1.1 This Policy statement provides information on the obligations and policies of
BODIK in respect of an individual customer’s Personal Data. BODIK undertakes to
use reasonable efforts in applying, where practicable, those principles and the
processes set out herein to its operations.
1.2 BODIK's officers, management, and members of staff shall use reasonable
endeavours to respect the confidentiality of and keep safe any and all Personal Data
collected and/or stored and/or disclosed and/or used for, or on behalf of, BODIK.
BODIK shall use reasonable endeavours to ensure all collection and/or storage
and/or disclosure and/or usage of Personal Data by BODIK shall be done in an
appropriate manner and in accordance with the Act (as defined below) and this
1.3 For the purposes of this Policy, in line with the provisions under the Personal
Data Protection Act 2012 (No. 26 of 2012), (the “Act”), “Personal Data” shall mean
data, whether true or not, about an individual customer who can be identified from
that data; or from that data and other information to which an organisation has or is
likely to have access. Such Personal Data shall also refer to that which is already in
the possession of BODIK or that which shall be collected by BODIK in the future.
2. Contacting the Data Protection Officer
2.1 Where you legitimately request access to and/or correction of Personal Data
relating to you which is in the possession and control of BODIK, it shall provide
and/or correct that data in a reasonable time and manner in accordance with its
standard procedures as stated hereinafter.
2.2 In accordance with the Act, BODIK has established a process for receiving and
responding to any query or complaint that may arise with respect to the application of
this Act. To ensure that BODIK receives your complaints and enquiries, please send
the same via email to the Data Protection Officer (the “DPO”) of BODIK at the
following email address: [[email protected]]
2.3 Should you not wish BODIK to use your Personal Data for any of the purposes
listed in Clauses 3.2 to 3.5, or not to receive promotional materials from BODIK, you may opt out by sending a clearly worded email to the DPO via the email address
provided in Clause 2.2. Your request shall be processed within a reasonable time.
3. Statement of Practices
Types of Personal Data Collected
3.1 As part of its day to day activities, BODIK may collect from you, through various
means, including via our websites, smart phone applications, marketing events such
as road shows and any forms used by BODIK from time to time, the following
Personal Data: name (first and surname); postal address; phone number (including
mobile); fax number; e-mail address; bank account/credit card details; gender;
Personal Data of your emergency contacts; IP addresses; photographs and images;
age; weight; lifestyle habits and general health information.
web browsers are designed to accept cookies. If you do not wish to receive any
cookies, you may set your browser to refuse it.
3.3 We may use traffic log cookies to identify which pages are being used. This use is
designed to assist us in gathering data on web page traffic. The gathered data is
used only for statistical purposes and is removed from our database shortly after.
3.4 Overall, the data collected by the cookies is used for the purpose of improving
your browsing experience on our website. Cookies do not grant us access to your
computer or any information about you outside of your browsing activity on our
Purpose of Collection of Personal Data
3.5 The above Personal Data mentioned in Clause 3.1 is collected for the purposes
of processing your application and registration of your membership and to ascertain if
you are eligible for discounts, privileges or benefits or other related purposes; to
conduct market research and analysis; for general marketing purposes; for direct
marketing through voice calls; text messages; email; direct mail and facsimile
messages; for payment and/or credit control purposes; to notify you of any changes
to our policies or services which may affect you; to respond to queries and feedback;
for identification and club access; maintaining and updating your membership details;
and informing you of new developments, services, promotions of BODIK and other
third parties which we are associated with.
Disclosure of Personal Data
3.6 In order to carry out the functions described above, BODIK may, from time to
time, disclose your Personal Data between BODIK’s companies.
3.7 Without derogating from any of the above, BODIK may also disclose your
Personal Data to the following third parties, namely: regulators and law enforcement
officials; lawyers; auditors; third party service providers and consultants; third party
investors; credit, debit and charge card companies, banks and other entities
processing payment; and any agent or subcontractor acting on BODIK’s behalf for
the provision of BODIK’s services.
3.8 BODIK may disclose your Personal Data to the abovementioned parties also in
the occurrence of any of the following events, namely, to the extent that BODIK is
required to do so by the law; in connection with any legal proceedings or prospective
legal proceedings; to establish, exercise or defend BODIK’s legal rights; to the
purchaser (or prospective purchaser) of any company, business or asset which
BODIK is (or is contemplating) selling; to any person and/or entity for the purpose of
processing such information on BODIK’s behalf; to third parties who provide services
to BODIK or on its behalf; to any third party that purchases BODIK’s or BODIK’s
companies, business or any part of BODIK or BODIK’s business; for the purposes of
disaster recovery; and any other purpose with your specific consent.
Optional Personal Data Requests
3.9 In some instances, you may also be requested to provide certain Personal Data
that may be used to further improve BODIK’s products and services and/or better
tailor the type of information presented to you. In most cases, this type of data is
optional although, where the requested service is a personalised service, or provision
of a product or dependent on your providing all requested data, failure to provide the
requested data may prevent BODIK from providing the service to you. This type of
data includes, but is not limited to: your age; gender; salary range and employment
details; education and profession; hobbies and leisure activities; other related
products and services subscribed to; and family and household demographics.
