Privacy Policy
Last updated: 15 Feb 2024
1.1. This privacy policy sets out the basis on which Pick Network Pte. Ltd. (“Pick”) may collect, use, disclose or otherwise process your Personal Data in accordance with the Personal Data Protection Act 2012 (No. 26 of 2012), its accompanying subsidiary legislation (“PDPA”), and guidelines issued by the Personal Data Protection Commission of Singapore (the “Privacy Policy”).
1.2. By accessing and using, and continuing to access and use the Services provided by Pick, and/or mobile application (the “App”), and/or any of Pick’s websites which can be found at www.picknetwork.com, www.lockeralliance.net, send.picknetwork.com & partner.lockeralliance.net (“Website”), you hereby expressly give consent to, acknowledge and agree that this Privacy Policy shall govern Pick’s collection, use, disclosure and/or processing of any of your Personal Data that is collected by Pick in the course of your access and use of Pick’s Services, App and/or Website.
1.3. This Privacy Policy also applies to Personal Data in Pick’s possession or under Pick’s control, including Personal Data in the possession of organisations which Pick has engaged to collect, use, disclose or process Personal Data for Pick’s purposes.
1.4. The App and Websites may contain links to third-party applications and websites. These linked sites are only for your convenience, and you therefore access them at your own risk. Pick does not guarantee the security of Personal Data and/or other information that you provide on third-party applications and websites. Pick is not responsible or liable for the content of any such third-party applications, websites or services, and the privacy practices applicable in respect of any such third-party applications, websites or services, and your use of such third-party applications, websites or services may be subject to such terms and conditions (including with respect to such third-party’s data collection and privacy practices) as may be imposed by such third-party. You are advised to check on the applicable privacy policies of those third-party applications or websites to determine how Personal Data and/or other information collected (if any) will be handled.
2.1 As used in this Privacy Policy, “Personal Data” means data, whether true or not, about an individual who can be identified:
a. from that data; or
b. from that data and other information to which Pick has or is likely to have access.
All other terms used in this Privacy Policy shall have the meanings given to them in the PDPA (where the context so permits).
2.2 Depending on the nature of your interaction with Pick, Pick may collect your Personal Data directly or indirectly via various channels, including when:
i. you visit Pick’s Websites;
ii. you use Pick’s Services or enter into transactions with Pick;
iii. you contact Pick or request that Pick contact you through various communication channels, for example, through social media platforms, messenger platforms, face-to-face meetings, telephone calls, emails, fax and letters;
iv. you respond to Pick’s promotions, rewards, referral program or subscribe to Pick’s mailing lists;
v. your images are captured via photographs or videos taken by Pick or Pick’s representatives when you are at Pick’s locker.
3.1 Pick generally do not collect your Personal Data unless
a. it is provided to Pick voluntarily by you directly, or via a third-party who has been duly authorised by you to disclose your Personal Data to Pick (your “Authorised Representative”) after:
i. you or your Authorised Representative have been notified of the purposes for which the Personal Data is collected; or
ii. you or your Authorised Representative have provided express consent to the collection and usage of your Personal Data for these purposes; or
b. collection and use of Personal Data without consent is permitted or required by the PDPA or any other law.
3.2 If you do not provide Pick with your Personal Data as stated in Clause 2.2, Pick will not be able to process your Personal Data for the purposes outlined in this document and depending on your interaction with Pick, this may cause Pick to be unable to provide you with your requested Services.
3.3 Your provision of Personal Data to Pick is voluntary and you have the right to withdraw your consent for Pick to use your Personal Data at any time by contacting and submitting a request to Pick. Your withdrawal will take effect after your request is processed. However, if you choose not to provide Pick with the Personal Data require, it may not be possible for Pick to fulfil the purposes for which Pick require the Personal Data, including providing products and Services which you need from Pick.
3.4 Pick shall notify you or seek your consent before collecting any additional Personal Data and before using your Personal Data for a purpose which has not been notified to you or your Authorised Representative, except where permitted or authorised by law.
3.5 Pick may collect and use your Personal Data for any or all of the following purposes:
a. to facilitate the provision of Services, including responding to, handling, and processing queries, requests, applications, complaints, feedback, and to carry out instructions from you;
b. managing, operating, providing and/or administering your use of and/or access to Pick’s Services, as well as your relationship and user account with Pick;
c. making a record of your visits to Pick’s App, Website and Services, including for the purposes of preparing general statistics and analytics on the usage of Pick’s App, Website and the prevention and/or detection of crime;
d. making a record of your visits and search activities on Pick’s App or Website for the purpose of analysis, understanding and optimizing the performance of Pick’s App, Website and functions;
e. complying with any 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;
f. surveys, engagement, marketing and promotional purposes and/or events organized by Pick or where Pick is a partner facilitating registration. You can unsubscribe from receiving marketing information at any time by using the unsubscribe function within the electronic marketing material.
