Privacy Policy
Our Privacy Policy
To meet the objectives of the Personal Data Protection Act 2012, when we process personal data, we have a privacy policy.
Our privacy policy also specifies how you can contact us to update your data, submit requests, ask questions, or provide feedback on our privacy methods and practices.
Our group (depending on context, 'we', 'us' or 'our') is a company registered under PDPA laws. We respect the protection of your personal data and value the relationship we have with you.
This privacy policy ('PDP') describes the types of personal data we may collect from you, how we use this information, and with whom we share it. Our policy also describes the measures we take to protect the security of the information you provide, including, but not limited to, this website. We also inform you how to contact us to update your personal data, ask questions about our privacy practices, or provide feedback.
Personal data in this policy refers to data, whether true or not, about a person who can be identified from this data or other information that the organization has or is likely to have access to.
Personal Data – What We Collect
The types of personal data we may collect about individuals may include, but are not limited to, the following:
Personal information (e.g., name, date of birth, contact information, residential address, NRIC/FIN/Passport details and/or educational data)
Financial information (e.g., income, expenses, taxes, insurance, risk profile, investments, business interests, assets, financial goals, knowledge, experience, bank accounts, transactions and/or credit history)
Signature sample
Audio, video, and image recordings
Employment information and related details (e.g., occupation, title and positions, duties and responsibilities, employment history, compensation and/or benefits)
Personal opinions provided to us (e.g., feedback or survey responses)
You may have provided us with personal data yourself or authorized others to submit your personal data to us and consented (on your behalf) to the collection of your personal data by those individuals.
If you provide us with personal data about yourself, you confirm that you agree to the use, disclosure, storage, and processing of this personal data for the purposes described in the section “Personal Data – Why We Collect It” or for other purposes for which your consent has been obtained.
If you provide us with personal data about other people, you confirm that you are authorized to disclose it and to agree on their behalf to the use, disclosure, storage, and processing of this personal data for the purposes described in the section “Personal Data – Why We Collect It” or for other purposes for which authorized consent has been obtained on their behalf.
**Personal Data – Why We Collect It
The personal data we collect may, but is not necessarily, used for the following purposes:
If you are a Supplier / Service Provider / Business PartnerTo conduct due diligence/background checks required by legal regulations or our internal policies, requirements and practices
To facilitate the provision of products and services and support by vendors/service providers/business partners
To inform vendors/service providers/business partners about changes to our policies
To evaluate and improve our products and services
To assess products and services provided by vendors/service providers/business partners
To facilitate interactions with us
To conduct due diligence/background checks required by legal regulations or our internal policies, requirements and practices
To facilitate the provision of products and services and to communicate with customers in connection with providing products and services
To evaluate and improve our products and services
To respond to inquiries or comments regarding our products and services
To evaluate applications for employment/positions in our company
To conduct due diligence/background checks on applicants
To organize and manage events for charitable and nonprofit purposes
For security clearance/access control to our premises
We collect and use personal data only for purposes you have agreed to and for which we are authorized. If we need to use your personal data for a purpose you have not previously agreed to, we will obtain your consent before using your personal data for the new purpose.
Personal Data – Disclosure, Sharing, and Transfer
We do not sell or rent personal data collected from individuals, including our website visitors. In connection with providing our products and services to our customers, we may disclose, share, and transfer personal data to the following parties for the following purposes:
To our agents/suppliers/subcontractors/consultants/business partners for the purpose of providing products and services to our customers on our behalf
To government and non-government authorities, agencies and/or regulatory bodies, as required by law or as per instructions or orders from government and non-government authorities, agencies and/or regulatory bodies for security or regulatory approvals or permits
To other companies to respond to questions, concerns, comments or feedback regarding our products or services or our business, or to share knowledge on topics such as industry developments, our business, market outlook, corporate events, and other products and services that may be of interest to your company, organization or business
To other companies to facilitate the provision of products and services to our customers if the project or collaboration involves other companies
To organizers and service providers for planning events/functions that we organize or participate in
We may transfer, store, process, and/or handle your personal data outside the country. If we do so, we will comply with the PDPA and other applicable privacy and data protection laws.
We may also disclose and transfer personal data to the following parties for the purpose of managing, operating, organizing, and running our business as well as for our business and legal purposes:
To other companies for security purposes
To other companies to evaluate our products, services and business as a group
To financial institutions for payments and transactions related to providing our products and services or in connection with products and services provided to us by our suppliers/service providers/consultants
To our service providers (who may be located outside the country) engaged to provide services on our behalf or on behalf of our companies, including:
Service providers that provide IT and outsourcing services, such as data storage, email services, IT management operations and HR outsourcing services
Professional, financial and legal advisors, tax advisors, auditors, insurers and insurance brokers
Suppliers, service providers and consultants engaged to manage, operate, administer and execute our business processes or to provide services supporting the delivery of our products and services
External contractors to provide consulting and evaluation services for us and our products and services or to organize events for us
For applicants, your personal data may be shared with other companies in the group if we believe you may be suitable or qualified for another position within our group, unless you inform us otherwise (see Section 7). The personal data will be used confidentially to assist our group in monitoring recruitment processes.
