This Privacy Policy ("Privacy Policy") explains how Jom (ISSN 3029-2379) handles and processes Personal Data in relation to the Service and in accordance with the Personal Data Protection Act 2012 (“the Act”) and other applicable laws. This Privacy Policy does not apply to websites, apps, destinations, or other offerings that we do not own or control, even if they are linked to from the Service. Read this Privacy Policy to enable you to know and understand the purposes for which Jom collects, uses and discloses your Personal Data.

You can access this Privacy Policy any time in the footer of the Service's home page. By purchasing a Product, registering for any aspect of the Service, or otherwise accessing, visiting, interacting with or using the Service, you acknowledge your understanding of this Privacy Policy. This means you agree and consent to Jom collecting, using, disclosing and sharing amongst ourselves your Personal Data, and disclosing such Personal Data to Jom’s authorised service providers and relevant third parties in the manner and for any of the purposes set forth in this Privacy Policy. This Privacy Policy will also inform you on the bases upon which we may lawfully collect, use and/or disclose your Personal Data without your consent, where permitted by applicable law. If you do not agree with the contents of this Privacy Policy, you should not access, visit and/or use the Service, or request or receive a Product.

In addition to reviewing this Privacy Policy, please also review our User Agreement and any other terms and conditions that may be posted elsewhere in the Service or otherwise communicated to our users, because the User Agreement and all such terms and conditions are also part of the Agreement between you and us.

We reserve the right to modify this Privacy Policy from time to time, so check back often. So that you are aware changes have been made, we will adjust the "Last Updated" date at the end of this document. If we make a material change to this Privacy Policy, we will also post on the Service a notice that a change was made. To the maximum extent permissible under applicable law, you agree to be bound by the prevailing terms of the Privacy Policy as updated from time to time on our Site. Continued access, visitation and/or use of the Service by you, or continued receipt of a Product, will constitute your acceptance of any changes or revisions to the Privacy Policy.

This Privacy Policy supplements but does not supersede nor replace any other consents you may have previously provided to Jom nor does it affect any rights which Jom may have at law in connection with the collection, use or disclosure of your Personal Data, and any consents you may have provided in connection with this Privacy Policy are cumulative and additional to any rights which we may have under applicable law to handle or process your Personal Data.

For avoidance of doubt, this Privacy Policy forms a part of the User Agreement (‘Website Conditions’). In the event of any conflict, inconsistency or conflict between this Privacy Policy and the Website Conditions, the Privacy Policy shall prevail. All defined terms contained in the Website Conditions shall apply to this Privacy Policy unless otherwise specifically stated.

1. Your Personal Data

1.1 In this Privacy Policy, “Personal Data” refers to any data or information about you from which you can be identified either (a) from that data; or (b) from that data and other information to which we have or are likely to have access. Examples of such Personal Data which you may provide to us include (depending on the nature of your interaction with us):

(a) identifiers, such as your name, signature, NRIC, passport or other identification number, telephone number(s), mailing address, e-mail address and any other information relating to you which you have provided us in any forms you may have submitted to us, or in other forms of interaction with you;

(b) information about your use of Jom’s website and service, including cookies, IP address, subscription account details and membership details, but only to the extent that Jom may identify you from such information;

(c) characteristics protected by applicable law, such as gender, marital status, nationality and country of origin;

(d) your employment history, education background, and income levels;

(e) your payment-related information, such as your bank account or credit card information, and your credit history; and

(f) information about your usage of and interaction with our website and/or service including computer and connection information, device capability, bandwidth, statistics on page views, and traffic to and from our website.

2. Collection of Personal Data

2.1 Generally, Jom collects your Personal Data in one or more of the following ways:

(a) when you submit forms or other documents relating to our products or service;

(b) when you register for or use of our service on the website owned or operated by us or when you register as a member of the website owned and/or operated by us, or use the service on the website;

(c) when you interact with Jom’s employees;

(d) when you use our service, e.g. our subscription service;

(e) when you establish any online accounts with us;

(f) when you request that we contact you;

(g) when you are contacted by, and respond to, our marketing representatives, agents and other service providers;

(h) when you respond to our request for additional Personal Data;

(i) when you ask to be included in an e-mail or other mailing list;

(j) when you respond to our promotions and other initiatives;

(k) when you submit a job application or any request related to our service;

(l) when you enter into tenancy agreements with us;

(m) when we receive references from business partners and third parties, for example, where you have been referred by them; or

(n) when you submit your Personal Data to us for any other reason.

