DATA PROTECTION NOTICE FOR CUSTOMERS (Singapore)
This Data Protection Notice (“Notice”) sets out the basis which CAREER AGILITY INTERNATIONAL 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” means an individual who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us; and
“personal data” means data, whether true or not, about a customer 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, marital status, employment information, financial information, career profile and personal profile.
3. Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).
COLLECTION, USE 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 law).
5. 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 the goods and/or services requested by you;
(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) 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;
(g) any other purposes for which you have provided the information;
(h) 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;
(i) any other incidental business purposes related to or in connection with the above;
(j) in the process of generating Reports or Test Results; and
(k) in the process of registration for services.
6. We may disclose your personal data:
(a) where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods and services requested by you.
7. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to your employment contract should you be hired) 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).
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 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.
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 ninety (90) business 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 7 above.
11. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
ACCESS TO AND CORRECTION OF PERSONAL DATA
12. 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.
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. In general, our response will be within ninety (90) 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
15. 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, encryption, use of privacy filters, and disclosing personal data both internally and to our 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. 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
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.
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.
TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
20. We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.
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, in the following manner:
Name of DPO : ADRIAN CHOO
Contact No. : +65 9450 3990
Email Address : [email protected]
Address : 24, Raffles Place, #26-06B,Clifford Centre, Singapore 048621
EFFECT OF NOTICE AND CHANGES TO NOTICE
22. 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.
23. 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 : 08/04/2019
Last updated :
Career Agility International Pte Ltd (we, us, our) complies with applicable privacy and data protection laws, including the General Data Protection Regulation of the European Union (GDPR) when dealing with personal information.
Personal information is information about an identifiable individual (a natural person), and includes personal data, personally identifiable information and equivalent information under applicable privacy and data protection laws.
This policy does not limit or exclude any of your rights under applicable privacy and data protection laws, including the GDPR. For further information on the GDPR, see https://ec.europa.eu/info/law/law-topic/data-protection_en.
This policy was drafted with brevity and clarity in mind. It does not provide exhaustive detail of all aspects of our collection and use of personal information. We are happy to provide any additional information or explanation needed. Any request for further information should be sent to [email protected]
CHANGES TO THIS POLICY
We may change this policy by uploading a revised policy onto our website. The change will apply from the date that we upload the revised policy.
This policy was last updated on 1 March 2019.
Users of our SaaS service may collect personal information from individuals (e.g. their employees and customers) and upload, store or process that information to or in that service (User Data).
Unless required otherwise under applicable law, if we receive any request or enquiry relating to User Data, we will forward this request to our relevant customer.
We do not intend to collect personal information from or about children aged under 16. If you have reason to believe that we have collected personal information from or about a child under the age of 16, please contact us at [email protected].
WHAT personal information DO WE COLLECT
Directly from you
We collect the following information directly from you.
When you register for, or login to, an account on our website or related services, we collect your name, email address, user name, password, phone number, demographic information, date of birth, location and any other information we require or ask for to set you up with an account.
When you set up a profile, we collect your name, email address, address, location, phone number, gender, bio, date of birth, profile photo and any other information we require or ask for to set you up a profile.
When you fill in a contact or enquiry form on our website, call us, meet us in person or otherwise contact us, we collect your name, email address, phone number and any other information you choose to provide to us.
When you sign up to our newsletter and other electronic alerts, we collect your name, email address, phone number, user preferences and any other information you provide to us when you ask to receive our newsletter or other alerts.
When you respond to our feedback surveys, we collect your name, email address, date of birth, demographic information and any other information you choose to include in your response.
When you refer another person to use our website or related services, we collect your name and email address that other person’s name and email address and any other information you choose to include in the referral.
When you purchase products or services from us, we collect your name, email address, phone number, credit card information, purchase history and any other information you submit to us for billing and order fulfilment purposes.
When you purchase products or services from us that we need to physically deliver to you, we collect your name, address, phone number, delivery instructions and any other information you submit to us for delivery purposes.
