This Privacy Policy describes the practices in which NTUC Club & its subsidiaries, which include Resorts Concept Pte Ltd, Quebec Leisure International Pte Ltd, Leisurequest Pte Ltd, NCI Golf Pte Ltd, UPlay Ventures Pte Ltd, Orchid Leisure Enterprise Pte Ltd (Orchid Country Club) and Pasir Ris Resort Pte Ltd (Aranda Country Club) (“us” or “we” or “our”) collect, use and disclose Personal Data collected from you.

For the purpose of this Policy, “Personal Data” shall mean data, whether true or not, about an individual which can be identified – from that data; or from that data and other information which an organisation has or is likely to have access. Such Personal Data shall also refer to the data which is already in our possession or the data to be collected by us.

It supplements but does not supersede nor replace any other consent that you may have previously provided to us, nor does it affect any right that we may have at law in connection with the collection, use, disclosure and / or retention of your Personal Data.

1. Personal Data Collected
   1. We may collect your Personal Data in various situations such as account / member sign-up, newsletter subscription, resort booking, golf game booking, event photography and participation in lucky draw / survey / event / activity, etc.
   2. Personal Data collected by us may vary depending on entity.
      1. Personal Data collected by Orchid Leisure Enterprise Pte Ltd (Orchid Country Club) and Pasir Ris Resort Pte Ltd (Aranda Country Club) include:
         1. Name;
         2. Identity number;
         3. Email address;
         4. Residential/Postal address;
         5. Contact number;
         6. Date of birth;
         7. Nationality;
         8. Bank account / Credit or debit card Information;
         9. Photographs;
         10. Videos and images;
         11. Facial and biometric information;
         12. Membership number;
         13. Particulars of your home club (if any);
         14. Information of the products and services you have purchased from us;
         15. Marriage certificate;
         16. Birth certificate;
         17. Vehicle and vehicle insurance information and log card;
         18. Marital status;
         19. Annual gross income;
         20. Profession, designation; and
         21. Any other personally identifiable information which we may require from time to time.
      2. Personal Data collected by NCI Golf Pte Ltd (Marina Bay Golf Course) include:
         1. Name;
         2. Identity number;
         3. Email address;
         4. Residential/Postal address;
         5. Contact number;
         6. Date of birth;
         7. Nationality;
         8. Bank account / Credit or debit card Information;
         9. Photographs;
         10. Videos and images;
         11. Membership number;
         12. Particulars of your home club (if any);
         13. Information of the products and services you have purchased from us; and
         14. Any other personally identifiable information which we may require from time to time.
      3. Personal Data collected by NTUC Club (Resorts Concept Pte Ltd, Quebec Leisure International Pte Ltd, Leisurequest Pte Ltd) include:
         1. Name
         2. Identity number;
         3. Email address;
         4. Residential/Postal address;
         5. Contact number;
         6. Date of birth;
         7. Bank account / Credit or debit card Information;
         8. Photographs;
         9. Videos and images;
         10. Facial and biometric information;
         11. Information of the products and services you have purchased from us; and
         12. Any other personally identifiable information which we may require from time to time.
      4. Personal Data collected by Uplay Ventures Pte Ltd (My Golf Kaki) include:
         1. Name
         2. Identity number;
         3. Passport Number
         4. Email address;
         5. Residential/Postal address;
         6. Contact number;
         7. Date of birth;
         8. Nationality
         9. Bank account / Credit or debit card Information;
         10. Photographs;
         11. Videos and images;
         12. Facial and biometric information;
         13. Membership number;
         14. Particulars of your home club (if any);
         15. Information of the products and services you have purchased from us; and
         16. Any other personally identifiable information which we may require from time to time.
   3. Where Personal Data of any third party are provided by you to us, you undertake to obtain the consent of the third party to our collection, use and/or disclosure of those Personal Data in accordance with our Privacy policy. We reserve the right to request for the verification of such consent where required.
   4. We may rely on the legitimate interests exception to collect, use or disclose personal data without consent for some or all of the following purposes:
      1. Security purposes;
      2. To prevent misuse of our services;
      3. To prevent money laundering;
      4. To prevent terrorism;
      5. To prevent fraud;
      6. Evaluative purposes;
      7. Investigation or proceedings;
      8. Recovering a debt from you;
      9. Paying a debt to you;
      10. In the course of the provision of legal services or obtaining legal services;
      11. For the purposes of preparation by credit bureau of a credit report / relates to a credit report provided by a credit bureau to a member of the credit bureau in relation to a transaction between the member and you;
      12. To confer an interest or a benefit you under a private trust or benefit plan / administer that trust or benefit plan, at the request of the settlor or the person establishing the benefit plan, as the case may be;
      13. Where the personal data is provided to us by another individual to enable the organisation to provide a service for the personal or domestic purposes of that other individual and is collected, used or disclosed (as the case may be) by us solely for that purpose;
      14. Where the personal data is included in a document produced in the course, and for the purposes, of an individual’s employment, business or profession and is collected, used or disclosed (as the case may be) for purposes consistent with the purpose for which the document was produced; and
      15. For entering into an employment relationship with the individual or appointing the individual to any office or managing or terminating the employment relationship with or appointment of the individual.
   5. For more information on our reliance on the legitimate interests exception, please contact us at the email address listed in Clause 8.2 below.
2. Purpose of Collection of Personal Data
   1. By interacting with us and submitting information to us, or signing up for any products or services offered by us, you agree and consent to us for collecting, using, and disclosing such Personal Data in the manner set forth in our Privacy policy and as notified to you at the point of collection.
   2. Your Personal Data collected may be used for some or all of the following purposes:
      1. To provide the products and / or services you have purchased;
      2. To assist you with your enquiries;
      3. To process your application for membership and administering and/or managing your relationship with us;
      4. To fulfill your obligations as our member;
      5. To process payments for your purchases;
      6. To improve customer service;
      7. To conduct statistical analysis and research including building analytical solutions;
      8. To keep you updated of our future offers / promotions and events;
      9. To comply with applicable laws and regulations;
      10. For access and security purposes;
      11. For carrying out lucky draws and marketing campaigns, promotions, discounts, offers, and providing you with information on new products and services;
      12. To send you invitations to events and activities;
      13. To offer member benefits and privileges;
      14. To conduct ecommerce activities;
      15. To facilitate your use of our platforms and services through the use of WIFI and digital technologies
      16. Ad targeting;
      17. To carry out due diligence or relevant screening activities in accordance with legal or regulatory obligations or risk management procedures;
      18. To recover any amounts owed to us;
      19. To prevent, detect, and investigating fraud, misconduct, unlawful action or omission in relation to your dealings with us;
      20. To manage our infrastructure and business operations, comply with policies and procedures that may be required by law and/or that is put in place us; and
      21. Any other purposes which we may notify you from time to time.
3. Updating You of Our Offers / Promotions
   1. You may be contacted via email, text message or voice call, to be informed of our latest offers or promotions.
   2. You may also receive non-marketing messages such as surveys, customer-service notices and other service related notices if you have signed up as a member under any of our membership schemes or utilised any of our services / facilities.
4. Disclosure of Your Personal Data
   1. We may disclose your Personal Data to the following organisations for the purposes mentioned above:
      • NTUC and entities in the NTUC Group;
      • Amongst ourselves within NTUC Club and its subsidiaries;
      • Financial institutions including credit card companies and their service providers;
      • Business partners;
      • Agents, contractors, data intermediaries or third party service providers;
      • Hospitals, clinics or insurance companies in connection with claims;
      • Professional advisor such as legal advisers, auditors;
      • Regulators or other government bodies as required by law; and
      • Any other organisations with your consent or where deemed consent applies.
5. Use of Cookies
   1. We may use cookies on our websites to record session information, collect visit and access details to our web pages that enable us to continue to improve our services and provide better and useful features to our website users.
   2. Should you wish to disable the cookies associated with these technologies you may do so by changing the settings on your browser. However, please note that this may affect the functionality of the website(s).
   3. We are not responsible for the Personal Data policies (including Personal Data protection and cookies), content or security of any third party websites linked to our websites.
6. Protection of Your Personal Data
   1. We maintain appropriate security safeguards and practices to protect your Personal Data from accidental loss, misuse or destruction, in accordance with the applicable laws
7. Accuracy of Your Personal Data
   1. We take all reasonable and practicable measures to ensure that your Personal Data remains accurate, complete and up-to-date. Please keep us informed when there are any changes to your Personal Data. You confirm that all personal data provided to us is accurate and that you are responsible in maintaining the accuracy of the personal data provided to us. As a My Golf Kaki member, you have declared and are responsible to furnish accurate personal data and to maintain the accuracy of your personal data which is provided to My Golf Kaki on their membership website.
8. Access and Correction of your Personal Data
   1. You may request access to or make corrections to your Personal Data records, subject to some exceptions allowed by law. A fee may be charged to cover the cost of providing the requested information and we will respond to your request within 30 days.
   2. Please submit your request to us at the following email addresses :

