This Data Protection and Privacy Notice (“Privacy Notice”) sets out how Tokyo Century Leasing (Singapore) Pte. Ltd and its respective holding companies, subsidiaries, affiliates, associated companies and jointly controlled entities (collectively, “TCLS”, “we”, “our” or “us”) may collect, use, disclose, process, and protect your personal data through the use of https://tcls.com.sg/ (“Site”).
This Privacy Notice applies to all Site users, customers, or other individual’s personal data which is in our possession or under our control (collectively, “you”, “your” or “yours”).
TCLS is committed to ensure that your privacy is protected. Should we ask you to provide certain information by which you can be identified when using this website, you can be assured that it will only be used in accordance with this Privacy Notice. By continuing to visit any part of the Site, you are deemed to consent to the terms described in this Privacy Notice.
1. Collection, Use and Disclosure of Personal Information
1.1 Personal data is data that can be used to identify a natural person. We may collect the following personal data from you for our core business purposes, including but not limited to:
(a) Your Profile / Account Information. We may collect your name, gender, date of birth, nationality, passport or other personal identification numbers, employment information, financial information, mailing address, phone number, email address and/or billing information when you are provided with an account with us and/or when you conduct transactions through the Site;
(b) Voluntarily Provided Information. We collect information which you voluntarily provide to us or which is provided to us via a third party who has been duly authorised by you to disclose your personal data. You may choose not to provide certain information, but choosing to do so may prevent you from being able to take advantage of some of our Site’s features or from conducting transactions;
(c) Usage and Log Information. We collect diagnostic, cookie information and performance information when you use the Site;
(d) Site Support and Feedback. We collect copies of your messages and how to contact you to provide Site support when you contact us with queries or provide feedback to us on your use of the Site;
(e) Transactional Information. If you pay us, we may receive information and confirmations, such as payment receipts, including from the Site or other third parties processing your payment;
(f) Information Other Parties Provide About You. We may receive information that third parties provide to us, which may include information about you;
(g) Third-Party Providers. We may work with third-party providers to help us operate, provide, improve, understand, customise, support and market the Site. These providers may provide us with information about you in certain circumstances; and
(h) Third-Party Services. We may allow you to use the Site in connection with third-party services. Please note that when you use third-party services, their own terms and privacy policies will govern your use of those services.
1.2 We may collect, use, disclose, retain, process or transfer your personal data for the following purposes, including but not limited to:
(a) setting up, managing and maintaining your account with us;
(b) performing our obligations to you in the course of provision of our services and products and/or provision of products of our business partners which are provided through us;
(c) for accounting, billing and verification purposes;
(d) for processing of your payment instructions or direct debit facilities, if applicable;
(e) to perform credit checks, screening, and due diligence checks;
(f) to perform appropriate anti-fraud checks or fraud prevention measures,
(g) for shipping and delivery purposes;
(h) to provide and improve our services and our operations of the Site, including informing you of any change or updates in our Site;
(i) to carry out statistical research, planning and analysis for the purposes of developing or improving our products and services;
(j) to evaluate, assess and process applications, instructions or requests from you;
(k) for administering fee adjustments, refunds and waivers, if applicable;
(l) to respond to any feedback, queries or requests;
(m) to address or investigate any complaints, claims or disputes;
(n) managing your relationship with us;
(o) handling any issues which have come to our attention;
(p) to enforce any terms of agreement which you may have with TCLS, if applicable;
(q) providing or marketing services, products and benefits to you;
(r) notifying you on about events or activities organised by us, our partners, sponsors or advertisers;
(s) to facilitate investigations into or to take action regarding any suspicious or illegal activity on the Site;
(t) for disaster recovery and back-up;
(u) for internal administrative and management purposes;
(v) where required by any act, statute, law, or regulation, or by the order of a government authority or a court or tribunal of competent jurisdiction;
(w) any purposes exempted under the applicable laws;
(x) such other purposes as consented to by you for which your personal information is collected; and
(y) any other purpose reasonably related to the aforesaid.
(collectively, “Purposes”)
1.3 We may from time to time share any of your personal data within our group of companies, including our holding companies, subsidiaries, affiliates, associated companies and jointly controlled entities, located in Singapore, Japan or elsewhere in the world. We may transfer, store, process and/or deal with your personal data outside of Singapore. In doing so, we will comply with the Personal Data Protection Act 2012 (“PDPA”) and other applicable data privacy protection and privacy laws.
