Data Protection Policy
We at ABC Horizon Pte. Ltd. (“ABC Horizon”) take our responsibilities under the Personal Data Protection Act 2012 (the “PDPA”) seriously. We also recognize the importance of the Personal Data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your Personal Data.
This Data Protection Policy (the “Policy”) will assist you in understanding how we collect, use, disclose and/or process the Personal Data you have provided to us or that we possess about you, as well as to assist you in making an informed decision before providing us with any of your Personal Data. The term “Personal Data” refers to information that is connected to you as an identifiable individual, defined under the PDPA to mean data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access. This may include, without limitation, your name, address, telephone number, email address, date of birth, gender, information about your preferences, and any other information collected by us where you are identified or identifiable.
This Policy applies to the [products, services,] website(s) provided and/or the business conducted, by ABC Horizon and explains how we handle Personal Data and comply with the requirements of Singapore’s PDPA. If you, at any time, have any queries on this Policy or any other queries in relation to how we may manage, protect and/or process your Personal Data, please do not hesitate to contact our [Data Protection Officer] at: [Insert Contact Information]
1. COLLECTION OF YOUR PERSONAL DATA
- We may collect Personal Data from you through various means, including but not limited to through our website. We will collect your Personal Data in accordance with the PDPA. In general, before we collect any Personal Data from you, we will notify you of the purposes for which your Personal Data may be collected, used and/or disclosed, as well as obtain your consent for the collection, use and/or disclosure of your Personal Data for the intended purposes.
- You have no obligation to provide any of the Personal Data requested by us. However, depending on circumstances, it may be the case that if you do not provide the requested Personal Data, we may not be able to provide you with certain products and services, or otherwise deal with you, that depend on the collection, use or disclosure of your Personal Data.
2. PURPOSES FOR COLLECTION, USE & DISCLOSURE OF PERSONAL DATA
- The Personal Data which we collect from you may be collected, used and/or disclosed for the following purposes:
- facilitating and/or processing your [transaction/relationship] with us;
- facilitating, processing, dealing with, administering, managing and/or maintaining your relationship with us, including but not limited to the provision of products or services to you;
- carrying out your instructions or responding to any enquiry given by (or purported to be given by) you or on your behalf;
- sending you invitations to events held by us;
- contacting you or communicating with you via phone/voice call, text message and/or fax message, email and/or postal mail for the purposes of administering and/or managing your use of the website and/or facilitating your relationship with us or any transactions made by you with us. You acknowledge and agree that such communication by us coold be by way of the mailing of correspondence, documents or notices to you, which coold involve disclosure of certain Personal Data about you to bring about delivery of the same as well as on the external cover of envelopes/mail packages;
- conducting research, analysis and development activities (including but not limited to data analytics, surveys and/or profiling) to improve our services and facilities in order to enhance your relationship with us or for your benefit, or to improve any of our products or services for your benefit;
- carrying out due diligence or other screening activities (including background checks) in accordance with legal or regolatory obligations (whether Singapore or foreign country) applicable to us or our affiliates/associated companies, the requirements or guidelines of governmental authorities (whether Singapore or foreign country) which we determine are applicable to us or our affiliates/associated companies, and/or our risk management procedures that may be required by law (whether Singapore or foreign country) or that may have been put in place by us or our affiliates/associated companies;
- to prevent or investigate any fraud, unlawfol activity or omission or misconduct, whether or not there is any suspicion of the aforementioned; dealing with and/or investigating complaints;
- complying with or as required by any applicable law, court order, order of a regolatory body, governmental or regolatory requirements of any jurisdiction applicable to us or our affiliates/associated companies, including meeting the requirements to make disclosure under the requirements of any law binding on us or our affiliates/associated companies, and/or for the purposes of any guidelines issued by regolatory or other authorities (whether of Singapore or elsewhere), with which we or our affiliates/associated companies are expected to comply;
- complying with or as required by any request or direction of any governmental authority (whether Singapore or foreign country) which we are expected to comply with; or responding to requests for information from public agencies, ministries, statutory boards or other similar authorities (whether Singapore or foreign country). For the avoidance of doubt, this means that we may/will disclose your Personal Data to such parties upon their request or direction;
- monitoring, processing and/or tracking your use of the website in order to provide you with a seamless experience, facilitating or administering your use of our website, and/or to assist us in improving your experience in using our website;
- storing, hosting, backing up (whether for disaster recovery or otherwise) of your Personal Data, whether within or outside Singapore;
- facilitating, dealing with and/or administering external audit(s) or internal audit(s) of the business of ABC Horizon or that of its affiliates/related corporations;
- for marketing purposes and in this regard, we woold be providing you with marketing, advertising and promotional information, materials and/or documents relating to products, contests, services and/or events (including those of third party organisations whom we may collaborate with) that we (including our affiliates/related corporations) or such third party organisations may be selling, marketing, offering, organizing, involved in or promoting, whether such products, services and/or events exist now or are created in the future:
- by way of postal mail, electronic transmission to your email address(es), push notifications, other forms of browser based notifications or harnessing other technologies (such as geo-location technology) on your computers, and/or through other modes of communication that is not the 3 DNC Modes (defined below), in compliance with the PDPA. You may opt out of this or withdraw from this at any time by sending an email to our Data Protection Officer. For the avoidance of doubt, unlike (ii) below, the application of or your acceptance of or your consent to, this Policy, constitutes your consent to this subparagraph (i); and/or
- if you have separately expressly consented to one or more of the following 3 DNC Modes, by way of the 3 modes of communications of voice calls, text messages or faxes (the “3 DNC Modes”) to your Singapore telephone number, in compliance with the requirements of the PDPA.