      My Golf Kaki

      : dpo@mygolfkaki.com

9. Storage and Retention of Personal Data
   1. We 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, according to our data retention policies.
   2. We may from time to time transfer your Personal Data overseas to servers owned by third party service providers, for storage purposes and to continue to provide our services to you.
   3. Where your Personal Data is transferred in this manner, we will ensure that the recipient of the Personal Data is bound by legally enforceable obligations to provide to the Personal Data a standard of protection that is at least comparable to that under the Personal Data Protection Act 2012.
10. Minors
    1. We cannot distinguish the age of persons accessing our websites. If a minor (according to applicable laws) has provided us with Personal Data without parental or guardian consent, the parent or guardian should contact us to inform us and we shall restrict any collection, use or disclosure of that personal data.
11. Contacting Us
    1. If you have any questions about our Personal Data protection policy or practices, or wish to withdraw your consent to any use or disclosure of any Personal Data provided to us, you can write to My Golf Kaki at dpo@mygolfkaki.com.
12. Policy Updates
    1. We may update our Privacy Policy at any time without prior notice in response to changes to applicable laws or our practices. You are advised to check our Privacy Policy on this page regularly
13. Governing Law
    1. This Policy is governed by and shall be construed in accordance with the laws of Singapore.

Last updated 27 December 2023