Collection of Personal Data
2. The Singapore Personal Data Protection Act 2012 defines personal data as “data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which the organisation has or is likely to have access and includes information about you, from which you are identifiable (“Personal Data”).
3. The types of Personal Data Qi Xiang collects about you includes your name, nationality, address, telephone number, fax number, contact details, bank details, credit card details, gender, resident status, financial background, personal interests, email address, your occupation, educational experience, personal qualifications, your photo, any information about you which you have provided to Qi Xiang in registration forms, application forms or any other similar forms and/or any information about you that has been or may be collected, stored, used and/or processed by Qi Xiang from time to time and includes sensitive personal data such as your identification card number, driving licence number, birth certificate number, passport number, race, ethnic origin, date of birth, marital status, education background, and data relating to health, religious or other similar beliefs. If you are a service provider, we may also collect telematics data (such as your speed, acceleration, and braking data).
4. The provision of your Personal Data is voluntary. However, if you do not provide Qi Xiang your Personal Data, Qi Xiang will not be able to process your Personal Data for the Purposes and Additional Purposes outlined below and may cause Qi Xiang to be unable to provide services or products to or accept payments from you.
5. If you are an agent, vendor, supplier or service provider, provision of your Personal Data is mandatory and failure to provide your Personal Data, may be a breach of laws or regulatory requirements, and may cause Qi Xiang to be unable to engage you to provide services or products or issue payments to you for products or services provided.
6. Your personal data may be collected in the following situations, including the following:
(a) when you carry out transactions or interact with Qi Xiang or use any of its services;
(b) when you register any account with Qi Xiang;
(c) when you contact Qi Xiang by email, telephone, or in person, to resolve any issues that you may be facing or with inquiries or requests;
(d) when you leave your personal data to respond back to any request or query;
(e) when you subscribe to Qi Xiang’s services or notifications;
(f) when you leave your contact details with any of Qi Xiang’s representatives or at its website or interact with any of its representatives;
(g) when you respond to any of Qi Xiang’s advertisements or marketing materials;
(h) when you fill in any application, inquiry or survey forms;
(i) when you submit a job application to Qi Xiang; and
(j) when you provide feedback or make any complaints to Qi Xiang.
7. In addition to the Personal Data you provide to Qi Xiang directly, Qi Xiang may collect your Personal Data from publicly available sources or from third parties, for example:
(a) from filled up application or registration forms or other similar forms
(b) from publicly available sources such as directories;
(c) from Qi Xiang’s official and related social media pages, if you follow, like or are a fan of such pages;
(d) from credit reporting agencies, insurance providers, or financial services providers;
(e) when you interact and communicate with Qi Xiang at any events or activities;
(f) when you enter contests organized by Qi Xiang;
(g) from other entities who provide you with services or with whom you have a contractual relationship;
(h) from marketing service providers or partners; or
(i) from various entities or divisions under Qi Xiang;
(j) by using Qi Xiang apps and websites, which includes all apps and websites operated by Qi Xiang and under the names of its respective brands (respectively “Apps” and “Websites”).
8. Your personal data may also be collected from cookies used on the Websites, and if you are a service provider, from your accelerometer data, GPS data and data collected when XINDOTS app is on.
