PDPA

At Vault@268 Pte. Ltd. (our “Company”, “we” or “us”), our fundamental philosophy is “members first”.  Our value of putting our clients’ needs as our topmost priority powers all of the decisions we make, including how we gather and respect your personal information...

We have crafted this Privacy Policy (“Privacy Policy”) to be as clear and straightforward as possible.  Our aim is for you – our clients – to always feel informed and empowered with respect to your privacy at Vault@268 Pte Ltd.

Your privacy is very important to us and we fully respect, and will therefore protect, your personal data and your online privacy.  We have set out in details our personal data protection protocols herein this Privacy Policy in order for you to understand how we collect, use, communicate, disclose and make use of personal information.  We are committed to conducting our business in accordance with these principles, and consistent with the Personal Data Protection Act 2012 (“PDPA”), in order to ensure that the confidentiality of Personal Data is protected and maintained.

Please note that your access and use of our website www.vault268.com.sg (our "Site") is subject to our  Terms of Use as well as the terms and conditions as set out herein this Privacy Policy.  Accordingly, by accessing our Site, you are agreeing to our collection and use of your information pursuant to this Privacy Policy.  Should you disagree with any provision in our Terms of Use and/or this Privacy Policy, please immediately cease your access to our Site.

For expediency and compliance with any changes in the law, we reserve the right to amend at any time this Privacy Policy and our Terms of Use.  We may notify you of such changes, but we are not obligated to do so.  Accordingly, you agree that your continued access of our Site and/or our Services (defined below) constitutes your unconditional acceptance of our amended Privacy Policy.  You agree that it is your sole responsibility to keep yourself updated of any amendments by reviewing this Privacy Policy at www.vault268.com.sg regularly.

  1. 1) Collection of Information

We collect information that can, whether on its own or in conjunction with other information, be used to identify an individual (“Personal Data”).  The Personal Data that we collect will generally include: -

  • Name;
  • Gender;
  • Age / Birthday;
  • NRIC Number / FIN Number / Passport Number;
  • Mobile Number;
  • Other Contactable phone number(s);
  • Email Address (es);
  • Residential Address;
  • Business Address;
  • Bank account details;
  • Credit card details;
  • Debit card details;
  • Personal preferences in relation to being contacted by our Company; and/or
  • Other relevant information required for our Company to serve you better.

As you would be aware, our Company is in the business of providing secure depositories for your valuables and other ancillary services (whether through third parties or our Company), such ancillary services include but is not limited to insurance for your valuables and our Client Portal (collectively, our “Services”).  Accordingly, your Personal Data is required in order for us to ensure that your valuables are well-protected and that you receive the high-level security and service that you deserve.  You further understand and agree that in order for us to provide you with our Services, the Personal Data that you provide to us must be accurate, and that all Personal Data as may be relevant for that particular purpose/circumstance must be provided (for example, in order to implement security measures in relation to the access of your valuables, we must necessarily possess copies of your identification documents). 

The Personal Data which we collect from you is therefore Personal Data voluntarily provided by you to our Company, Personal Data that is relevant for the provision of our Services to you, or for you to obtain more information regarding our Services (at your request).  Your Personal Data may have also been provided to us by a third-party (authorised individual and/or organization) on your behalf, in which case you have the responsibility to ensure that such third-party has been duly authorised by you, and you therefore agree that it is reasonable for us to deem that such Personal Data provided to us through a third-party has been given to us with your permission and consent for the purposes of you enjoying our Services and/or your receiving information/updates regarding our Services.  Your Personal Data might have been submitted to our Company via our Website, application forms, request forms, agreement, quotation, proposals, invoices and/or emails for the purpose of your utilizing our Services or to receive information/updates regarding our Services (the “Purposes”).

  • 2) Use of Information

The Personal Data collected, used, disclosed, retained and transferred by us is pursuant to the Purposes only, unless you have given us your permission to use your Personal Data in another manner, for example to add you to one of our mailing lists for information on promotions not related to our Services.  Personal Data collected will be used pursuant to the Purposes in the following manner:-

2a            Considering and/or assessing your application or request for our Services.

2b            Processing your application for our Services.

2c            Processing your application or request for any transactions with us.

2d           Fulfilling specific request(s) from you, including responding to your queries or comments on our products and services, or carrying out your instructions.

2e           To provide you business services through our Client Portal located at www.vault.268.sg, managing marketing campaigns, sending of e-mailers, sending of invitation cards and/or promotional material through mail or email, management of sales and enquiries, organising and managing workshops and other activities pursuant to or related to our Services.

2f            To allow a business partner or third party service provider to contact you where you have requested for us to assist you in obtaining ancillary Services such as insurance for your valuables.

2g           Evaluation of applications for employment, participation in charitable activities, sponsorships, donations, and/or scholarships.

2h           Performing due diligence checks including identity verification or screening activities pursuant to our Services and/or in accordance with legal or regulatory obligations.