When you post information for publication on our website (e.g. on message boards or chat rooms), we collect the information you include in those posts.
Some of the personal information that we collect directly from you may be mandatory and some may be optional. We will let you know which of these applies at the time we collect the relevant personal information. While you do not have to provide us with some of the information that we may request, this might mean that our products and services may not perform as well as they should, or that we may not be able to provide some parts of the website or all of our products or services to you. If you require further information about the consequences of not providing us with any information, please contact us at [email protected].
From third party sources
Where possible, we collect personal information from you directly. However, sometimes we may collect personal information that is publicly available (e.g. through LinkedIn profiles or public directories).
We may combine the personal information about you that we receive from third parties with the personal information we collect from you directly.
How we use your personal information
We may use your personal information to:
▲ verify your identity
▲ provide our website, products and services to you
▲ market our products and services to you, including contacting you electronically (e.g. by text or email for this purpose)
▲ improve our website, products and services
▲ publish things on our website (e.g. comments on message boards or chat rooms)
▲ run promotions (e.g. referral and loyalty programmes, surveys and contests)
▲ bill you and collect money that you owe us, including authorising and processing credit card transactions
▲ respond to communications from you, including enquiries and complaints
▲ conduct research and statistical analysis (on an anonymised basis)
▲ tailor content or advertisements on our website to you
▲ protect and/or enforce our legal rights and interests, including defending any claim
▲ respond to lawful requests by public authorities, including to comply with law enforcement requirements, or
▲ for any other purpose authorised by you or applicable law.
We may transfer your information in the case of a sale, merger, consolidation, liquidation, reorganisation or acquisition.
We conduct automated decision-making to deliver customised solutions to our clients.
You can stop receiving our marketing emails by following the unsubscribe instructions included in those emails or contacting us at [email protected]
Disclosing your personal information
We may disclose your personal information to:
▲ another company within our group
▲ third parties (for anonymised statistical information)
▲ a person who can require us to supply your personal information (e.g. a law enforcement agency or regulatory authority)
▲ any other person with your consent
▲ any other company in the case of a sale, merger, consolidation, liquidation, reorganisation or acquisition
▲ any other person authorised by applicable law.
international TRANSFERS OF PERSONAL INFORMATION
A business that supports our website, products and services may be located outside of Singapore (the country where we are incorporated) and also outside of the country where you are located. This means that the personal information we collect may be transferred to, and stored in, a country outside of Singapore and the country where you are located.
If you are located in the European Economic Area (EEA), your personal information may be transferred outside of the EEA. Under the GDPR, the transfer of personal information to a country outside the EEA may take place where the European Commission has decided that the country ensures an adequate level of protection. In the absence of an adequacy decision, we may transfer personal information if other appropriate safeguards are in place.
Where we transfer personal information outside the EEA, it will only be transferred to countries that have been identified as providing adequate protection for EEA data, or to a third party where approved transfer mechanisms are in place to protect your personal information (e.g. to organisations in the United States under the EU-U.S. Privacy Shield framework or by entering into the European Commission’s Standard Contractual Clauses). For further information, please contact at [email protected].
Protecting your personal information
As required by applicable law, we will take steps to keep your personal information safe from loss, unauthorised activity, or other misuse. We implement appropriate technical and organisational measures to ensure a level of security appropriate to the risks inherent in processing personal information.
You play an important role in keeping your personal information secure by maintaining the confidentiality of any password and accounts used in relation to our products and services. You should not disclose your password to third parties. Please notify us immediately if there is any unauthorised use of your account or any other breach of security.
Accessing and correcting your personal information
Subject to certain grounds for refusal under applicable law, you have the right to access your personal information that we hold and to request a correction to your personal information. Before you exercise this right, we will need evidence to confirm that you are the individual to whom the personal information relates.
Where you request a correction, if we think the correction is reasonable and we are reasonably able to change your personal information, we will make the correction. In all other cases, we will take reasonable steps to make a note of the personal information that was the subject of your correction request.
