Privacy Policy

This Privacy Policy (“Policy”) describes how the Consumers Association of Singapore (“CASE”, “we”, “us” or “our”) collects, uses, processes and discloses your Personal Data through the Price Kaki App.

This Policy is incorporated as part of the Terms of Use. Your use of the Price Kaki App is subject to the Terms of Use and this Policy. Unless specifically defined in this Policy, the defined terms shall have the same meaning as defined in the Terms of Use.

“Personal Data” is any information which can be used to identify you or from which you are identifiable. This includes but is not limited to your name, Price Kaki App account name, Price Kaki App points statement, profile picture, mobile number, email address, mailing or delivery address, survey responses where linked to you or your account, redemption or transaction details, and ranking on the respective leaderboards.

1.Collection of Personal Data

We collect Personal Data about you in the ways listed below. We may also combine the collected Personal Data with other data in our possession. CASE takes reasonable efforts to ensure that your Personal Data collected by us is accurate and complete. You are responsible for ensuring that the Personal Data you provide to us, including your contact details and mailing or delivery address, is accurate and complete. Inaccurate or incomplete information may affect our ability to provide services, process rewards, or fulfil merchandise purchase or redemption requests. Please refer to clause 6 of this Privacy Policy for if you need to update your personal details.

1.1.You provide your Personal Data to us

We collect your Personal Data when you voluntarily provide it to us. For example, you may provide your Personal Data to us when you:

1. Register an account on the Price Kaki App;
2. Provide information to claim, purchase, redeem, collect or receive rewards, merchandise, vouchers, prizes or promotional items;
3. Participate in surveys, polls, questionnaires, feedback forms or other engagement activities conducted through the Price Kaki App;
4. Provide comments, queries or other information in your correspondence with us.

1.2.When you use the Price Kaki App

Personal Data may be collected through the normal operation of the Price Kaki App. Some examples are:

1. Your location; and
2. Information about how you interacted on the Price Kaki App (such as features used, search history and content viewed).

1.3.Surveys, promotions, rewards and fulfilment activities

We may collect Personal Data when you participate in surveys, polls, questionnaires, feedback exercises, promotions, rewards programmes, prize draws, merchandise purchases or merchandise redemptions conducted through the Price Kaki App.

Depending on the specific in-App activity which you may participate in, the Personal Data collected would include your account details, survey responses, demographic information, preferences, opinions, feedback, contact details, mailing or delivery address, redemption details, transaction details, and other information reasonably required to administer the relevant activity or fulfil the relevant purchase, redemption, reward, prize, merchandise or promotional item.

Unless otherwise stated, participation in surveys is voluntary. If you choose not to provide the Personal Data requested for a survey, promotion, purchase, redemption or fulfilment activity, we may be unable to process your participation, purchase, redemption, reward, prize, merchandise or promotional item.

2.Use of Personal Data

CASE may use, combine and process your Personal Data for the following purposes (“Purposes”).

2.1.Providing services and features

Your Personal Data will be used to provide, personalise, maintain and improve the Price Kaki App. This includes using your Personal Data to:

1. Create and update your account;
2. Enable features that personalise your Price Kaki App, such as lists of your favourite places and previous destinations;
3. Share information on the Price Kaki App via the “share” function;
4. Perform internal operations necessary to make the Price Kaki App available;
5. Protect the security or integrity of the Price Kaki App;
6. Compile and release aggregated or anonymised statistics regarding your use of the Price Kaki App;
7. Administer surveys, polls, questionnaires, feedback exercises, research activities and other engagement activities conducted through the Price Kaki App, and analyse responses or feedback to improve the Price Kaki App, our services, user experience, consumer research, outreach and engagement activities;
8. Verify your Price Kaki account and eligibility for rewards, promotions, purchases, redemptions, surveys, prize draws or other activities;
9. Process, validate, manage and fulfil rewards, merchandise purchases or redemptions, vouchers, prizes, promotional items or other requests made through the Price Kaki App;
10. Contact you about your survey participation, reward, promotion, purchase, redemption, prize, merchandise request, collection, mailing or delivery;
11. Arrange collection, delivery, mailing or other fulfilment of Rewards, merchandise, vouchers, prizes, promotional items or other items.

2.2.Customer support

We use Personal Data to resolve customer support issues. For example, we may:

1. Investigate and address customer feedback;
2. Monitor and improve our customer support responses;
3. Respond to questions and comments; and
4. Inform you about steps taken to resolve customer support issues.

2.3.Research and development and security

We may use the Personal Data we collect, including survey responses and feedback, for testing, research, analysis, consumer insights, product development and service improvement. This allows us to understand and analyse users’ needs and preferences, improve and enhance the Price Kaki App, develop new features, improve our outreach and engagement activities, and enhance the safety and security of the Price Kaki App. Where practicable, we will use aggregated or anonymised data for analytics, reporting and research.

