Privacy Policy
PERSONAL DATA
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In this Privacy Policy,
"customer" means an individual who has contacted us through any means to find out more about any goods or services we provide, or may/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 an individual who can be identified 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, nationality, gender and employment information, as well as device and technical information such as IP address, browser type and version, device identifiers, cookie identifiers and similar technologies, usage logs, interaction and communication records, preferences and feedback that you choose to provide.
- Other terms used in this Privacy Policy shall have the meanings given to them in the PDPA (where the context so permits).
COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
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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 (or your authorised representative) have provided consent (which may be in writing or in a manner permitted under applicable law) 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. You may withdraw your consent at any time, subject to reasonable notice and our assessment of the request in accordance with the PDPA.
We will 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 (unless such collection or use without consent is permitted or authorised by law). Where practicable, we will provide you with a clear notification of the new purpose and how you may provide or decline consent.
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We may collect and use your personal data for any or all of the following
purposes:
(a) performing obligations in the course of or in connection with the provision of the goods and/or services requested by you;
(b) verifying your identity;
(c) responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
(d) complying with any applicable laws, regulations, codes of practice, guidelines or rules, or assisting in law enforcement and investigations conducted by any governmental and/or regulatory authority;
(e) monitoring website performance, analysing user behaviour and improving user experience (including using cookies to track traffic, heatmaps and preferences), and, where legally required, obtaining consent for non-essential cookies/trackers and providing you with choices to manage your preferences;
(f) ensuring information security, fraud prevention and detection, incident response, and maintaining logs and audit trails as reasonably necessary for security and compliance purposes;
(g) conducting internal reporting, analytics, training, quality assurance, research and development, and service improvement (including using de-identified or aggregated data where appropriate);
(h) managing our business operations, including contract administration, billing, payments, account management, record-keeping, and responding to legal demands or claims;
(i) any other purposes for which you have provided the information;
(j) transmitting to any unaffiliated third parties including our third-party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
(k) any other incidental business purposes related to or in connection with the above.
Where personal data is transferred outside Singapore, we will implement appropriate legal, technical and organisational measures to ensure a standard of protection that is at least comparable to that provided under the PDPA, including data processing/transfer agreements, standard contractual clauses, encryption and access controls.
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We may disclose your personal data:
(a) where such disclosure is required or reasonably necessary for performing obligations in the course of or in connection with the provision of the goods and/or services requested by you; or
(b) to our third party service providers, agents, contractors, professional advisers (including auditors and lawyers), affiliates and other organisations engaged by us to perform any of the functions with reference to the above- mentioned purposes, subject to appropriate confidentiality and data protection obligations;
(c) to any competent governmental, regulatory, supervisory, tax or law enforcement authorities, courts or tribunals, or to comply with applicable laws, regulations, codes of practice or rules, or to establish, exercise or defend legal claims; and
(d) with your consent, or as otherwise permitted under applicable law.
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Cross-border disclosures. Where personal data is disclosed to recipients outside Singapore, we will implement appropriate legal, technical and organisational measures to ensure a standard of protection that is at least comparable to that provided under the PDPA, including data processing/transfer agreements, standard contractual clauses, encryption and access controls.
WITHDRAWING YOUR CONSENT
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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 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 below.
For the avoidance of doubt, your withdrawal of consent will not affect our processing to the extent necessary for complying with applicable laws and regulations, or for the performance of a contract with you. Where applicable, you may withdraw consent selectively (e.g., for specific marketing communications) while retaining consent for other purposes.
If you wish to opt out of marketing emails, you may also do so at any time by using the unsubscribe link provided in our emails or by contacting us.
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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 ten (10) business days of receiving it.
Where we require additional time due to complexity or where verification of your identity is needed, we will inform you of the reasonable time required and keep you updated on the status.
Please note that certain communications (e.g., service notices and transactional or customer support messages) are not affected by marketing opt- out preferences.
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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 7 above.
Even if you withdraw consent, we may retain and process your personal data as permitted or required under applicable law (including for record-keeping, establishing, exercising or defending legal claims, and compliance purposes), and only for so long as necessary for those purposes.
- Please note that withdrawing consent does not affect our 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. For the avoidance of doubt, we may continue processing to the extent necessary to comply with applicable laws and regulations or to perform a contract with you. After withdrawal of consent, we will cease collecting and using your personal data for website analytics and delete relevant cookies data within 7 days, subject to technical limitations and where feasible, but this will not affect the fulfilment of existing service obligations. Please note that certain service notices and transactional or customer support messages are not affected by marketing opt-out preferences.
ACCESS TO AND CORRECTION OF PERSONAL DATA
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If you wish to make (a) an access request for access to a copy of the personal
data which we hold about you or information about the ways in which we use
or disclose your personal data, or (b) a correction request to correct or update
any of your personal data which we hold about you, you may submit your
request in writing or via email to our Data Protection Officer at the contact
details provided below.
