FRESH CLEANING FACILITIES MANAGEMENT
PRIVACY POLICY

This Privacy Policy (the “Policy”) governs the collection, use, and disclosure of Personal Data (as hereinafter defined) in connection with the goods and/or services provided by Fresh Cleaning Facilities Management Pte Ltd (collectively referred to as the “Company”).

1. General

1.1
This Policy outlines the obligations and practices of Fresh Cleaning Facilities Management Pte Ltd (hereinafter referred to as “the Company”) with respect to the collection, use, disclosure, and protection of an individual’s Personal Data. The Company is committed to making reasonable efforts, where practicable, to implement the principles and procedures set forth herein across its operations.

1.2
All officers, management personnel, and employees of the Company shall make reasonable endeavours to uphold the confidentiality and security of all Personal Data that is collected, stored, disclosed, or used by or on behalf of the Company. The Company will take appropriate steps to ensure that the handling of Personal Data is conducted in accordance with the provisions of the Personal Data Protection Act 2012 (the “Act”) and this Policy.

1.3
By engaging with the Company — whether through interaction, submission of personal information, or enrolment in any of the Company’s products or services — you signify your acknowledgement and consent to the Company, including its duly appointed representatives and/or agents (collectively referred to as “the Company”, “we”, “us”, or “our”), collecting, using, disclosing, and sharing your Personal Data with authorised service providers and relevant third parties, in accordance with the terms outlined in this Policy.

1.4
This Policy is intended to complement, and does not supersede or replace, any prior consents you may have provided concerning the use of your Personal Data. The consent provided herein is in addition to any legal rights that the Company may have to collect, use, or disclose Personal Data.

1.5
For the purposes of this Policy, and in alignment with the provisions of the Personal Data Protection Act 2012 (No. 26 of 2012), “Personal Data” refers to data, whether accurate or not, about an individual who can be identified from that data, or from that data in conjunction with other information to which the organisation has or is likely to have access. This includes all such Personal Data currently in the Company’s possession, as well as any such data that may be collected in the future.

2. Contacting the Data Protection Officer

2.1
If you wish to access or request correction of your Personal Data held by the Company, and such data is in the possession and control of the Company, the Company will respond to such legitimate requests within a reasonable timeframe and in accordance with its established procedures, as set out in this Policy.

2.2
In compliance with the Personal Data Protection Act 2012 (the "Act"), the Company has implemented a structured process for receiving and addressing any enquiries or complaints relating to its obligations under the Act. To ensure your enquiries or complaints are properly received, please submit them via email to the Company’s Data Protection Officer (the “DPO”), with the subject line clearly stating “Personal Data Matter:” at the following email address: hello@officecleaning.sg.

2.3
If your Personal Data was submitted to the Company by a third party (for example, through a referral by an existing member), you are advised to contact that individual directly in order to submit any related queries, complaints, or requests for access or correction on your behalf.

2.4
If you do not wish for the Company to use your Personal Data for any of the purposes outlined in Clauses 3.2 to 3.3, or if you prefer not to receive marketing or promotional communications from the Company, you may withdraw your consent by sending a clearly articulated request via email, with the subject line beginning with “Personal Data Matter:”, to the DPO at the email address provided in Clause 2.2. Your request will be processed within a reasonable period of time.

3. Statement of Practices

Types of Personal Data Collected

3.1
In the course of its regular business operations, the Company may collect Personal Data from individuals through various channels. These may include, but are not limited to, the Company’s official websites, telephone conversations, email correspondence, mobile applications, marketing activities such as roadshows, and any forms or documentation issued by the Company from time to time. The types of Personal Data that may be collected include the following:

• - Full name (first name and surname);
• - National Registration Identity Card (NRIC) number and/or passport details;
• - Residential and/or mailing address;
• - Contact numbers – including mobile, office, and fax numbers;
• - Company registration number;
• - Email address;
• - Bank account and/or credit card information;
• - Gender;
• - Personal Data of designated emergency contacts;
• - Internet Protocol (IP) address; and
• - Photographs and videos.

Use of Cookies

The Company’s websites utilise cookies to monitor site traffic, analyse usage trends, and enhance the user experience. Most internet browsers are pre-configured to accept cookies. Should you prefer not to receive cookies, you may modify your browser settings accordingly; however, please note that certain website features may not function properly as a result.