If you want to exercise either of the above rights, email us at [email protected] Your email should provide evidence of who you are and set out the details of your request (e.g. the personal information to be corrected and the correction that you are requesting).
Subject to applicable law, we may charge you our reasonable costs of providing to you copies of your personal information or correcting that information.
While we take reasonable steps to maintain secure internet connections, if you provide us with personal information over the internet, the provision of that information is at your own risk.
If you post your personal information on our website’s message board or chat room, you acknowledge and agree that the information you post is publicly available.
DATA Retention policy
The personal information that we collect and use will not be kept longer than necessary for the purposes for which it is collected, or for the duration required for compliance with applicable law, whichever is longer.
The name and contact details of our Data Protection Officer for the purposes of the GDPR are:
+65 9450 3990
GDPR ADDITIONAL TERMS
lAWFUL basis for PROCESSING PERSONAL INFORMATION
Our lawful basis for processing (as that term is defined in the GDPR) personal information that we collect, use and disclose depends on the personal information collected and the context in which we collect it.
Generally, we collect personal information from you where we have your consent, where processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, or where processing is necessary for the purposes of our legitimate interests (except where such interests are overridden by your interests or fundamental rights and freedoms).
Where we process personal information based on your consent, you may withdraw your consent at any time.
Despite the above, we may process your personal information where such processing is necessary for compliance with applicable laws.
If you have any question about the legal basis on which we process personal information or need further information, please contact us at [email protected]
Your rights under the gdpr
If you are located in the European Union, your rights in relation to your personal information include:
▲ right of access - if you ask us, we will confirm whether we are processing your personal information and provide you with a copy of that personal information
▲ right to rectification - if the personal information we hold about you is inaccurate or incomplete, you have the right to have it rectified or completed. We will take reasonable steps to ensure inaccurate personal information is rectified. If we have shared your personal information with any third party, we will tell them about the rectification where possible
▲ right to erasure – when your personal information is no longer needed for the purposes for which you provided it, we will delete it. You may request that we delete your personal information and we will do so if deletion does not contravene any applicable law. If we have shared your personal data with any third party, we will take reasonable steps to inform those third parties that they must delete your personal information
▲ right to withdraw consent - if the basis of our processing of your personal information is consent, you can withdraw that consent at any time
▲ right to restrict processing - you may request that we restrict or block the processing of your personal information in certain circumstances. If we have shared your personal information with any third party, we will tell them about this request where possible
▲ right to object to processing - you may request that we stop processing your personal information at any time and we will do so to the extent required by the GDPR
▲ right to data portability - you may obtain your personal information from us that you have consented to give us or that is necessary to perform a contract with you. We will provide this personal information in a commonly used, machine-readable and interoperable format to enable data portability to another data controller. Where technically feasible, and at your request, we will transmit your personal information directly to another data controller
▲ the right to complain to a supervisory authority - you can report any concern you have about our privacy practices to your local data protection authority.
Where personal information is processed for the purposes of direct marketing, you have the right to object to such processing, including profiling related to direct marketing.
If you would like to exercise any of your above rights, please contact us at [email protected]. If you are not satisfied by the way we deal with your query, you may refer your query to your local data protection authority.
By continuing to use our website and related services, you indicate your agreement for us to use the cookies described below.
WHAT ARE COOKIES
Cookies are text files containing small amounts of information which are downloaded to your browsing device, e.g. a computer or smartphone, when you visit a website. Cookies can be recognised by the website that downloaded them, or by other websites that use the same cookies. This helps a website know if the browsing device has visited that or other websites before.
Cookies can be used to collect information relating to your use of a website or your device, let you navigate between pages effectively, help to remember your preferences and generally improve your browsing experience. Cookies can also help ensure advertising you see online is more relevant to you and your interests.
Cookies can be session or persistent cookies. Session cookies are temporary and only stay on your browser until you stop browsing. Persistent cookies stay on your device until they expire or are deleted.
