Privacy Policy

Cityneon Holdings Pte Ltd, together with its affiliated and related companies (collectively “Neon”) as well as their respective representatives and/or agents (“Neon Group”, “us”, “we” or “our”) are committed to safeguarding the privacy of users and the Personal Information you have entrusted to us. We strive to be transparent about how we collect, use, disclose, and process your information, to keep your information secure. This privacy policy (“Privacy Policy”) is meant to help you understand what information Neon Group collects, how, and why we collect it, and what we do with it. Cityneon Holdings Pte Ltd will be the responsible data controller under this Privacy Policy (where identification of the controller is required by Data Protection Laws).

By providing your Personal Information to us, interacting with us, submitting information to us (including on or through any of our websites (“Website”) or mobile applications (“App”), visiting or using the pages available on our Website or App, or signing up for any events, products and/or services offered by us (such events, products and/or services hereinafter collectively referred to as “Services”), you are deemed to have read and understood the Privacy Policy. To the extent required by Data Protection Laws to lawfully process Personal Information, and subject to the jurisdiction-specific addenda in this Privacy Policy, you agree and consent to the Neon Group collecting, using, disclosing, processing and sharing amongst themselves your Personal Information, and disclosing such Personal Information to our business partners, authorised service providers, vendors, sub-contractors, advisors (e.g. legal, financial, business or other advisors) and relevant third parties in the manner and for any of the purposes set forth in this Privacy Policy.

Please review this Privacy Policy carefully prior to visiting or using the pages available on our Website and App or otherwise providing us with any Personal Information. If you do not provide your Personal Information, we may not be able to effectively provide you with the relevant Services.

This Privacy Policy supplements but does not supersede nor replace any consents you may have previously provided to us in respect of your Personal Information.

Subject to your rights at law, you agree to be bound by the prevailing terms of this Privacy Policy as updated from time to time on our Website and App. Please check our Website or App regularly for updated information on the collection, use, disclosure and/or processing of your Personal Information.

1. Scope of Personal Information and Data Protection Laws

1.1 In this Privacy Policy:

(a) “Personal Information” means information about an identifiable individual, including all data, whether true or not, about an individual who can be identified (i) from that data, or (ii) from that data and other information to which the organisation has or is likely to have access;
(b) “Data Protection Laws” means any applicable law relating to the protection, privacy and security, collection, use, disclosure and/or processing of sensitive or other personally identifiable information, including Regulation (EU) 2016/679 (the “GDPR”), the UK GDPR, the Singapore Personal Data Protection Act 2012 (“PDPA”) and the California Consumer Privacy Act (“CCPA”) (collectively, “Data Protection Laws”), each as amended from time to time.

1.2 Examples of such Personal Information which you may provide us include (depending on the nature of your interaction with us):

(a) your name and address, image, age and gender, payment information, identification numbers including your National Registration Identification Card number, Passport number, Social Insurance number and personal references, to the extent permitted by applicable local laws, and any other information that you have provided to us or was collected by us from other sources, or in other forms of interaction with you; and
(b) information about your use of our Website, App and services, including cookies, information about your domain name and other identifiers such as IP address.

We typically do not process sensitive Personal Information, but if you provide sensitive Personal Information to us, we will handle it in accordance with Data Protection Laws. Where we process Personal Information in deidentified form, we will take reasonable measures to maintain it in such form and not attempt to reidentify it.

1.3 The Neon Group relies upon different lawful bases for collecting, using, disclosing and/or processing your Personal Information, depending on the jurisdiction. This includes but is not limited to obtaining your consent to specific processing activities. Where we rely on consent, you may withdraw your consent by contacting us using the contact details set out below.