2.2 When you browse our website, you generally do so anonymously but please see the section below on cookies and other related technologies which we have implemented on our website. We do not, at our website, automatically collect Personal Data unless you provide such information to us.

2.3 If you provide us with any Personal Data relating to a third party (e.g. information of spouse, children, parents, employees and/or authorised representatives), by submitting such information to us, you represent to us that you have obtained the consent of the third party to you providing us with their Personal Data for the respective purposes.

2.4 You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with the product and service you have requested, or processing any requests and applications you may have made to us.

3. Purposes for the Collection, Use and Disclosure of Your Personal Data

3.1 Generally, Jom collects, uses and discloses your Personal Data for the following purposes:

(a) responding to, processing and handling your queries, requests, complaints and feedback;

(b) managing the infrastructure and business operations of Jom and complying with internal policies and procedures;

(c) facilitating business asset transactions (which may extend to any merger, acquisition or asset sale);

(d) matching any Personal Data held which relates to you for any of the purposes listed herein;

(e) verifying your identity;

(f) preventing, detecting and investigating crime, including fraud and money-laundering, and analySing and managing other commercial risks;

(g) protecting and enforcing our contractual and legal rights and obligations;

(h) conducting audits, reviews and analysis of our internal processes, action planning and managing commercial risks;

(i) compliance with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities; and/or

(J) any other purpose relating to or reasonably necessary for any of the above.

3.2 In addition, Jom may collect, use and disclose your Personal Data for the following purposes, depending on the nature of our relationship with you:

(a) If you have a subscription or user account with us:

(i) to process your application for Online Subscription Services and/or Print Subscription Services;

(ii) to maintain your account with us;

(iii) to verify and process your personal particulars and payments in relation to provision of Online Subscription Service and/or Print Subscription Services to you;

(iv) to provide you with the goods and services which you have signed up for, including the provision and delivery of magazines requested;

(v) communicating with you to inform you of changes and development to Jom policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you;

(vi) resolving complaints and handling requests and enquiries;

(vii) conducting market research for statistical, profiling and statistical analysis for the improvement of services provided to you; and/or

(viii) any other purpose relating to or reasonably necessary for any of the above;

(b) If you download or use any of our Apps;

(i) where the App includes App Subscription Services, to process your application for these services;

(ii) to maintain your account with us and to ensure your access of the App is within the scope of your subscription;

(iii) to verify and process your personal particulars and payments in relation to provision of goods and services connected to the App;

(iv) to provide you with the goods and services which you have signed up for and to push articles, events and/or promotions to you which may be relevant to you;

(v) communicating with you to inform you of changes and development to Jom's policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you;

(vi) resolving complaints and handling requests and enquiries;

(vii) conducting market research for statistical, profiling and statistical analysis for the improvement of products and services provided to you; and/or

(viii) any other purpose relating to or reasonably necessary for any of the above;

3.3 In addition, where permitted under applicable laws, Jom may also collect, use and disclose your Personal Data, and share your Personal Data with Jom’s business partners, service providers and/or other third parties for the following purposes (which we may describe in our documents and agreements as "Additional Purposes" for the handling of Personal Data):

(a) providing services, products and benefits to you, including promotions, loyalty and reward programmes;

(b) matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision or offering of products and services, whether by Jom or other third parties;

(c) sending you details of products, services, special offers and rewards, either to our customers generally, or of particular products and services, special offers and rewards which may be of interest to you; and/or

(d) conducting market research, data analytics, understanding and determining customer location, preferences and demographics for us, our service providers and/or other third parties to develop insights into the industry, review, develop and improve our, our business partners', service providers' and/or other third parties' products, services and also develop special offers and marketing programmes.

