Privacy Policy

1. Introduction

At Food Empire Holdings Limited (“Food Empire”), we respect the privacy and confidentiality of personal data and we are committed to protecting your privacy and safeguarding your personal data.

Our Privacy Statement covers
● How We Collect Your Personal Data
● Types of Personal Data We Collect About You
● How We Use Your Personal Data
● Who We Disclose Your Personal Data To
● How We Manage the Collection, Use and Disclosure of Your Personal Data
● How You Can Access and Make Correction to Your Personal Data
● How We Ensure the Accuracy of Your Personal Data
● How We Protect Your Personal Data
● How We Retain Your Personal Data
● How We Transfer Your Personal Data
● How We Handle Queries and Complaints

In doing so, our Privacy Statement has set out the choices that you can make about Food Empire’s use of your personal information and how you can make informed decisions about what personal data you would like to share with us.

Food Empire may, in our sole discretion, permit users of our website to post, upload, publish, submit or transmit content, which may include but is not limited to photos, write-ups, videos or links (“User Content”).

2. How We Collect Your Personal Data

We collect your personal data in the following ways:
● When you respond to events, surveys or campaigns
● When you provide feedback to us on our quality of service or your user experience
● When you communicate with us online, via email or written correspondence
● When you submit your Curriculum Vitae and job application form or provide any other information to us in response to our advertisements or through recruitment firms or job portals
● When you visit our physical premises or websites or social media platforms and leave behind your contact information
● When you are within our premises and your images are being captured via CCTV
● When you attend our annual general meetings
● When we prepare for personal income tax filing
● When we are processing your payments, credit notes and refunds
● When we are performing functions such as billing, accounting, auditing and the maintenance of proper book-keeping of Food Empire’s operations.

3. Types of Personal Data We Collect About You

The types of personal data we collect about you may include:
● Your personal information (such as name, date of birth, citizenship), contact information (such as address, email address and mobile phone number), bank account and shareholding details and other information necessary to manage your shareholding with us and to fulfill your other requests
● Your personal government-issued identification document numbers such as NRIC/FIN/work permit/birth certificate and passport numbers; as required by law (such as those applicable to public listed companies) or necessary to accurately establish or verify your identity to a high degree of fidelity
● Other personal details (where relevant) when applying for an intern or employee position such as work experience and academic history and other relevant information in the Curriculum Vitae
Food Empire may also collect non-personally identifiable information about you, such as use of our website, internet protocol addresses, browser and computer system information, cookies, invisible pixels, web beacons, and aggregated data related to your use of our website.

4. How We Use Your Personal Data

We use the personal data we have collected about you for one or more of the following purposes:
● Marketing and promotion activities
● Communicate with enquirers and analyse website visitors
● Respond to enquiries, update requests and feedback on user experience
● Monitor the movement of visitors to our physical premises for safety and/or security purposes
● Facilitate your attendance at our Annual General Meetings
● Process job applications and selection
● Process billing, claims, payment, disbursements and other credit-related activities
● Carry out our obligations arising from any contracts entered into between you and us
● Comply with legal obligations and regulatory requirements

5. Who We Disclose Your Personal Data To

We disclose some of the personal data we have collected about you to the following parties or organisations outside Food Empire:
● Government Agencies & Regulatory Authorities such as Ministry of Manpower, Central Provident Fund
● Providers of Professional Services such as Share Registrars, Auditors, Lawyers, Consultants, Company Secretaries
● Banks, Payment Card Processing Companies and other Financial Institutions
● Data Processing and Hosting Companies such as IT Service Providers, Webhosting Companies and Cloud Service Providers
● Recruitment Agencies / Headhunters
● Providers of Goods or Services such as Freight and Courier Services

We will use our best endeavours to ensure that your personal data is protected by such third parties.