2.4.Legal purposes

We may use the Personal Data we collect to investigate and resolve claims or disputes, or as allowed or required by applicable law.

We may also use your Personal Data when we are required, advised, recommended, expected or requested to do so by our legal advisors or any local or foreign legal, regulatory, governmental or other authority.

For example, we may use your Personal Data to:

• Comply with court orders or other legal, governmental or regulatory requirements;
• Enforce our Terms and Conditions or other agreements; and
• Protect our rights or property in the event of a claim or dispute.

3.Disclosure of Personal Data

We need to share Personal Data with various parties for the Purposes. These parties include:

3.1.Other account holders

As an account holder, your account name, profile picture and ranking would be disclosed to other account holders on the leaderboards on the Price Kaki App.

3.2.With CASE’s service providers and business partners

We may disclose Personal Data to Participating Outlets, Merchants, consultants, survey administrators, research firms, IT service providers, hosting providers, analytics providers, customer support providers, delivery or courier providers, payment processing providers, prize or merchandise fulfilment vendors, marketing partners and other service providers or business partners, where reasonably necessary for the Purposes or as permitted or required by applicable law.

For example, we may disclose your name, contact details, delivery address and redemption or transaction details to delivery or fulfilment providers for the purpose of mailing or delivering merchandise, Rewards, vouchers, prizes or other items to you. We may also disclose survey-related data to survey administrators or research firms to administer surveys, analyse responses and prepare reports, including aggregated or anonymised reports where practicable.

4.Retention of Personal Data

CASE will retain your Personal Data for as long as it is necessary for the purposes for which it was collected, used or disclosed, or as required or permitted by applicable law. Account-related Personal Data may be retained for as long as you maintain your account on the Price Kaki App. Personal Data collected for specific activities, such as surveys, promotions, merchandise purchases, merchandise redemptions, Rewards fulfilment, customer support or legal/compliance purposes, may be retained for the period reasonably necessary to administer, fulfil, audit or resolve the relevant activity or matter.

Once your Personal Data is no longer necessary for the relevant purposes, and we no longer have a legal or business purpose for retaining it, we will take reasonable steps to cease retention of such Personal Data or anonymise it.

5.Withdrawal of Consent

You may refuse or withdraw your consent for CASE to collect, use, or disclose your Personal Data at any time by submitting a request through the Price Kaki App’s settings or by emailing pricekaki@case.org.sg. CASE will process your request within 30 calendar days.

Please note that withdrawing consent may affect our ability to provide certain services, features or activities to you. For example, if you withdraw consent for Personal Data required to maintain your Price Kaki account, your account may be deactivated and you may no longer be able to access app features, saved data, points or survey participation. If you withdraw consent for Personal Data required for a survey, promotion, purchase, redemption, reward, prize or merchandise fulfilment activity, we may be unable to process or complete that activity.

Withdrawal of consent will not affect any collection, use or disclosure of Personal Data that occurred before your withdrawal was processed, or any collection, use or disclosure that is permitted or required under applicable law.

6.Amendments and updates

We reserve the right to modify, vary and change the terms of this Policy at any time without prior notice to you by posting such changes on the Price Kaki App. Such modification, variations and/or changes to this Policy shall be effective upon the posting of an updated version on the Price Kaki App.

You have the right to:

• Access your Personal Data that we hold;
• Request correction of any inaccuracies in your Personal Data.

To exercise these rights, please contact our Data Protection Officer at dataprotection@case.org.sg. We will respond to your request within 30 calendar days from the date of receipt.

7.Measures to Protect Personal Data

We have implemented reasonable administrative, physical and technical measures to protect your Personal Data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. These measures include:

• Secure servers and firewalls;
• Encryption and secure storage;
• Access control policies limited to authorised personnel only.

We also regularly review and update our data protection practices to ensure the continued security of your Personal Data.

8.Cross-border Transfers of Personal Data

In certain cases, your Personal Data may be transferred to and stored in servers located outside Singapore. When this occurs, we ensure that such transfers are carried out in compliance with the requirements of the Personal Data Protection Act (PDPA) of Singapore, and that recipients provide a standard of protection comparable to that provided under the PDPA.

9.Data Breach Notification

In the event of a data breach involving Personal Data, we will take steps to contain and assess the breach in accordance with our data breach response procedures. Where the breach is assessed to be a notifiable data breach under the PDPA, including where it is likely to result in significant harm to affected individuals or is of a significant scale, we will notify the Personal Data Protection Commission as soon as practicable and in any event no later than 3 calendar days after determining that the breach is notifiable. Where required under the PDPA, we will also notify affected individuals in a reasonable manner.