At Straits Interactive Pte Ltd and/or Data Protection Excellence Network (DPEX) (collectively Straits) we respect the privacy and confidentiality of the personal data of our Clients, Associates and others whom we interact with in the course of providing our services. Being Data Protection Trustmark (DPTM) certified, we are committed to implementing policies, practices and processes to safeguard the collection, use and disclosure of the personal data you provide us, in compliance with the Singapore Personal Data Protection Act (PDPA) 2012.
We have developed this Data Protection Notice to assist you in understanding how we collect, use, disclose, process, protect and retain your personal data that is in our possession.
Personal data refers to any information that can uniquely identify an individual person (a) on its own, or (b) when combined with other information. Under the PDPA, business contact information (e. g. full name, business address, business telephone number) is not considered as personal data so long as it is used strictly for business-to-business (B2B) transactions.
We generally collect personal data that you knowingly and voluntarily provide:
The types of personal data we collect about you include (but not limited to) the following:
We use the personal data you provide us for one or more of the following purposes:
We disclose some of the personal data you provide us to the following entities or organisations outside Straits in order to fulfil our services to you:
Where required to do so by law, we may disclose personal data about you to the relevant authorities or to law enforcement agencies.
Before we collect, use or disclose your personal data, we will notify you of the purpose why we are doing so. We will obtain written confirmation from you on your expressed consent. We will not collect more personal data than is necessary for the stated purpose. We will seek fresh consent from you if the original purpose for the collection, use or disclosure of your personal data has changed.
Under certain circumstances, we may assume deemed consent from you when you voluntarily provide your personal data for the stated purpose, e. g. when you apply for a job with us using our job application forms.
We may rely on exceptions to the need for consent under the PDPA for the collection, use or disclosure of your personal data under the following circumstances (only those relevant to Straits are included):
You have choices regarding our collection, use or disclosure of your personal data. If you choose not to provide us with the personal data described in this Notice, we may not be in a position to process your required services. You have the right to object to the processing of your personal data and withdraw your consent in the manner described in this section 6.2.
If you wish to withdraw consent, you should give us reasonable advance notice. We will advise you of the likely consequences of your withdrawal of consent, e. g. without your personal contact information we may not be able to inform you of future services offered by us.
Your request for withdrawal of consent can take the form of an email or letter to us, or through the UNSUB feature in an online service.
Most cookies we use are session cookies, which will be deleted automatically from the hard disk of your computer at the end of the session.
You may choose not to accept cookies by turning off this feature in your web browser. Note that by doing so, you may not be able to use some of the features and functions in our web applications.
We do not get consent on behalf of another individual. We only get consent from the individual who will be dealing directly with us.
We will take reasonable steps to ensure that the personal data we collect about you is accurate, complete, not misleading and kept up-to-date.
From time to time, we may do a data verification exercise for you to update us on any changes to the personal data we hold about you. If we are in an ongoing relationship with you, it is important that you update us of any changes to your personal data (such as a change in your mailing address).
We have implemented appropriate information security and technical measures (such as data encryption, firewalls and secure network protocols) to protect the personal data we hold about you against loss; misuse; destruction; unauthorised alteration/modification, access, disclosure; or similar risks. These are governed by our internal data protection and information security policy.
We have also put in place reasonable and appropriate organisational measures to maintain the confidentiality and integrity of your personal data, and will only share your data with authorised persons on a need to know basis.
When we engage third-party data processors to process personal data on our behalf, we will ensure that they provide sufficient guarantees to us to have implemented the necessary organisational and technical security measures, and have taken reasonable steps to comply with these measures.
We have a document retention policy that keeps track of the retention schedules of the personal data you provide us, in paper or electronic forms. We will not retain any of your personal data when it is no longer needed for any business or legal purposes.
We will dispose of or destroy such documents containing your personal data in a proper and secure manner when the retention limit is reached.
You may write in to us to find out how we have been using or disclosing your personal data over the past one year. Before we accede to your request, we may need to verify your identity by sighting your NRIC or other legal identification document. We will respond to your request as soon as possible, or within 30 days from the date we receive your request. If we are unable to do so within the 30 days, we will let you know and give you an estimate of how much longer we require. We may also charge you a reasonable fee for the cost involved in processing your access request.
If you find that the personal data we hold about you is inaccurate, incomplete, misleading or not up-to-date you may ask us to correct the data. Where we are satisfied on reasonable grounds that a correction should be made, we will correct the data as soon as possible, or within 30 days from the date we receive your request.
Where there is a need to transfer your personal data to another country outside Singapore, we will ensure that the standard of data protection in the recipient country is comparable to that of Singapores PDPA. If this is not so, we will enter into a contractual agreement with the receiving party to accord similar levels of data protection as those in Singapore.
If you have any query or feedback regarding this Policy, or any complaint you have relating to how we manage your personal data, you may contact our Data Protection Officer (DPO) at: firstname.lastname@example.org
Any query or complaint should include, at least, the following details:
We treat such queries and feedback seriously and will deal with them confidentially and within a reasonable time.
We may update this Data Protection Notice from time to time. We will notify you of any changes by posting the latest Notice on our website. Please visit our website periodically to note any changes.
Changes to this Notice take effect when they are posted on our website.