Privacy policy

SPEARING EVENTS PTE LTD DATA PROTECTION POLICY

This Data Protection Policy (the "Policy") applies to the collection, use, and disclosure of an individual customer's Personal Data arising from goods and/or services offered by Spearing Events Pte Ltd ("Spearing Events," "we," "us," or "our").

1. GENERAL

1.1 This Policy provides information on the obligations and policies of Spearing Events in respect of an individual customer's Personal Data. Spearing Events undertakes to use reasonable efforts to apply the principles and processes set out in this Policy to its operations.

1.2 Spearing Events' officers, management, and members of staff shall use reasonable endeavours to respect the confidentiality of, and keep safe, all Personal Data collected, stored, disclosed, or used for or on behalf of Spearing Events. Spearing Events shall use reasonable endeavours to ensure that all collection, storage, disclosure, and use of Personal Data is carried out in an appropriate manner and in accordance with the Singapore Personal Data Protection Act 2012 (as amended from time to time) (the "Act") and this Policy.

1.3 By interacting with us, submitting information to us, or signing up for any products or services offered by us, you agree and consent to Spearing Events and its respective representatives and/or agents ("Representatives") collecting, using, disclosing, and sharing amongst themselves your Personal Data, and disclosing such Personal Data to Spearing Events' authorised service providers and relevant third parties in the manner set out in this Policy.

1.4 This Policy supplements but does not supersede or replace any other consents you may have previously provided to us in respect of your Personal Data, and your consents under this Policy are additional to any rights we may have at law to collect, use, or disclose your Personal Data.

1.5 For the purposes of this Policy, in line with the provisions of the Act, "Personal Data" means data, whether true or not, about an individual who can be identified from that data, or from that data together with other information to which an organisation has or is likely to have access. Personal Data includes data already in our possession and data that may be collected in future.

2. CONTACTING THE DATA PROTECTION OFFICER

2.1 Where you legitimately request access to and/or correction of Personal Data relating to you that is in the possession and control of Spearing Events, we shall provide and/or correct that data in a reasonable time and manner in accordance with our standard procedures.

2.2 In accordance with the Act, Spearing Events has established a process for receiving and responding to queries or complaints arising from the application of the Act. To ensure your queries and complaints reach us, please send them by email to our Data Protection Officer (the "DPO") at dpo@spearing.com.sg.

2.3 If your Personal Data has been provided to us by a third party (for example, by a member through a referral process), you should contact that individual to make queries, complaints, and access or correction requests to Spearing Events on your behalf.

2.4 If you do not wish for Spearing Events to use your Personal Data for the marketing purposes listed in Clause 3.2, or to receive promotional materials from Spearing Events, you may opt out by sending a clearly worded email to the DPO at the email address provided in Clause 2.2. Your request will be processed within a reasonable time.

3. STATEMENT OF PRACTICES

Types of Personal Data Collected

3.1 As part of our day-to-day activities, Spearing Events may collect from you, through various means including our websites, mobile applications, marketing events such as roadshows, and any forms used by us from time to time, some or all of the following Personal Data:

  • Name (first and surname);
  • Postal address;
  • Phone number (including mobile);
  • Office number;
  • Email address;
  • Bank account or credit card details;
  • Gender;
  • Personal Data of your emergency contacts;
  • IP addresses;
  • Photographs and images you submit to us (for example, pre-submission photographs of cards you provide as part of a grading submission);
  • Submission and grading data (including card details, certification numbers, declared values, and grading service preferences);
  • Transaction history (including purchase records, reservations, and deposit information);
  • WhatsApp and other messaging communications with our team.

Cookies

We use cookies on our websites to track website visitorship, improve user experience, and support analytics and marketing functions. Cookies used on our website may include:

  • Strictly necessary cookies — required for the website to function (for example, Shopify session cookies);
  • Functional cookies — to remember preferences and settings;
  • Analytics cookies — to understand how visitors use the website (for example, Google Analytics);
  • Marketing cookies — to support marketing and retargeting (for example, Meta Pixel).

Most web browsers are designed to accept cookies. If you do not wish to receive cookies, you may set your browser to refuse them. Please note that disabling certain cookies may affect the functionality of the website.

Purpose of Collection of Personal Data

3.2 The Personal Data described in Clause 3.1 is collected for purposes connected with the services we provide, including:

  • Processing purchases, payments, reservations, and grading submissions;
  • Coordinating shipping, delivery, and collection of orders and grading submissions;
  • Facilitating grading submissions with third-party grading companies (such as PSA, BGS, and CGC) on the Customer's behalf;
  • Communicating with you regarding orders, grading status, claims, and other operational matters;
  • Determining eligibility for discounts, privileges, or benefits;
  • Conducting market research and analysis;
  • Direct marketing via voice calls, text messages, email, direct mail, and messaging applications;
  • Payment processing and credit control;
  • Notifying you of changes to our policies or services;
  • Responding to queries and feedback;
  • Identifying customers and providing access to services;
  • Maintaining and updating membership and customer records;
  • Informing you of new developments, services, and promotions from Spearing Events and associated third parties.

