Personal Data Protection Policy

WWF-World Wide Fund for Nature (Singapore) Limited (“WWF-Singapore”)

1. Overview
 

Your privacy is very important to us. The purpose of this privacy statement (the “Data Privacy Statement”) is to inform you of how WWF - World Wide Fund for Nature (Singapore) Limited (“WWF-Singapore”) manages the Personal Information (as defined below) we hold. Please take a moment to read this Data Privacy Statement so that you know and understand the purposes for which we collect, use, process and disclose your Personal Information.
 

The Personal Information which you provide to us, whether previously or from now on, will be collected, used, processed and disclosed and will continue to be collected, used, processed and disclosed by us, in accordance with this Data Privacy Statement (as amended, varied, revised or restated from time to time).
 

By interacting with us, submitting information to us, or entering into an agreement with WWF- Singapore for the purposes set out hereunder, you agree and consent to WWF-Singaporecollecting, using, processing, disclosing and sharing your Personal Information, and disclosing such Personal Information to each of the Permitted Recipients (as defined below) in the manner set forth in this Data Privacy Statement.
 

This Data Privacy Statement supplements but does not supersede nor replace any other consent you may have previously provided to WWF-Singapore nor does it affect any rights we may have at law in connection with our collection, use, processing or disclosure of your Personal Information.
 

WWF-Singapore may from time to time update this Data Privacy Statement to ensure that this Data Privacy Statement is consistent with future developments, industry trends and/or any changes in laws, regulations, guidelines or such other applicable regulatory requirements. You agree to be bound by the prevailing terms of this Data Privacy Statement (as amended, varied, revised or restated from time to time).


2. Definitions
 

In this Data Privacy Statement, unless the context otherwise requires, the following terms shall have the meanings assigned to them below:

 

“PDPA” means the Personal Data Protection Act 2012 (No. 26 of 2012) of Singapore, as amended from time to time; and
 

“Personal Information” refers to all information relating to: (i) you or your related parties; (ii) your dealings with WWF-Singapore; (iii) any other information of a confidential nature; and (iv) any personal data as defined in the PDPA belonging to you or any related parties.
 

3. How we collect your data
 

Generally, we collect and process your Personal Information through a variety of channels, including but not limited to:
 

(a) information that you provide to WWF-Singapore. This includes information about you that you give to us by filling in forms or by communicating with us, whether face-to- face, by phone, e-mail or otherwise (which may be monitored or recorded);
 

(b) information we collect or generate about you. This may include (but is not limited to) information that we collect about you and/or your representatives in the course of the following:

  •  you signing a petition or becoming involved with one of our campaigns through WWF-Singapore or from a commissioned third party agency;
  • you applying for a job, freelance role or consultancy role with us; 
  • you buying any of our gifts, merchandise or products;
  • you becoming a supporter of WWF-Singapore;
  • you participating in an event of WWF-Singapore or volunteering with us;
  •  you making a donation to us;
  •  you subscribing to our e-newsletters or requesting any information from us;
  •  you visiting one of our websites or social media pages via tools such as cookies and online identifiers, including if you make comments on our message boards or discussion forums;
  •  you contacting us or becoming involved with us in any other way than as stated above; and
  •  our use of other online and offline sources, such as public databases and social media platforms.


(c) information we obtain from other third party or publicly available sources. To the extent that we collect and/or process your Personal Information through such third party or other publicly available sources, WWF-Singapore will provide confirmation of such to you in writing (whether via e-mail or otherwise), and you will thereafter receive emails from WWF-Singapore on various updates and be given the option to opt-out from receiving emails from WWF-Singapore.

 
4. Types of Personal Information we collect, use, process and disclose
 

WWF-Singapore only collects, uses, processes and/or discloses your Personal Information for applicable purposes, which are deemed necessary by WWF-Singapore and as described in this Data Privacy Statement, which includes but is not limited to:

  •  your (or your officers’, directors’, partners’, members’ or employees’) name, birthdate, age, social security number, passport number or company registration number, company incorporation date, gender, address, phone numbers, and email addresses;
  • copies of your (or your officers’, directors’, partners’, members’ or employees’) passport and other documentation required for identity or address verification purposes;
  •  financial information such as banking details, source of wealth information, bank statements, accounts, credit card numbers and/or tax information;
  •  history of giving and purchase to WWF-Singapore;
  •  estimated wealth based on publicly available sources;
  •  images, photograph, videos at WWF-Singapore events;
  •  reasons for and instances of support for conservation projects of WWF-Singapore and areas of interests;
  • participation at WWF-Singapore events and activities; and
  •  position(s) and title(s) in connection with any application for employment, job evaluation or reference check(s), or to provide services to WWF-Singapore.
 