3.10 Under certain circumstances, telephone calls made to any of the BODIK
companies order and/or service hotlines and/or inquiry telephone numbers are
recorded for the purposes of quality control, appraisal, as well as staff management
and development. In such an event, by agreeing to this Policy, you hereby give your
clear and unambiguous consent for the collection, use and disclosure of such
Personal Data in accordance to this Policy.
4. Transfer of Personal Data Overseas
Your Personal Data may be processed by BODIK, its affiliates, agents and third
parties providing services to BODIK, in jurisdictions outside of Singapore. In this
event BODIK will comply with the terms of the Act.
5. Accuracy of Personal Data
Where possible, BODIK will validate data provided using generally accepted
practices and guidelines. In some instances, BODIK may validate the data provided
against pre-existing data held by BODIK. Accordingly, BODIK will be required to see
original documentation before we may use the Personal Data such as with Personal
Identifiers and/or proof of address. To assist in ensuring the accuracy of your
Personal Data in the possession of BODIK, please inform us of any updates or
corrections of any parts of your Personal Data by sending a clearly worded email to
the DPO at the email address earlier provided.
6. Protection of Personal Data
BODIK uses commercially reasonable physical, managerial, and technical
safeguards to preserve the integrity and security of your Personal Data and will not
knowingly allow access to this data to anyone outside BODIK, other than to you or as
described in this Policy. However, BODIK cannot ensure or warrant the security of
any information you transmit to BODIK and you do so entirely at your own risk. In
particular, BODIK does not warrant that such information may not be accessed,
altered, collected, copied, destroyed, disposed of, disclosed or modified by breach of
any of BODIK’s physical, technical, or managerial safeguards.
7. Access and Correction of Personal Data
7.1 In accordance with the Act, you have the right to:
a) check whether BODIK holds any Personal Data relating to you and, if so, obtain
copies of such data; and
b) require BODIK to correct any Personal Data relating to you which is inaccurate for
the purpose for which it is being used.
7.2 BODIK reserves the right to charge a reasonable administrative fee in order to
meet your requests under Clause 7.1. Upon payment of the requisite fee, your
request shall be processed within a reasonable time.
7.3 If you wish to verify the details you have submitted to BODIK or if you wish to
check on the manner in which BODIK uses and processes your personal data,
BODIK’s security procedures mean that BODIK may request proof of identity before
we reveal information. This proof of identity will take the form of full details of name,
membership number and NRIC or Passport or Fin number. You must therefore keep
this information safe as you will be responsible for any action which BODIK takes in
response to a request from someone using your membership details.
8. Storage and Retention of Personal Data
BODIK will delete, as reasonably possible, or otherwise anonymise any Personal
Data in the event that the Personal Data is not required for any reasonable business
or legal purposes of BODIK and where the Personal Data is deleted from BODIK's
electronic, manual, and other filing systems in accordance with BODIK's internal
procedures and/or other agreements.
9. Contacting you
To the extent that any of the communication means which you have provided BODIK
with (which may include, your telephone number and fax number) is/will be listed on
the Do Not Call Registry (the “DNC”), by agreeing to this Policy through your signing
of any consent form, or by any other means of indication, you hereby grant BODIK
your clear and unambiguous consent to contact you using all of your communication
means you have provided to BODIK including using SMS and MMS messages for the
above purposes. This will ensure your continued enjoyment of BODIK’s promotional
rates and services.
10. Change Policy
BODIK reserves the right to alter any of the clauses contained herein in compliance
with local legislation and/or to meet its global policy requirements, and for any other
purpose deemed reasonably necessary by BODIK. You should look at these terms
regularly. If you do not agree to the modified terms, you should inform us as soon as
possible of the terms to which you do not consent. Pending such notice, if there is
any inconsistency between these terms and the additional terms, the additional terms
will prevail to the extent of the inconsistency.
11. Governing Law
11.1 This Policy is governed by and shall be construed in accordance with the laws of
Singapore. You hereby submit to the non-exclusive jurisdiction of the Singapore
11.2 This Policy has been prepared in duplicate in English and Japanese languages,
both having equal force. In case of any divergence of interpretation, the English
language version shall prevail.
12.1 This Policy only applies to the collection and use of Personal Data by BODIK. It
does not cover third party sites to which we provide links, even if such sites are co-
branded with our logo. BODIK does not share your Personal Data with third party
websites. BODIK is not responsible for the privacy and conduct practices of these
third party websites, so you should read their own privacy policies before disclosure
of any Personal Data to these websites.
12.2 BODIK will not sell your personal information to any third party without your
permission, but we cannot be responsible or held liable for the actions of third party
sites which you may have linked or been directed to BODIK’s website.
12.3 BODIK’s websites do not target and are not intended to attract children under
the age of 16 years old. BODIK does not knowingly solicit personal information from
children under the age of 16 years old or send them requests for personal data. In
case of members who are between 16 and 18 years of age, his/her parents or legal
guardian are required to sign any consent form under the Policy on his/her behalf. By
signing such consent form, parents or legal guardians are deemed to have confirmed
that the relevant member understands and is aware of what he/she has consent and