1.4 We may combine information about you that we have with information we obtain from business partners or other companies, and may secure information about you from our joint marketing partners or from unrelated third parties.
1.5 We can also share your personal data as part of a sale, merger or change in control, or in preparation for any of these events. Any other entity which acquires or merges with us will have the right to continue to use your data, but only in the manner set out in this Privacy Notice unless you agree otherwise.
1.6 Notwithstanding anything to the contrary, we may generate aggregated and statistical data derived from your use of the Site and/or from your information, including, without limitation, aggregated or anonymized data, the number of records, the number and types of transactions, configurations, and reports processed (“Aggregated Data”). By using the Site and storing data on the Site, you agree that we may have access to your data for the purpose of generating Aggregated Data. Such Aggregated Data shall not include any personally identifiable information.
You acknowledge and agree that we own:-
(a) the Aggregated Data; and
(b) the processed data that results from any data analysis and processing by us or our affiliates (“Processed Data”).
Nothing herein shall be construed as prohibiting us from utilizing or disclosing the Aggregated Data and/or Processed Data for purposes of operating our business, provided that our use of Aggregated Data and/or Processed Data will not reveal the identity, whether directly or indirectly, of any individual. In no event shall the Aggregated Data and/or Processed Data include any personally identifiable information.
You further acknowledge and agree that, as part of our Site operations, we may from time to time provide on the Site product or service advertisements from us or our affiliates or partners based on the Aggregated Data and/or Processed Data collected or processed by us.
2. Disclosure of Personal Data
2.1 We may disclose your personal data to our staff, partners, third party service providers (such as lawyers or auditors), agents, contractors, subcontractors and affiliates in Singapore or elsewhere, for the Purposes, to maintain and facilitate the functionalities and features of the Site, or to protect the security or integrity of this Site and our databases. We will use commercially reasonable efforts to ensure that such partners do not use your personal data for a purpose other than the purposes for which the personal information were originally given. You agree and acknowledge that the respective privacy policies of our partners, third party service providers, agents, contractors, subcontractors and affiliates may apply in respect of your personal data collected by them.
2.2 We will use our reasonable endeavours to ensure that your personal data disclosed to any of the above parties is kept confidential and secure. Nevertheless, we do not warrant or take responsibility for any misuse undertaken by such parties which are beyond our control.
3. Withdrawal of consent
3.1 The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.
3.2 Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within fourteen (14) business days of receiving it.
3.3 Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be able to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing or via email.
3.4 Please note that the withdrawal of your consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclosure without consent is permitted or required under applicable laws.
4. Accuracy of Personal Data
4.1 To ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.
4.2 You represent, warrant and undertake to us that all personal data you have provided to us or stored in the Site is true, accurate, up-to-date and not misleading.
4.3 You agree and acknowledge that all representations and warranties given by you are personal statements and assurances on which we and any other third parties receiving information posted by you on the Site can rely on.
5. Access to and Correction of Personal Data
5.1 Subject to certain exceptions in the Act, you may request to:-
(a) access your personal data or other appropriate information on your personal data in accordance with the requirements of the Act;
(b) Correct an error or omission in your personal data that is in our possession or control in accordance with the requirements of the Act.
You may do so by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below. We will respond to your request as soon as reasonably possible and generally within fourteen (14) business days. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
5.2 To protect your privacy and security, we may ask you to verify your identity and/or provide other details to help us respond to your request before granting access or making corrections.
6. Protection of Your Personal Data
6.1 The security of your personal data is important to us. To safeguard your personal data, all electronic storage and transmission of personal data is secured with appropriate security technologies. We endeavour to protect against unauthorised disclosures by limiting access to your personal information to certain individuals where required, and by informing our employees about their responsibility to adhere to our own business ethical standards and confidentiality policies. To prevent unauthorised access, maintain data accuracy and ensure the correct use of personal information, we have put in place physical, technical and operational procedures to safeguard and secure the confidentiality and integrity of the personal information we collect. We use technology designed to transfer information securely from your web browser to our web servers. This should mean that all of your personal information is encrypted to avoid the decoding of that information by anyone. These aforementioned safeguards are designed to protect against, but are not a guarantee against, the loss, misuse and unauthorized access, disclosure, alteration and destruction of personal data. Where appropriate, we use available technology to protect the security of communications made through the Site. However, you should be aware that no method of transmission over the Internet can be guaranteed to be completely secure. We cannot guarantee the security of any information you transmit to us, and you transmit such information at your own risk. We do not accept liability for the security, authenticity, integrity or confidentiality of any transaction and other communications made through the Site. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
6.2 Internet communications may be susceptible to interference or interception by third parties. Despite our best efforts, we make no warranties that the Site is free of viruses or other unauthorised software.