Purpose of Collection of Personal Data

3.2
The Personal Data described in Clause 3.1 is collected for purposes reasonably required to support the Company’s operations and service delivery. Such purposes include, but are not limited to:

• - Facilitating the provision of services by the Company;
• - Assessing eligibility for discounts, benefits, and other customer entitlements;
• - Conducting market research, customer segmentation, and data analysis;
• - Engaging in direct marketing via telephone calls, text messages, emails, postal mail, and facsimile transmissions;
• - Processing of payments and management of credit and billing matters;
• - Providing updates on changes to the Company’s policies, terms, or services;
• - Responding to customer enquiries, requests, and feedback; and
• - Informing customers of new initiatives, services, promotions, and events offered by the Company and/or its affiliated third-party partners.

Disclosure of Personal Data

3.3
Without prejudice to the foregoing clauses, the Company may, where appropriate and necessary, disclose your Personal Data to the following categories of third parties:

• - Government authorities, regulatory bodies, and law enforcement agencies;
• - Legal advisors and counsel;
• - External and internal auditors;
• - Third-party service providers, consultants, and professional advisors;
• - Financial institutions and payment processing entities, including credit, debit, and charge card companies and banks;
• - Prospective investors, acquirers, or purchasers of the Company or any of its affiliated companies; and
• - Agents, contractors, or subcontractors engaged by the Company to support the delivery of its goods and/or services.

In addition, your Personal Data may be disclosed to the aforementioned parties under the following circumstances:

• - Where such disclosure is required by applicable laws and regulations;
• - In connection with any actual or anticipated legal proceedings;
• - Where necessary for the establishment, exercise, or defence of the Company’s legal rights;
• - To a purchaser or prospective purchaser in the context of any proposed acquisition, sale, or transfer of the Company’s business or assets (in whole or in part);
• - To any party processing Personal Data on behalf of the Company;
• - To third parties providing operational, administrative, technical, or professional services to the Company;
• - To any third party acquiring or seeking to acquire the Company, its business, or any of its subsidiaries or business segments; and
• - For purposes related to data backup, business continuity, and disaster recovery planning.

Optional Provision of Personal Data

In certain circumstances, you may be invited to voluntarily provide additional categories of Personal Data, which may be used to enhance the Company’s offerings, improve service delivery, and tailor communications or content more effectively to your preferences. While the provision of such information is generally optional, there may be instances where the requested data is necessary to enable the Company to deliver specific personalised services or products. In such cases, the absence of the required data may limit the Customer’s ability to fulfil the requested service.

The types of optional Personal Data that may be requested include, but are not limited to, the following:

• - Age;
• - Gender;
• - Salary range and employment information;
• - Educational background and professional occupation;
• - Hobbies, interests, and leisure activities;
• - Details of other related products and services to which you are subscribed; and
• - Household and family demographic information.

3.4
In certain circumstances, telephone calls made to the Company’s entities—whether through order hotlines, service lines, or inquiry numbers—may be recorded for purposes including, but not limited to, quality assurance, performance evaluation, and staff training and development. By accepting the terms of this Policy, you hereby provide your explicit and unequivocal consent to the collection, use, and disclosure of such Personal Data in accordance with the provisions set forth herein.

4. Transfer of Personal Data Outside of Singapore

Your Personal Data may be transferred to, stored, and processed by the Company, its affiliated entities, authorised agents, or third-party service providers in jurisdictions outside of Singapore. In such instances, the Company shall ensure that the transfer is carried out in compliance with the requirements of the Personal Data Protection Act 2012 (the “Act”) and any applicable data protection regulations.

5. Accuracy of Personal Data

The Company endeavours to ensure that all Personal Data in its possession is accurate and up to date. Where feasible, the Company employs industry-standard verification practices, including but not limited to checksum validation of numerical fields (e.g., bank account or credit card numbers). In some cases, the Company may cross-reference the data provided against existing records, or require submission of original documentation (such as official identification or proof of address) before processing specific categories of Personal Data.

To assist the Company in maintaining accurate and current records, you are encouraged to notify the Company of any changes to your Personal Data. Such updates should be communicated clearly via email to the Data Protection Officer, whose contact details are provided in Section 2.2 of this Policy.