Purposes of Processing
9. Qi Xiang may use and process your Personal Data for business and transportation, delivery and logistics (including food and beverage) and payment and financial services activities of Qi Xiang which shall include, without limitation the following (“Purposes”):
(a) where you are a customer of the services provided by Qi Xiang:
(i) to perform the Qi Xiang’s obligations in respect of any contract entered into with you;
(ii) to provide you with any service you have requested;
(iii) to process your subscriptions and to deliver the services to you;
(iv) where you have requested to download and use the XINDOTS App, or any other Qi Xiang applications, to process your request, to deliver the App to you and to provide you a license for the use of the App;
(v) to process and manage your rewards and loyalty points;
(vi) to process your participation in any events, activities, focus groups, research studies, contests, promotions, polls, surveys or any productions;
(vii) to process, manage or verify your application for subscription with the Qi Xiang and to provide you the benefits offered to subscribers;
(viii) to validate your bookings and process payments relating to any products or services you have requested;
(ix) to understand and analyse our sales as well as your needs and preferences;
(x) to develop, enhance and provide products and services to meet your needs;
(xi) to process exchanges or product returns;
(xii) providing to you the products and services that you have specifically requested; and
(b) where you are an agent, vendor, supplier, partner, contractor or service provider:
(i) for the purposes of engaging you to provide services or products;
(ii) to facilitate or enable any checks as may be required by Qi Xiang in order to engage you;
(iii) to process payments relating to any products or services you have provided;
(iv) to provide personalised feedback to you, so that you are able to identify specific areas for improvement;
(v) to assess safety and quality;
(vi) to contact you in relation to the provision of your services.
(c) generally for the following purposes:
(i) to respond to questions, comments and feedback from you;
(ii) to communicate with you for any of the purposes listed in this Policy;
(iii) providing you with alerts, newsletter, education materials or information that you requested or signed up to;
(iv) carrying out our obligations arising from any contracts entered into between you and Qi Xiang;
(v) designing and conducting surveys/questionnaires for client profiling/segmentation, statistical analysis, improving and furthering the provision our products and services;
(vi) providing third parties with statistical information about our users. Such statistical information may be used to personalise advertising on our website, but cannot be used to identify any individual user;
(vii) researching, designing and launching services or products including seminars/events/forums;
(viii) conducting market research and analysis;
(ix) processing any job application;
(x) shortlisting candidates for interviews;
(xi) for internal administrative purposes, such as auditing, data analysis, database records;
(xii) for purposes of detection, prevention and prosecution of crime;
(xiii) legal proceedings, including collecting overdue amounts and seeking professional advices;
(xiv) to maintain the safety and security of our services;
(xv) for Qi Xiang to comply with its obligations under law; and
(xvi) any purposes directly related or incidental to the above.
and you agree and consent to Qi Xiang using and processing your Personal Data for the Purposes and in the manner as identified in this Policy.
Marketing and promotional purposes
10. Qi Xiang may also use and process your data for other purposes such as (“Additional Purposes”):
(a) to send you alerts, newsletters, updates, mailers, promotional materials, special privileges, festive greetings from Qi Xiang, its partners, sponsors or advertisers;
(b) to notify and invite you to events or activities organized by Qi Xiang, its partners, sponsors or advertisers;
(c) To process your registration to participate in or attend an event or activity and to communicate with you regarding your attendance at the event or activity;
(d) to share your Personal Data amongst its subsidiaries, associate companies and jointly controlled entities as well as with its agent, vendor, supplier, partner, contractor or service provider who may communicate with you to market their products, services, events or promotions; and
(e) for direct marketing generally,
by way of post, telephone call, short message service (SMS), online messaging service, by hand and/or by email.
11. In respect of our use and processing of your Personal Data for direct marketing, please note that:
(a) your name, contact details (including address, contact number, email address), products and services information, transaction pattern and behaviour, background and demographic data held by Qi Xiang from time to time may be used by Qi Xiang in direct marketing;
(b) the following classes of services, products and subjects may be marketed in direct marketing:
(i) services and products related to Qi Xiang’s website and/or that of its affiliates (including marketing affiliates programs it is a part of);
(ii) reward, loyalty or privileges programmes, promotional offers and related services; and
(iii) invitations to events such as seminars/webinars/tele-seminars, conferences, live programs or events.
(c) Qi Xiang may conduct direct marketing via fax, email, direct mail, telephone and other means of communication or send e-newsletters to you. You may choose not to receive promotional materials, by simply telling Qi Xiang’s data protection officer.