For the avoidance of doubt, this subparagraph is without prejudice to subparagraph (f) above for which you have hereby consented to us contacting you for a survey, which you may subsequently opt out of by sending our Data Protection Officer notice;
- dealing with and/or facilitating a business asset transaction or a potential business assert transaction, where such transaction involves ABC Horizon as a participant or involves only a related corporation or affiliated company of ABC Horizon as a participant or involves ABC Horizon and/or any one or more of ABC Horizon’s related corporations or affiliated companies as participant(s), and there may be other third party organisations who are participants in such transaction. “business asset transaction” means the purchase, sale, lease, merger or amalgamation or any other acquisition, disposal or financing of an organisation or a portion of an organisation or of any of the business, shares or assets of an organisation;
- to implement and maintain our information technology systems, including to store and process Personal Data in computer databases and servers located within and outside Singapore; and
- reporting and sharing with our Head Office and/or affiliated / related corporations.
- In order to conduct our business operations more smoothly, we may also be disclosing the Personal Data you have provided to us to our third party service providers, agents and/or our affiliates or related corporations, which may be sited outside of Singapore, for one or more of the above-stated Purposes. This is because such third party service providers, agents and/or affiliates or related corporations woold be processing your Personal Data on our behalf for one or more of the above-stated Purposes.
3. SPECIFIC ISSUES FOR THE DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES
- We respect the confidentiality of the Personal Data you have provided to us.
- In that regard, we will not disclose any of your Personal Data to any third parties without first obtaining your express consent permitting us to do so. However, please note that we may disclose your Personal Data to third parties without first obtaining your consent in certain situations, including, without limitation, the following :
- cases in which the disclosure is required based on the applicable laws and/or regolations;
- cases in which the purpose of such disclosure is clearly in your interests, and if consent cannot be obtained in a timely way;
- cases in which the disclosure is necessary to respond to an emergency that threatens the life, health or safety of yourself or another individual;
- cases in which there are reasonable grounds to believe that the health or safety of yourself or another individual will be seriously affected and consent for the disclosure of the data cannot be obtained in a timely way, provided that we shall, as soon as may be practicable, notify you of the disclosure and the purposes of the disclosure;
- cases in which the disclosure is necessary for any investigation or proceedings;
- cases in which the Personal Data is disclosed to any officer of a prescribed law enforcement agency, upon production of written authorisation signed by the head or director of that law enforcement agency or a person of a similar rank, certifying that the Personal Data is necessary for the purposes of the functions or duties of the officer; and/or
- cases in which the disclosure is to a public agency and such disclosure is necessary in the public interest.
- The instances listed above at paragraph 3.2 are not intended to be exhaustive. For an exhaustive list of exceptions, you are encouraged to peruse the Second, Third and Fourth Schedoles of the PDPA which is publicly available at http://statutes.agc.gov.sg.
- In all other instances of disclosure of Personal Data to third parties with your express consent, we will endeavor to provide adequate supervision over the handling and administration of your Personal Data by such third parties, as well as to provide for adequate forms of protection over such Personal Data.
- Where Personal Data is transferred by us to any third parties outside of Singapore, we will ensure that such transfers are compliant with the requirements under the PDPA. In this regard, we will take such necessary measures to ensure that such overseas recipients are bound by legally enforceable obligations to ensure that these overseas recipients provide a standard of protection to the Personal Data so transferred that is comparable to the protection under the PDPA.