We may require you to provide sufficient information to verify your identity and to facilitate processing of your request (e.g., the specific data or timeframe concerned). Where lawful, we may provide access in a reasonable alternative form (such as a summary) if providing a direct copy is not reasonably practicable or would adversely affect the rights and freedoms of others.
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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.
We do not charge a fee for a correction request, unless the request is manifestly unfounded or excessive. If we charge a fee for access, we will explain the basis of the fee and proceed only after receiving your confirmation to continue.
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We will respond to your request as soon as reasonably possible. In general,
our response will be within ten (10) business days. Should we not be able to
respond to your request within thirty (30) days after receiving your request, we
will inform you in writing within thirty (30) days of the time by which we will be
able to respond to your request. If we are unable to provide you with any
personal data or to make a correction requested by you, we shall generally
inform you of the reasons why we are unable to do so (except where we are
not required to do so under the PDPA).
Where we require additional time due to the complexity of the request, third- party data implications, or the need to verify your identity, we will notify you of the extension and keep you updated on the status.
Where an access request would unreasonably interfere with the privacy of others, reveal confidential commercial information, or is otherwise subject to exceptions under the PDPA, we may refuse or provide access in a limited form and will, where required, provide the basis for such refusal.
For correction requests, if we disagree with your requested correction, we will annotate the personal data with your view (where required by law) and inform you of our reasons, unless we are not required to do so under the PDPA.
PROTECTION OF PERSONAL DATA
- 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 web security measures that are reasonable and proportionate to the risks involved.
- 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 will take reasonable and appropriate measures to protect the security of your information and are committed to constantly reviewing and enhancing our information security measures. Without limiting the foregoing, Internet communications may be susceptible to interference or interception by third parties, and we do not warrant that our Site is free of viruses or other unauthorised software to the fullest extent permitted by applicable law.
ACCURACY OF PERSONAL DATA
- 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 below. We may require sufficient information to verify your identity and to identify the specific data to be updated. Where appropriate, you may also update certain details through the self-service account/profile settings (if available).
RETENTION OF PERSONAL DATA
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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.
We apply reasonable retention schedules based on the nature of the data, legal/regulatory requirements, limitation periods for claims, and our operational needs. Where we process personal data on behalf of another organisation, retention may also follow that organisation's instructions and applicable contracts.
- 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, subject to technical limitations (e.g., system backups) and to the extent feasible. In particular, website analytics data will generally not be retained for more than two (2) years, unless a longer period is required or permitted by law or necessary for the establishment, exercise or defence of legal claims.
TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
- We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, 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. Where consent is required by law, we will obtain your consent for the transfer. If using cross-border analytics tools (e.g., Google Analytics), we will implement appropriate safeguards (for example, data transfer contractual clauses and technical/organisational measures) to ensure PDPA-level protection.
MANAGE COOKIES
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When you visit our website, we use cookies to improve your experience. You
must explicitly consent (opt-in) to enable non-essential cookies (analytics) via
a pop-up banner to accept/reject. Essential cookies (functional) are
automatically enabled and are necessary for the site to work or to remember
your privacy choices. These cookies help us record information about your
device or browser, as well as your preferred settings.
Our website may store or retrieve information on your browser, mainly through cookies. This data could relate to you, your preferences, or your device. While it usually does not directly identify you, it enables a more personalised browsing experience.
We use cookies to monitor website performance and for analytics. They help us count visits and track traffic sources, allowing us to evaluate and enhance our site's functionality. Additionally, these cookies reveal which pages are most and least popular and show how users navigate through the site. Some cookies may also be used to create a profile of your interests to provide you with relevant content or messages. These cookies do not store personal information directly but may rely on uniquely identifying your browser and internet device.
You may withdraw consent at any time through your browser settings, and we will respect your choice. Please note that disabling certain cookies may affect site functionality.
CONTACT
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You may contact our Data Protection Officer (DPO) for any queries, feedback
or requests as follows:
Name of DPO:Mr. Shieh Ping LungEmail Address:Address:2 International Business Park, The Strategy, Tower One, #02-06/07, Singapore 609930
We will make our best effort to respond to your feedback and/or request within thirty (30) days.
EFFECT OF PRIVACY POLICY AND CHANGES TO NOTICE
- 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 us.
- We may revise this Privacy Policy from time to time. Non-material updates may be made without prior notice. For material revisions (e.g., introducing new purposes, expanding data categories or disclosures that may materially impact you), we will provide prior notice, and where required by law or where the change materially affects how we process your personal data, we will seek your renewed consent. 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 our services constitutes your acknowledgment and acceptance of such changes. Where renewed consent is required and not obtained, we will not proceed with the affected processing unless another legal basis applies.