2. Collection of Personal Information

2.1 Generally, we collect your Personal Information in the following ways:

(a) Information you provide to us: Personal Information that you provide to us, such as when using the contact form on our Website or App, including your name, image, email address, and other contact details;
(b) Our correspondence: if you contact us, we will typically keep a record of that correspondence;
(c) Survey information: We may also ask you to complete surveys that we use for research purposes. In such circumstances we shall collect the information provided in the completed survey;
(d) Promotions: We may request Personal Information to administer your participation in contests, sweepstakes or other promotions that we organise;
(e) Marketing preference information: Details of your marketing preferences (e.g. communication preferences) and information relevant to selecting appropriate products and services to offer you;
(f) Website, App and communication usage: Details of your visits to and interaction with the Websites and Apps and information collected through cookies and other tracking technologies including, but not limited to, your IP address and domain name, your device, browser version and operating system, traffic data, location data, web logs, other communication data, and the resources that you access;
(g) CCTV and Events: When your images are captured by us via CCTV cameras while you are within our property and/or premises, or via photographs or videos taken by us or our representatives when you attend our events;
(h) Activities on Social Networking Sites (SNS): If you choose to participate (for example, by “liking” our profile on Facebook, Instagram, Linkedin, Twitter, posting a message, or answering a poll), we will have access to the information you divulge which may include Personal Information; and
(i) Publicly Available Sources: From publicly available sources.

2.2 When you browse our Website or use our App, you may generally do so without directly identifying yourself, but please see further below for information on cookies which we have implemented on our Website that may collect indirect identifiers.

2.3 If you provide us with any Personal Information relating to a third party (e.g. information on your dependent, spouse, children and/or parents), by submitting such information to us, you represent and warrant to us that you have obtained the consent of such third party to you providing us with their Personal Information, and for the further collection, use, disclosure and/or processing by us of their Personal Information, for the purposes contemplated hereunder, and that such consents have not been withdrawn.

2.4 You shall ensure that all Personal Information 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 products and/or services which you have requested.

3. Purposes for the Collection, Use, Disclosure and/or Processing of Personal Information

3.1 In general, we collect, use, disclose and/or process your Personal Information for the following purposes:

(a) To provide and manage products and services you have requested. To administer our services, including to carry out our obligations arising from any agreements entered into between you and us, or to notify you about changes to our services and products, as well as to ensure that we have correct or up to date information about you (such as your current address or date of birth) and to better manage your relationship with us.
(b) To communicate with you regarding information, products and services that may be of interest. To provide you with updates and offers.
(c) To understand our customers and to develop and tailor our products and services. We may analyse the Personal Information we hold in order to better understand your usage patterns and preferences, as well as to better understand our business and develop our products and services;
(d) To inform you of changes. To notify you about changes to our services and products;
(e) To ensure Website or App content is relevant. To ensure that content from our Websites or Apps is presented in the most effective manner for you and for your device, which may include passing your data to business partners, suppliers and/or service providers;
(f) To reorganise or make changes to our business. In the event that we: (i) are subject to negotiations for the sale of our business or part thereof to a third party; (ii) are sold to a third party; or (iii) undergo a re-organisation, we may need to transfer some or all of your Personal Information to the relevant third party (or its advisors) as part of any due diligence process for the purpose of analysing any proposed sale or re-organisation. We may also need to transfer your Personal Information to that re-organised entity or third party after the sale or reorganisation for them to use for the same purposes as set out in this policy;
(g) In connection with legal or regulatory obligations. We may process your Personal Information to comply with our regulatory requirements or dialogue with regulators as applicable which may include disclosing your Personal Information to third parties, the court service and/or regulators or law enforcement agencies in connection with enquiries, proceedings or investigations by such parties anywhere in the world or where compelled to do so. Where permitted, we will direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime;
(h) To conduct audits. To conduct audits, reviews and analysis of our internal processes, action planning and manage commercial risks; and/or
(i) For purposes which are reasonably related to the aforesaid.

3.2 Where permitted under Data Protection Laws, we may also collect, use, disclose and/or process your Personal Information for any of the following purposes:

(a) to send you invitation(s) to form part of our consumer panel, testing product, interviews or research groups (unless you unsubscribe from receiving marketing material from Neon Group);
(b) to contact you regarding current or new Services offered by the Neon Group or current or new events, products and/or services offered by other third parties (unless you unsubscribe from receiving marketing material from Neon Group);
(c) to inform you of new features, special offers and sales promotions offered by the Neon Group or other third parties (unless you unsubscribe from receiving marketing material from Neon Group); and/or
(d) to match Personal Information with other data collected for other purposes and from other sources (including third parties) in connection with the customisation, provision or offering of products, services, marketing or promotions, whether by the Neon Group or other third parties.

