• personal particulars (e.g. name, mobile number, email addresses, gender, postal code and date of birth);
• transactional information based on your activities on our Website and/or the “Great Rewards” mobile application (such as buying or receiving vouchers, sending vouchers electronically to other parties and other content you may generate or that relates to your account with us);
• additional information we ask you to submit to authenticate yourself or if we believe you are violating site policies (for example, we may ask you to send us an ID or bill to verify your address, or to answer additional questions online to help verify your identity or ownership of an account);
• information about your use of the Website and/or the “Great Rewards” mobile application and related services, including cookies, Internet Protocol (“IP”) address and account details;
• discussions, chats, dispute resolution, correspondences through the Website and/or the “Great Rewards” mobile application / emails;
• precise location data, including the real-time geographic location of your computer or device. Where available, location-based services may use Global Positioning System, wireless networking technologies and your Internet Protocol (“IP”) address, along with crowd-sourced Wi-Fi hotspot and cell tower locations, and other technologies to determine your computers’ or devices’ approximate location; and
• personal opinions made known to us (e.g. feedback or responses to surveys).

Please note that we are the data owner in respect of all personal information you provide or is made available about you when you interact with our Website and/or our “Great Rewards” mobile application. Your customer relationship on the use of the Website and/or the “Great Rewards” mobile application is with GWCC/CPPL, which processes your personal information in accordance with Personal Data Protection Act of Singapore and other applicable data protection and privacy laws and regulations. However, we shall not be responsible for any refusal by a participating retailer to accept the redemption of vouchers which are issued by the owners and/or managers of the relevant participating mall. Such issues should be directed to the customer service of the relevant mall.

Generally, we collect personal information on our users in the following ways:

• when you sign up for an account with us through the Customer Service Counter or the “Great Rewards” mobile application;
• when you register or make a transaction at the Customer Service Counter or on the “Great Rewards” mobile application;
• when you respond to our request for further personal information about you when interacting with our customer service assistants through telephone, email or other means of communication;
• when you use the Website and/or the “Great Rewards” mobile application;
• when you consent to your devices’ location data being sent to us through the use of the Website and/or the “Great Rewards” mobile application;
• when you use or purchase e-Vouchers through the “Great Rewards” mobile application.
• when you contact us or request that we contact you for assistance;
• when you respond or our request for feedbacks or surveys;
• when you request to be included in our marketing communications;
• when you respond to our promotions and other marketing initiatives; or
• when you disclose any personal information to us for any other reason.

Once you register with us, you are not anonymous to us. Information regarding the usage of our Website and/or our “Great Rewards” mobile application may also store information about your mobile phone configuration such as your IP address, location, where you have executed transactions stored within the application, screens viewed within the mobile application, cookie information and the parts of the Website and/or the “Great Rewards” mobile application accessed.

When you send e-Vouchers to a third party such as family members and friends, or invite others to participate in our related services, we may collect the personal information you provide about those people. You represent and warrant that the consent of such third party has been obtained for the collection and use of such information in accordance with this policy.

We may use personal information collected provided by you for the following purposes:

• processing your application for your account with us, and facilitating, administrating, managing and/or maintaining your account;
• keeping you updated on our announcements, software updates, policy updates, changes to the relevant terms and conditions with us and upcoming events;
• to provide you with the relevant eVouchers which you have purchased or otherwise acquired dealing in any matter relating to all products, services and activities;
• for marketing purposes, communicating with you on our marketing activities, promotional events, special offers and responding to any queries, responses or complaints from you;
• creating, developing, operating, delivering and improving our services, content and advertising;
• developing processes and technologies for loss prevention and prevention, detection and investigation of crimes, including fraud and money laundering;
• customizing and displaying content which may be of interest to you on the Website or in the “Great Rewards” mobile application and to match offers to your preferences;
• for verification of identity, carrying out due diligence and other screening activities assisting with identification of users, and to determine appropriate services;
• for delivery of important notices, such as communications about changes to our terms, conditions and policies;
• for handling complaints and disputes and the conduct of relevant investigations and proceedings;
• for internal purposes such as risk assessment, auditing, data and statistical analysis, and research;
• for conducting research, analysis including data analytic, surveys and/or profiting to improve all services and products and/or otherwise for business operations and purposes;
• protecting and enforcing our legal rights and obligations;
• managing our business operations and to comply with internal policies and procedures;
• generating reports containing various statistical data on an aggregated level to participating retailers, owners and/or managers of malls and other relevant stakeholders offering their products, vouchers or services over the Website and/or the “Great Rewards” mobile application;
• if you enter into a contest or similar promotion, we may use the personal information to administer those programmes; and
• to comply with any applicable laws, regulations, codes and/or guidelines;
• to assist in law enforcement and investigations by relevant authorities; and
• if you are a corporate, in communicating with your staff regarding any of the above.

We will not, without your permission, distribute or sell personal information provided by you to any unaffiliated third party, except under the following circumstances:

• for the purposes of providing products or services that you have requested or purchased;
• monitoring products and services provided by or made available through the Website and the “Brand name” mobile application;
• providing the personal information to our parent company, subsidiary, associated or affiliated company and/or any third-party service providers under contract who help with our business operations: We may employ other companies and individuals to perform functions on our behalf. Examples include payment processing for purchases of vouchers, sending marketing e-mails and short message services, analyzing data, providing marketing assistance, investigating frauds and providing customer service. They have access to personal information needed to perform their functions, but may not use it for other purposes;
• for the purposes of sharing personal information with companies, third party service providers or partners who provide services including, but not limited to, information processing, managing and enhancing customer data, providing customer service, assessing your interest in our services, and conducting customer research or satisfaction surveys. These companies are obligated to protect your personal information in accordance with applicable data protection and privacy laws;
• if required by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence for us to disclose your personal information. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate;
• responding to queries or feedback;
• addressing or investigating any complaints, claims or disputes;
• enforcing obligations owed to us;
• seeking professional advice, including legal advice;
• complying with all applicable laws, regulations, rules, directives, orders, instructions and requests from any local or foreign authorities, including regulatory, governmental, tax and law enforcement authorities or other authorities;
• financial reporting, regulatory reporting, management reporting, risk management (including monitoring credit exposures), audit and record keeping purposes;
• providing the personal information collected to the owners and/or the managers of the malls in respect of which you have purchased vouchers redeemable at such malls upon your termination of the account or the termination of their relationship with us. Redemption of vouchers at the relevant malls are obligations of the relevant owners and/or managers of the malls where such vouchers are directly issued by such owners and/or managers of the malls, and they have access to personal information needed to continue providing necessary customer service to you; and
• we may also disclose information about you if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users.

Where your personal information is to be disclosed to any third party, we shall do so in compliance with all applicable laws on data privacy, and we will require such third parties to ensure that any personal information disclosed to them are kept confidential and secure.

For the avoidance of doubt, if we have reasonable grounds to believe that you are in breach of any of the terms of this policy, we reserve the right, in our sole and absolute discretion, to cooperate fully with governmental authorities, private investigators, all the rightful owner(s) or interest holder(s) and/or injured third parties in the investigation of any potential or on-going criminal or civil wrongdoing.

Further, we may disclose your identify and contact information, or such other transaction-related data, if requested by a government or law enforcement body, private investigator, rightful owner or interest holder and/or any injured third party or as a result of a subpoena or other legal action, or if we are of the view, in our sole and absolute discretion, that it would be in our best interest to do so. We shall not be liable for damages or results arising from such disclosure, and you agree not to bring action or claim against us for such disclosure.