2i         For the receipt of professional advice and/or the maintenance of our records in accordance with legal requirements, such professional advice and/or maintenance of our records being performed by our third party book-keepers, accounting firms, audit firms, law firms and/or other professional advisory firms. 

2j            Disclosure to governmental, regulatory or law enforcement bodies who have a legal right to demand for your Personal Data.

2k          Conducting research, analysis and development activities to improve our services and facilities in order to enhance your relationship with us, for which we may engage the services of a data intermediary subject to such data intermediary being bound by contractual or legal obligations to protect the confidentiality and security of your Personal Data.

2l         Providing and/or transferring Personal Data to our affiliated or related companies, business partners, and/or third party service providers (collectively “Third Service Providers”), such Third Party Service Providers being necessary for your continued use of our Services and our Site.  The aforesaid Third Party Service Providers provide necessary services such as administration, storing, hosting, backing up (whether for disaster recovery or otherwise) of your Personal Data, maintenance of our Site, maintenance of our Client Portal, assisting us to send you updates on our Services, mass mailing, ancillary or related services to our Services, etc.  Where such Third Party Service Providers are located outside of Singapore, any transfer of Personal Data outside of Singapore to such Third Party Service Providers shall be subject to such Third Party Service Providers being contractually or legally obligated to protect Personal Data pursuant to obligations similar to/comparable with the requirements of the PDPA.

2m          Disclosure and/or transfer of Persona Data to our affiliated or related companies and/or third parties to whom we may sell, divest, transfer, assign, share or otherwise engage in a transaction that involves, some or all of our Company’s assets (which may include your Personal Data), in the course of a corporate divestiture, corporate restructuring, merger, acquisition, joint venture, bankruptcy, dissolution, reorganisation, or any other similar transaction or proceeding.

For the avoidance of doubt, we require that our Third Party Service Providers adhere strictly to equal or higher level of Personal Data protection and non-disclosure as us.

Web Cookies / Tracking Technology

A cookie is a small file that asks permission to be placed on your computer's hard drive.  Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site.  Cookies allow web applications to respond to you as an individual.  The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

We use traffic log cookies to identify which pages are being used.  This helps us to analyse data about webpage traffic and improve our Site in order to tailor it to your needs.  This automatic collection of non-personal information includes (without limitation) collection of your IP address, the web browser software that you used, the specific pages of our Site viewed by you, and third party websites that you may have visited prior to our Site.  We only use the aforesaid information for statistical analysis purposes, to enhance your experience of our Site, and then the data is removed from the system.

Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not.  A cookie in no way gives us access to your computer or any Personal Data about you, other than the data you choose to share with us.

You can choose to accept or decline cookies.  Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer.  This may prevent you from taking full advantage of our Site.

  • 3) Retention of Personal Data

We will retain your Personal Data for the duration that is necessary for us to:-

  • provide our Services to you;
  • fulfil our contractual obligations to you;
  • provide our services and information to you pursuant to any ongoing relationship between us;
  • send you updates on our Services;
  • send you information and/or updates on any other matters (including marketing materials not related to our Services) if you have so requested it of us and have not revoked your request or consent; and
  • comply with applicable laws and regulations, assist in any legal investigations, meet the demands from any regulatory or law enforcement bodies, for utilization in legal proceedings, minimizing fraud, collection of debts, resolving disputes, identifying issues, enforcing contractual breaches and/or claiming for damages.

Thereafter when no more legitimate business or legal purposes exist for retention of your Personal Data, we shall destroy or anonymize your Personal Data.

For the avoidance of doubt, Personal Data collected from applicants for employment, participation in charitable activities, sponsorships, donations, and/or scholarship, shall be retained for up to seven (7) years for the purpose of meeting any regulatory and legal obligations, unless the applicant has informed us otherwise.

  • 4) Links to other websites

Our Site may contain links to other third parties’ websites (“Third Party Sites”) that may be of interest to you.  However, once you have used these links to leave our Site, you should note that we do not have any control over the Third Party Sites.  Therefore, we cannot be responsible for the protection and privacy of any information that you provide whilst visiting such Third Party Sites, and this Privacy Policy does not govern such Third Party Sites.  You should exercise caution and review the privacy policy applicable to the Third Party Site before you access, use or disclose any information to such Third Party Site.  We seek your understanding that we are not liable for any acts or omissions or any loss or damage that you may suffer due to your use or access of any Third Party Sites.

  • 5) Disclosure, Sharing and Distribution of Information

We will not sell, distribute, rent or lease your Personal Data to another party other than pursuant to the provisions of this Privacy Policy or where you have given us your specific consent to sell, distribute, rent or lease your Personal Data to such other party.

We may use your Personal Data to send you promotional information about third parties’ products or services, which we think you may find interesting if you tell us that you wish this to happen.  If we require your Personal Data for other purposes than what was consented by you and pursuant to this Privacy Policy, we will seek your permission (by phone, email or in writing) before commencement.