3.3 If you have provided us with your telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your telephone number(s), then from time to time, we may contact you using such telephone number(s) (including via voice calls, text, fax or other means) with information about our products and services.

3.4 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, disclose and/or process your Personal Information. If so, we will collect, use, disclose and/or process your Personal Information for these additional purposes as well, unless we have specifically notified you otherwise.

4. Disclosure of Personal Information

4.1 Subject to the provisions of any applicable law, you hereby agree and acknowledge that your Personal Information may be disclosed for any of the purposes listed above in this Privacy Policy (as applicable) to the following entities or parties, regardless of whether they are located overseas or in Singapore:

(a) amongst the Neon Group and its subsidiaries, affiliates and related corporations (including their respective staff);
(b) contractors, agents, service providers and other third parties we use to support our business. These include but are not limited to those which provide administrative or other services to us such as delivery service providers, insurance providers, payment processing service providers, web analytics tool providers, mailing houses, telecommunication companies, information technology companies and data centres;
(c) vendors or third party service providers and our marketing and business partners in connection with any Services and/or marketing promotions;
(d) our corporate clients;
(e) 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);
(f) external banks, credit card companies, other financial institutions and their respective service providers;
(g) our professional advisers such as consultants, auditors and lawyers;
(h) 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 governmental authority; and/or
(i) any other party to whom you authorise us to disclose your Personal Information to.

4.2 We may share information about you in aggregate or anonymised form, for example, information regarding business product related reviews, with the abovementioned entities or parties (e.g. our business partners).

5. Consent and Other Bases for Handling or Processing Your Personal Information

In certain jurisdictions, we will process your Personal Information on the basis of your consent (including your deemed consent, where applicable). In those jurisdictions, subject to and in accordance with applicable law, you shall be deemed to have consented to Neon Group collecting, using, disclosing and sharing amongst ourselves your Personal Information, and disclosing such Personal Information to Neon Group’s authorised service providers and relevant third parties:

(a) where in response to a request for your Personal Information in connection with identified purposes, you voluntarily provide such Personal Information to Neon Group for such purpose(s);
(b) where the collection, use or disclosure of your Personal Information 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 Information not indicated in this Privacy Policy; 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 Websites, Apps or via other forms of communication (e.g. SMS or email) based on the contact particulars that we may have of you in our records from time to time.

In addition to any consents you have provided for our collection, use and disclosure of your Personal Information for the purposes set out elsewhere in this Privacy Policy, where permitted by applicable law, Neon Group may rely upon alternate legal bases to collect, use and/or disclose your Personal Information as further detailed below where we meet the requirements of applicable law:

(a) for our legitimate interests or the legitimate interests of a third party, including but not limited to the purposes expressly set forth in this Privacy Policy, such as to improve our products, services, processes and business;
(b) where necessary to perform or enter into a contract to which you are a party or to take steps at your request prior to entering into a contract;
(c) where necessary to comply with a legal obligation; or
(d) where necessary to protect a person’s vital interests (e.g., in the event of an emergency).

6. Securing your Personal Information

6.1 We use commercially reasonably physical, electronic and procedural safeguards to protect against unauthorized use, access, modification, destruction, disclosure, loss or theft of your Personal Information in our custody or control in accordance with applicable law.

6.2 We have agreements and controls in place with third party service providers requiring that any information we provide to them must be safeguarded and used only for the purpose of providing the service we have requested the company to perform.

6.3 We remind you, however, that no data transmission over the Internet, or Website or App can be guaranteed to be secure from intrusion.

7. Retention of your Personal Information

Our retention periods for personal data are based on business needs and legal requirements. We retain your Personal Information for as long as is necessary for the processing purpose(s) for which the information was collected, and any other permissible, related purposes.

8. Use of Cookies

8.1 Our Website and platforms use cookies and similar technologies. Cookies are small text files stored in your computing or other electronic devices when you visit our Website) and platforms for record keeping purposes. Cookies are stored in your browser’s file directory, and the next time you visit the Website or platform, your browser will read the cookie and relay the information back to the Website, platform or element that originally set the cookie. Depending on the type of cookie it is, cookies may store user preferences and other information.

8.2 Web beacons (also known as pixel tags and clear GIFs) involve graphics 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 Website 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 our Website 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.

