PRIVACY POLICY

So Drama! Entertainment (“SDE”) respects your privacy. This Privacy Policy (“Policy”) informs you of how SDE manages the personal data collected and how the data will be processed in accordance with the Singapore Personal Data Protection Act 2012 (“PDPA”), its associated regulations and subsidiary legislation, and guidelines issued by the Singapore Personal Data Protection Commission (“PDPC”). This Policy applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.

What this Privacy Policy covers

If you are a SDE customer:

• This Privacy Policy covers our treatment of personal data that we may collect when you interact with us, submit information to us, access and/or use our products or services, including but not limited to all online and mobile websites, social media platforms, applications, radio stations, publications, music and/or drama services, and other digital services belonging to So Drama! Entertainment (collectively, the “SDE Services”).
• This policy does not apply to the practices of companies that we do not own or control, or to people that we do not employ or manage. SDE Services may contain links to other websites, social media platforms, applications and other services. Please note that we are not responsible for the privacy practices of such other websites, social media platforms, applications and other services and we advise you to read the privacy statements of such websites, social media platforms, applications and other services you visit which collects personal information.
• This Privacy Policy shall be read in conjunction with SDE's Terms and Conditions of Use, End User Licence Agreement, SDE Contest Rules, and any other policies, rules and regulations which SDE may impose from time to time (collectively referred to as the “Agreements”).

Information you give us

If you are a SDE customer:

• Depending on the products and services you use, we collect different kinds of personal information from or about you.
• We receive and store any information you enter or give us on all our online and mobile websites, social media platforms, applications, other digital services and/or through our radio stations or such other media as you may use to access any of the SDE Services. You can choose not to provide certain information, but then you might not be able to take advantage of many of our features available from the SDE Services. We use the information that you provide for such purposes as responding to your requests, customising future features for you, improving our services and communicating with you.
• We collect the personal information you provide, such as your name, username and email address when you use our products and services, create an account, contact us or participate in any online surveys, community discussions or chatrooms or otherwise interact with us. We also collect information about you when you create or share content, message or communicate with others using any of SDE Services.
• We also receive information from you when you participate in our contests which may be broadcast on our online and mobile websites, social media platforms, applications, other digital services platforms, or radio stations and/or participate in any events and/or roadshows organised by us, and if you choose not to provide any information, you may not be able to participate in such contests organised by us. Information collected by us for our contests and/or events would include, amongst other things, your personal information such as your name, address, identification number, contact number and email address. In addition, photographs, audio recordings and/or video recordings may be taken during such contests and/or events. You consent to us taking such audio and/or video recordings.
• If you make any purchase, the information we collect shall include but is not limited to your credit card and/or debit card number, other card information, other account and authentication information, personal banking details, billing, shipping and contact details.
• If you visit our online and mobile websites, social media platforms and/or access our applications and other digital services, or call into our radio stations, we may collect information about you, the type of device you use, your device’s unique identifier, the IP address of your device, your operating system, the type of internet browser that you use, usage information, diagnostic information, browsing information, session summary information, file attributes (including attributes for photos, videos, music and documents), and local information from or about the computers, phones, or other devices on which you install or access our products or services (as the case may be).
• We may gather all the above information automatically. Where available, our services may also use GPS, your IP address and other technologies to determine a device’s approximate location to allow us to improve our products and services.
• We may also collect information from third parties, including business partners and marketing agencies. This includes your contact information from marketing partners when we engage in joint marketing or co-branding activities, your IP address or location information from service providers to offer certain products and/or services relevant to your location, and data from your social networks to authenticate your product and/or services use with us, or that you grant permission to our products and/or services to access.

If you are a job applicant:

Personal data which we may collect includes, without limitation, your:

• Name or alias, gender, date of birth, nationality, and country and city of birth;
• Mailing address, telephone numbers, email address and other contact details;
• Resume, educational qualifications, professional qualifications and certifications and
• Employment references;
• Employment and training history;
• Work-related health issues and disabilities; and
• Photographs

If you are an SDE employee:

Personal data which we may collect in the context of your employment with us includes, without limitation, your:

• Name or alias, gender, NRIC/FIN or passport number, date of birth, nationality, and
• Country and city of birth;
• Mailing address, telephone numbers, email address and other contact details;
• Employment and training history;
• Salary information and bank account details;
• Details of your next-of-kin, spouse and other family members;
• Work-related health issues and disabilities;
• Records on leave of absence from work;
• Photographs and other audio-visual information;
• Performance assessments and disciplinary records; and
• Any additional information provided to us by you as a job applicant (that is, prior to being engaged as an employee).

Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context so permits).

What is the information used for?