g. providing you with any service you have requested or any other purposes for which you have provided the Personal Data;
h. developing, enhancing and providing products and Services to meet your needs;
i. internal administrative purposes, such as auditing, data analysis, database records;
j. maintaining the safety and security of Pick’s Services;
k. transmitting to any unaffiliated third parties, including Pick’s third-party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes;
l. protecting personal safety and the rights, property or safety of others;
m. maintaining and administering any software updates and/or other updates and support that may be required from time to time to ensure the smooth running of Pick’s Services;
n. to prevent or investigate any actual or suspected violations of Pick’s terms of service, fraud, unlawful activity, omission or misconduct, whether relating to your use of Pick’s Services or any other matter arising from your relationship with us;
o. to store, host, back up (whether for disaster recovery or otherwise) of your Personal Data;
p. for follow up on enquiries and feedback: Pick’s App or Website allows you to get in touch with Pick for enquiries and feedback through contact forms. Depending on the contact form you submit, Pick may collect your name, email address, telephone or mobile number, company information or job designation for Pick to follow up with you on your enquiry or feedback submitted via Pick’s App or Website.
q. Pick also provides customer support via a customer service hotline. When you call Pick’s customer service hotline for assistance or enquiry, Pick and Pick’s appointed agents would automatically have access to the phone number you use to contact Pick through Caller-ID. Depending on your permission, Pick and Pick’s appointed agents may also collect information on your name and contact number for follow up purposes and you may object to providing Pick this information if you do not wish to be contacted.
r. for locker Services: For Pick to provide Services to you, your email address or mobile phone number will be provided by your authorized merchant(s)/ marketplace(s)/ logistics service provider(s) to Pick, in order for Pick to send you an App, email or SMS notifications relating to your parcel delivery. For security reasons, Pick’s lockers may require you to input your mobile number for verification and it will also capture your photograph during each of your interaction with Pick’s lockers. The lockers are monitored by CCTV for security purposes.
s. for geo-location Services: Pick App and Website offers location-enabled Services, such as OneMap. If you use these applications, they may receive information about your actual location of your mobile device and/or your personal device (such as GPS, Wi-Fi, or other signals sent by a mobile device or personal device) or information that can be used to approximate a location. You will/may be asked if the geo-location service can be activated on your device, and you can also object to this geo-location service within Pick’s Website.
t. for App or web analytics: Pick App or Website may contain application or web analytical services provided by Google Analytics. This means that when you visit Pick’s Website, a cookie (as defined below) will be stored on your computer or mobile device, except when your browser settings do not allow for such cookies. This also means that when you visit Pick’s Website, the Personal Data described above in Clause 2.1, the data from "web beacons and tracking links" and information stored in Google Analytics' cookies will be sent to Google Analytics for analysis for and on behalf of Pick. Device-specific information, including your device type, operating system, unique device identifier, IP address, and mobile network information may also be collected.
u. Google Analytics acts as Pick’s agent, which means that Pick solely determine the purposes for which the data collected by them is being used. Google Analytics uses cookies, which generates information, which Google will use for the purpose of evaluation of your use of the Services, compiling reports on App or Website activity for App or Website operators and providing other Services relating to App or Website activity and Internet usage. You can find out more about the relationships between Google Analytics and Pick in the Google Analytics' Privacy Policy.
v. if you do not wish for information about your behaviour or your interaction with Pick’s Website being collected and assessed by Google Analytics, you can install the Google Analytics opt-out browser add-on. This add-on instructs the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) to not send your site visit information to Google Analytics. The browser add-on is available for most modern browsers. The Google Analytics opt-out browser add-on does not prevent information from being sent to the Website itself or in other ways to web analytics Services.
w. for Referrals: Pick may collect information about the referrals you make, including the names and contact details of the referred individuals via the App.
x. for Rewards: Pick may collect information about your activities, such as locker services rendered, referrals, and engagement via the App.
y. to contact or communicate with you or your Authorized Representative via voice call, text message and/or fax message, email and/or postal mail or otherwise for the purpose of administering and/or managing your relationship with Pick or your use of Pick’s Services (such as but not limited to communicating administrative information to you relating to Pick’s Services). You acknowledge and agree that such communication by Pick could be by way of the mailing of correspondence, documents or notices to you, which could involve disclosure of certain Personal Data about you to bring about delivery of the same as well as on the external cover of envelopes; and
z. any other incidental business purposes related to or in connection with the above.
3.6 Pick may disclose your Personal Data:
a. where such disclosure is required for performing obligations in the course of deploying and operating the nationwide parcel locker network; or
b. to third-party service providers, agents and other organisations Pick has engaged to perform any of the functions with reference to the abovementioned purposes.
3.7 Provisioning of Personal Data belonging to others by you:
a. In certain circumstances, you may also provide the Personal Data of persons other than yourself, including your family members. If you do so, you are responsible for informing him/her of the purposes for which Pick requires his/her Personal Data and warrant that you are validly acting on behalf of him/her to consent to Pick’s collection, use and disclosure of his/her Personal Data.