If you believe that any Personal Data of yours in our possession is incorrect or incomplete, please download the Forms from www.vault268.com.sg (refer to section 7 of this Privacy Policy).  We will promptly correct any information found to be incorrect.

  • 6) Commitment to Data Security

To make sure your Personal Data is securely protected, we communicate our privacy policies and security guidelines to all our employees and strictly enforce privacy safeguards within our Company.

We ensure that our Site is protected by reasonable security measures afforded by current technology, and that all our data hosts and servers are similarly protected by such security measures, including but not limited to firewalls.

Your Personal Data is also encrypted and kept secure against unauthorised access.  Only authorised employees and agents (who have agreed to keep your Personal secure and confidential) have access to your Personal Data on a need-to-know basis.

  • 7) Privacy Contact Information

When you contact our Client Support services at vault@268.com.sg or Data Protection Officer at dpo.vault@268.com.sg, we will collect information that helps categorise your question, respond and, if applicable, investigate any breach of this Privacy Policy.  We also use this information to track potential problems and trends and customise our support responses to better serve you.

We take reasonable measures to ensure that your Personal Data is accurate and complete.  Therefore if there is any change or update in your information, we would like to be updated.

If you would like to update your Personal Data with us, you can do so through your account at our Client Portal. However,  if you do not wish to or are unable to update your Personal Data through our Client Portal, or should you have any questions, concerns, or comments about our Privacy Policy, you may contact our Personal Data Protection Officer at dpo.vault@268.com.sg or 6737 7268.

For identification purposes, please provide us with the following details when you contact us:

  • Your name,
  • Email address or mailing address
  • Contact number
  • Nature of relation between us
  • The information to be changed and/or updated.

If you are an applicant for employment, internship, attachment, and/or scholarship and would like to update your Personal Data or you would like us to remove your personal information for future openings, please contact us at our website/Email:

All requests shall be performed as soon as is reasonably practicable, and in any event within thirty (30) days of receiving such requests, unless there are complications for which we may need to liaise further with you before we can act on such requests.  We may contact you if we require further clarifications, supporting documents and/or when your request is fulfilled.

  • 8) Withdrawal of Consent

We respect your selections in relation to the channels via which you wish to receive any information from us in relation to our Services or other marketing materials.  Therefore, if you have registered your telephone and/or fax number with the Do-Not-Call Registries in relation to telephone calls, text or fax messages, we will not contact you via the channels that you have opted out of by registering with the Do-Not-Call Registries.  However, if you have previously consented to our sending you information in relation to our Services and other marketing materials via your telephone number (calls or text messages) and/or facsimile number, we will continue doing so until you withdraw your consent by contacting our Data Protection Officer at dpo.vault@268.com.sg or 6737 7268.

For the avoidance of doubt, this Privacy Policy supplements but does not supersede any earlier consent(s) that you have provided to us previously, nor does it supersede any rights that is granted by the law in relation to our collection, use, disclosure and/or transfer of your Personal Data.  The Personal Data for which you have provided to us previously prior to 2nd January 2014 shall continue to be used for the purposes for which you provided such Personal Data to us previously.

You may at any time withdraw your consent to our use, retention, disclosure of transfer of your Personal Data pursuant to this Privacy Policy by calling our Data Protection Officer at 6737 7268 or emailing her at dpo.vault@268.com.sg.  However, please note that any such withdrawal of consent may result in us being unable to continue providing our Services or fulfilling our contractual obligations to you.  Accordingly, your withdrawal of consent may also lead to the termination of any contract(s) that you may have with our Company, for which our Company expressly reserves its rights and remedies thereto.  Our Data Protection Officer will further advise you on the legal consequences that may ensue should you contact her/him to withdraw your consent.

  • 9) Personal Data of Minors

Our Site and our Services are not meant for persons who may be defined as minors under applicable law.  We do not knowingly collect Personal Data from minors, however, through the internet, we are not able to ascertain on our end whether such individuals are minors.  It is thus the responsibility of parents or guardians to ensure that their minors do not provide us with Personal Data without their parental/guardian's consent.  If a parent or guardian becomes aware that his or her minor has provided us with Personal Data without their consent, he or she should contact our Data Protection Officer at dpo.vault@268.com.sg or 6737 7268 promptly.  If we become aware that a minor under 18 has provided us with Personal Data without their parent or guardian's consent, we will delete such information from our records.

  • 10) Governing Law and Jurisdiction

The terms and conditions of this Privacy Policy are governed by the laws of Singapore.  In the event of any disputes arising from this Privacy Policy and your use of the Site, you must first contact our Data Protection Officer at dpo.vault@268.com.sg or 6737 7268 regarding your concern and use your best endeavours to amicably settle any dispute in good faith.  We on our part will also use our best endeavours to amicably settle your concerns in good faith.  However, if no amicable resolution is reached within 30 days, you agree to submit to the exclusive jurisdiction of the Courts of Singapore.

Privacy Policy Effective Date : 2 July 2014