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.
PERSONAL DATA
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 :
08/04/2019
PRIVACY
POLICY (EU/Elsewhere)
INTRODUCTION
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.
WHEN DOES THIS PRIVACY POLICY APPLY
This privacy policy applies to
personal information we collect from visitors to our website, our customers and
other person with whom we deal directly.
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).
For the purposes of the GDPR, our
customers are the data controller
when storing or otherwise processing User Data and we are the data processor. Our customers determine what and how they
collect, use, disclose and transfer User Data.
This means that our customers’ collection and use of User Data is
governed by their privacy policy and practices, not ours.
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.
The remainder of this privacy
policy does not apply to User Data.
CHILDREN
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.
Also,
we may share information about your use of our website with our trusted
advertising and analytics partners through the use of cookies, web beacons, and
similar storage technologies. Please
refer to our cookie policy below for further information.
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.
Internet use
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.
If you follow a link on our
website to another website, the owner of that website will have its own privacy
policy relating to your personal information.
We suggest you review that website’s privacy policy before you provide
personal information to that owner or website.
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.
ContactING us
If you have any question about
this privacy policy, or our privacy practices, or if you would like to request
access to, or correction of, your personal information, you can contact us at
[email protected]
The name and contact details of our Data Protection
Officer for the purposes of the GDPR are:
Name | Adrian Choo |
Email address | |
Phone number | +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
▲
rights related to automated decision-making, including profiling - you have
the right to not be subject to a decision based solely on automated processing,
including profiling, which produces legal effects concerning you or similarly
significantly affects you, except where such automated decision-making is
necessary for entering into, or the performance of, a contract with you, is
authorised by applicable laws or is based on your explicit consent . We carry out automated decision-making,
including profiling, as described above in the general terms section of this
privacy policy
▲
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.
Cookie policy
INTRODUCTIOn
We use cookies on our website and
as part of our related services, and receive information collected through
cookies. This cookie policy explains how
we use cookies and how you can opt out of cookies.
By continuing to use our website
and related services, you indicate your agreement for us to use the cookies
described below.
We use the term cookies in this cookie policy to mean
cookies or similar technologies such as web beacons, clear GIFs, and pixel
tags.
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.
Functionality
cookies
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.
Performance
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
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.
GOOGLE
COOKIES
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.
For further information on how
Google uses your personal information when you use our website and how to opt
out of Google’s use of cookies, see here. In addition to the
process described in this link, you can opt out using the process described below.
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.
Third party website cookies
If you follow a link on our
website to another website, the owner of that website will have its own
cookies. We suggest you review that
website’s cookie policy before you visit that website.
