and to improve our service delivery and your customer experience at our touch points;
- providing additional Products and Services and benefits to you, including promotions, loyalty and reward programs from eLifeStyle 4 U;
- matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision, marketing or offering of Products and Services by eLifeStyle 4 U;
- leads generation and management for marketing eLifeStyle 4 U’s Products and Services;
- administering contests, competitions and marketing campaigns, and personalizing your experience at eLifeStyle 4 U’s touch points;
- communicating to you advertisements involving details of our Products and Services, special offers and rewards, either to our customers generally, or which we have identified may be of interest to you (including but not limited to upselling, cross selling and telemarketing);
- organizing promotional events and corporate social responsibility projects; and
- purposes which are reasonably related to the aforesaid.
b) In addition, where permitted under the Act and subject to the provisions of any applicable law, your Personal Data may be disclosed, for eLifeStyle 4 U Additional Purposes, to the vendors or other third party service providers in connection with promotions and services offered by eLifeStyle 4 U.
c) eLifeStyle 4 U may also collect, use and disclose your Personal Data for the following “Preferred Partners Additional Purposes” :
- conducting market research and surveys to enable us to understand and determine customer location, preferences and demographics to develop special offers and marketing programs with our preferred partners;
- matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision, marketing or offering of products and services (including promotions, loyalty and reward programs) by our preferred partners;
- leads generation and management for marketing the products and services offered by our preferred partners;
- administering contests, competitions and marketing campaigns in connection with the products and services offered by our preferred partners;
- sending you informational, recruitment and other notification messages communicated by our preferred partners;
- communicating to you advertisements involving details of the products, services, special offers and rewards offered by our preferred partners, either to our customers generally, or which we or our preferred partners have identified may be of interest to you (including but not limited to upselling, cross selling and telemarketing); and
- purposes which are reasonably related to the aforesaid.
d) In addition, where permitted under the Act and subject to the provisions of any applicable law, your Personal Data may be disclosed, for Preferred Partners’ Additional Purposes, to the vendors or other third party service providers in connection with promotions and services offered by eLifeStyle 4 U’s preferred partners. However, please be assured that we do not disclose your Personal Data to our preferred partners for the purposes of the above.
4.3. If you have provided your Singapore telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your Singapore telephone number(s), then from time to time, eLifeStyle 4 U may contact you using such Singapore telephone number(s) (including via voice calls, text, fax or other means) with information about our Products and Services or those products and services offered by our preferred partners (including discounts and special offers).
4.4. In relation to particular Products and Services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.
4.5 You have a choice to withdraw your consent for receiving marketing or promotional materials/communication. You may contact us using the contact details found below.
4.6 Please be aware that once we receive confirmation that you wish to withdraw your consent for marketing or promotional materials/communication, it may take up to 30 working days for your withdrawal to be reflected in our systems. Therefore, you may still receive marketing or promotional materials/communication during this period of time. Please note that even if you withdraw your consent for the receipt of marketing or promotional materials, we may still contact you for other purposes in relation to the Products and Services that you hold or have subscribed to with ELifeStyle 4 U.
5. Disclosure of Personal Data
5.1. eLifeStyle 4 U will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, your Personal Data may be disclosed, for the purposes listed above (where applicable), to the following:
- (a) eLifeStyle 4 U’s related corporations and employees to provide content, Products and Services to you, address your questions and requests in relation to your customer accounts, subscription and billing arrangements with us as well as our Products and Services, to activate, deactivate, install, maintain and operate our systems and/or services;
(b) companies providing services relating to insurance and consultancy to ELifeStyle 4 U;
(c) agents, contractors or third party service providers who provide operational services to eLifeStyle 4 U, such as courier services, telecommunications, information technology, payment, printing, billing, payroll, processing, technical services, training, market research, call centre, security or other services to eLifeStyle 4 U;
(d) vendors or third party service providers in connection with marketing promotions and services offered by eLifeStyle 4 U or its preferred partners;
(e) commercial shops and retailers in relation to providing rewards and benefits;
(f) other telecommunications, content or other service providers to facilitate their provision of content or services, or for interconnection, inter-operability, system operation and maintenance and billing between service providers;
(g) any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving any of the Companies;
(h) collection and repossession agencies in relation to the enforcement of repayment obligations for debts;
(i) external banks, credit card companies and their respective service providers;
(j) our professional advisers such as auditors and lawyers;
(k) relevant government regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and
(l) any other party to whom you authorize us to disclose your Personal Data to.
6.2. The cookies in our website are used for the following purposes:
- enabling certain features and functions on our websites, eg. remembering your user-id, favorite channel selections, browsing and other service preferences;
- building up a profile of how you and other users use the website;
- improving the efficiency of our website;
- administering services to you and to advertisers; and
- establishing usage statistics
6.3. Internet browsers provide users the option of turning off the processing of cookies. However this may result in the loss of functionality, restrict your use of the website and/or delay or affect the way in which it operates.
6.4. Advertisements in the websites operated by eLifeStyle 4 U, may be provided by third party advertisers and their agencies. These may generate cookies to track how many people have seen a particular advertisement (or use the services of third parties to do this), and to track how many people have seen it more than once. eLifeStyle 4 U does not control these third parties and their cookie policies and if you have questions about their cookie policies, please contact eLifeStyle 4 U and we will try our best to assist by providing you information about these third party advertising agencies.
6.5. eLifeStyle 4 U is not responsible for the Personal Data policies (including Personal Data protection and cookies), content or security of any third party websites linked to the eLifeStyle 4 U website.
7. Web analytics by Google Analytics
7.2 This also means that when you visit our website or use any mobile or web-based applications, the personal data described in this document, and information stored in Google Analytics’ cookies, will be sent to Google Analytics for analysis for and on behalf of us. When you create an online profile at our website or mobile or web-based application and if you are logged in with 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.
7.4 If you do not wish information about your behavior at our website or any mobile or web-based applications being collected and assessed by Google Analytics, you can install the Google Analytics opt-out browser add-on. The browser add-on is available for most modern browsers. The Google Analytics opt-out browser add-on does not prevent information from being sent to the website itself or in other ways to web analytics services.
8. Retargeting Technologies
8.1 Our website and mobile or web-based applications may use internet retargeting technologies. This enables us to show our visitors, who were already interested in our online services, products, and online portals, advertisement from us on partner websites.
8.2 We work with other companies who use tracking technologies to serve advertisements on our behalf across the Internet. These companies may collect non-personally identifiable information about your visits to our websites or mobile or web-based applications and your interaction with our communications, including advertising.
8.3 Retargeting technologies analyse your cookies and display advertisement based on your past surfing behaviour. For further information on cookies, please refer to paragraph 6 of this document.
9. Contacting Us
10. Governing Law
This Personal Data Protection Policy and your use of this website shall be governed in all respects by the laws of Singapore.