We are committed to protecting your personal data and ensuring that we collect, use and disclose appropriately, lawfully and transparently. This data protection policy explains how we comply with the requirements of Personal Data Protection Act 2012 of Singapore and its regulation(s) (“PDPA”). In this policy, “personal data” refers to information about an individual such as name, date of birth, contact details etc.
1. Collection of Personal Data
We collect personal data from clients, business contacts, partners, employees, representatives, contractors and other individuals. Such personal data may be provided to us in forms filled out by individuals, face to face meetings, email messages, telephone conversations, through our websites or provided by third parties.
We collect these personal data when it is necessary for business purposes or to meet the purposes for which the individuals have submitted the information. We will only collect, hold, process, use, communicate and/or disclose such personal data, in accordance with this policy.
If any party is acting as an intermediary or otherwise on behalf of a third party individual or supplying us with information regarding a third party individual (such as a friend, a colleague, an employee etc), such intermediary party undertakes that you are an authorised representative or agent of such third party individual and that you have obtained all necessary consents from such third-party individual to the collection, processing, use and disclosure by us of their personal data. Because we are collecting the third-party individual’s data from you, you undertake to make the third party individual aware of all matters listed in this policy preferably by distributing a copy of this policy to them or by referring them to our website.
2. Use of Personal Data
In general, we use personal data for the following purposes unless as specified upon obtaining consent from individuals:
Individual may choose to withdraw their consent or unsubscribe from registrations or mailing lists to stop receiving marketing information by contacting our Data Protection Officer or through email instruction. Such requests will be processed within 30 days.
3. Disclosure of Personal Data
We do not disclose personal data to third parties except when required by law, when we have the individual’s consent or deemed consent or in cases where we have engaged third parties such as data intermediaries or subcontractors specifically to assist with our activities. Any such third parties whom we engage will be bound contractually to keep all information confidential.
We may disclose personal data to other third-party firms where it is necessary (i) to meet the purpose for which such individual has submitted the information; or (ii) to enable such individual to be provided with information at a later date which may be of relevance and interest to such individual based on the nature and purpose of such individual’s voluntary requests.
4. Access to and Correction of Personal Data
Upon request, we will provide the individual with access to their personal data or other appropriate information on their personal data in accordance with the requirements of the PDPA.
Upon request, we will correct an error or omission in the individual’s personal data that is in our possession or control in accordance with the requirements of the PDPA.
We may charge for a request for access in accordance with the requirements of the PDPA.
5. Withdrawal of Consent
Upon reasonable notice being given by an individual of his withdrawal of any consent given or deemed to have been given in respect of our collection, use or disclosure of his personal data, we will inform the individual of the likely consequences of withdrawing his consent. We will cease collecting, using or disclosing the personal data unless it is required or authorised under applicable laws within 30 days.
6. Accuracy of Personal Data
We make reasonable effort to ensure that personal data collected by us or on our behalf is accurate and complete. We may request individuals to provide supporting documents or to confirm the data provided by them is accurate by obtaining their declaration.
7. Security and Protection of Personal Data
We put in place reasonable technology and operational security to protect the personal data in our possession or under our control and to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. Only authorised personnel are provided access to personally identifiable information and these personnel have agreed to ensure confidentiality of this information.
8. Retention of Personal Data
We will cease to retain personal data, as soon as it is reasonable to assume that the purpose for collection of such personal data is no longer being served by such retention, and such retention is no longer necessary for legal or business purposes.
9. Transfer of Personal Data outside of Singapore
We will ensure that any transfers of personal data to a territory outside of Singapore will be in accordance with the PDPA so as to ensure a standard of protection to personal data so transferred that is comparable to the protection under the PDPA.
10. Privacy on Our Websites
This Policy also applies to any personal data we collect via our websites. Cookies may be used on some pages of our websites. “Cookies” are small text files placed on your hard drive that assist us in providing a more customised website experience. Cookies are now used as a standard by many websites to improve users’ navigational experience. If individuals are concerned about cookies, most browsers permit individuals to decline cookies. In most cases, a visitor may refuse a cookie and still fully navigate our websites, however other functionality in the site may be impaired. After termination of the visit to our site, a visitor can always delete the cookie from his system if he wishes.
If an individual wishes to withdraw consent given to us, or if an individual believes that information we hold about him or her is inaccurate or out of date and wishes to correct the personal data, or if an individual would like to access the personal data handled by us, or if an individual has concerns or further queries about how we handle personal data, or for any problem or complaint about such matters, please contact our Data Protection Officer, Evon Lim via the form below, or call us on our main line, +65 6654 1787.
We reserve the right to modify or amend this policy at any time.
229 Mountbatten Road
#03-30 Mountbatten Square
Main Line: +65 6654 1888
Fax: +65 6654 1887