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Privacy Policy Notice - Personal Data Protection Act

1. Introduction

  • 1.1.
    This privacy policy sets out how we comply with the provisions of the Personal Data Protection Act 2012 of Singapore (“PDPA”) as follows:
    • (a)
      our policies on how we manage your Personal Data;
    • (b)
      the types of Personal Data we collect, use, disclose and/ or retain;
    • (c)
      how we collect, use, disclose and/ or retain your Personal Data; and
    • (d)
      the purpose(s) for which we collect, use, disclose and/ or retain your Personal Data.
  • 1.2.
    We will collect, use or disclose Personal Data for reasonable business purposes only if there is consent or deemed consent from the individual and information on such purposes have been notified.
  • 1.3.
    We may also collect, use or disclose Personal Data if it is required or authorised under applicable laws.
  • 1.4.
    You agree and consent to us, our authorised service providers and third parties to collect, use and disclose and/ or retain your Personal Data in accordance with this privacy policy.
  • 1.5.
    This privacy policy supplements but does not supersede nor replace any other consent which you may have previously provided to us nor does it affect any right that we may have at law in connection with the collection, use, disclosure and/ or retention of your Personal Data.
  • 1.6.
    From time to time, we may update this privacy policy to ensure that our policy is consistent with any regulatory changes, however, subject to your legal rights in Singapore, the prevailing terms of the privacy policy shall apply.

2. Personal Data

  • 2.1.
    In this privacy policy, “Personal Data” refers to any data and/or information about you from which you can be identified by, either from that data; or from that data and other information to which we may have legitimate access to.
  • 2.2.
    Examples of such Personal Data include but are not limited to:
    • (a)
      your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address and any other information relating to you which you have provided in any forms you may have submitted to use, or in other forms of interaction with you;
    • (b)
      your photos;
    • (c)
      your employment history, education background, and income levels;
    • (d)
      Personal Data of your family members, such as next of kin, spouses, and children; and
    • (e)
      information about your usage of and interaction with our website and/or services.

3. Collection of Personal Data

  • 3.1.
    We collect Personal Data from clients, customers, business contacts, partners, personnel, contractors and other individuals.
  • 3.2.
    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.
  • 3.3.
    If any individuals contact us, we may keep a record of that contact.
  • 3.4.
    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.
  • 3.5.
    We will only collect, hold, process, use, communicate and/or disclose such Personal Data, in accordance with this privacy policy.
  • 3.6.
    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.
  • 3.7.
    As 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 privacy policy preferably by distributing a copy of this privacy policy to them or by referring them to our website.

4. Use of Personal Data

In general, we may use your Personal Data for the following purposes:

  • (a)
    to provide our services;
  • (b)
    to respond to the individual’s request or for the purposes for which it was provided to us as stated at the time of the collection (or as is obvious from the context of collection);
  • (c)
    to maintain contact with clients, contractors and other contacts;
  • (d)
    for general management and reporting purposes;
  • (e)
    for recruitment purposes;
  • (f)
    for purposes related to the employment of our personnel and providing internal services to our personnel;
  • (g)
    all other purposes related to our business; and
  • (h)
    to comply with applicable laws and regulations.

5. Disclosure of Personal Data

  • 5.1
    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 company’s activities.
  • 5.2
    We may also disclose your Personal Data to the following group of external organisations, subject to the requirements of applicable laws:
    • (a)
      our affiliated companies;
    • (b)
      agents, contractors, data intermediaries or third-party service providers who provide services, such as telecommunications, mailing, information technology, payment, payroll, data processing, storage and archival, to us;
    • (c)
      external banks, financial institutions and their respective service providers;
    • (d)
      our professional advisers;
    • (e)
      relevant government regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any government authority; and
    • (f)
      any other person in connection with the purposes set forth above.

6. Third-Party Sites

  • 6.1.
    Our website may contain links to other websites operated by third parties independent of us, but we are not responsible for the privacy practices of such websites operated by third parties even though it is linked to our website(s).
  • 6.2.
    We encourage you to learn about the privacy policies of such third-party website(s) by checking the policy of each site you visit and contact its owner or operator if you have any concerns or questions.

7. Protection of your Personal Data

  •  
    We maintain appropriate security safeguards and practices to protect your Personal Data unauthorised access, collection, use, disclosure, copying, modification disposal or similar risks, in accordance with applicable laws.

8. Access and Correction of your Personal Data

  • 8.1.
    We take all reasonable measures to ensure that your Personal Data remains accurate, complete and up-to-date.
  • 8.2.
    You may also keep us informed when there are any updates to your Personal Data by contacting us directly.
    8.3.
    You may request access to or make corrections to your Personal Data records, but we have the right to charge a reasonable fee for processing your request.
  • 8.4.
    Please submit your request to us by writing to our Data Protection Office at MOPS.PDPCommittee@modec.com or MMS.PDPCommittee@modec.com.

9. Withdrawal of Consent

10. Contacting Us

  •  
    If you have any questions or complaints relating to the use or disclosure of your Personal Data, or if you wish to know more about our data protection policies and practices, please contact our Data Protection Office via email at MOPS.PDPCommittee@modec.com or MMS.PDPCommittee@modec.com.