If you are a SDE customer:

Your personal data will be collected, used, disclosed and/or processed by us or our agents for the following purposes:

• To send you notices, information, promotions and updates, including marketing and advertising materials in relation to our goods and services and those of third-party organisations selected by us.
• To allow you access to use SDE Services.
• To provide goods and services by us or by our designated representatives and/or business partners to you or to parties designated by you and matters ancillary thereto.
• To verify and process payment when you purchase goods and services from us.
• For verification and record of your personal particulars, including comparing it with information from other sources and using the information to communicate with you.
• To conduct statistical analysis of the users of the SDE Services, including the number of users, the frequency of use, profile of users and using such analysis for our business plans, the enhancement of our products and services, targeted advertisements and conveying such information in broad terms (but not information in relation to specific individuals) to third parties who have or propose to have business dealings with us.
• To comply with any request from any third party or any order of court or directive from authorities investigating any alleged offence, misdeeds and/or abuse or for the purposes of taking legal action against any users.

If you are a job applicant:

Your personal data will be collected and used by us for the following purposes, and we may disclose your personal data to third parties where necessary for the following purposes:

• Assessing and evaluating your suitability for employment in any current or prospective position within the organisation; and
• Verifying your identity and the accuracy of your personal details and other information provided.

If you are an employee:

Your personal data will be collected and used by us for the following purposes, and we may disclose your personal data to third parties where necessary for the following purposes:

• Performing obligations under or in connection with your contract of employment with us, including payment of remuneration and tax;
• All administrative and human resources related matters within our organisation, including administering payroll, granting access to our premises and computer systems, processing leave applications, administering your insurance and other benefits, processing your claims and expenses, investigating any acts or defaults (or suspected acts or defaults) and developing human resource policies.
• Managing and terminating our employment relationship with you, including monitoring your internet access and your use of our intranet email to investigate potential contraventions of our internal or external compliance regulations, and resolving any employment related grievances;
• Assessing and evaluating your suitability for employment/appointment or continued employment/appointment in any position within our organisation;
• Ensuring business continuity for our organisation in the event that your employment with us is or will be terminated;
• Performing obligations under or in connection with the provision of our goods or services to our clients;
• Facilitating any proposed or confirmed merger, acquisition or business asset transaction involving any part of our organisation, or corporate restructuring process; and
• Facilitating our compliance with any laws, customs and regulations which may be applicable to us.

We may use or disclose your personal data under the “Exceptions to Consent” according to the Amendment Act 2020 for the following:

• Legitimate interest for the purpose of detecting or preventing illegal activities (e.g., fraud or money laundering) or threats to physical safety and security, ensuring IT and network security, or preventing the misuse of services.
• Business improvement where there is a need to:
  • Carry out operational efficiency and service improvements;
  • Develop or enhance products/services; or
  • Know more about the organisation's customers
• Research - it applies to institutes carrying out scientific research and development, or arts and social science research, or to market research aimed at understanding potential customer segments.

The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).

Can you opt out?

• Whenever we send you any marketing information, we will endeavour to include instructions on how to unsubscribe.
• Be that as it may, in the event that you wish to opt out from, and/or discontinue the collection, use, disclosure, processing of your personal data, and/or delete your personal data by us for any of the above purposes, you may also write in to us at dpo@sodrama.sg to inform us.
• Thereafter the withdrawal, SDE will cease (and cause personal data that are in the possession and/or control of third-party organisations and data processors engaged by it to cease) collecting, using or disclosing these personal data unless it is required or authorised under applicable laws.
• An acknowledgement email will be sent within fourteen (14) days upon receipt of your email to inform you of the consequence of your request for the withdrawal of consent, and we shall process your request within one (1) month upon receipt of your email.
• Your choice to withdraw consent for collection, use, disclosure, processing and/or storage of your personal data may hinder your ability to continue using SDE services and future interactions with SDE.

Can you access or correct your personal data?

If you are a SDE customer:

• You may update your personal information at any time by accessing your registered account(s) with us or by writing in to us at dpo@sodrama.sg to inform us of the same.
• Please note that a reasonable fee may be charged for an access request if request is comprehensive and required extensive manual effort. If so, we will inform you of the fee before processing your request.
• We will respond to your access request as soon as reasonably possible. Should we not be able to respond to your access request within thirty (30) days after receiving your access request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).
• Please note that depending on the request that is being made, we will only need to provide you with access to the personal data contained in the documents requested, and not to the entire documents themselves. In those cases, it may be appropriate for us to simply provide you with confirmation of the personal data that our organisation has on record, if the record of your personal data forms a negligible part of the document.

If you are an employee:

If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold, you may submit your request in writing or via email to our HR department. Alternatively, you may also submit your request to Data Protection Officer at the contact details provided above.

Will your personal information be shared with anyone?

