Privacy Policy
Last updated: 29 August 2019
This Data Protection
Privacy Statement (“Privacy Statement”) sets
out the
basis which AG Corporate Pte. Ltd. and its
affiliates (together “Jordans Group” (hereinafter “we”,
“us”,
or “our”)
may collect,
use, disclose
or otherwise
process your personal data in accordance
with the Personal Data
Protection Act 2012 (“PDPA”). This Privacy Statement applies to personal data
in our
possession or under our control, including personal data in the
possession of organizations which we have
engaged to collect, use,
disclose or process personal data
for our
purposes.
When you visit our websites or
request a service from any entity within Jordans
Group, your use or continued use of our services shall be deemed as your
acceptance and agreement to be bound by the provision of this Privacy Statement
For the purposes of the Act, we are a data
intermediary when we process personal data on behalf of and for the purposes of
another organisation. At the same time, we also collect, use and disclose
personal data for purposes that are reasonable and appropriate.
This Privacy Statement forms part of the terms and
conditions, if any, governing your specific relationship with any entity within
Jordans Group and should be read in conjunction with
such terms of engagement. In the event of any conflict or inconsistency between
the provisions of this Privacy Statement and the terms of engagement, the terms
of engagement shall prevail to the fullest extent permissible by law.
PERSONAL
DATA
1.
As used in
this Privacy
Statement:
a.
“customer”
means an individual who (i) has contacted us
through any means to find
out more
about any services we
provide, or (ii) may, or
has, entered
into a
contract with us for the supply
of any
goods or services by us;
and
b.
“personal
data” means data, whether true
or not,
about a customer 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.
c.
“affiliates” means companies
within Jordans Group and refers to the following
companies:
i. K.C. Chan & Co PAC
ii. Accountancy Hub
iii. Jordans Management Pte. Ltd.
iv. Jordans Business Pte. Ltd.
v. XBRL Services Pte. Ltd.
vi. Jordans Corporate Pte. Ltd
vii. AG Corporate Pte. Ltd.
viii.
Waterwell1 Pte.
Ltd.
ix. Jordans Info Pte. Ltd.
x. Jordans Insolvency Unit Pte. Ltd.
2.
Some examples of
personal data which we may collect
from you
include:
a.
Your name and
identification information such as your
NRIC number;
b.
Contact
information such as your address, email address
or telephone
number;
c.
nationality,
gender, date of birth, marital
status, photographs and other audio-visual information, employment information and financial
information such as credit card
numbers, debit card numbers or bank
account information;
d.
Investment information such as such as rented
properties.
3.
Other
terms used in this Privacy
Statement 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 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.
transmitting
to any unaffiliated third parties including our third-party service providers and agents, whether in Singapore
or abroad, and relevant governmental
and/or regulatory authorities, whether in
Singapore or abroad, for the
aforementioned purposes; and
h.
any other incidental
business purposes related to or
in connection
with the
above.
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
services requested by you; or
b.
to third party
service providers, agents and other
organisations we have engaged to
perform any of the
functions listed in clause 5
above for us (who may in turn disclose
such data to their agents, employees or other third parties with our prior
written consent).
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).
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 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 ten
(10) 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
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 and
disclose personal data where
such collection,
use and
disclose without consent is permitted
or required under applicable
laws.
PROTECTION OF PERSONAL DATA
12. 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 and
the use of privacy filters
to secure
all storage
and transmission
of personal
data by
us, and
disclosing personal data both
internally and to our authorised
third party service providers and agents only on a
need-to-know basis.
13. 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
14. 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.
15. We
may, upon written request, allow you to view stored personal information
subject to legal requirements. We reserve the right to charge a reasonable
administrative fee for this service. We will respond to such request within 30
days of receipt of your written request.
RETENTION OF PERSONAL DATA
16. 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 and 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.
WEBSITE
17. You
may choose to turn off all cookies on our website as we use cookies to provide
you with a more personalised experience. However, by turning off the cookies
you may not have access to some of the features and some of the services on our
website will not function properly. Please
refer to your browser’s documentation to check if cookies have been enabled on
your computer or to request not to receive cookies.
TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
18. To fulfil the purposes for which your personal data
has been collected, we have adopted a cloud-based solution that will store and
analyse the personal data provided by you (or your authorised representative).
The personal data as stored in the cloud-based solution may be accessed by
our third-party service providers and
agents, whether overseas or in Singapore. We
shall ensure that the third-party service providers and agents are
legally bound to provide a standard of protection that is at least
comparable to that provided
under the PDPA for your personal data
in the overseas countries and territories
that your personal data will be transferred to and shall require such
third-party service providers and agents to impose similar obligations of
protection on such third parties they deal with.
DATA INTERMEDIARY
19. If we process personal data on your behalf and for
your purposes as a data intermediary, we shall:
a. Observe the relevant obligations under the Act in the
performance of our services
b. Process the personal data we receive from you only to
the extent necessary for the purposes specified in the engagement and in
accordance with your instructions from time to time given in writing and shall
not process the personal data for any other purpose;
c. Ensure that access to the personal data is limited to
employees who need to access to perform the services under the engagement.
d. In order to perform the services, we may share the
personal data with our affiliates, whether in Singapore or elsewhere. When
doing so, we will require them to ensure that the personal data are kept secure
and confidential;
e. Use reasonable degree of professional care to prevent
unauthorised use, dissemination or disclosure of personal data, and shall
implement any generally applicable physical, technical and administrative
measures to protect the personal data from accidental or unauthorized
disclosure, alteration, loss or destruction;
f. Notify you promptly if we become aware of any
accidental or unauthorised disclosure, alteration, destruction or loss of
personal data unless prohibited from doing so by law
g. Take reasonable action within reasonable time, and
investigate the security incident, and use its best efforts to mitigate the
impact and scope of any security incident, and to carry out such recovery or
other action we determined necessary in the circumstance to remedy the security
incident; and
h. Not hold personal data any longer than required by law
for the purpose of performing or having performed the services for legal or business
purposes
20. In the same regard, if we process personal data on
your behalf and for your purposes, you;
a. Will provide us with specific written instructions
with regard to the processing of personal data. Oral instructions given by your
authorised representatives will be accepted by us in case of emergency only and
subject to immediate written confirmation
b. Undertake and warrant that you have lawfully obtained
personal data of your employees and have sufficient legal grounds, including
all necessary authorizations, consents or permissions to provide us with the
personal data, and that the same are accurate and provided in any form, to us
in a secured way;
c. Will inform us immediately in writing of any change,
including any error or omission, with regard to the lawful processing and use
of any of the personal data; and
d. Will inform us as soon as reasonably possible of any
access request, request for correction or blocking or deletion of personal data
or any objection made by the employees related to the processing of their
personal data.
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:
Data Protection Officer
Jordans Group
105 Cecil Street #15-00 The Octagon
Singapore 069534
Tel: 6324 7718/20
Email: dpo@jordans.com.sg
If your personal data was provided to us by a third party,
kindly contact that organisation to make such request or query on your behalf.
EFFECT OF PRIVACY STATEMENT AND CHANGES TO PRIVACY
STATEMENT
22. This Privacy
Statement applies in conjunction
with any
other notice, 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 Privacy Statement 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
Privacy Statement was last updated. Your continued use of our services
constitutes your acknowledgement and
acceptance of such changes.