8.3 Neon deploys different types of cookies. We use some cookies that are “strictly necessary” and help make the Website or platform usable by enabling basic functions. These cookies are necessary for the Website or platform to function. You may be able to decline these cookies through your browser settings, but if you do, certain parts of the Website or platform may not work. We use “performance and operational cookies”, which allow us to count visits and traffic sources, perform customer surveys and other web analytics, so we can measure and improve the performance of our Website or platform. We use “functional cookies” to enable the Website or platform to provide enhanced functionality, aid Website personalisation, maintain user-selected options and Website navigation aids. We use “marketing and targeted advertising cookies” to track our visitors’ browsing habits and activity across our Website and platform.

8.4 We may employ cookies and other technologies as follows:
(a) tracking information such as the number of visitors and their frequency of use, profiles of visitors and their preferred sites;
(b) making our Website and platforms easier to use. For example, cookies may be used to help speed up your future interactions with our Website and platforms;
(c) to better tailor our products and services to your interests and needs. For example, cookies information may be identified and disclosed to our vendors and business partners to generate consumer insights;
(d) collating information on a user’s search and browsing history;
(e) when you interact with us on our Website and platforms, we may automatically receive and record information on our server logs from your browser. We may collect for the purposes of analysis, statistical and site-related information including, without limitation, information relating to how a visitor arrived at the Website or platform, the browser used by a visitor, the device and operating system a visitor is using, a visitor’s IP address, and a visitor’s click stream information and time stamp (which may include for example, information about which pages they have viewed, the time the pages were accessed and the time spent per web page);
(f) using such information to understand how people use our Website and platforms, and to help us improve their structure and contents;
(g) using cookies that are necessary in order to enable our Website and platforms to operate, for example, cookies that enable you to log onto secure parts of our Website and platforms; and/or
(h) personalising the Website and platform for you, including delivering advertisements which may be of particular interest to you and using cookie related information to allow us to understand the effectiveness of our advertisements.

8.5 Some cookies we use are from third party companies to provide us with web analytics and intelligence about our Website and platforms. These companies collect information about your interaction with our Website and platforms. We use such information to compile statistics about visitors who interact with the Website, platforms and other Neon Group’s online content, to gauge the effectiveness of our communications, and to provide more pertinent information to our visitors.

8.6 If you do not agree to such use of cookies, you can adjust your browser settings. Unless you have adjusted your browser settings to block cookies, our system will issue cookies as soon as you visit our Website or click on a link in a targeted email that we have sent you, even if you have previously deleted our cookies. If you are located in the EEA or UK, you can select your cookie preferences using the cookie banner that will appear when you access our Website.

8.7 If you do not agree to our use of cookies and other technologies as set out in this Privacy Policy, you should delete or disable the cookies associated with our Website and platforms by changing the settings on your browser accordingly, or if you are located in the EEA or UK, by changing your cookie settings through the cookie banner. However, you may not be able to enter certain part(s) of our Website or platforms. This may also impact your user experience while on our Website or platforms.

9. Third-Party Sites

Our Website and App may contain links to other websites operated by third parties, including for example our business partners. We are not responsible for the data protection practices of websites operated by third parties that are linked to our Website and App. We encourage you to learn about the data protection practices of such third party websites. Some of these third party websites may be co-branded with our logo or trade mark, even though they are not operated or maintained by us. Once you have left our Website and/or App, you should check the applicable privacy policy of the third party website to determine how they will handle any information they collect from you.

10. Contacting Us – Withdrawal of Consent, Access and Correction of Your Personal Information

10.1 We will use reasonable endeavours to ensure that your Personal Information is accurate. In order to assist us with this, you should notify us of any changes to the Personal Information that you have provided to us by contacting us as set out in the “Contacting Us” section below.

10.2 If you:

(a) have any questions in relation to our use of your Personal Information, or about this Privacy Policy;
(b) would like to withdraw your consent to any use of your Personal Information as set out in this Privacy Policy; or
(c) would like to obtain access and make correction to your Personal Information records, please contact us as follows:

Cityneon Holdings Pte Ltd
Data Protection Officer

25 Tai Seng Avenue, #06-01 Neon Building
Singapore 534104
dpo@neonglobal.com

10.3 Please note that if your Personal Information has been provided to us by a third party (e.g. your employer), we encourage you to contact that organisation or individual in the first instance to make such queries, complaints, and access and correction requests.

