A. PERSONAL DATA
1. As used in this Policy:
(a) “individual” means any person who (i) has contacted us or interfaced with us through any means, (ii) may, or has, entered into a contract or relationship with us, or (iii) has visited our physical locations or otherwise engaged with any of our staff; and
(b) “personal data” means data, whether true or not, about an individual who can be identified (i) from that data, or (ii) from that data and other information to which we have or are likely to have access.
2. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include your name and identification information such as your NRIC number or other government identification number, contact information such as your address, email address or telephone number, nationality, gender, date of birth, marital status, photographs and other audio-visual information, employment information, medical information, and financial information such as credit card numbers, debit card numbers or bank account information.
3. Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context so permits).
B. COLLECTION, USE, RETENTION AND DISCLOSURE OF PERSONAL DATA
4. We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third-party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by applicable law).
5. We may collect, use, retain, or disclose your personal data for any or all of the following purposes:
(a) performing or fulfilling obligations entered into with you (or where applicable, your employer), whether directly or indirectly;
(b) verifying your identity;
(c) responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
(d) managing your relationship with us;
(e) processing payment or credit transactions;
(f) sending your marketing information about our goods or services including notifying you of our marketing events, and initiatives and promotions;
(g) complying with any applicable laws, orders of a competent court, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
(h) operating and tracking traffic (for data analytics) to our website;
(i) for our offices’ and facilities’ security and safety;
(j) any other purposes for which you have provided the information;
(k) transmitting to any unaffiliated third parties including our third-party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
(l) any other incidental business purposes related to or in connection with the above.
6. Additionally, we may also disclose your personal data to third-party service providers, agents, and other organisations (whether locally or overseas) we have engaged to perform any of the functions listed in clause 5 above on our behalf.
7. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).
C. WITHDRAWING YOUR CONSENT
8. The consent that you provide for the collection, use, and disclosure of your personal data will remain valid until such time it is withdrawn by you in writing. You may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.
9. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within 21 days of receiving it.
10. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 8 above.
11. Please note that withdrawing consent does not affect our right to continue to collect, use, retain, and disclose personal data where such collection, use, retention, and disclosure without consent is permitted or required under applicable laws.
D. ACCESS TO AND CORRECTION OF PERSONAL DATA
12. You may make requests (a) for access to a copy of the personal data which we hold about you, (b) for information about the ways in which we use or disclose your personal data or (c) to correct or update any of your personal data which we hold about you. These requests must be made in writing to our Data Protection Officer at the contact details provided below.
13. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
14. We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).
E. PROTECTION OF PERSONAL DATA
15. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal, or similar risks, we employ appropriate administrative, physical, and technical measures to (a) secure all storage and transmission of personal data by us; and (b) disclose personal data both internally and to authorised third-party service providers and agents only on a need-to-know basis.
16. You should be aware, however, that no method of transmission over the internet or method of electronic storage is completely secure.
F. ACCURACY OF PERSONAL DATA
17. We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete, and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.
G. RETENTION OF PERSONAL DATA
18. We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
19. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.
H. TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
20. We may transfer your personal data to countries outside of Singapore. However, if we do so, we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that required under the PDPA.
I. DATA PROTECTION OFFICER
21. You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, via email at email@example.com or in writing at:
GDMC Pte. Ltd.
21 Biopolis Rd, Nucleos North Tower, #02-03
Attention: Data Protection Officer
J. EFFECT OF POLICY AND CHANGES TO POLICY
22. This Policy applies in conjunction with any other policies, contractual clauses, and consent clauses that apply in relation to the collection, use, retention, and disclosure of your personal data by us.
23. We reserve the right to amend the terms of this Policy at our absolute discretion and may revise this Policy from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued use of our services and/or interfacing with us in any way constitutes your acknowledgement and acceptance of such changes.
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