DATA PROTECTION NOTICE FOR CUSTOMERS
This Data Protection Notice (“Notice”) sets out the basis which Konexo Singapore Pte. Ltd. (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of our customers in accordance with the Personal Data Protection Act (“PDPA”). This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.
1. As used in this Notice:
“customer” ("you" or "your") means an individual or organisation that (a) has contacted us through any means to find out more about any services we provide, or (b) may, or has, entered into a contract with us for the supply of any services by us; and
“personal data” means data, whether true or not, about a customer or provided by a customer about an individual or individuals who can be identified: (a) from that data; or (b) 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 name, identification numbers (such as NRIC, FIN, work permit and birth certificate), residential address, email address, telephone number, nationality, gender, date of birth, employment information and financial information of you or your key personnel and representatives.
3. Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).
COLLECTION OF PERSONAL DATA
4. We generally do not collect 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 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. If you require us or our service providers to process any personal data on your behalf, we and our service providers will only do so in accordance with your written instructions and any data protection policies or procedures that you have provided to us or our service providers with the appropriate notice and training on such policies and procedures.
5. By providing us with any personal data relating to a third party (including but not limited to information about your authorised representatives or employees), you represent to us that you have validly obtained the consent of the third party to provide us with their personal data for the respective purposes below.
6. 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 law).
USE OF PERSONAL DATA
7. We may collect and use your personal data for any or all of the following purposes:
- (a) performing obligations in the course of or in connection with our provision of services requested by you;
- (b) verifying your identity or that of your authorised representatives;
- (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) complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority; for our internal administrative purposes and / or internal record keeping;
- (g) for organising events and programmes for you;
- (h) for sending material such as newsletters, articles and other updates;
- (i) for sending marketing and promotional material to you;
- (j) to enforce or defend our rights and your rights under, and to comply with, our obligations under the applicable laws, legislation and regulations;
- (k) to enable us to send you information that might interest you by e-mail, telecommunication means (telephone or text messages) or social media;
- (l) any other purposes for which you have provided the information;
- (m) 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
- (n) any other incidental business purposes related to or in connection with the above.
DISCLOSURE OF PERSONAL DATA
8. We may disclose personal data:
9. The purposes listed in the above paragraphs may continue to apply even in situations where your relationship with us (for example, pursuant to an agreement or engagement with us) 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 a contract with you).
- (a) where such disclosure is required for performing obligations in the course of or in connection with our provision of the services requested by you; or
- (b) to third party service providers, agents and other organisations we have engaged to perform any of the functions with reference to the above mentioned purposes or
- (c) to any
- i) person to whom we are compelled or required to do so under law or in response to a competent regulatory or government agency;
- ii) government agencies, statutory authorities and industry regulators;
- iii) other Konexo Entities, our parent company Eversheds Sutherland (International) LLP and members of the Eversheds Sutherland network of firms;
- iv) external advisors and other professional advisors, such as lawyers, auditors, tax consultants, accountants, insurers and other financial or professional advisors;
- v) banks and financial institutions; and
- vi) any other party that we deem necessary for the purposes, as outlined in paragraph 5 above.
WITHDRAWING YOUR CONSENT
10. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, 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.
11. 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 ten (10) business days of receiving it.
12. 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 paragraph 10 above.
13. Please note that depending on the personal data concerned, the withdrawal of your consent may affect our ability to provide services to you. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclosure without consent is permitted or required under applicable laws.
ACCESS TO AND CORRECTION OF PERSONAL DATA
14. If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
15. 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.
16. We will respond to your request as soon as reasonably possible. In general, our response will be within thirty (30) business days. 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).
PROTECTION OF PERSONAL DATA
17. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection and disclosing personal data both internally and to our authorised third party service providers, agents and others only on a need-to-know basis.
18. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
ACCURACY OF PERSONAL DATA
19. 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.
RETENTION OF PERSONAL DATA
20. 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.
21. 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.
TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
22. We operate globally and where we consider it necessary and appropriate, we may transfer your personal data to other Konexo Entities, our parent company Eversheds Sutherland (International) LLP, members of the Eversheds Sutherland network of firms or to a third party service or product providers within or outside Singapore for the performance of the purposes set out in paragraph 5 above, under conditions of confidentiality and similar levels of security safeguards. We may also in limited circumstances share your personal data with government authorities or others as required to protect our business interest or others, as necessary or as required by applicable law or court order.
23. Konexo is the name and brand under which the Konexo Entities provide legal or other services to clients around the world. For more information on the Konexo Entities and their relationship with Eversheds Sutherland, a global provider of legal services, please click here.
DATA PROTECTION OFFICER
24. 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, in the following manner:
Name of DPO : Joan Oh
Contact No. : +65 8798 1588
Email Address : firstname.lastname@example.org
EFFECT OF NOTICE AND CHANGES TO NOTICE
25. This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
26. We may revise this Notice 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 constitutes your acknowledgement and acceptance of such changes.
Effective date : 01/10/2020
Last updated : 01/10/2020