Disclosure of Personal Data

3.3 To carry out the functions described above, Spearing Events may, from time to time, disclose your Personal Data between Spearing Events' related companies, including Spearing Collectibles LLC (a Delaware-incorporated affiliate) where relevant to the services provided.

3.4 Without derogating from the above, Spearing Events may also disclose your Personal Data to the following third parties:

  • Grading companies (such as PSA, BGS, CGC, and Beckett) where you have engaged us to facilitate a grading submission on your behalf. Please note that grading companies process your Personal Data under their own privacy policies, which may involve transfer of your data outside of Singapore;
  • Couriers and shipping providers (such as FedEx, DHL, and other appointed couriers) for the purpose of arranging delivery of products or grading submissions;
  • Payment processors (including credit, debit, and charge card companies and banks);
  • Regulators and law enforcement authorities;
  • Lawyers, auditors, and professional advisors;
  • Third-party service providers and consultants acting on our behalf;
  • Potential buyers or investors of Spearing Events or any of its affiliated companies;
  • Any agent or subcontractor acting on our behalf to provide our services.

3.5 Spearing Events may disclose your Personal Data to the parties mentioned above in any of the following circumstances:

  • To the extent required by law;
  • In connection with any legal proceedings or prospective legal proceedings;
  • To establish, exercise, or defend our legal rights;
  • To the purchaser (or prospective purchaser) of any business or asset which Spearing Events is selling or contemplating selling;
  • To any person or entity processing information on our behalf;
  • To third parties providing services to us or on our behalf;
  • To any third party purchasing Spearing Events or any part of its business;
  • With your consent;
  • For the purposes of disaster recovery.

Optional Provision of Personal Data

3.6 In some instances, you may also be requested to provide certain Personal Data that may be used to further improve our products and services, or to better tailor information presented to you. In most cases, this type of data is optional. However, where the requested service is a personalised service, or where provision of a product depends on your providing the requested data, failure to provide it may prevent us from providing the service to you. This type of data includes, but is not limited to:

  • Your age;
  • Gender;
  • Salary range and employment details;
  • Education and profession;
  • Hobbies and leisure activities;
  • Other related products and services subscribed to;
  • Family and household demographics.

3.7 Under certain circumstances, telephone calls made to our service hotlines or enquiry telephone numbers may be recorded for the purposes of quality control, appraisal, and staff management and development. Where calls are recorded, you will be notified at the start of the call. By agreeing to this Policy, you give your clear and unambiguous consent for the collection, use, and disclosure of such Personal Data in accordance with this Policy.

4. WITHDRAWAL OF CONSENT

4.1 You may withdraw your consent to our collection, use, or disclosure of your Personal Data at any time by sending a clearly worded request to the DPO at dpo@spearing.com.sg.

4.2 Please note that withdrawal of consent may affect our ability to provide certain services to you. For example, if you withdraw consent for us to process your contact details and address, we may not be able to fulfil orders, coordinate grading submissions, or notify you of important updates. We will inform you of the likely consequences of withdrawing consent at the time of your request, so that you may make an informed decision.

4.3 Where you have withdrawn consent, we will cease collecting, using, or disclosing your Personal Data within a reasonable time, except where we are required or permitted to continue processing under the Act (for example, to comply with legal obligations or to defend legal claims).

5. TRANSFER OF PERSONAL DATA OVERSEAS

Your Personal Data may be processed by Spearing Events, its affiliates, agents, and third parties providing services to Spearing Events, in jurisdictions outside Singapore. This includes transfers to grading companies and couriers based in the United States and other jurisdictions in the course of providing our services. In any such transfer, Spearing Events will comply with the requirements of the Act, including ensuring that the recipient is bound by legally enforceable obligations to provide a standard of protection comparable to that under the Act.

6. ACCURACY OF PERSONAL DATA

Where possible, Spearing Events will validate data provided using generally accepted practices and guidelines. This includes the use of checksum verification on certain numeric fields such as account numbers or credit card numbers. In some instances, we are able to validate data against pre-existing data held by us. In other cases, we may require sight of original documentation before we use Personal Data, such as for identity verification or proof of address. To help ensure the accuracy of your Personal Data in our possession, please inform us of any updates by sending a clearly worded email to the DPO at the email address provided in Clause 2.2.

7. PROTECTION OF PERSONAL DATA

7.1 Spearing Events uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your Personal Data and will not knowingly allow access to this data to anyone outside Spearing Events, other than to you or as described in this Policy.

