By providing your Personal Data to BCRS Ltd., you hereby consent to BCRS Ltd. collecting, retaining, using and disclosing your Personal Data in accordance with the clauses below.

For the avoidance of doubt, this Policy does not apply to Business Contact Information or business-related data collected from BCRS Ltd.’s stakeholders (including without limitation beverage producers, retailers, suppliers and business partners). Examples of such Business Contact Information or business-related data which BCRS Ltd. may collect from you include company names, Unique Entity Numbers, business contact details of employees of respective companies, business email addresses, product information (including without limitation brand, packaging material type and sales volume), company financial data and company payment or refund details.

For more information on how BCRS Ltd. manages your Business Contact Information or business-related data, please request a copy of BCRS Ltd.’s Data Management Policy from our Data Protection Officer at the contact details in Clause 13 below.

BCRS Ltd. generally does not collect and/or use your Personal Data unless:

1. it is provided to BCRS Ltd. voluntarily by you after you have been notified of the purposes for which the Personal Data is collected, and you have provided written consent to the collection and usage of your Personal Data for those purposes; and
2. collection or use of Personal Data without consent is permitted or required under PDPA or any other laws.

BCRS Ltd. may collect and use your Personal Data for any or all of the following purposes:

1. operating BCRS Ltd.’s website and/or its subdomains (“Website”);
2. responding to your queries, feedback, complaints and requests;
3. managing the administrative and business operations of BCRS Ltd. and complying with internal policies, reporting requirements and procedures;
4. requesting feedback or participation in surveys, as well as conducting market research and/or analysis for statistical, planning or other purposes for BCRS Ltd. to improve the Scheme;
5. monitoring or recording phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation;
6. updating your personal and contact information;
7. conducting investigations relating to disputes or fraud in relation to the refund of deposits provided under the Scheme;
8. hosting, storing or backing-up your Personal Data, which may be on third party servers or data clouds;
9. enforcing our legitimate and/or lawful interests pursued by us or third-parties appointed by us;
10. complying with applicable laws, regulations, codes of practice, guidelines or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
11. any other purpose for which you have provided your Personal Data; and
12. any other incidental purposes related to or in connection with the above.

BCRS Ltd. will take all reasonable measures to protect your Personal Data against unauthorised disclosure. BCRS Ltd. has implemented strict internal protocols to protect the confidentiality of your Personal Data.

Subject to the provisions of any applicable law (including the PDPA), your Personal Data may be disclosed under the following circumstances:

1. where necessary to enforce BCRS Ltd.’s Terms of Use;
2. where such disclosure is required for performing our obligations in the course of or in connection with the provision of services requested by you;
3. to third party service providers, agents and other organisations BCRS Ltd. has engaged to perform any of the functions with reference to the purposes in Clause 3.2;
4. to 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 government authority;
5. to BCRS Ltd.’s professional advisers, including without limitation BCRS Ltd.’s lawyers, auditors and consultants; and/or
6. any other party to whom you authorise us to disclose your Personal Data to.

The consent that you provide for the collection, use and disclosure of your Personal Data shall remain valid until it is withdrawn by you in writing. You may withdraw your consent and request BCRS Ltd. 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 to our Data Protection Officer at the contact details in Clause 13 below.

Upon receipt of your written request to withdraw your consent, BCRS Ltd. will require reasonable time (depending on the complexity of your request) for your request to be processed and for BCRS Ltd. to notify you of the consequences of withdrawing your consent, including any legal consequences which may affect your rights and liabilities to us. In general, BCRS Ltd. will endeavour to process your request within ten (10) business days of receipt of your request.

Depending on the nature and scope of your request, BCRS Ltd. may not be in a position to continue providing services to you. If so, BCRS Ltd. will notify you before processing your request.

You may:

1. make an access request for access to a copy of your Personal Data held by BCRS Ltd., or the ways in which BCRS Ltd. uses or discloses your Personal Data; and
2. make a correction request to correct or update your Personal Data held by BCRS Ltd,

by submitting your request in writing to our Data Protection Officer at the contact details in Clause 13 below.

BCRS Ltd. may charge a reasonable fee to process your access request. If so, BCRS Ltd. will inform you of the fee before your request is processed.

Upon receipt of your written request to access or correct your Personal Data, BCRS Ltd. will require reasonable time (depending on the complexity of your request) for your request to be processed. In general, BCRS Ltd. will endeavour to process your request within thirty (30) days of receipt of your request. If BCRS Ltd. is unable to provide you with your Personal Data or make a correction requested by you, BCRS Ltd. will generally inform you of the reasons why we are unable to do so, except where we are not required to do so under the PDPA.

BCRS Ltd. relies on the accuracy of the Personal Data provided by you. To ensure that your Personal Data is current, complete and accurate, you may update us if there are changes to your Personal Data by informing our Data Protection Officer in writing at the contact details in Clause 13 below.

BCRS Ltd. may retain your Personal Data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted under applicable laws.

BCRS Ltd. will cease to retain your Personal Data as soon as it is reasonable for us to assume that such retention no longer serves the purpose for which the Personal Data was collected, and that the Personal Data is no longer necessary for legal or business purposes.

BCRS Ltd. generally does not transfer your Personal Data outside of Singapore. If BCRS Ltd. does so, we will obtain your consent for the transfer to be made. BCRS Ltd. will take all reasonable steps to ensure that your Personal Data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.

When you interact with BCRS Ltd. through the Website, you acknowledge and accept that the Website may place and access certain cookies on your device used to access the Website. BCRS Ltd. uses cookies to improve your experience using the Website, and has taken steps to ensure that your privacy is protected at all times.

If you wish to deny the use and saving of cookies from the Website onto your device, you may take the necessary steps within your internet browser’s security settings to block all cookies from the Website.

You can delete the cookies at any time. However, you may lose information that enables you to access the Website more quickly and efficiently, including without limitation personalisation settings.

BCRS Ltd. will take all reasonable steps to protect Personal Data in our possession or control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification or disposal or similar risks. BCRS adopts appropriate administrative, physical and technical measures to protect Personal Data, including without limitation data encryption, secure storage, access controls and authentication mechanisms.

However, BCRS Ltd. makes no representations or guarantees regarding the security of the Personal Data we may have collected from you, or that no harmful code (including without limitation viruses, bugs, trojan horses, spyware, malware or adware) will enter the Website.

The Website may contain links to external, third party operated websites of which BCRS Ltd. has no control over. BCRS Ltd. makes no representations or guarantees as to the quality, suitability, functionality or legality of the material on these external websites. BCRS Ltd. does not monitor such external websites and is not responsible or liable for any loss arising from the use of such external websites, including the content or the accuracy of the material therein.

This Policy does not extend to your use of external websites. You are advised to read the privacy or data protection policy of such external websites before using them.

Please note that if your Personal Data has been provided to us by a third party, such as your company, you should contact that organisation or individual to make such queries, complaints and withdrawal, access or correction requests to BCRS Ltd. on your behalf.

BCRS Ltd. reserves the right to revise this Policy from time to time without prior notice to you. You may determine whether any revision to this Policy has been made by referring to the date on which this Policy was last updated. Your continued use of the Website and our services constitutes your acknowledgement and acceptance of such changes.

This Policy and your use of the Website shall be governed by and construed in accordance with the laws of Singapore.