Effective Date: 08 August 2018
This Privacy Policy (“Policy”) sets out the basis on which Centenal Pte. Ltd (“Centenal” “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 Policy applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to process personal data for our purposes.
1. PERSONAL DATA
1.1. As used in this Policy:
“customer” means an individual who (a) has contacted us through any means to find out more about any services we provide or (b) may, or has, entered into an online subscription and/or software license with 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.
1.2. Depending on the nature of your interaction with us, we may collect the following personal data from you: your name, contact information such as your address, email address, telephone number, professional standing and financial information such as credit card numbers, debit card numbers and/or bank account information.
1.3. Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context permits).
2. COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
2.1. We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly after (i) you have been notified of the purposes for which the data is collected, and (ii) you have by writing or other positive act consented 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 authorized by law).
2.2. We may collect and use your personal data for any or all of the following purposes:
2.2.1 performing obligations in the course of or in connection with our provision of services requested by you;
2.2.2 verifying your identity;
2.2.3 responding to, handling, and processing queries, requests, applications, complaints and/or feedback from you;
2.2.4 managing your relationship with us;
2.2.5 processing payment or credit transactions;
2.2.6 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;
2.2.7 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.
2.3. We may disclose your personal data:
2.3.1 where such disclosure is required for performing obligations in the course of or in connection with our provision of services requested by you;
2.3.2 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.
2.4. The purposes is 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).
3. WITHDRAWING YOUR CONSENT
3.1. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time as it is withdrawn by you. 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 using the same method by which you previously consented to the collection, use and disclosure of your personal data by us.
3.2. Upon receipt of your request to withdraw your consent, we may require a 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 10 business days of receiving it.
3.3. 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 provide your consent in the manner provided in the clause 4 above.
3.4. Please note that withdrawing consent does not affect our right to collect, use and disclose personal data where such collection, use and disclosure without consent is required under applicable law.
4. ACCESS TO AND CORRECTION OF PERSONAL DATA
4.1. 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.
4.2. We will respond to your request within thirty (30) business days. No charge shall be made for an access request. Should we not be able to respond to your request within thirty (30) business days, we will inform you 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 permitted to do so under the PDPA).
5. PROTECTION OF PERSONAL DATA
5.1. To a safeguard your personal data from unauthorized 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.
5.2. 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.
6. ACCURACY OF PERSONAL DATA
6.1. We generally rely on personal data provided by you. 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 updating your online account profile details or by informing our Data Protection Officer in writing or via email at the contact details provided below.
7. RETENTION OF PERSONAL DATA
7.1. We may retain your personal data for as long as it is necessary to fulfill the purpose for which it was collected, or as required by applicable laws.
7.2. We will cease to retain your personal data, or remove the means by which the data can be associated with you, no later than fifteen (15) working days after such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal purposes.
8. TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
8.1. We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will first obtain your consent to the transfer 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.
9. DATA PROTECTION OFFICER
9.1. You may contact our Data Protection Officer if you have any enquirers 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
Centenal Pte. Ltd
One Raffles Place
#24-01 Singapore
048616
Tele: +65 6408 0600
Email: DPO@centenal.com
10. EFFECT OF POLICY AND CHANGES TO POLICY
10.1. This Policy applies in conjunction with any other notices, contractual clauses and consents clauses that apply in relation to the collection, use and disclosure of your personal data by us.
10.2. We may revise this Policy from time to time by giving at least fifteen (15) days prior notice, such notice shall be made by email attaching a copy of the revised Policy for your consideration. Your continued use of our services constitutes your acknowledgment and acceptance of any such changes.
10.3. We may from time to time request that you re-confirm your consent to our collection, use and disclosure of your personal data applying the same procedures and requirements contained in clause 4 above.
