Personal Data Protection Policy

In compliance with the Personal Data Protection Act (2012) of the Republic of Singapore (“PDPA”), Creative Labs Pte Ltd and its subsidiaries and affiliated companies (or "Creative", "we", "our" and "us") value your personal data and will do what we can, to ensure that your personal data is respected and protected, in line with applicable laws and the policies as described in this Policy.

This Policy seeks to help you better understand how we collect, use, disclose and protect your personal information.

Please read this Policy carefully before you use any of Creative's web sites ("Site(s)") or when you provide us with your personal data. By using or accessing our Sites or when you provide us with your personal data, you consent to and accept Creative's collection, use and disclosure of your personal data in accordance with the terms of this Policy. We reserve the right to amend, change or modify this Policy (or any part hereof) at any time and from time to time, without any notice to you. We encourage you to refer to this Policy on an ongoing basis so that you are aware of the current terms.

1. What is Personal Data?

   Personal data refers to data, whether true or not, about an individual who can be identified from that data alone or together with other information to which the organisation has or is likely to have access.

   This includes unique identifiers (e.g. NRIC number, passport number); as well as any set of data (e.g. name, age, biometric data (which may include head captures (inclusive of face and ears)), address, telephone number, occupation, etc.), which when taken together would be able to identify the individual. (For more information, please refer to http://www.pdpc.gov.sg.)

2. How We Collect Your Personal Data

   We collect your personal data in a variety of ways. Some of the ways include occasions when you use our apps or products, take part in our contests, lucky draws, surveys etc., when you subscribe to our newsletter, when you register a Creative product online, contact us for support or when you buy products from our online stores.

   When you are submitting your personal data to us (for whatever the purpose may be), please ensure that the data you provide us is accurate, complete, correct and true or we may not be able to contact you for the reasons for which you submitted the data.

3. The Information We Collect
   1. 3.1. The information we collect depends on the apps or products you bought or use, or the contests or activities you signed up for or subscribed to. You may have the opportunity to participate in any of the following activities at some Creative Sites including but not limited to: contests, product registration, special offers, promotions, surveys, polls, referral programs, software downloads, online shopping, newsletter subscription and/or forum participation.
   2. 3.2. These activities and the use of our apps or products may require the collection of your personal information including: your name, postal address, e-mail address, telephone number, fax number, biometric data (which may include head captures (inclusive of face and ears)), credit card details (only for payment obligations to complete your order(s), where so required), and/or information about your interests in the use of Creative's various products, programs and services. Such data collected may be combined with the information you had previously provided (for example, in the event that you had previously registered the ownership of your Creative products).
4. How We Use Your Information

   We will use your information for general administrative purposes including processing of orders and/or payments, personalizing your user experience, activating or deactivating accounts, responding to queries, technical support, audit purposes, to meet any governmental, legal or regulatory requirements, to enable us to keep you updated on our latest products, offerings, promotions, software updates etc.

5. How We Disclose Your Information

   We may disclose certain or all of the information (described above) that we collect, as stated above and in accordance with the terms and the purposes as set forth in this Policy. We do not reveal personally identifiable information about you to third-parties for their independent use, save as follows: (1) unless you request or authorize us; (2) in connection with our Sites as described above; (3) the information is required to be provided in compliance with applicable laws, regulations, search warrants, subpoenas or court orders, enforce an agreement we have with you, or to protect our rights, property or safety, or the rights, property or safety of our employees or others; (4) the information is provided to our agents, vendors or service providers who perform functions on our behalf, where such information may be processed on servers located outside the country where you live; or (5) the information is to address emergencies or acts of God or to address disputes or claims, or to persons holding a legal or beneficial interest. By entering into and using this web site, you consent to the processing of data about you by our third party vendors and marketing agents for the purposes set out hereinabove.

   If you wish to opt-out, please contact us at the contact details provided in clause 6 below. We shall, under no circumstance, be liable or responsible to you in any way for the data protection policies, privacy policies, security or other policies of these third party vendors/social media/marketing agents or otherwise. Subject to the provisions and exceptions as provided in the PDPA, we may disclose or share your information with our subsidiaries or affiliated companies within the Creative Group, or our service providers as necessary.

6. Opting Out

   Save as otherwise provided herein, Creative will not use or share the personally identifiable information that you provide to us. If you wish to withdraw your consent previously provided to us, you can exercise your choice to opt out, by contacting us at https://sg.creative.com/contactus.

   Please do note that after opting out, we may no longer be able to provide you with certain services which may include any requests for technical support, warranty or otherwise. Our legal rights are hereby expressly reserved.

7. Protection of Your Personal Data

   To prevent unauthorized access to our database systems, and to ensure the appropriate use of information, we have used commercially reasonable efforts to put in place electronic and managerial processes and procedures to help safeguard your personal information. If your information is transferred out of Singapore as required for any of the purposes set forth in this Policy, we use commercially reasonable efforts to ensure that your information will be protected according to standards comparable to the PDPA.

8. Access and Correction of Personal Data

   You may contact us at https://sg.creative.com/contactus for access to your personal data or to correct errors to the personal data you previously submitted to us. We reserve the right to charge a nominal administrative fee per access request. Please give us at least thirty (30) days to process each request.

   Please note that we are inter alia, prohibited from providing you with access if the provision of the personal data or other information could reasonably be expected to:

   1. threaten the safety or physical or mental health of an individual other than the individual who made the request;
   2. cause immediate or grave harm to the safety or to the physical or mental health of the individual who made the request;
   3. reveal personal data about another individual;
   4. reveal the identity of an individual who has provided personal data about another individual and the individual providing the personal data does not consent to the disclosure of his identity; or
   5. be contrary to the national interest.

   Please also note the exceptions to the correction obligation found in the Sixth Schedule of the PDPA. (For more information, please refer to http://www.pdpc.gov.sg.)

9. Feedback and Comments

   If you have comments or feedback on the matters referred to in this Policy, please drop us a line at the contact details provided in clause 10 below.

10. Contact Us
    

    Email:	dpo@ctl.creative.com
    Address:	Data Protection Officer Creative Technology Ltd 31 International Business Park #03-01 Creative Resource Singapore 609921