6.3 You should take appropriate steps to keep your information, software and equipment secure. This includes choosing your password carefully, keeping your password confidential, keeping your password and computer or mobile device secure by signing out after using the Site, and clearing your Internet browser cookies and cache before and after using any services on the Site.
7. Retention of Personal Data
7.1 We may retain your personal data as long as we are providing services to you and/or for such period of time that you have an account with us for the Purposes or otherwise as permitted under the Act. We may also retain personal data after we cease providing services directly or indirectly to you, even if you close your account with us or after any agreement between yourself and the Company has been terminated, for the Purposes or otherwise as permitted under the Act or to the extent necessary to comply with our legal and regulatory obligations, and for the purpose of fraud monitoring, detection and prevention.
7.2 We may retain your personal data to comply with our tax, accounting, and financial reporting obligations, where we are required to retain the data by our contractual commitments to our financial partners, and where data retention is mandated by the payment methods that we support. Where we retain data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law.
7.3 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 purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.
7.4 Notwithstanding the foregoing, we reserve the right to destroy or delete any of your personal data from our system at our sole discretion without further reference to you.
8. Confidentiality
Save where expressly provided herein, we will not reveal to any person, firm or company any personal data which may come to our knowledge hereunder and shall keep with complete secrecy the personal data provided by you and shall not use or attempt to use any such personal data in any manner without your permission. These restrictions shall cease to apply to information or knowledge which may come into the public domain other than as a result of any act or breach of this Privacy Notice by us.
9. How we use cookies
9.1 Our websites uses cookies, a small file which 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.
9.2 We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website to tailor it to customer needs. We only use this information for statistical analysis purposes and the data is removed from the system thereafter.
9.3 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. Please note that this may prevent you from taking full advantage of the website.
10. Third Party Websites
10.1 Our websites may contain hyperlinks to and from other websites, web pages and/or apps which are not produced or maintained by us, and it is important to note that the privacy practices implemented on those websites may vary. We make no representation and are not responsible for the content of those sites and shall not be liable for any damages or loss arising from access to those sites. Any content, services, representations made on such sites are solely the responsibility of the operator of those sites and we assume no responsibility for any content, the operation or the services provided thereon. Use of the hyper-links and access to such linked websites, web pages and/or apps are entirely at your own risk.
10.2 All hyper-links to other websites, web pages and/or apps are provided as a convenience to you as a user of the Site. In no circumstance shall TCLS be considered to be associated or affiliated in whatever manner with any trade or service marks, logos, insignia or other devices used or appearing on the sites to which the Site is linked.
10.3 Please be aware that this Privacy Notice is exclusive to our site, so it is advised that you proceed with caution and read the privacy statements of any external websites you visit.
11. Contacts
11.1 If you wish to revoke your consent to the collection, use and disclosure of your personal data, or if you wish to correct your personal data, or if you have any comments, concerns or questions about this Privacy Notice, our policies and practices, you may contact our Data Protection Officer at [email protected] or call to 6532 3436. We will endeavour to respond to you within fourteen (14) business days.
11.2 If you receive promotional emails, marketing communications, text messages or other communications from us and you wish to stop receiving the materials, please contact us at [email protected] to let us know.
12. Applicable Law
The terms in this Privacy Notice are governed by the laws of the Republic of Singapore.
13. Modification of Privacy Notice
The terms of this Privacy Notice may be changed from time to time. All changes will be made available on this page. You can tell if this policy has changed by checking the revision date at the bottom of this page. Your access or use of the Site after such changes have been posted will constitute your agreement to the modified Privacy Notice and all of the changes. All communications, transactions and dealings with us shall be subject to the latest version of this policy in force at the time. You should therefore read this page carefully each time you visit the Site.
14. Terms of Use
By accessing or using the Site, you are deemed to have also accepted our General Terms of Use at https://tcls.com.sg/terms-of-use.
Last updated: Dec 2024
