Who we are
As used in this Policy:
“Customer / Supplier” means an individual who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us; and
“Personal Data” means data, whether true or not, about a customer who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.
Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include name, email address, telephone number and employment information.
Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context so permits).
1. Appointment and Contact of DPO
1.1 The DPO have been appointed to oversee compliance with the Act (“PDPA”). Other employees within the Company may be delegated to act on behalf of the DPO or to take responsibility for the day-to-day collection and processing of Personal Data.
1.2 The Company shall make known, upon request, the title of the person or persons designated as DPO.
1.3 You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:
Name of DPO : Steven Goh
Contact No. : 6701 1188
Email Address : firstname.lastname@example.org
2. COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
2.1 We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you(oryour authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall 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 (except where permitted or authorised by law).
2.2 We may collect and use your personal data for any or all of the following purposes:
- performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
- verifying your identity;
- managing your relationship with us;
- processing payment or credit transactions; and
- transmitting to our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes.
2.3 We may disclose your personal data:
- where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods and services requested by you; or
- to third party service providers, agents and other organisations we have engaged to perform any of the functions with reference to the above-mentioned purposes.
2.4 The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under a contract with you).
3. DEEMED CONSENT
3.1 Persons are deemed to have given their consent for the collection, use and disclosure of Personal Data in the following circumstances:
- When the customer / supplier voluntarily provides their Personal Data to us;
- When the customer / supplier is aware of the purposes for which they are providing their Personal Data to us;
- It is reasonable for the customer / supplier to have provided the Personal Data to us in the circumstances; and
- Where the collection, use or disclosure is reasonably necessary for the conclusion of a contract between the customer / supplier and us;
- When the customer / supplier is made aware of our intention to collect, use or disclose the personal data and the purpose for the same and does not notify us of its non-consent within a reasonable time;
- In any other circumstances where consent is deemed under the Act (“PDPA”).
4. Collection of Personal Data Pursuant to Exceptions under the PDPA
4.1 From time to time and if required by circumstances, the Company may collect, use or disclose personal data without seeking consent:
Legitimate Interest Exceptions:
- Lawful interest of the Company, such as for evaluative purposes, to recover or pay a debt owed, or for any investigation or legal proceedings;
- Detecting or preventing illegal activities such as fraud or money laundering, or threats to physical safety and security, ensuring IT and network security, and
- Prevent misuse of services
Business Improvement Exceptions:
- Business Improvement such as enhancing or developing new good or services
- Enhancing and developing new processes for business operations
- Learning or understanding behaviour and preferences of groups of individuals or individuals
Research and Development Exceptions:
- Conduct of broader research and development that may not have immediate application to our services or business operations
4.2 The Company will not make use of these exception for direct marketing messages nor disclose to 3rd party vendor or marketing organisations.
4.3 To use these exceptions, the Company will:
- Identify and clearly articulate the legitimate interest situation and purpose
- Conduct an assessment to determine the benefits and likely adverse effect to the individual. The Company is under no obligation to disclose to public the assessment conducted
- As much as possible, inform the affected individuals
- Provide the contact information of the person who is able to address any queries
- In the event of any individual withdraw their consent, the Company may continue to rely on these exceptions to fulfil the purposes of these exceptions
5. LIMITING COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
5.1 Unless permitted by Laws, the Company will not disclose Personal Data to other persons or entities for the advertising, promotion or marketing of such other party’s products and services, and the Group will not sell for payment the Personal Data to anyone for any marketing purpose; without your consent.
6. RETENTION OF PERSONAL DATA
6.1 We 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.
6.2 We 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.
7. Data Access and Correction
7.1 You can submit request to access the personal data we hold about you, please contact our DPO in writing. However, we will need to verify and confirm your identity as well as the nature of your request. We reserve the right, or may, charge a reasonable fee for the processing of any data access request. We seek to provide you with the relevant personal data within 30 days. Where we are unable to respond to you within the said 30 days, we will notify you of the soonest possible time within which we can provide you with the information requested.
7.2 We endeavour to ensure that the personal data we hold about you is accurate and up to date. We realize that such personal data changes frequently with changes of address and other personal circumstance. We encourage you to contact us as soon as possible in order to update any personal data we hold about you. Please contact our DPO. We may require you to verify your identity.
7.3 From time to time, the DPO may reject to proceed with your request, DPO will respond in writing to you. The DPO may not be obliged to provide grounds for the rejection. Should you object to the decision by DPO, you may write to the DPO again to highlight your objection and the DPO will escalate to higher management to review the decision and ground to reject your request. The DPO will endeavour to revert to you within 30 days.
8. WITHDRAWING YOUR CONSENT
8.1 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 us 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 our Data Protection Officer at the contact details provided above.
8.2 Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within fifteen (15) business days of receiving it.
8.3 Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 6.1 above.
8.4 Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
9. PROTECTION OF PERSONAL DATA
9.1 To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as minimised collection of personal data, authentication and access controls (such as good password practices, need-to-basis for data disclosure, etc.), and up-to-date antivirus protection.
9.2 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, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
10. ACCURACY OF PERSONAL DATA
10.1 We generally rely on personal data provided by you (or your authorised representative). 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 our Data Protection Officer in writing or via email at the contact details provided above
11. RETENTION OF PERSONAL DATA
11.1 We 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.
11.2 We 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.
12. TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
12.1 We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and we 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.
13. EFFECT OF POLICY AND CHANGES TO POLICY
13.1 This Policy applies in conjunction with any other policies, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
13.2 We may revise this 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 Policy was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.
13.4 For more information on the Personal Data Protection Act 2012 or to contact the Personal Data Protection Commission (PDPC) please visit http://www.pdpc.gov.sg/.
14. Updates to this Policy
14.1 This policy will be reviewed from time to time to take account of the new laws and technology, changes to our operations and practices and the changing business environment. This policy was last updated on 18 Apr 2022. If you are unsure whether you are reading the most current version, please contact our DPO via email.