- As used in this Policy:
“person” 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 enter or has entered into a contract with us for the supply of any products or services by us, or (c) has submitted a job or internship application with us; and
“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 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 your name, contact information such as your address, email address or telephone number, nationality, gender, date of birth, marital status, photographs and other audio-visual information, employment information, education background, and information about your usage of and interaction with our website.
- Other terms used in this Policy shall have the meanings given to them in the Singapore Personal Data Protection Act (where the context so permits).
Collection, Use and Disclosure of Personal Data
4. We may collect personal data from our customers, business partners, contractors, employees and other individuals such as job applicants. We would only collect data that has been provided to us voluntarily by you or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”).
5. These personal data may be furnished to us in forms filled out by you, face to face meetings, email messages, telephone conversations or through our website(s). We may also keep a record of any contact you have with us. These data would be collected only for business purposes or for the purpose(s) stated by us when we gather the personal data from you.
6. The personal data collected may be used for any or all of the following purposes:
6.1 to provide services to you;
6.2 as part of our business operations;
6.3 for job application and recruitment purposes;
6.4 for billing and reporting, such as for invoicing and account management purposes;
6.5 for follow-up action regarding any complaints, feedback, queries or requests received via our website or any other communication channels; and
6.6 assisting in law enforcement and investigations conducted by any governmental and/or regulatory authority.
7. We may disclose your personal data:
7.1 with your consent, where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods or services requested by you;
7.2 to comply with any applicable laws, regulations, codes of practice, guidelines or rules; or
7.3 with your consent, to third party service providers, agents and other organisations we have engaged to perform any of the functions listed in Paragraph 6 above for us. Any third parties engaged by us will be contractually bound to keep all personal data confidential.
8. The purposes listed in Paragraph 6 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 any contract with you).
Withdrawal of Consent
9. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is withdrawn by you in writing. You may withdraw your consent and request us to stop 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.
10. Depending on the complexity of the request and its impact to our relationship with you, we will cease (and instruct any of our data intermediaries and agents to cease) collecting, using or disclosing the personal data within 30 days of our receipt of your request, unless required or authorised under applicable laws.
Access to and Correction of Personal Data
11. Subject to Paragraph 13 below, within a reasonable timeframe of receiving your request in writing, we will provide you with access to your personal data that is in our possession or control and/or information about the ways in which your personal data has been or may have been used or disclosed by us within a year before the date of the request.
12. Subject to Paragraph 13 below, within a reasonable timeframe of receiving your request in writing, we will correct an error or omission in your personal data that is in our possession or control and send the corrected personal data to other organisations to which the personal data was disclosed within a year before your request was made.
13. If your request relates to personal data which we are processing on behalf of another organisation, we will instead forward your request to the relevant organisation for their necessary action.
14. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
Protection of Personal Data
15. 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 up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to authorised third parties and agents only on a need-to-know basis.
16. However, 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 personal data and are constantly reviewing and enhancing our information security measures.
Accuracy of Personal Data
17. We will make every reasonable effort to ensure that personal data collected by us or on our behalf is accurate and complete.
Retention of Personal Data
18. We may retain your personal data for as long as it is necessary to fulfil the purpose(s) for which it was collected, or as required or permitted by applicable laws.
19. For job applicants, we will retain your personal data for a maximum of six (6) months from your application date.
Cross-border Transfers of Personal Data
20. Unless for business-related needs, we generally do not transfer your personal data to other jurisdictions. 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 applicable personal data protection laws and regulations.
Data Protection Officer
21. You may contact our Data Protection Officer if you have any enquiry, feedback or complaint regarding our personal data protection policies and procedures, if you wish to make any request, or if you believe that information we hold about you is incorrect or out-dated.
22. You may contact our Data Protection Officer via email at firstname.lastname@example.org or phone at +65 6222 7496.
Data Protection Officer
23. We may revise this Policy at any time without any prior notice. Your continued use of our services and/or products constitutes your acknowledgement and acceptance of such changes.
Effective: 15 August 2020
Last Updated: 16 September 2020