Effective Date: 24 April 2025
2.1. Identifiers: We may collect personal identifiers such as your name, email address, postal address, phone number, and unique online identifiers (e.g., IP address, device ID, cookie ID).
2.2. Commercial Information: We may collect records of the products or services you have purchased, obtained, or considered, as well as your purchasing or consuming histories or tendencies.
2.3. Internet or Electronic Network Activity: We may collect information about your browsing history, search history, and interactions with the Website or our online advertisements.
2.4. Geolocation Data: We may collect precise location data from your device, such as GPS coordinates, when you use certain features of the Website.
2.5. Inferences: We may create profiles about you by inferring preferences, characteristics, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes from the personal data we collect.
3.1. Directly from You: We collect personal data when you voluntarily provide it to us, such as when you complete a contact form or contact our customer support.
3.2. Automatically: We may collect certain personal data automatically through the use of cookies, web beacons, and other tracking technologies when you use the Website.
3.3. From Third Parties: We may collect personal data from third-party sources, such as service providers, data brokers, and social media platforms, with your consent or as permitted by the applicable laws and regulations.
4.1. To Provide and Improve Our Services: We use your personal data to deliver the products and services you request, process transactions, and enhance the user experience on the Website.
4.2. For Marketing and Advertising: We may use your personal data to send you marketing communications, personalize your experience, and display targeted advertisements, in accordance with the requirements of the applicable regulations. You have the right to opt-out of such communications at any time.
4.3. For Research and Development: We may use your personal data to analyze trends, track website usage, and improve our products, services, and operations.
4.4. To Comply with Legal Obligations: We may use your personal data to comply with applicable laws, regulations, and legal processes, as well as to protect our rights, property, or the safety of our users, employees, or others.
5.1. We process your personal data on the following legal bases:
6.1. Within YY Group: We may share your personal data with our affiliates and subsidiaries within the YY Group, as permitted by the applicable privacy and data protection laws. Such sharing is governed by intra-group data transfer agreements that ensure appropriate safeguards for your personal data.
6.2. With Service Providers: We may share your personal data with third-party service providers who perform services on our behalf, such as payment processors, web hosting providers, and analytics providers. These service providers are contractually obligated to protect the confidentiality and security of your personal data and may only use it for the specific purposes we prescribe.
6.3. With Third Parties: We may share your personal data with third parties for marketing, advertising, and other business purposes, as permitted by applicable regulations in Singapore. We will obtain your consent where required by law before sharing your personal data for these purposes.
6.4. With Law Enforcement and Legal Authorities: We may disclose your personal data to law enforcement, government agencies, or other third parties as required by applicable law or in response to legal process, such as a court order or subpoena.
7.1. We may transfer your personal data to recipients in other countries or jurisdictions. When we transfer personal data outside of Singapore, we ensure that appropriate safeguards are in place to protect your personal data, such as standard contractual clauses approved by the relevant authorities or binding corporate rules.
7.2. By using our Website and services, you acknowledge and consent to the transfer of your personal data to countries or jurisdictions that may not provide the same level of data protection as your home jurisdiction.
8.1. Access and Correction: You have the right to access and correct your personal data held by us. To exercise this right, please submit a written request to dpo@hongyegroup.com.sg or dpo@yycircle.com with the subject line “Personal Data Access/Correction Request.” We will respond to your request as required by Singaporean law.
8.2. Deletion: You have the right to request the deletion of your personal data, subject to certain exceptions under applicable laws. To submit a deletion request, please contact us at dpo@hongyegroup.com.sg or dpo@yycircle.com with the subject line “Personal Data Deletion Request.” We will process your request within 30 days, unless a longer period is required by law.
8.3. Opt-Out of Marketing: You can opt-out of receiving marketing communications from us at any time by:
8.4. Objection to Processing: You have the right to object to the processing of your personal data for certain purposes, such as direct marketing or profiling, in accordance with the applicable laws and regulations. To exercise this right, please contact us at dpo@hongyegroup.com.sg or dpo@yycircle.com with the subject line “Objection to Processing.”
8.5. Data Portability: You have the right to request a copy of your personal data in a structured, commonly used, and machine-readable format, subject to the requirements of the applicable laws and regulations. To exercise this right, please contact us at dpo@hongyegroup.com.sg or dpo@yycircle.com with the subject line “Data Portability Request.”
8.6. Withdrawal of Consent: Where we process your personal data based on your consent, you have the right to withdraw that consent at any time. To withdraw your consent, please contact us at dpo@hongyegroup.com.sg or dpo@yycircle.com with the subject line “Consent Withdrawal.”
9.1. Security Measures: We implement appropriate technical and organizational measures, in accordance with industry standards and the requirements of the applicable laws and regulations, to protect your personal data from unauthorized access, use, disclosure, alteration, or destruction. These measures include, but are not limited to:
9.2. Data Retention: We will retain your personal data for as long as necessary to fulfill the purposes for which it was collected, or as required by the applicable laws and regulations in Singapore. The specific retention periods for different types of personal data are as follows:
9.3. When personal data is no longer necessary for the purposes for which it was collected, we will securely delete or anonymize it in accordance with our data retention policies and applicable laws.
11.1. We may update this Policy from time to time to reflect changes in our practices, applicable laws, or regulatory requirements. We will post any updates on the Website and indicate the effective date of the changes.
11.2. We encourage you to review this Policy periodically to stay informed about our data protection practices. Your continued use of the Website after any changes to this Policy constitutes your acceptance of the updated Policy.
12.1. If you have any complaints or disputes regarding our processing of your personal data, please contact us first at dpo@hongyegroup.com.sg or dpo@yycircle.com with the subject line “Privacy Complaint.” We will investigate and attempt to resolve any complaints or disputes internally.
12.2. If you are not satisfied with our response, you have the right to lodge a complaint with the relevant data protection authority:
13.1. While we take reasonable precautions to protect your personal data, no method of transmission over the Internet or electronic storage is 100% secure. Therefore, we cannot guarantee absolute security of your personal data.
13.2. To the fullest extent permitted by applicable law, we shall not be liable for any direct, indirect, incidental, special, or consequential damages resulting from the use or inability to use our Website or services, or from any unauthorized access to or use of your personal data, except to the extent that such liability cannot be excluded by law.
14.1. If you have any questions, concerns, or requests regarding this Policy or the processing of your personal data, please contact our Data Protection Officer at:
YY Group Holding Ltd.
Attn: Data Protection Officer
60 Paya Lebar Road, #09-13 to 17 Paya Lebar Square, S409051
Email: dpo@hongyegroup.com.sg | dpo@yycircle.com
Phone: +65 6604 6896 | +65 6604 6919
14.2. We will respond to your inquiry within 30 days or as required by applicable law.
This Privacy and Data Protection Policy was last updated on May 2, 2025
By using our Website and services, you acknowledge that you have read and understood this Privacy and Data Protection Policy and agree to the collection, use, and disclosure of your personal data as described herein.