6. How We Manage the Collection, Use and Disclosure of Your Personal Data

6.1 Obtaining Consent

Before we collect, use or disclose your personal data, we will notify you of the purpose why we are doing so. We next obtain written confirmation from you on your expressed consent. As far as possible, we will not collect more personal data than necessary for the stated purposes within this notice.

Under certain circumstances, we may assume deemed consent from you when you voluntarily provide your personal data for the stated purpose, e.g. when you request information from us

6.2 Third-Party Consent
If you do a transaction with us on behalf of another individual, you must first obtain consent from that individual in order for us to collect, use or disclose their personal data. Where consent can be obtained, that individual must be notified of the purposes for the collection, use or disclosure of their personal data.

6.3 Withdrawal of Consent

If you wish to withdraw consent, you should give us reasonable advance notice. You have to be aware, though, of the likely consequences of your withdrawal of consent, e.g. without your personal contact information, we may not be able to inform you of future services offered by us or our clients.
Your request for withdrawal of consent can take the form of an email or letter to us, or through the “UNSUB” feature on an online service.

7. How You Can Access and Make Correction to Your Personal Data

You may write in to us to find out what personal data about you we have in our possession or under our control and how it may have been used and/or disclosed by us in the past one year. You may also ask us to correct it if there is any error or omission. Before we accede to your request, we may need to verify your identity.

We will endeavor to fulfill your request within 30 days, with an estimate of the fee for processing the request (if applicable). If we are not able to do so within 30 days, we will notify you of the additional time required.

8. How We Ensure the Accuracy of Your Personal Data

We will take reasonable precautions and verification checks to ensure that the personal data we have collected from you is reasonably accurate, complete and up-to-date.

9. How We Protect Your Personal Data

We will take the necessary security arrangements to protect your personal data that is in our possession to prevent unauthorised access, use, disclosure, or similar risks. We will take reasonable and appropriate measures to maintain the confidentiality and integrity of your personal data, and will only share your data with authorised persons on a ‘need to know’ basis.

External Data Intermediaries who process and maintain your personal data on our behalf will be bound by contractual information security arrangements that we have with them.

10. How We Retain Your Personal Data

We will not retain any of your personal data under our charge when it is no longer necessary for any business or legal purposes. Based on our Document Retention Policy, we will ensure that your personal data that are no longer needed by us will be destroyed or disposed of in a secure manner.

11. How We Transfer Your Personal Data

If there is a need for us to transfer your personal data to another organization outside of Singapore (such as to other subsidiaries and associates within the Food Empire Group), we will ensure that the standard of data protection in the recipient country is comparable to that of Singapore’s PDPA. If this is not so, we will enter into a contractual agreement with the receiving party to accord similar levels of data protection as that in Singapore.

12. Compliance with Laws
Where required to do so by law, we will disclose personal data about you to the relevant authorities or to law enforcement agencies.

13. Links to Other Sites
Our website may contain links to other websites that are not operated by us. If you click on a third party link, you will be directed to that third party’s website. It is important that you review the Privacy Policy of every site you visit. We have no control over, and are unable to assume any responsibility for, the content, privacy policies or practices of any third party sites or services
14. Changes to this Data Protection Policy

We may update our Data Protection Policy from time to time. We will notify you of any changes by posting the policy on this page. Please revisit this page periodically for any changes. Changes to this Policy are effective when they are posted on this page.
15. Contacting Us
If you have any questions about our collection, use, and/or disclosure of personal data about you; feedback regarding this Policy, or any complaint you have relating to how we collect, use, disclose and store personal data about you, you may contact our Data Protection Officer(s) at dpo@foodempire.com.
Any query or complaint should include, at least, the following details:
● Your full name and contact information
● A brief description of your query or complaint
We treat such queries and complaints seriously and will deal with them confidentially and within reasonable time.

16. Review and Revision

This External Data Protection Policy will be reviewed as it is deemed appropriate, but no less frequently than every 12 months.

The review will be undertaken by the DPO together with the PDP Committee.