Important information and who we are

Purpose of this privacy policy

This policy is designed to provide you with information about how we use the personal data and information that you provide to us during your use of the pureminutestelecoms.com websites or mobile apps (as applicable) (the “Sites”) when you purchase from us.

Go Mobile Link Pte Ltd is the controller of the information you provide. Go Mobile Link Pte Ltd ( “we” “us” “our”) (t/a Pure Minutes is a company registered in Singapore with registered number 201215069E. Our registered office address is 8 Defu Lane 1 01 – 08 Defu Industrial Park A 539483 Singapore

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It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.

We may change our privacy policy from time to time. This policy was last updated on 10th December 2021 and is version 4.7.

2.              The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

·       Identity Data includes first name (first name, last name) marital status, title, date of birth and in some circumstances proof of identity.

·       Contact Data includes billing address, delivery address, email address and telephone numbers.

·       Financial Data includes bank account and payment card details (stored in a tokenised format).

·       Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

·       Technical Data includes internet protocol (IP) address, access times, any websites you linked from, pages you visit, the links you use, the ad banners and other content you view, your login data, browser type and version, information about your device, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.

·       Usage Data includes information about how you use our website, products and services.

·       Marketing and Communications Data includes your preferences in receiving marketing from us.

·       Image Data in relation to CCTV footage of you when you visit any physical store.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

3.              How is your personal data collected?

We use different methods to collect data from and about you including through:

·       Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

·       purchase our products or services on a website.

·       agree that marketing can be sent to you;

·       enter a competition, promotion or survey;

·       interact with us on social media; or

·       give us feedback or contact us.

·       Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy below for further details.

·       Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:

·       Technical Data from the following parties:

(a)        analytics providers;

(b)        advertising networks; and

(c)         search information providers.

·       Contact, Financial and Transaction Data from providers of technical, payment and delivery services.

·       Identity and Contact Data from publicly available sources such as Companies House

4.              How we use your personal data

We will only use your personal data when the law allows us to. We only collect, keep, use or share your information for genuine business purposes in our legitimate interests, when you’ve approved us to do so or when we’re legally obliged to. Most commonly, we will use your personal data in the following circumstances:

·       Where we need to perform the contract we are about to enter into or have entered into with you (for example when you buy a washing machine or mobile phone).

·       Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

·       Where we need to comply with a legal obligation.

·       In limited circumstances, we may request your consent to process your personal data.

Lawful Basis

For us to be allowed to process your personal data, we must have a legal basis for the processing. The data protection legislation sets out what these bases are. We have described below the different bases that we rely on and provided examples of the processing.

·       Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us. If you do not want us to process any of the personal data we have listed as being processed for legitimate interests, you have the right to object. For more information see the section below relating to your rights. Please note that if you object we may still continue to process your personal data in certain circumstances. Please also remember that if we can’t process your personal data for these purposes your customer experience may not be as enjoyable.

·       Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. For example when you buy a product or service on any of our Sites, it creates a contract between us. We need to process your personal data that you provide in the order to fulfil our part of the contract and deliver the products to you. If you do not provide your details we won’t be able to complete your order.

·       Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to. For example, if you buy a product which is an age restricted item (such as a game rated 18) or if there is a product recall.

·       Consent means processing your personal data where you have explicitly told us that you will allow us to do so. In some cases, we will ask whether you would like us to process your personal data. For example, when an item is out of stock and you provide your telephone number for us to call to discuss available alternatives or notify you when the out of stock item becomes available. If you provide us with consent, you may withdraw it at any time by contacting us.

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate. 

When we will contact you

We may contact you by telephone shortly after your purchase to discuss your delivery and make sure that it all goes smoothly for you. We may also offer you other services which relate to the products that you have purchased. If you decide not to purchase a product protection plan on such call we may contact you around the expiry of the manufacturer’s guarantee to see whether this would then be of interest to you. If you do not wish to receive these calls, please contact us by phone, email or post.

As part of our monitoring and auditing process, if you have purchased in store using our finance option, we may contact you to ensure that our agents have provided you the correct information to make your purchase.

Please note, if you submit information in relation to your order but there is an error or delay in processing, we may use the details you’ve submitted to contact you to complete your order.

Should you wish to review our products or services, we may contact you after leaving the review.

Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.

5.              Disclosures of your personal data

We may share your personal data with the parties set out below for the purposes set out in the table above.

Internal Third Parties

Other companies acting as joint controllers or processors and who are based elsewhere and provide IT, shared services, logistics services, system administration services and undertake leadership reporting.