5. Purposes for collecting, using, processing and disclosing your Personal Information
 

Generally, we will only collect, use, process and/or disclose your Personal Information where deemed necessary in support of the charity causes and campaigns of WWF-Singapore, and for, including but not limited to, the purposes below:
 

(a) to provide information and updates relating to WWF-Singapore or such services you requested in relation to your status at WWF-Singapore;
 

(b) to process your donations;
 

(c) to conduct surveys, research and statistical analysis with the aim of helping WWF- Singapore monitor and improve our services;
 

(d) to provide information and updates relating to all campaigns and events of WWF- Singapore;
 

(e) to comply with applicable laws, regulations, rules, codes of practice, guidelines, proceedings or to assist in inquiries from regulatory authorities, and enforcement agencies or similar purposes (whether relating to any fraudulent activities or otherwise), or in response to any investigation or debt recovery;
 

(f) to enable us to verify you or your related parties or persons acting on behalf of you (including without limitation, your connected persons, authorized persons and beneficial owners) identities through sanctions screening, due diligence checks, anti- tax evasion and/or anti-money laundering checks and conducting screening against politically exposed persons and such other relevant database(s), as may be required under applicable law or regulation;


(g) preventing, detecting and investigating crime, offence or unlawful activity including but not limited to fraud, money-laundering, terrorist financing and bribery, and analysing and managing commercial risks;


(h) observing and complying with any other legal, governmental or regulatory requirements, rules, laws or regulations, regulatory policies, guidelines or industry codes, orders, directions or requests issued by any court, legal or regulatory bodies of any relevant jurisdiction (whether in Singapore or otherwise), including any disclosure or notification requirements to which any recipient of the Personal Information is subject or the carrying out of audit checks, surveillance and investigation;


(i) in accordance with the PDPA and such other applicable data protection laws and regulations, to notify the Personal Data Protection Commission of Singapore or the relevant individuals or organisations of any data breaches that (i) result in or are likely to result in significant harm to an affected individual or is, or is likely to be, of a significant scale or (ii) are required to be disclosed under applicable laws and regulations, and you acknowledge that such notification or disclosure shall not be treated as a breach of any confidence of or restriction upon the disclosure of information imposed on WWF-Singapore by law, enactment, contract, rules of professional conduct or otherwise;


(j) to collect information for recruitment, payroll, compensation and benefits, performance, training, business communications and compliance with respect to WWF-Singapore;


(k) handling feedback, queries or complaints;


(l) all purposes reasonably related to one or more of the foregoing; and


(m) conducting general administration in relation to the foregoing.
 

6. Your Personal Information will generally be disclosed to the following persons:
 

(a) each of the respective employees, officers, directors, agents, and advisers of WWF- Singapore (collectively, the “Authorized Representatives” and each, an “Authorized Representative”);


(b) each of the respective subsidiaries, holding companies, related corporations (as defined under Section 6 of the Companies Act, Chapter 50 of Singapore) and such other affiliates of WWF-Singapore;


(c) each of the respective delegates, service provider or third parties of WWF-Singapore which are engaged to provide services, directly or indirectly, to WWF-Singapore (including but not limited to any auditors, banks or other institutions);


(d) service providers to perform other data processing services on the behalf of WWF- Singapore, including without limitation, payment processing, payrolls, data analytical mining and system penetration testing; and


(e) third parties where deemed necessary by WWF-Singapore, which may include regulatory authorities and tax authorities, (collectively, the “Permitted Recipients”).
To the extent we engage with a third party to collect, use, obtain and/or process your Personal Information, we will procure that such third party exercise reasonable efforts to ensure that it is in compliance with the PDPA and such other applicable laws and regulations, and is transparent on the purpose of collecting, using, obtaining and/or processing your Personal Information.