We require that parties to whom we transfer personal data, as well as our service providers, implement reasonable protection measures to safeguard personal data. We also require that these parties process personal data solely for the purposes for which we engaged them and in accordance with the purposes described in the section “Purposes for which we collect and use personal data” or other purposes for which consent has been obtained.
Additionally, we may disclose personal data in the following cases:
when we are legally required to do so
in response to a request from law enforcement or other government officials
to comply with a court order or instruction from a government or regulatory authority to disclose personal data
when disclosure is necessary for investigations or legal proceedings
Cookies & Internet Technologies
Websites and other online and mobile applications [“apps”] that we may own or operate may place small text files called cookies on your computer or mobile device when you visit a website or use an app. Cookies collect data such as IP addresses and other information related to your visit or use of our websites or apps. We use cookies and other technologies to facilitate and improve your interaction with our systems and to track the effectiveness of our websites and apps.
We may also use pixel tags or web beacons, which are invisible tags placed on web pages, not on your computer. Pixel tags are typically used with cookies to track user behavior visiting the website.
You can set your web browser to block cookies, preventing pixel tags from tracking your website visit. You can also remove stored cookies from your computer or mobile device. However, blocking cookies and pixel tags may prevent you from using certain features and functions of our websites.
Our websites may contain links to other websites not operated by us. This privacy policy applies only to our websites. When visiting other websites, you should read their privacy policies regarding the use of their websites.
Protection of Personal Data
We have security measures in place to protect personal data from accidental or unauthorized access, collection, use, disclosure, copying, distribution, disposal, deletion, alteration, and similar risks.
Retention of Personal Data
We retain personal data only as long as necessary for the purposes for which we collected the personal data, as described in this policy, and for our business and legal purposes.
As a general rule, we do not retain personal data for longer than 7 years after the original purposes for which the personal data was collected no longer apply, unless the law or binding court or authority orders specify otherwise, or retention is necessary for legal proceedings or similar investigations.
For unsuccessful applicants, we do not retain your personal data for more than one year to assess your suitability for future positions within our group unless you inform us otherwise (see Section 7).
How to Contact Us
If you have questions or comments about this policy or our policies and practices regarding collection, use, disclosure, or retention of personal data, you can contact our Data Protection Officer:
If you are applying as an applicant and wish to inform us that:
if you do not want us to share your personal data with other companies in our group to assess your suitability for another position within our group other than the one you applied for, or
if you do not want us to retain your personal data to assess your suitability for future positions within our group, please contact us:
Updating or Correcting Your Personal Data
We take reasonable steps to ensure that personal data we collect about individuals is accurate and complete. Therefore, we request to be informed of any changes or updates to personal data.
If your personal data changes or needs updating, or if a correction of personal data we hold about you is required, please write to us and provide the following details:
Your name
An address where you can be contacted
The nature of our relationship with you
The personal data to be changed, updated or corrected
You can send your requests to our Data Protection Officer using the contact details in Section 7 above. We will aim to acknowledge receipt of your request within seven working days.
As it is important that the personal data we hold about you is accurate and complete, we may request supporting documents from you. We will contact you if such documents are needed.
There may be circumstances in which we do not update or correct personal data, including:
The personal data consists of opinion data retained solely for evaluation purposes
The personal data is in documents related to law enforcement where all associated proceedings have not yet been completed
Requests & Feedback on Personal Data
You may request information on the personal data we hold about you and how we used and disclosed your personal data in the past year before the date of your request. To learn more about how to make an access request, please see our Information Request Notice.
You may withdraw your consent for the use, collection, disclosure, or processing of your personal data by our group at any time. To learn more about how to withdraw consent, please see our Withdrawal of Consent Notice.
Please note that withdrawing your consent for the use of your personal data may affect the provision of our products and services to you or our business relationship with you, depending on the nature of your relationship with us.
If you have concerns, feedback, or complaints regarding the use and/or disclosure of your personal data, we welcome your feedback or complaint. To learn more about how to submit a complaint regarding our use and/or disclosure of your personal data, please see our Feedback and Complaint Notice.
Policy Updates
We may change or update parts of this policy at any time without prior notice. Please review this policy from time to time to stay informed about changes or updates. We will indicate the effective date of the policy. If you disagree with the changes or updates to the policy, you have the option to withdraw your consent to the collection, use, disclosure, and processing of your personal data (see Section 9 above).