External Third Parties

·       Service providers acting as processors who provide delivery services, insight services, delivery of marketing communications services, IT remote set up services, and IT and system administration services.

·       Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in who provide consultancy, banking, legal, insurance and accounting services.

·       Our credit reference agencies (CRA) Equifax and/or Transunion for the purposes of performing credit checks.

·       Singapore Data for the purposes of undertaking anti money laundering checks required by law.

·       Domestic and General Insurance will receive Identity Data, Contact Data, Financial Data and Transaction Data if you choose to purchase an insurance plan. Additionally, it may receive recordings of telephone calls between you and us in respect of any extended warranty.

·       Mobile networks in order to enter you into a contract with your chosen mobile network provider.

·       If you are a rental customer we may share your information with your local housing association.

·       Social media platforms or internet platforms either as processors or joint controllers (in some instances this may be based on cookies for more information see https://pureminutestelecoms.com for pureminutestelecoms.com

·       Third party payment providers which are integrated into our website. When you pay using one of these methods e.g. Paypal, you are redirected to the providers portal. Your use of these services is subject the terms and conditions and the privacy policies of these payment providers.

·       Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

·       Our suppliers, in relation to resolving a product issue you have raised or in the event of a product recall.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We never sell your data. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6.              Our Credit Reference Agencies, Equifax and Transunion

We may also send your information to:

·       Equifax who will act as a credit reference agency (CRA). For more information on how Equifax will use your data please see https://www.equifax.com  l; or

·       Transunion who will act as a credit reference agency (CRA). For more information how Transunion use your data please see their privacy policy at  https://www.transunion.com

7.              International transfers

We may transfer your personal data outside of the Singapore Area.

Whenever we transfer your personal data out of Singapore, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

8.              Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

By law we have to keep basic information about our customers relating to purchases and rentals (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax and other regulatory purposes. We retain your transaction data for a period of ten years after your purchase, this is a requirement inline with certain product liability provisions under the Consumer Protection Act 1987.

If you call or message our contact centre with an enquiry (but do not place an order) we will keep your personal data for one month.

If you ask us to notify you about an out of stock item, we will do so if it becomes available within one month of your request.

In some circumstances you can ask us to delete your data: see your legal rights below for further information.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

9.           Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data.

You have the right to:

Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to the processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

·       If you want us to establish the data’s accuracy.

·       Where our use of the data is unlawful but you do not want us to erase it.

·       Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.

·       You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us at dataprotection@pureminutestelecoms.com.

No fee usually required

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10.           Contact details

We’re always looking for new ways to improve your shopping experience with us, that’s why we love hearing from you. If you have any questions about how we use your personal data or if you’d like to amend or stop us from processing your data (for marketing purposes), please contact us. You can get in touch by giving our friendly contact centre a call on +65 9134 8268 for any purchases from pureminutestelecoms.com or in any physical store. Alternatively, you can write to us at our registered office address – 8 Defu Lane 1 01 – 08 Defu Industrial Park A 539483 Singapore.

If you have any questions about this privacy policy or our privacy practices, we have appointed a Data Protection Officer (DPO). You may contact the DPO by writing to us at the registered office address set out above or by emailing dataprotection@pureminutestelecoms.com.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

11.           Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. 

12.           Security

Your privacy is important to us which is why we’ve ensured every part of our site uses secure connections. Look for the green padlock in the address bar and the letters ‘https’, as these should always be present when browsing our site.

We only take orders through web browsers that allow communication through Secure Socket Layer (SSL) technology. There’s no way you can order through an unsecured connection.

To keep you safe, we gain accreditation from the Payment Card Industry (PCI) every year. This third-party certification certifies that we take appropriate precautions to make sure your details are kept safe. This covers everything from ensuring our teams are well trained in the security risks and vulnerabilities today, to implementing security compliant IT solutions. More information regarding this security standard can be found here: https://www.pcisecuritystandards.org/pci_security/.

For extra security, you’ll see our checkout uses Verified by Visa, Mastercard SecureCard and American Express Safekey, which safeguards you from unauthorised use of your cards. Once you’ve registered and created a password with your card issuer, you’ll be prompted to provide this each time you check out.

We’re constantly monitoring and testing our IT systems and using the latest technology to identify potential vulnerabilities and attacks to provide a safe and secure shopping environment.

We maintain physical, electronic and procedural safeguards in connection with the collection, storage and disclosure of personal customer information. Our security procedures mean that we may occasionally request proof of identity before we disclose personal information to you.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to d