12. Before Qi Xiang collects, uses or discloses your personal data, it will notify you of the purpose for the same and as far as possible, it will not collect more personal data than necessary for the stated purpose. Under certain circumstances, it may assume deemed consent from you when you voluntarily provide your personal data for stated purposes. If you interact and transact with Qi Xiang on behalf of another individual, you must first obtain consent from that individual in order for Qi Xiang to collect, use or disclose his or her personal data.
13. If you wish to unsubscribe to the processing of your Personal Data for Additional Purposes by Qi Xiang, please click on the link “Unsubscribe” which is embedded in the relevant email or message in order not to receive any such messages in the future. Please note that if you unsubscribe, we may still send you service-related messages, such as ride receipts.
14. If you wish to revoke the consent that Qi Xiang has obtained from you for the Purposes stipulated herein, please notify Qi Xiang using the contact details stated below.
15. Please be aware that upon your withdrawal of consent, Qi Xiang may not be able to provide you with services or access to its services and applications.
Transfer of Personal Data
16. Your Personal Data may be transferred to, stored, used and processed in a jurisdiction other than your home nation or otherwise in the country, state and city in which you are present while using any services provided by Qi Xiang (“Alternate Country”), to companies under Qi Xiang which are located outside of your home nation or Alternate Country and/or where Qi Xiang’s servers and/or service providers and partners are located outside of your home nation or Alternate Country. You understand and consent to the transfer of your Personal Data out of your home nation or Alternate Country as described herein.
Disclosure to Third Parties
17. Your personal data may be transferred, accessed or disclosed to third parties for the Purposes and Additional Purposes. Further, Qi Xiang may engage other companies, service providers or individuals to perform functions on its behalf, and consequently may provide access or disclose to your Personal Data to such service providers or third parties. The third parties include, without limitation:
(a) Qi Xiang partners, which include parties with whom Qi Xiang collaborates with for certain events, programs and activities;
(c) event management companies and event sponsors;
(d) marketing research companies;
(e) service providers, including, information technology (IT) service providers for infrastructure, software and development work;
(f) professional advisors and external auditors, including legal advisors, financial advisors and consultants, agents, financial institutions and service providers;
(g) persons to whom we are required to make disclosure under applicable laws and regulations in or outside Singapore;
(h) actual or proposed transferees or participants of our services in or outside Singapore;
(i) other entities within Qi Xiang;
(j) Qi Xiang’s overseas offices, affiliates, business partners and counterparts (if any); and
(k) governmental authorities to comply with statutory, regulatory and governmental requirements.
18. Your Personal Data may also be shared in connection with a corporate transaction, such as the formation of a joint venture, a sale of a subsidiary or a division, merger, consolidation, or asset sale, or in the unlikely event of winding-up.
Access & Correction Requests and Inquiries, Limiting the Processing of Personal Data
19. Subject to any exceptions under applicable laws of your home nation or Alternate Country, you have the right to:
(a) check whether Xi Qiang has any personal data relating to you and, if so, obtain copies of such data and information;
(b) find out how it has been using or disclosing your personal data; and
(c) require it to correct any personal data relating to you which is inaccurate for the purpose for which it is being used.
All requests should be sent and addressed to the data protection officer in the manner stated below.
20. You may also request to limit the processing of your Personal Data for the Additional Purposes and/or make any inquiries regarding your Personal Data.
21. To contact Qi Xiang’s data protection officer, please contact the following:
Data Protection Officer
Qi Xiang Technology Pte. Ltd.
2 Shenton Way,
#15-01 SGX Centre 1,
22. Subject to any laws of your home nation or Alternate Country, Qi Xiang reserves the right to impose a fee for access of your Personal Data in the amounts as permitted therein.
23. In respect of your right to access and/or correct your Personal Data, Qi Xiang has the right to refuse your requests to access and/or make any correction to your Personal Data for the reasons permitted under law, such as where the expense of providing access to you is disproportionate to the risks to your or another person’s privacy.