3.8 Pick may also collect, use, disclose and process your Personal Data for other purposes, without your knowledge or consent, where this is required or permitted by law.
4.1 Pick, and third parties with whom Pick partner, may from time to time use cookies, web beacons, tags, scripts, local shared objects such as HTML5 and Flash (sometimes called “flash cookies”), advertising identifiers (including mobile identifiers such as Apple’s IDFA or Google’s Advertising ID) and similar technology or features (“Cookies”) in connection with your use of Pick’s App and/or Website in which a record of visit or access is created. The record will show your IP address and details of the pages visited.
4.2 Some of the information may be gathered through the use of Cookies, where a small data file is sent to your browser to store and track information about you when you enter Pick’s App, Website or third-party 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. While the Cookie can tell Pick when you enter Pick’s sites and which pages you visit, it cannot read data off your hard disk. Third parties may be able to associate the information they collect with other information they have about you from other sources. Pick does not have access to or control over the Cookies they use.
4.3 You can choose to accept or decline Cookies by selecting the appropriate settings on your browser or device. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline Cookies if you prefer. However, please note that this this may prevent you from taking full advantage of the features that Pick Website provides.
5.1 The consent that you provide for the collection, use and disclosure of your Personal Data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request Pick 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 or via email to Pick’s Data Protection Officer at the contact details provided below in Clause 11.
5.2 Upon receipt of your written request to withdraw your consent, Pick may require reasonable time, depending on the complexity of the request and its impact on Pick’s relationship with you, for your request to be processed and for Pick to notify you of the consequences of Pick acceding to the same, including any legal consequences which may affect your rights and liabilities to Pick. In general, Pick shall seek to process your request within fifteen (15) business days of receiving it.
5.3 While Pick respects your decision to withdraw your consent, please note that depending on the nature and scope of your request, Pick may not be in a position to continue providing Pick’s Services to you and Pick shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform Pick in writing or via email to Pick’s Data Protection Officer at the contact details provided below in Clause 11.
5.4 Please note that withdrawing consent does not affect Pick’s right to continue to collect, use and disclose Personal Data where such collection, use and disclosure without consent is permitted or required under applicable laws.
6.1 If you wish to make (a) an access request for access to a copy of the Personal Data which Pick holds about you or information about the ways in which Pick uses or discloses your Personal Data, or (b) a correction request to correct or update any of your Personal Data which Pick holds about you, you may submit your request in writing or via email to Pick’s Data Protection Officer at the contact details provided below in Clause 11.
6.2 Please note that a reasonable fee may be charged for an access request. If so, Pick will inform you of the fee before processing your request.
6.3 Pick will respond to your request as soon as reasonably possible. In general, Pick will respond within fifteen (15) business days. Should Pick not be able to respond to your request within thirty (30) days after receiving your request, Pick will inform you in writing within thirty (30) days of the time by which Pick will be able to respond to your request. If Pick is unable to provide you with any Personal Data or to make a correction requested by you, Pick shall generally inform you of the reasons why Pick are unable to do so (except where Pick are not required to do so under the PDPA).
7.1 To safeguard your Personal Data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, Pick has introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption, and only disclosing Personal Data both internally and to Pick’s authorised third-party service providers and agents on a need-to-know basis.
7.2 You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, Pick strives to protect the security of your information and are constantly reviewing and enhancing Pick’s information security measures.
8.1 Pick generally rely on Personal Data provided by you or your Authorised Representative. You agree not to submit any information to us which is inaccurate or misleading. In order to ensure that your Personal Data is current, complete and accurate, please update us if there are changes to your Personal Data by informing Pick’s Data Protection Officer in writing or via email at the contact details provided below in Clause 11. Pick reserves the right and sole discretion to require further documentation to verify the information provided by you.
9.1 Pick 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 by applicable laws. If you cease use of Pick’s Services, Pick may continue storing, using and/or disclosing your Personal Data in accordance with this Privacy Policy and Pick’s obligations under the PDPA or any other applicable laws.
9.2 Pick will cease to retain your Personal Data or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the Personal Data was collected, and is no longer necessary for legal or business purposes. Subject to applicable laws, Pick may also securely remove or dispose of your Personal Data without prior notice to you.
10.1 Pick generally do not transfer your Personal Data to countries outside of Singapore. However, if Pick does so, Pick will obtain your consent for the transfer to be made and Pick will take 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.
11.1 You may contact Pick’s Data Protection Officer if you have any enquiries or feedback on Pick’s Personal Data protection policies and procedures, or if you wish to make any request, in the following manner:
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Mailing Address: |
Data Protection Officer No. 1 Maritime Square, Harbourfront Centre #11-03A/03B Singapore 099253 |
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Email Address: |
12.1 This Privacy Policy applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your Personal Data by Pick.
12.2 Pick may revise this Privacy Policy from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Privacy Policy was last updated. Your continued use of Pick’s App, Website or Services constitutes your acknowledgement and acceptance of such changes.