 
7. We will notify you of the confirmation of your request


We will notify you of the purpose of collecting, using, processing and/or disclosing your Personal Information at the point of obtaining your consent, through various channels in which we deal with you, including but not limited to, telephone conversations, in person, or electronic communications.


8. If you are a minor
 

Generally, we do not collect any Personal Information from individuals under the age of 13 years old. However, there may be circumstances, for reasons outside of our control, where we may be unaware of your age, and may collect, use, process and/or disclose your Personal Information when you are under the age of 13 years old.


If we learn that we have obtained your Personal Information, when you are under the age of 13 years old, (i) we will seek the consent in writing from your guardian or a parent who is legally able to provide consent on your behalf, and (ii) if no such consent is provided, any Personal Information relating to you will be returned, and all physical, electronic copies deleted, and, after returning or deleting all Personal Information, we will provide confirmation that we no longer possess any Personal Information, save to the extent that we are required to retain any such information by an applicable law, rule or regulation.


Given the sensitivity relating to the dealings with Personal Information of minors, we shall, at all times, when collecting, using, processing and/or disclosing Personal Information of minors ensure that:

  • We will take appropriate steps to ensure that you are able to effectively give consent on your behalf. If we have reason to believe or it can be shown that you do not have sufficient understanding of the nature and consequences of giving consent, we will seek the consent in writing from your guardian or a parent who is legally able to provide consent on your behalf;
  • We will not use any undue influence or provide misleading messages, in order to obtain your consent for the provision of any Personal Information;
  • A parent or a guardian who is legally able to provide consent on your behalf has the right to request to withdraw your consent to use, collect, process and/or disclose your Personal Information. This request can be made by such parent or guardian at any time via the following means:
 
Email: WWF-Singapore at info@wwf.sg or member@wwf.sg
Phone: WWF-Singapore mainline at (65) 6730 8100 or the Membership line at (65) 6730 8117
Post: Provide a letter to WWF-Singapore (address provided below) requesting a withdrawal of consent
Electronic: Unsubscribe from any of the electronic mail(s) provided by WWF- Singapore

9. Your right to withdraw your consent


We understand the ever-changing legal landscape and respect your rights to withdraw your consent to use, collect, process and/or disclose your Personal Information in accordance with the terms of this Data Privacy Statement. In the event you notify us of such withdrawal of consent, we will seek to respond to your requests within 10 calendar days and you will receive a notification from us seeking confirmation for the completion of your withdrawal of consent request.


You may withdraw your consent at any time via the following means:

 
Email: WWF-Singapore at info@wwf.sg or member@wwf.sg
Phone: WWF-Singapore mainline at (65) 6730 8100 or the Membership line at (65) 6730 8117
Post: Provide a letter to WWF-Singapore (address provided below) requesting a withdrawal of consent
Electronic: Unsubscribe from any of the electronic mail(s) provided by WWF- Singapore


You further acknowledge and agree that any such withdrawal of consent shall not prevent the continued use, processing, collection, transfer and/or disclosure of the Personal Information by WWF-Singapore for the purposes of compliance with laws, regulations and/or the request of any applicable regulatory authority within Singapore and any foreign jurisdiction.

10. Your right to request access and correct your Personal Information

Subject to the PDPA and such other applicable laws and regulations, you have the right to request access to and/or to correct an error or omission in your Personal Information that is within our possession or under the control of our organisation. We will seek to respond within 30 calendar days of any such requests.


In the event that we cannot respond to your request within a 30 calendar day period, we will notify you of such either by phone or email. In the meantime, you acknowledge and agree that we can continue with the collection, use, processing and/or disclosure of your Personal Information while we seek to respond to you as soon as reasonably practicable.


You may request access to and/or correct your Personal Information via the following means:

 
Email: WWF-Singapore at info@wwf.sg or member@wwf.sg
Phone: WWF-Singapore mainline at (65) 6730 8100 or the Membership line at (65) 6730 8117
Post: Provide a letter to WWF-Singapore (address provided below) requesting for access of or to correct the data

11. How we verify your identity


When receiving requests to access and/or correct the Personal Information, WWF-Singapore will do our due diligence to verify your identity.