6. Protection of Personal Data

The Company adopts commercially reasonable physical, administrative, and technical safeguards to ensure the integrity and security of your Personal Data. Access to such data is restricted to authorised personnel within the Company or to third parties as specified under the terms of this Policy. The Company will not knowingly permit access to your Personal Data by any unauthorised party.

However, you acknowledge that the transmission of data over the internet or other communication networks is inherently subject to security risks. As such, while the Company endeavours to protect your Personal Data, it cannot guarantee absolute security and shall not be held liable for unauthorised access, alteration, collection, copying, destruction, disclosure, disposal, or modification resulting from a breach of the Company’s safeguards.

7. Access and Correction of Personal Data

7.1
Subject to Clause 2.1 of this Policy and in accordance with the applicable provisions of the Personal Data Protection Act 2012, you have the rights to:

• - a) Ascertain whether the Company holds any Personal Data pertaining to you and, if so, request access to such data; and
• - b) Request the correction of any Personal Data relating to you that is inaccurate or incomplete for the purposes for which it is being used.

7.2
The Company reserves the right to impose a reasonable administrative fee to process requests made pursuant to Clause 7.1. Upon receipt of the requisite fee, the Company will endeavour to process your request within a reasonable timeframe.

7.3
Should you wish to verify the Personal Data you have provided to the Company or inquire into how your data is being utilised and processed, the Company may, in line with its security protocols, require verification of your identity before disclosing any information. Such verification may include, but is not limited to, the provision of your full name and your National Registration Identity Card (NRIC), Passport, or Foreign Identification Number (FIN). You are therefore responsible for safeguarding this information, as the Company shall not be liable for any action taken in response to requests made using such credentials.

8. Storage and Retention of Personal Data

The Company shall take reasonable steps to delete or anonymise Personal Data that is no longer required for any legitimate business or legal purposes. Such deletion or anonymisation shall be carried out in accordance with the Company’s internal policies and procedures, and in compliance with any relevant contractual or regulatory requirements. This includes the removal of Personal Data from the Company’s electronic, manual, and other storage systems in a secure and proper manner.

9. Communication and Contact

To the extent that any contact details you have provided to the Company—including, but not limited to, your telephone number or fax number—are currently listed or may in the future be listed on the Do Not Call Registry (the “DNC”), you hereby provide your clear and unequivocal consent, by agreeing to the terms of this Policy and by continuing to use the Company’s services, to be contacted by the Company through all communication channels made available by you. This includes, but is not limited to, voice calls, SMS, WhatsApp, MMS, facsimile, and other similar communication platforms or methods, for the purposes specified in Clause 3.2 of this Policy. This consent ensures the continued delivery of the Company’s promotional offerings and services to you.

10. Revisions to this Policy

The Company reserves the rights to amend, modify, or supplement the provisions contained in this Policy at any time, as may be required to comply with applicable local laws, align with the Company’s internal policies, or address other operational or legal considerations as deemed reasonably necessary. You are encouraged to review this Policy periodically to stay informed of any updates.

Should you disagree with any revised terms, you are advised to notify the Company promptly of the specific provisions to which you do not consent. In the absence of such notice, and in the event of any inconsistency between this Policy and any supplementary terms or notices provided by the Company, the supplementary terms shall prevail to the extent of such inconsistency.

11. Governing Law

This Policy shall be governed by, and construed in accordance with, the laws of the Republic of Singapore. By accepting the terms of this Policy, you agree to submit to the non-exclusive jurisdiction of the courts of Singapore for the resolution of any disputes arising in connection with this Policy.

12. Miscellaneous

12.1
This Policy applies solely to the collection, use, and disclosure of Personal Data by the Company. It does not extend to third-party websites that may be linked to or from the Company’s website(s), even where such links display the Company’s branding or logo. The Company does not share your Personal Data with these external websites and is not responsible for their privacy policies, data handling practices, or terms of use. You are strongly advised to review the privacy statements of any third-party websites prior to disclosing your Personal Data to them.

12.2
The Company does not sell your Personal Data to any third party without your explicit consent. However, the Company shall not be held responsible or liable for the actions, omissions, or data practices of any third-party websites that are accessed through links provided on the Company’s website(s), including any redirections to such websites.

12.3
The Company’s website(s) are not directed at, and are not intended for use by, individuals under the age of 18. The Company does not knowingly collect, solicit, or process Personal Data from individuals under 18 years of age, nor does it knowingly communicate requests for such data to minors.