4. REQUEST FOR ACCESS AND/OR CORRECTION OF PERSONAL DATA
- You may request to access and/or correct the Personal Data currently in our possession at any time by submitting your request through the following methods :
- Singapore telephone number : +65 [insert details]
- E-mail : [insert details]
- Office address : [insert details]
- For a request to access Personal Data, once we have sufficient information from you to deal with the request, we will seek to provide you with the relevant Personal Data within 30 days. Where we are unable to respond to you within the said 30 days, we will notify you of the soonest possible time within which we can provide you with the information requested. The PDPA exempts certain types of Personal Data from being subject to your access request.
- For a request to correct Personal Data, once we have sufficient information from you to deal with the request, we will deal with your request in compliance with the PDPA, including correct your Personal Data within 30 days. Where we are unable to do so within the said 30 days, we will notify you of the soonest practicable time within which we can make the correction. Note that the PDPA exempts certain types of Personal Data from being subject to your correction request as well as provides for situation(s) when correction need not be made by us despite your request.
- We may also charge you a reasonable fee for the handling and processing of your requests to access your Personal Data. If so, we will provide you with a written estimate of the fee. Please note that we are not required to respond to or deal with your access request unless you have agreed to pay the fee.
5. REQUEST TO WITHDRAW CONSENT
- You may withdraw your consent for the collection, use and/or disclosure of your Personal Data in our possession or under our control at any time by submitting your request to the contact details listed below at paragraph 7.2.
- We will process your request within a reasonable time from such a request for withdrawal of consent being made, and will thereafter refrain from collecting, using and/or disclosing your Personal Data in the manner stated in your request.
6. ADMINISTRATION AND MANAGEMENT OF PERSONAL DATA
- We will take reasonable efforts to ensure that your Personal Data is accurate and complete, if your Personal Data is likely to be used by us to make a decision that affects you, or disclosed to another organisation. However, this means that you must also update us of any changes in your Personal Data that you had initially provided us with. We will not be responsible for relying on inaccurate or incomplete Personal Data arising from you not updating us of any changes in your Personal Data that you had initially provided us with.
- We will also take commercially reasonable efforts to take appropriate precautions and preventive measures to ensure that your Personal Data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorized access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your Personal Data. However, we cannot assume responsibility for any unauthorized use of your Personal Data by third parties which are wholly attributable to factors beyond our control.
- We will also take commercially reasonably efforts to ensure that the Personal Data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that (i) the purpose for which that Personal Data was collected is no longer being served by the retention of such Personal Data; and (ii) retention is no longer necessary for any other legal or business purposes.
7. COMPLAINT PROCESS
- If you have any complaint or grievance regarding about how we are handling your Personal Data or about how we are complying with the PDPA, we welcome you to contact us with your complaint or grievance.
- Please contact us through one of the following methods with your complaint or grievance :
- Singapore telephone number:+65-6808-7773.
- E-mail: [insert details]. Attention it to the ‘Data Protection Officer.
- Office address:11 North Buona Vista Drive, The Metropolis Tower 2 #08-09, Singapore 138589. Attention it to the ‘Data Protection Officer
- Where it is an email or a letter through which you are submitting a complaint, your indication at the subject header that it is a PDPA complaint woold assist us in attending to your complaint speedily by passing it on to the relevant staff in ABC Horizon to handle. For example, you coold insert the subject header as “PDPA Complaint”.
- We will certainly strive to deal with any complaint or grievance that you may have speedily and fairly.
8. UPDATES ON DATA PROTECTION POLICY
- As part of our efforts to ensure that we properly manage, protect and process your Personal Data, we will be reviewing our policies, procedures and processes from time to time.
- We reserve the right to amend the terms of this Policy at our absolute discretion. Any amended Policy will be posted on our website and can be viewed at [website address to be finalised after this Annex has been appropriately customized to be customer friendly].
- You are encouraged to visit the above website from time to time to ensure that you are well informed of our latest policies in relation to Personal Data protection.
- Your consent that is given pursuant to this Policy is additional to and does not supersede any other consents that you provided to ABC Horizon with regard to processing of your Personal Data.
- For the avoidance of doubt, in the event that the PDPA permits an organisation such as us to collect, use or disclose your Personal Data without your consent, such permission granted by the law shall continue to apply.
Last Updated on [insert date of current version]
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