The cookies used on our website may be first party cookies (i.e. set by us) or third party cookies (i.e. cookies set on our website by a person other than us). The third party companies that place cookies on our website will have their own privacy policies.
WHAT Types of cookies DO we use
The types of cookies used by us, and most websites, can generally be categorised as follows.
Strictly necessary cookies
These cookies are essential for the full functionality of our website and related services. They enable you to navigate around our website and services and use their features e.g. accessing secure areas and enabling services that you have asked to receive. If you opt out of these cookies, you may not be able to access all the functions of our website and some services that you have asked to receive.
These cookies do not track where else you have been on the internet and do not remember your preferences beyond your current visit. These cookies are generally first party session cookies which will expire when you close your browsing session. These cookies do not collect information that could be used for marketing purposes.
These cookies allow a website to remember choices you make and provide enhanced, more personal features. e.g. these cookies allow us to remember the settings you have applied to the website (such as font size, preferences or colours), identify whether you are a returning website visitor and present you with a personalised version of the website, or eliminate the need for you to re-enter your login details. The information these cookies collect is generally anonymous and they do not track your browsing activity on other websites. These cookies may be first or third party, session or persistent cookies.
These cookies collect information about how you use a website, e.g. which pages are the most visited and if you receive any error message from any page. This information helps us improve the way our website and related services work and helps us manage the performance and design of the website and services. These cookies do not gather information that identifies you. All of the information these cookies collect is aggregated and anonymous. These cookies may be first or third party, session or persistent cookies.
Targeting cookies are used to present advertising that is relevant to you and your interests. These cookies collect information about your browsing habits e.g. the pages you have visited and the links you have followed across the internet. They may also be used to limit the number of times you see an advertisement and help measure the effectiveness of advertising campaigns. These cookies will usually be persistent but time-limited and may be placed on our website by third party service providers or advertising partners with our permission.
We use targeting cookies to present interest-based advertising on our website and for retargeting. This is a form of interest-based advertising that enables our advertising partners to build a profile of your interests and show you advertising based on your browsing activity across the internet, including to allow us to advertise to people who previously visited our website.
We use Google Analytics to collect information about visitors to our website. Google Analytics collects information related to your device, browser, IP address, network location, and website activities to measure and report statistics about your interactions on our website. We use this information to help us manage the performance and design of our website and to improve our website.
We use Google Analytics Advertising Features, including Remarketing with Analytics, Demographic and Interests reporting in Analytics, Campaign Manager integration (formerly known as DoubleClick), Display & Video 360 integration, Google Display Network (GDN) Impression Reporting and Segments. We also use Google Ads.
How to control or OPT OUT OF cookies AND TARGETED ADVERTISING
You can control and/or delete cookies as you wish. You can delete all cookies that are already on your computer and you can set most browsers to prevent them from being placed. However, if you do this, you may have to manually adjust some preferences every time you visit our website and attempt use our services, you may not be able to access certain parts of our website or services, and some functionalities may not work.
You can find out more information about how to change your browser cookie settings at http://www.aboutcookies.org.uk.
To learn more about how to control cookie settings through your browser:
▲ click here to learn more about the Private Browsing setting and managing cookie settings in Firefox
▲ click here to learn more about Incognito and managing cookie settings in Chrome
▲ click here to learn more about InPrivate and managing cookie settings in Internet Explorer
▲ click here to learn more about Private Browsing and managing cookie settings in Safari.
You may opt out of targeted advertising at http://www.youronlinechoices.eu/. You can learn more about interest-based advertising and opt out of interest-based advertising from participating online advertising companies at the following links.
▲ Network Advertising Initiative (NAI) – http://optout.networkadvertising.org/
▲ Digital Advertising Alliance (DAA) – http://optout.aboutads.info/
▲ Digital Advertising Alliance EU (EDAA) – http://www.youronlinechoices.com/
▲ DAA AppChoices page – http://www.aboutads.info/appchoices
Please note that opting out of interest-based advertising does not mean you will no longer be served advertising. You will continue to receive generic ads.
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