• We will not sell or rent your personal information to anyone.
• We will only share your personal details with a third party for the purposes and situations as described above, or for other purposes where we have your consent to do so.
• For the avoidance of doubt, you consent to:
  • SDE collecting, using, disclosing and/or processing your personal data for the purposes and situations as described above;
  • SDE transferring your personal data out of Singapore to SDE’s third party service providers or agents for the purposes and situations as described above.
  • You acknowledge and agree that when you share and communicate using any of SDE Services, such as our social media platforms and Mobile App, you may be sharing and/or publicising personal information about yourself, and such information may be viewed by anyone (whether such person has an account and/or utilises any of SDE Services). You further acknowledge that such people who may have access to the personal information you shared can choose to share it with others on any of SDE Services or on any other platforms available publicly. In addition, whenever you comment or react to anybody's post or message, your comment or reaction may be visible to others.

Third-Party Services and YouTube API Usage

• SDE Services may contain links to other websites, social media platforms operated by third parties. You agree that we are not responsible for the privacy practices of websites operated by third parties that are linked to our website/s, social media platforms or other digital platforms.
• Our application integrates with third-party platforms, including YouTube, through the use of their APIs. By using any features of our services that involve YouTube content, you acknowledge and agree to be bound by the YouTube Terms of Service.
• For more information on how YouTube handles your data, please refer to the Google Privacy Policy.

How is your data protected?

If you are a SDE customer:

To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us. No other party, including SDE's employees, can change the information. However, you must remember to log off from your registered account and close the requisite application/s after use so that no unauthorised party can have access. You are responsible for the safe keeping of your password. You must not, at any time, disclose your password to any third party, including SDE's employees and/or representatives and/or contractors. We will not be responsible, and you agree that we cannot be held liable for any losses or damage incurred by you whatsoever caused by your non-compliance to any of the foregoing. All information gathered by SDE is stored in systems that may only be accessed by authorised SDE's staff using assigned user ids and passwords. In certain areas, SDE uses industry-standard SSL-encryption to protect data transmissions.

If you are an employee:

• Disclosing personal data both internally and to our authorised third-party service providers and agents only on a need-to-know basis.
• You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
• We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing the HR Department or our Data Protection Officer in writing or via email at the contact details provided below.

Retention of Personal Data

• We may retain your personal data for as long as it is necessary to fulfil the purposes for which they were collected, or as required or permitted by applicable laws.
• We will cease to retain your personal data or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purposes for which the personal data were collected and are no longer necessary for legal or business purposes.

Transfers of Personal Data Outside of Singapore

We generally do not transfer your personal data to countries outside of Singapore, except in accordance with the requirements prescribed under the PDPA. Where such transfers are necessary, we take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.

Changes to this Privacy Policy

• SDE may in its own discretion amend this policy from time to time. If we make any substantial changes in the way we use your personal information, we will notify you by posting an announcement on our online media platforms. You agree that such posting will constitute sufficient and adequate notice to you of the changes. You agree that your continued use of our products and services after such amendment will constitute your acceptance of and agreement to be bound by the modified policy.
• If you choose not to or do not want to receive our terms and conditions and/or other legal notices from us, such as this Privacy Policy, those notices will still govern your use of So Drama! Entertainment services, and it is your responsibility to review them for changes.

Use of Cookies, Web Beacons and Other User and Ad-targeting Technologies

When you access, use and/or interact with the SDE Services, we or our authorised service providers may use “cookies”, “web beacons” and other tracking technologies where small data files are sent to the app and/or browser, application or device to store and track information about you. The cookies, web beacons and other tracking technologies are used to track information such as the number of users and their frequency of use, online behavioural data, profiles of users and their preferred sites. They enable our own system to recognise you when you visit us again, enhance your web-viewing experience and allow for more effective online targeted advertising. You may accept or decline cookies by modifying the settings in the app and/or browser, application or device, if the app and/or browser, application or device so permits. However, please note that you may not be able to use all interactive features on the SDE Services if cookies have been disabled completely. While the cookie can tell us when you interact with the SDE Services and which pages you visit, it cannot access other data including from your computer or storage device and it does not contain information intended to identify you personally. SDE does not utilise persistent cookies to track, or target advertisements to, persons who are resident in the European Union.

Release

This policy is subject to any existing laws of the Republic of Singapore in relation to the protection of information and if required by any lawful authority for any legal purposes such as the enforcement of any laws or to prevent the breaching of any laws, we shall release all such information as is legally required by the requisite and lawful authority in accordance with the directions of the lawful court of the competent jurisdiction.

Contact

So Drama! Entertainment
If you would like to request access to your personal data held by us, or you would like to contact us for any reason regarding our privacy policy or practices, please contact our Data Protection Officer at:

21 Media Circle, #05-12
Singapore 138562
(Attention: Data Protection Officer)

Email: dpo@sodrama.sg