7.2 However, Spearing Events cannot ensure or warrant the security of any information you transmit to us, and you do so entirely at your own risk. In particular, Spearing Events does not warrant that such information may not be accessed, altered, collected, copied, destroyed, disposed of, disclosed, or modified by breach of any of our safeguards.

8. DATA BREACH NOTIFICATION

8.1 In the event of a data breach that we assess as likely to result in significant harm to affected individuals, or that affects 500 or more individuals, Spearing Events will notify the Personal Data Protection Commission and affected individuals in accordance with the Act and within the timeframes prescribed under the Act.

8.2 Notifications to affected individuals will set out the nature of the breach, the Personal Data involved, the steps we have taken or will take to address the breach, and the steps individuals can take to protect themselves where applicable.

8.3 We maintain internal procedures for detecting, assessing, and responding to data breaches, and conduct periodic reviews of these procedures.

9. ACCESS AND CORRECTION OF PERSONAL DATA

9.1 In accordance with Clause 2.1 of this Policy, you have the right to:

(a) check whether Spearing Events holds any Personal Data relating to you and, if so, obtain copies of such data; and

(b) require Spearing Events to correct any Personal Data relating to you that is inaccurate for the purpose for which it is being used.

9.2 Spearing Events reserves the right to charge a reasonable administrative fee to meet your requests under Clause 9.1. Upon payment of the requisite fee, your request will be processed within a reasonable time.

9.3 If you wish to verify the details you have submitted to Spearing Events, or check on how we use and process your Personal Data, our security procedures mean that we may request proof of identity before we release information. This proof of identity will typically take the form of full name, membership or customer number, and NRIC, Passport, or FIN number. You must keep this information safe, as you will be responsible for any action we take in response to a request from someone using your details.

10. STORAGE AND RETENTION OF PERSONAL DATA

10.1 Spearing Events retains Personal Data only for as long as it is necessary for the purposes for which it was collected, including the provision of services, the resolution of disputes and claims, and compliance with legal, accounting, and regulatory obligations.

10.2 Typical retention periods include:

  • Transaction records — retained for at least five (5) years from the date of the transaction, in accordance with the record-keeping requirements of the Income Tax Act and other applicable laws;
  • Grading submission records — retained for the duration of the grading process and for a reasonable period thereafter to support warranty, claims, and dispute resolution;
  • Marketing and communication records — retained until you withdraw consent or for a reasonable period after the conclusion of the customer relationship;
  • CCTV or call recordings (where applicable) — retained for a short, defined period as set by our internal procedures.

10.3 Where Personal Data is no longer required for any reasonable business or legal purpose, Spearing Events will, where reasonably possible, delete or anonymise such Personal Data in accordance with our internal procedures.

11. CONTACTING YOU

To the extent that any of the communication means you have provided to Spearing Events (which may include your telephone number) is or will be listed on the Singapore Do Not Call Registry (the "DNC"), by agreeing to this Policy through signing any e-forms or by other means of indication, you grant Spearing Events your clear and unambiguous consent to contact you via the communication means you have provided, including voice calls, SMS, WhatsApp, MMS, and other similar communications applications or methods, for the purposes stated in Clause 3.2. You may withdraw this consent at any time in accordance with Clause 4.

12. CHANGES TO THIS POLICY

Spearing Events reserves the right to alter any of the clauses contained in this Policy to comply with local legislation, to meet global policy requirements, or for any other purpose deemed reasonably necessary. You should review this Policy regularly. If you do not agree to any modified terms, you should inform us as soon as possible of the terms to which you do not consent. Pending such notice, if there is any inconsistency between these terms and any additional terms, the additional terms will prevail to the extent of the inconsistency.

13. GOVERNING LAW

This Policy is governed by and shall be construed in accordance with the laws of the Republic of Singapore. You submit to the non-exclusive jurisdiction of the Singapore courts.

14. MISCELLANEOUS

14.1 This Policy only applies to the collection and use of Personal Data by Spearing Events. It does not cover third-party sites to which we provide links, even if such sites are co-branded with our logo. Spearing Events does not share your Personal Data with third-party websites except as set out in this Policy. We are not responsible for the privacy and conduct practices of third-party websites; please review their privacy policies before disclosing any Personal Data to them.

14.2 Spearing Events will not sell your Personal Data to any third party without your permission. We cannot, however, be responsible or held liable for the actions of third-party sites to which you may have linked or been directed from Spearing Events' website.

14.3 Spearing Events' websites do not target and are not intended to attract children under the age of 18. Spearing Events does not knowingly solicit Personal Data from children under the age of 18 or send them requests for Personal Data. If a customer is under 18 years of age, the parent or legal guardian must write in to dpo@spearing.com.sg to request the relevant consent process before any Personal Data is collected.

15. CONTACT

For any questions, complaints, or requests regarding this Policy or your Personal Data, please contact: