Privacy Policy

(a) “Personal Information” means information about an identifiable individual, including all data, whether true or not, about an individual who can be identified (i) from that data, or (ii) from that data and other information to which the organisation has or is likely to have access;

(b) “Data Protection Laws” means any applicable law relating to the protection, privacy and security, collection, use, disclosure and/or processing of sensitive or other personally identifiable information, including Regulation (EU) 2016/679 (the “GDPR”), the UK GDPR, the Singapore Personal Data Protection Act 2012 (“PDPA”) and the California Consumer Privacy Act (“CCPA”) (collectively, “Data Protection Laws”), each as amended from time to time.

(a) your name and address, image, age and gender, payment information, identification numbers including your National Registration Identification Card number, Passport number, Social Insurance number and personal references, to the extent permitted by applicable local laws, and any other information that you have provided to us or was collected by us from other sources, or in other forms of interaction with you; and

(b) information about your use of our Website, App and services, including cookies, information about your domain name and other identifiers such as IP address.

(a) Information you provide to us: Personal Information that you provide to us, such as when using the contact form on our Website or App, including your name, image, email address, and other contact details;

(b) Our correspondence: if you contact us, we will typically keep a record of that correspondence;

(c) Survey information: We may also ask you to complete surveys that we use for research purposes. In such circumstances we shall collect the information provided in the completed survey;

(d) Promotions: We may request Personal Information to administer your participation in contests, sweepstakes or other promotions that we organise;

(e) Marketing preference information: Details of your marketing preferences (e.g. communication preferences) and information relevant to selecting appropriate products and services to offer you;

(f) Website, App and communication usage: Details of your visits to and interaction with the Websites and Apps and information collected through cookies and other tracking technologies including, but not limited to, your IP address and domain name, your device, browser version and operating system, traffic data, location data, web logs, other communication data, and the resources that you access;

(g) CCTV and Events: When your images are captured by us via CCTV cameras while you are within our property and/or premises, or via photographs or videos taken by us or our representatives when you attend our events;

(h) Activities on Social Networking Sites (SNS): If you choose to participate (for example, by “liking” our profile on Facebook, Instagram, Linkedin, Twitter, posting a message, or answering a poll), we will have access to the information you divulge which may include Personal Information; and

(i) Publicly Available Sources: From publicly available sources.

(a) To provide and manage products and services you have requested. To administer our services, including to carry out our obligations arising from any agreements entered into between you and us, or to notify you about changes to our services and products, as well as to ensure that we have correct or up to date information about you (such as your current address or date of birth) and to better manage your relationship with us.

(b) To communicate with you regarding information, products and services that may be of interest. To provide you with updates and offers.

(c) To understand our customers and to develop and tailor our products and services. We may analyse the Personal Information we hold in order to better understand your usage patterns and preferences, as well as to better understand our business and develop our products and services;

(d) To inform you of changes. To notify you about changes to our services and products;

(e) To ensure Website or App content is relevant. To ensure that content from our Websites or Apps is presented in the most effective manner for you and for your device, which may include passing your data to business partners, suppliers and/or service providers;

(f) To reorganise or make changes to our business. In the event that we: (i) are subject to negotiations for the sale of our business or part thereof to a third party; (ii) are sold to a third party; or (iii) undergo a re-organisation, we may need to transfer some or all of your Personal Information to the relevant third party (or its advisors) as part of any due diligence process for the purpose of analysing any proposed sale or re-organisation. We may also need to transfer your Personal Information to that re-organised entity or third party after the sale or reorganisation for them to use for the same purposes as set out in this policy;

(g) In connection with legal or regulatory obligations. We may process your Personal Information to comply with our regulatory requirements or dialogue with regulators as applicable which may include disclosing your Personal Information to third parties, the court service and/or regulators or law enforcement agencies in connection with enquiries, proceedings or investigations by such parties anywhere in the world or where compelled to do so. Where permitted, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime;

(h) To conduct audits. To conduct audits, reviews and analysis of our internal processes, action planning and manage commercial risks; and/or

(i) For purposes which are reasonably related to the aforesaid.

(a) to send you invitation(s) to form part of our consumer panel, testing product, interviews or research groups (unless you unsubscribe from receiving marketing material from Neon Group);

(b) to contact you regarding current or new Services offered by the Neon Group or current or new events, products and/or services offered by other third parties (unless you unsubscribe from receiving marketing material from Neon Group);

(c) to inform you of new features, special offers and sales promotions offered by the Neon Group or other third parties (unless you unsubscribe from receiving marketing material from Neon Group); and/or

(d) to match Personal Information with other data collected for other purposes and from other sources (including third parties) in connection with the customisation, provision or offering of products, services, marketing or promotions, whether by the Neon Group or other third parties.

(a) amongst the Neon Group and its subsidiaries, affiliates and related corporations (including their respective staff);

(b) contractors, agents, service providers and other third parties we use to support our business. These include but are not limited to those which provide administrative or other services to us such as delivery service providers, insurance providers, payment processing service providers, web analytics tool providers, mailing houses, telecommunication companies, information technology companies and data centres;

(c) vendors or third party service providers and our marketing and business partners in connection with any Services and/or marketing promotions;

(d) our corporate clients;

(e) any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale);

(f) external banks, credit card companies, other financial institutions and their respective service providers;

(g) our professional advisers such as consultants, auditors and lawyers;

(h) relevant government ministries, regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and/or

(i) any other party to whom you authorise us to disclose your Personal Information to.

(a) where in response to a request for your Personal Information in connection with identified purposes, you voluntarily provide such Personal Information to Neon Group for such purpose(s);

(b) where the collection, use or disclosure of your Personal Information is reasonably necessary for the conclusion and/or performance of a contract between you and us or any other organisation entered into at your request, which may include recipients of your Personal Information not indicated in this Privacy Policy; or

(c) where we have brought to your attention our intention to collect, use or disclose your personal data for identified purposes, and you have not taken any action to opt out within the period specified in our notices. For this purpose, you agree that we may provide you such notices via the Websites, Apps or via other forms of communication (e.g. SMS or email) based on the contact particulars that we may have of you in our records from time to time.

(a) for our legitimate interests or the legitimate interests of a third party, including but not limited to the purposes expressly set forth in this Privacy Policy, such as to improve our products, services, processes and business;

(b) where necessary to perform or enter into a contract to which you are a party or to take steps at your request prior to entering into a contract;

(c) where necessary to comply with a legal obligation; or

(d) where necessary to protect a person’s vital interests (e.g., in the event of an emergency).

(a) tracking information such as the number of visitors and their frequency of use, profiles of visitors and their preferred sites;

(b) making our Website and platforms easier to use. For example, cookies may be used to help speed up your future interactions with our Website and platforms;

(c) to better tailor our products and services to your interests and needs. For example, cookies information may be identified and disclosed to our vendors and business partners to generate consumer insights;

(d) collating information on a user’s search and browsing history;

(e) when you interact with us on our Website and platforms, we may automatically receive and record information on our server logs from your browser. We may collect for the purposes of analysis, statistical and site-related information including, without limitation, information relating to how a visitor arrived at the Website or platform, the browser used by a visitor, the device and operating system a visitor is using, a visitor’s IP address, and a visitor’s click stream information and time stamp (which may include for example, information about which pages they have viewed, the time the pages were accessed and the time spent per web page);

(f) using such information to understand how people use our Website and platforms, and to help us improve their structure and contents;

(g) using cookies that are necessary in order to enable our Website and platforms to operate, for example, cookies that enable you to log onto secure parts of our Website and platforms; and/or

(h) personalising the Website and platform for you, including delivering advertisements which may be of particular interest to you and using cookie related information to allow us to understand the effectiveness of our advertisements.

(a) have any questions in relation to our use of your Personal Information, or about this Privacy Policy;

(b) would like to withdraw your consent to any use of your Personal Information as set out in this Privacy Policy; or

(c) would like to obtain access and make correction to your Personal Information records, please contact us as follows:

Cityneon Holdings Pte Ltd
Data Protection Officer

25 Tai Seng Avenue, #06-01 Neon Building
Singapore 534104
[email protected]