24. Cookies are used on Qi Xiang’s website and applications to distinguish you from other users. Cookies help to provide you with a better experience when you browse and to improve Qi Xiang’s services to you. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
25. The types of cookies Qi Xiang uses includes cookies that are required for its website, cookies which allows it to recognise and count the number of visitors and to see how visitors move around its website when they are using it, cookies used to recognise you when you return to its website, and cookies which record your visit to our website.
technology (“Cookies”) in connection with your use of the Websites and Apps. Cookies may have unique identifiers, and reside, among other places, on your computer or mobile device, in emails we send to you, and on our web pages. Cookies may transmit information about you and your use of the Service, such as your browser type, search preferences, IP address, data relating to advertisements that have been displayed to you or that you have clicked on, and the date and time of your use. Cookies may be persistent or stored only during an individual session.
28. Additionally, Qi Xiang may share non-personally identifiable information from or about you with third parties, such as location data, advertising identifiers, or a cryptographic hash of a common account identifier (such as an email address), to facilitate the display of targeted advertising.
29. You can manage the type of cookies that are allowed through your browser settings, including completely blocking all cookies if you so wish, though this may affect the quality of your browsing.
30. If you do not wish for your Personal Data to be collected via Cookies on the Websites, you may deactivate cookies by adjusting your internet browser settings to disable, block or deactivate cookies, by deleting your browsing history and clearing the cache from your internet browser. You may also be able to limit our sharing of some of this information through your mobile device
settings, or by submitting your details firstname.lastname@example.org.
Links to Third-Party Websites
Personal Information from Minors and Other Individuals
32. As a parent or legal guardian, please do not allow the minor (individuals under 18 (eighteen) years of age) under your care to submit Personal Data to Qi Xiang. In the event that such Personal Data is provided to Qi Xiang, you hereby consent to the processing of the minor’s Personal Data and personally accept and agree to be bound by this Policy and take responsibility for his or her actions.
33. In some circumstances you may have provided personal data relating to other individuals (such as your spouse, family members or friends) and in such circumstances you represent and warrant that you are authorized to provide their personal data to Qi Xiang and you have obtained their consent for their personal data be processed and used in the manner as set forth in this Policy.
34. To the extent that any of the communication means which you have provided us with (which may include your telephone number and fax number) is listed on the Do Not Call Registry, by agreeing to this Policy, by any means of indication, you hereby grant to us your clear and unambiguous consent to contact you using all of your communication means you have provided to us including using voice calls, SMS, Whatsapp, fax or other similar communications for the purposes stated herein.
35. Where Qi Xiang has given you (or where you have chosen) a password which enables you to access certain parts of its site and services, you are responsible for keeping this password confidential.
36. No data transmission or storage can be guaranteed to be full proof and secure in all circumstances. As such, please note that while Qi Xiang strives to protect your personal data, you provide your personal data at your own risk. Insofar as permitted by law, you agree not to hold Qi Xiang responsible for any breach of security while accessing the internet that is out of its control.
Successors and Assigns
37. This Policy shall inure to the benefit of Qi Xiang’s successors and assigns.
38. This Policy shall be governed in all respects by the laws of Singapore.
Acknowledgement, Consent, and Data Retention
39. By communicating with Qi Xiang, using Qi Xiang’s services, purchasing products from Qi Xiang or by virtue of your engagement with Qi Xiang, you acknowledge that you have read and understood this Policy and agree and consent to the use, processing and transfer of your Personal Data by Qi Xiang as described in this Policy.
40. Qi Xiang shall have the right to modify, update or amend the terms of this Policy at any time by placing the updated Policy on the Websites. By continuing to communicate with Qi Xiang, by continuing to use Qi Xiang’s services, purchasing products from Qi Xiang or by your continued engagement with Qi Xiang following the modifications, updates or amendments to this Policy, such actions shall signify your acceptance of such modifications, updates or amendments.
41. In the event of any conflict between the English and other language versions, the English version shall prevail.