Under certain circumstances, we may deem that you have provided consent when you voluntarily provide your personal information for specific relevant purposes. For example, when you provide your name and contact information for the creation of an account, it is deemed that you have provided consent in relation to the creation of a profile linked to such account.
We may also rely on exceptions to the need for consent under certain circumstances such as the following:
Information We Collect
We may collect and process certain types of personal information. “Personal information” is data that relates to you and can (on its own or in combination with other information) identify you as an individual, whether true or not. It does not include data that has been aggregated or made anonymous whereby you can no longer be identified using means reasonably available to us.
Personal information includes, among other things, personal information that you voluntarily provide on this website, which may include your:
and any other types of information that you choose to upload, communicate or otherwise provide to us or that we may collect about you through our provision of any Services or your transactions with us in general, which may include any inquiries or feedback which we receive from you.
In addition, we may also collect personal information provided by other organisations such as your employer, company or third-party sources (including other entities we believe you have authorised to provide such personal information for and on your behalf, such as business partners, unaffiliated third-party social media companies, data brokers and analysts (via data analytics tools or otherwise), or other information providers, or other commercially and publicly available and legitimate sources as permissible by applicable law). We set out the privacy policies of certain relevant third-party websites for your reference – Kindly familiarise yourself with these and ensure that you are comfortable with them:
We also may collect information about you that is not personal information, which may include anonymised or aggregated information, intellectual property or other company information shared with us, from your use of the Services or otherwise. Where necessary, we may combine this information with personal information or other information that we receive from or about you to provide the Services you require in the manner set out below, which combination of such information possibly could be used to identify you personally.
How We Collect, Use and Process Your Personal Information
We may collect, use and/or process your personal information for the following purposes:
Disclosure of Personal Information and Other Information
We may disclose your information, including personal information:
Please review the privacy policies of any website or application that referred you to our websites or applications, or which you are accessing from our websites or application as we are unable to place limitations on their use of personal information.
Accuracy and Security of Personal Information
Where we have an ongoing relationship with you, it is crucial that you update us of any changes or updates to your personal information. As such, we may from time to time do data verification exercises for you to provide us with any such updates.
We strive to protect the security of your information and are constantly reviewing and enhancing our information security measures. We take reasonable effort to implement appropriate administrative, technical, personnel, and physical measures (a) to safeguard personal information against loss, theft, unauthorised use, copying, disclosure, or modification; and (b) to ensure the integrity of the personal information, as encapsulated in our internal data protection rules and PDPA compliance policies. For example, we have the Azure Web Application Firewall set up in place and use the HTTPS protocol throughout our websites and web applications to provide centralised protection from common vulnerabilities and exploits in general, as well as to specifically ensure that our user communications with the servers are encrypted so that personal information are unlikely to be hijacked by third parties without authorisation. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is 100% secure, in particular the transmission of data over open or public networks. Therefore, we recommend against transmitting any confidential or sensitive data over open or public networks.
In the unlikely event that we suffer a data breach in relation to personal information, we will assess whether the data breach is notifiable, and will attempt to notify the affected persons and/or the PDPC where it is assessed to be notifiable. To be clear, a data breach does not trigger any obligation to notify affected persons and/or the PDPC. For this purpose, a “data breach” in relation to personal information means (a) the unauthorised access, collection, use, disclosure, copying, modification or disposal of personal information; or (b) the loss of any storage medium or device on which personal information is stored in circumstances where the unauthorised access, collection, use, disclosure, copying, modification or disposal of the personal information is likely to occur.
Retention of Data
Any personal information in our possession or under control will be destroyed and/or anonymised when:
Transfer of Personal Information to Other Countries
Access, Correction and Withdrawal
The consent that you provide for the collection, use, disclosure and retention of all or any parts your personal information will remain valid until such time it is being withdrawn by you in writing.
You may request to access and/or correct the personal information currently in our possession or withdraw your consent for the collection, use, disclosure and/or retention of your personal information in our possession or under our control at any time by contacting us at email@example.com. Where appropriate, such request may be referred to the relevant data protection officer. To the extent possible, we may take steps to verify your identity before granting access or making any changes to your personal information to protect your privacy.
For a request to access personal information, we will process your request within a reasonable amount of time from when the request is made.
For a request to correct or update personal information, we will process your request as soon as practicable after the request has been made. Such correction or update may involve necessary verification, which may include sending the corrected or updated personal information to other organisations to which the personal information was disclosed within a year before the date the correction or update was made (unless that other organisation does not need the corrected personal information for any legal or business purpose), or if you so consent, only to specific organisations to which the personal information was disclosed by us within a year before the date the correction or update was made.
While we will, in most instances, provide a copy of the requested information or make the requested correction or update, where we are unable to provide you with any records of personal information or to make a correction or update requested, we shall, where required under applicable law or otherwise appropriate, inform you of the reasons why we are unable to do so. Please note that depending on the request that is being made, we will only need to provide you with access to the personal information contained in the documents requested, and not to the entire documents themselves. In those cases, it may be appropriate for us to simply provide you with confirmation of the personal information that we have on record, if the record of your personal information forms a negligible part of the document.
We may also charge a reasonable fee for the handling and processing of your requests to access, correct and/or update your personal information. You will be notified in advance of such costs.
For a request to withdraw your consent to the processing of personal information, we will process your request within a reasonable amount of time from when the request is made. Our ability to provide Services to you after such withdrawal may be affected. We will notify you of any impact before processing your request.
If you have registered your Singapore telephone number with any or all of the Singapore Do Not Call (“DNC“) registers (being the No Voice Call Register, the No Text Message Register and the No Fax Message Register), we will not send you promotional and marketing messages via SMS, fax, calls and other means, to the extent the respective Register(s) is/are applicable. However, if you have previously consented to our sending you such calls or messages to your Singapore telephone or facsimile number(s), we will continue to do so until you withdraw such consent in writing, regardless of your DNC nominations (prior or subsequent to such consent).
Also, if you currently have an existing, ongoing relationship with us, depending on the nature of that relationship, we may continue to send you promotional or marketing messages via SMS, fax, calls or any means, about Services which are related to that ongoing relationship notwithstanding your registration with the DNC Registry, unless you opt-out of receiving such messages by requesting for withdrawal in writing.
Questions or Feedback
Last Updated 16 March 2023