  • If the request is made directly by you, WWF-Singapore staff will ask you to verify your name and provide at least 2 other verification details such as email address, phone number, and/or physical mailing address.
  • If the request is made by your parent or a guardian to access your personal data (while you are a minor), WWF-Singapore staff will request a written consent from you to disclose your personal data.
  • If your spouse requests access on your behalf, WWF-Singapore staff will seek to obtain your consent in writing before any disclosure of personal data to your spouse. In the event that WWF-Singapore was not able to obtain your consent, WWF- Singapore will only disclose the personal data to the spouse who has provided the consent.
  • If the request for access and/or to make corrections to your Personal Information is made on your behalf by a third party, WWF-Singapore will request a written consent from such third party that he or she has the legal authority to validly act on your behalf to give WWF-Singapore consent to disclose the Personal Information to the third party. In the consent letter, (i) the third party will need to confirm and provide legal documentation that it has the legal authority to validly act on your behalf and that it consents to WWF-Singapore disclosing the Personal Information to the third party for the purposes of providing it with access and/or to correct the Personal Information, and (ii) the necessary details for WWF-Singapore to proceed with the request such as contact details of the third party will be included.

12. How we protect your Personal Information


WWF-Singapore protects your Personal Information by making reasonable arrangements (including, where appropriate, physical, administrative, procedural and information and communications technology measures) to prevent (a) unauthorised or accidental access, collection, use, processing, disclosure, copying, modification, disposal or destruction of the Personal Information, or other similar risks, and (b) the loss of any storage medium or device on which the Personal Information is stored, which includes but is not limited to:

 
(a) our employees are bound by an employment agreement with confidentiality obligations at the point of employment;

(b) our employees’ access to Personal Information is restricted – only authorized personnel, which are required to deal with Personal Information on a need to know basis, will be granted such access;

(c) all physical confidential documents are locked in a secure environment;

(d) we perform monthly vulnerabilities scanning for desktops, laptops, and servers;

(e) our computers are equipped with the proper patches and latest updates to reduce system vulnerabilities;

(f) our network server does not take on multiple roles or applications and is dedicated only to its specific task;

(g) our network server is located in a secured server room where access is restricted and with firewall security arrangements in place;

(h) requests for any user access account to WWF-Singapore, including e-mail, network or laptops, have to be approved by the line manager of the staff or intern with reasonable justification; and

(i) to the extent we engage any third party service providers, we will procure that such third party service providers enter into agreements with confidentiality provisions and for which are tailored to ensure that such service providers are able to adequately meet the requirements of the PDPA or such other applicable laws or regulations. 13. Retaining your data

 

WWF-Singapore does not retain the Personal Information for a period of time longer than is necessary under applicable laws and regulations. However, we may either delete or anonymise your Personal Information, and will ensure that any remaining Personal Information retained on our systems cannot be identifiable to you as an individual.


14. Transfer of your Personal Information to third parties


In general, we do not transfer or share any Personal Information with other third parties. In the event that we transfer certain of your Personal Information to a third party inside and or outside of Singapore for any of the purposes provided in this Data Privacy Statement, we will, where possible, take appropriate steps to ensure such Personal Information is adequately protected in compliance with the requirements of the PDPA or such other applicable data protection laws and regulations.


15. Our Data Breach Mitigation Response


In the event a data breach in relation to any of your Personal Information is identified, we will, as soon as practicable, take reasonable steps to assess and contain the risk to prevent any further loss of any Personal Information.


We will notify you if we become aware of a breach of any of our data protection obligations under applicable laws and regulations, except where such disclosure is made to any governmental, banking, taxation or such other regulatory authority or similar body.


If you notice that your Personal Information has been breached and/or compromised, you may contact us at:

 
Data Protection Officer
Email: dpo@wwf.sg
WWF-Singapore mainline (65) 6730 8100 or the membership line at (65) 7630 8117

16. Changes to our policy


This Data Privacy Statement was last updated in September 2021. We may, from time to time, amend, vary, revise or restate this Data Privacy Statement, and will publish any such changes on our website or send a copy of the updated Data Privacy Statement to you by post or email.


17. Contact us

If you have any questions on this Data Privacy Statement, you may contact us at:

 
WWF - World Wide Fund for Nature (Singapore) Limited
354 Tanglin Road
#02-11, Tanglin Block
Tanglin International Centre
Singapore 247672

Mainline: (65) 6730 8100 or Membership line (65) 7630 8117
Email: info@wwf.sg or member@wwf.sg

Updated: 21st September 2021