10.4 In cases where we rely upon your consent, if you withdraw your consent to any or all use of your Personal Information, depending on the nature of your request, we may not be able to continue to provide our Services to you.

11. Updates to this Privacy Policy

The Neon Group shall have the right to amend this Privacy Policy at any time. If changes are made to this Privacy Policy, they will be posted on this page and date stamped with the “date of last revision” indicated below, which is also the effective date of the updated Privacy Policy. We will inform you of any material changes in accordance with applicable law. We encourage you to review this page regularly in order for you to stay notified of any changes.

Your continued use of our Website and/or App and acceptance of our services after any change to this Privacy Policy shall constitute your consent to any such changes, to the extent such consent is not otherwise provided.

Addendum for EEA/UK Data Subjects

If you are a resident of the EEA or the UK, then you may be entitled to exercise, subject to applicable legal exemptions, the following rights by contacting our Data Protection Officer at dpo@neonglobal.com:

Request access to your Personal Information. This enables you to receive a copy of the Personal Information we hold about you.
Request correction of your Personal Information. This enables you to have any incomplete or inaccurate information we hold about you corrected.
Request erasure of your Personal Information. This enables you to ask us to delete or remove Personal Information where there is no good reason for us continuing processing it.
Object to processing of your Personal Information (where we are relying on a legitimate interest).
Request the restriction of processing of your Personal Information. This enables you to ask us to suspend the processing of your Personal Information, for example if you want us to establish its accuracy or the reason for processing it.
Request the transfer of your Personal Information to another party.
Withdraw your consent at any time if your Personal Information is processed on the basis of consent. If you withdraw your consent, this will not affect the lawfulness of how we used your Personal Information before you withdrew consent.

Please note that in some circumstances, we may not be able or required by law to comply with your request, but in such cases we will still respond to notify you of that decision and provide an explanation. In some cases, we may also need you to provide us with additional information, which may include Personal Information, to verify your identity and the nature of your request.

If you consider that the processing of your Personal Information infringes applicable law, you may lodge a complaint with a competent supervisory authority. We request that you contact us in the first instance so that we can consider your complaint.

Your Personal Information may be transferred to a third party, including as an international transfer to a third country without an adequacy decision issued by the European Commission or United Kingdom, as applicable. In such circumstances, Neon shall ensure adequate safeguards are in place which may include, as necessary, the use of standard contractual clauses. Where we rely upon such clauses, we shall provide you with a copy upon request.

Addendum for Residents of California

If you are a resident of California, please refer to the section “Collection of Personal Information” above, which describes the categories of Personal Information we have collected about consumers in the last 12 months and the purposes for which we have processed such Personal Information. Please also refer to the “Disclosure of Personal Information” section above, which describes the categories of Personal Information shared or disclosed to third parties, as well as the business purposes and categories of recipients of such disclosures. The Neon Group does not sell or share directly identifying information about you with third parties, but we do share online identifiers to provide more relevant services, content, and advertising to you, which may be considered a “sale” or “share” under the CCPA. [By clicking the “Do Not Sell or Share My Personal Information” link, you may opt out of the sale or sharing of your Personal Information.] The Neon Group does not have actual knowledge of selling or sharing the Personal Information of individuals under the age of 16.

You are also entitled to exercise the following rights (either directly or via an agent who is authorized to act on your behalf) by contacting our Data Protection Officer at dpo@neonglobal.com.

Request to know the categories of Personal Information we collect, the sources from which it is collected, the categories of third parties to whom such Personal Information is disclosed or shared, and the purposes of such disclosure or sharing;
Request to correct inaccurate Personal Information;
Request to delete Personal Information collected from you; and
Request to limit the use of sensitive Personal Information (if applicable).

We may ask you to provide certain information to verify your identity (and/or the identity and authority of any agent acting on your behalf) and the nature of your request. In some circumstances, we may not be able to fulfil or fully address with your request, and where that is the case, we will still respond to notify you of such a decision and provide an explanation.

We will not discriminate against you for exercising your rights and choices, although some of the functionality and features available may change or no longer be available to you. Any differences in functionality or features are related to the value provided.

PRIVACY POLICY