3.4 If you have provided your Singapore telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your Singapore telephone number(s), then from time to time, Jom may contact you using such Singapore telephone number(s) (including via voice calls, sms, fax or other means) with information about our products and services (including discounts and special offers).

3.5 In relation to particular products or services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, then we will collect, use and disclose your Personal Data for these purposes as well.

3.6 You may withdraw your consent for receiving marketing or promotional materials/communication by e-mailing us at info@jom.media. Once we receive confirmation that you wish to withdraw your consent for marketing or promotional materials/communication, it may take up to 30 calendar days for your withdrawal to be reflected in our systems. Therefore, you may still receive marketing or promotional materials/communication during this period of time. Please note that even if you withdraw your consent for the receipt of marketing or promotional materials, we may still contact you for other purposes in relation to the products and services that you have requested or purchased from Jom.

3.7 You also consent to the collection, use and disclosure of your Personal Data by Jom in connection with any transaction relating to the acquisition, divestment, securitisation, amalgamation, listing or other transaction relating to any interest in Jom,, and any other corporate transaction involving Jom, including any evaluation or due diligence relating thereto, as well as to the collection, use and disclosure of such information by the counterpart(ies) thereto for the same purposes, and the provision of goods and services by such counterpart(ies) following such transaction, as may be relevant.

4. Disclosure of Personal Data

4.1 Jom will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, this Personal Data may be disclosed, for the purposes listed above (where applicable), to the following third parties, whether they are located overseas or in Singapore:

(a) The Inquiry Pte Ltd;

(b) agents, contractors or third party service providers who provide operational services to Jom, such as telecommunications, information technology, payment, payroll, processing, training, market research, vendor services, delivery services, storage, archival or other services to Jom;

(c) vendors or any third party business partners who offer goods and services on Jom’s website, whether in conjunction with us or not;

(d) external business and charity partners in relation to corporate promotional events;

(e) the Credit Bureau, or in the event of default or disputes, any debt collection agencies or dispute resolution centres;

(f) 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);

(g) anyone to whom we transfer or may transfer our rights and duties;

(h) banks, credit card companies and their respective service providers;

(i) our professional advisors such as our auditors and lawyers;

(j) relevant government regulators or authority or law enforcement agency to comply with any laws or rules and regulations imposed by any governmental authority; and

(k) any other party to whom you authorise us to disclose your personal data.

5. Deemed consent

5.1 In addition to the matters set forth above, subject to and in accordance with applicable law, you shall be deemed to have consented to Jom collecting, using, disclosing and sharing amongst ourselves your Personal Data, and disclosing such Personal Data to Jom’s authorised service providers and relevant third parties:

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

(b) where the collection, use or disclosure of your Personal Data 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 Data not indicated in this Privacy Policy; and/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 Jom website, or via other forms of communication (e.g. SMS or e-mail) based on the contact particulars that we may have of you in our records from time to time.

6. Other Bases for Handling or Processing Your Personal Data

6.1 In addition to and without limiting the consents you have provided to our collection, use and disclosure of your Personal Data for the purposes set out elsewhere in this Privacy Policy, where permitted by applicable law, Jom may also in accordance with the requirements thereof also collect, use and/or disclose your Personal Data as further detailed below including without your further consent, where we meet the requirements of applicable law:

(a) for our legitimate interests or the legitimate interests of any other person, including but not limited to protecting the life, health and property safety of individuals in an emergency, and other purposes expressly set forth in this Privacy Policy; and/or

(b) for improving our products, services, processes or business, understanding customer preferences and personalising experiences and recommendations, based on your Personal Data records with Jom (regardless whether you are an existing or prospective customer of Jom).

7. Use of Cookies and Related Technologies

7.1 When you interact with us on our websites, applications or services, we may collect or analyse anonymised information from which individuals cannot be identified (“Aggregate Information”), such as number of users and their frequency of use, the number of page views (or page impressions) that occur on the website and common entry and exit points into website.

7.2 Jom uses cookies, and other related technologies which have different functions. They are either necessary for the functioning of our services, help us improve our performance, or serve to provide you with extra functionalities.

Cookies – Small data file which is sent to your browser to store and track Aggregate Information about you when you enter our websites. The cookie is used to track information such as the number of users and their frequency of use, profiles of users and their preferred sites

Cookies can be disabled or removed by tools that are available in most commercial browsers. The preferences for each browser you use will need to be set separately and different browsers offer different functionality and options.

Web beacons - Small graphic images (also known as "pixel tags" or "clear GIFs") that are not apparent to the user. Tracking links and/or similar technologies consist of a few lines of programming code and can be embedded in our websites or platforms. Web beacons are usually used in conjunction with cookies and primarily used for statistical analysis purposes. This technology can also be used for tracking traffic patterns on websites and platforms, as well as finding out if an e-mail has been received and opened and to see if there has been any response.

7.3 We may use the terms "cookies" or "related technologies" interchangeably in our policies to refer to all technologies that we may use to collect or store information in your browser or device or that collect information or assist in identifying you as a unique user in the manner described above.

7.4 Jom may use an independent market research company to measure and analyse the Internet usage across Jom’s website. The core information on the usage of our website, includes:

(a) The number of page views (or page impressions) that occur on Jom’s website;

(b) The number of unique visitors to Jomi’s website;

(c) How long these unique visitors (on average) spend on Jom’s website when they do visit; and

(d) Common entry and exit points into Jom’s websites.

7.5 This information is aggregated by an independent market research company and provided to Jom to assist in analysing the usage of Jom’s website. Such data is also accessible by media organisations and research companies, for the purpose of conducting industry comparisons with other Internet portals.

7.6 Pages on Jom’s website may be coded with software which enables an independent market research company to track visitors to our website.

(a) This includes the use of Google Anla

7.7 Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser. However, you may not be able to enter certain part(s) of our website.

8. Third-Party Sites

8.1 Our website may contain links to other websites operated by third parties, such as our business partners. We are not responsible for the privacy practices of websites operated by third parties that are linked to our website. We encourage you to learn about the privacy policies of such third party websites. Some of these third party websites may be co-branded with our logo or trademark, even though they are not operated or maintained by us. Once you have left our website, you should check the applicable terms, conditions and policies of the third party website to determine how they will handle any information they collect from you.

9. Retention of your Personal Data

9.1 Jom will store your Personal Data only to the extent necessary for legal and our business purposes, including for the purposes set forth in this Privacy Policy, except as provided otherwise by applicable laws. When there is no longer any business or legal purpose for retaining your Personal Data or the statutory retention period expires according to applicable laws, we will delete or anonymise your Personal Data.

10. Withdrawal, Access and Correction of your Personal Data

10.1 Should you wish to withdraw consent to use of your Personal Data or obtain access to or make corrections to your Personal Data records, please log in to the relevant account through which the Personal Data was provided, if any, failing which please contact Jom at info@jom.media.

10.2 Please note that if your Personal Data has been provided to us by a third party, you should contact such third party directly to make any queries, feedback, and access and/or correction requests to Jom on your behalf.

10.3 Please note that if you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, Jom may not be in a position to continue to provide its products or services to you or administer any contractual relationship in place, and this may also result in the termination of any agreements with Jom and your being in breach of your contractual obligations or undertakings, and Jom legal rights and remedies in such event are expressly reserved.

10.4 Should you wish to exercise any of your other legal rights as a data subject under applicable laws, you can e-mail us at info@jom.media. To the extent as permitted by applicable laws, we may not be able to respond to your request to exercise your rights in certain circumstances. For instance, if your request is contrary to our obligations under applicable laws, or may infringe our trade secrets, we may refuse to respond to your request. In addition, if we have sufficient evidence of any malice or abuse of rights, or that our response to your request would infringe the significant legitimate rights and interests of other individuals, we may also decline your request.

11. Governing Law

11.1 This Privacy Policy shall be governed in all respects by the laws of Singapore.