TPS Corporate Services Personal Data Protection Policy

Transcription

1 TPS Corporate Services Personal Data Protection Policy In this policy, we, us, our means and all its related companies (collectively known as TPS ), you, your or yours means the persons to whom this policy applies, as described. The ( TPS ) will include all its related companies listed below: TPS Accounting Services Pte Ltd TPS Corporate Advisory Pte Ltd TPS Corporate Suites Pte Ltd TPS Family Office Pte Ltd TPS Migration Services Pte Ltd TPS Marketing Pte Ltd TPS Realty Pte Ltd TPS Secretarial & Executive Search (1999) Pte Ltd Tomlinson Consulting Pte Ltd Mossack Fonseca & Co. (Singapore) Pte Ltd Capilion Corporation Pte Ltd TPS takes its responsibility to protect Personal Data and privacy rights of the individual who may provide it to us in relation to our various business activities. This policy is our Personal Data Protection Policy and Privacy Statement ( Policy ) and explains how TPS collects, uses, discloses and retains Personal Data. The privacy of your Personal Data is important to us and we are committed to complying with the applicable law and consistent with the Singapore Personal Data Protection Act 2012 (Act 26 of 2012) ( PDPA ). Section 1 - Personal Data we collect In this Policy, Personal Data refers to any data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which TPS has or is likely to have access to, including data in our records as may be updated from time to time. Example of such Personal Data you may provide to us includes: name, profession, job title; NRIC number, FIN number, Passport number age or birth date mobile number, telephone number, facsimile number; mailing or correspondence address

2 address photograph personal profile relating to you thru any related websites to support business transactions. Section 2 - How do we collect Personal Data Generally we collect Personal Data include (but are not limited to) directly or indirectly from you or authorized representative in a number of ways: when you submit to us a document containing Personal Data (for example, s, proof of identification, bank statements, credit card information, agreements, resumes etc) during interaction with our staff, including customer service officers and other representatives etc. via telephone calls, letters, fax, face-to-face meetings and ; when you request we contact you, or when you respond to our request for additional personal data and other initiatives; when you are applying for a job with us; during our conducting interviews; when you are using our product and services; our conducting or completing of transactions; when you submit your personal data to us for any other reasons. We may also collect Personal Data from third parties including: ACRA, IRAS or any other relevant other government entities Your service providers (e.g. your recruitment agency for job opportunities etc.) Your Personal Data will always be handled by us in accordance with this Policy and the PDPA. Section 3 - Purposes for which we Handle Your Personal Data and to Whom we disclose Your Personal Data We collect Personal Data about you so that we can provide best quality customer service in our daily business activities and functions. The purposes for which such personal data is Handled (collect, hold, use and disclose) includes: Providing professional services e.g. corporate secretarial services; statutory compliances; corporate advisory; real estate; migration services and family office etc. responding to queries and provide information or advice about existing and new products and services;

3 providing customer service e.g. responding to queries and requests; informing you about our product & services status (including updates in our policies, terms & conditions), sending you marketing brochures & alerts; complying with applicable legal laws, regulations and other requirements (including the regulatory and industry association reporting obligations), performing internal audits; maintaining customer relations (e.g. sending of marketing brochures and product/services update); Conducting and completing transactions e.g. processing payments; providing products or services as requested. performing evaluations e.g. on suitability of employees. updating our records and keeping your contact details up to date. Section 4 - Disclosure of Personal Data Depending on relevant product or service concerned, we may disclose or transfer your Personal Data to companies and various third party organizations which include: our related companies our joint venture, associate partners, alliance partners; our authorized service providers and specialist advisors to provide administrative, financial, legal, accounting, information technology such as web-hosting or other services; any third party organization if we determine that it s reasonably necessary to comply with any law, rule, regulatory and governmental authority. Section 5 Consent (What this Policy enables You and Us) By applying this Policy and the PDPA, you: a. have consented to TPS which enable us to facilitate you with the best quality products, services or communications, attending to you and/or relevant transactions. b. enable the exercise of your rights under the PDPA framework, including securing the right to access your personal data, withdraw your consents as to your personal data; Withdrawal of Consent You may withdraw consent to the collection, use or disclosure of your personal data, and TPS will respect your choices in this regard. You may notify us in writing to our contact details below as mentioned in Section 12. Your request will be attended to promptly upon the receipt of your notice (estimated require up to 4 weeks processing time) for the change to take effect.

4 Section 6 Access and Correction of Personal Data We endeavor to ensure personal data we hold about you is accurate and up-to-date. If you wish to access, update or otherwise change or remove any information that you have provided to us, pls contact us as mentioned in Section 12. Relevant forms to update or change your personal data are made available for your submission to us. Section 7 - Personal Data Transfer outside Singapore Your Personal Data may be transferred, stored and/or processed in a country or territory outside Singapore and you consent to any such transfer, storage and/or processing of your Personal Data outside Singapore, where applicable. We will take reasonable approach that any party to whom we transfer your Personal Data does not breach our Personal Data Policy or provides a standard of protection at least comparable to PDPA. Section 8 - Retention of Personal Data The PDPA requires not to store Personal Data longer than necessary. TPS will retain your Personal Data only for as long as the purposes for which such data is collected or used (as notified to you) continues, or where necessary for our legal or business purposes. Generally, we do not retain Personal Data for a period of longer than 7 years after the original purposes for which the Personal Data was collected have ceased to be applicable, unless otherwise required by law or other mandatory government authorities or for purposes of legal proceedings. For unsuccessful job applicants, TPS will retain your Personal Data for no longer than 1 year for the purposes of evaluating your suitability for future job openings within TPS Group, unless you inform us. When your Personal Data is no longer required, it will be destroyed or disposed. Section 9 Protection of Personal Data TPS has made security arrangement to protect Personal Data in its possession or control to prevent unauthorized access, disclosure, copying, use or modification with security safeguards appropriate to the sensitivity of the personal data. Technical measures are taken such as firewalls and other security software to protect its servers and networks from unauthorized use, access and tampering of files and other information that we store.

5 Section 10 - Do Not Call Registry TPS complies with all provisions regarding the DNC registry under PDPA. You may also, however, advise us in writing should you wish not to be contacted by us at your telephone or facsimile number(s) for any given purpose or all purposes. Section 11 Using our TPS Website Cookies may be used on some pages of our websites. Cookies are small text files placed on your hard drive that are now used as a standard by many websites to improve users navigational experience. If you are concerned about cookies, you may adjust your internet browser to disable cookies. If cookies are disabled you may still use the TPS website, but may be limited in the use of some of the features. After termination of the visit to our site, you can always delete the cookie from your system if you wish. The TPS website may contain links to or from other websites. TPS is not responsible for the privacy practices of other websites. Section 12 - Contacting Us - Withdrawal of Consent, Access and Correction of Personal data If you (a) have any questions relating to your Personal Data or about our Policy, (b) would like to withdraw your consent to any use of your Personal Data; or (c) would like to obtain access and make corrections to your Personal Data records, you may contact our Personal Data Protection Officer at or pdpa@tps.com.sg Available forms for download: Consent Withdrawal Form Personal Data Correction Form Section 13 Changes to Policy We reserve the right to amend, modify or alter this Policy at any time as it deems appropriate. Please review this Policy from time to time so you are aware of any changes or updates to the notice with the indicated effective date. If you do not agree with any of the changes or updates to the Policy, you have the option of notifying us (please refer to Section 5 above) or withdrawing your consent to our collection, use, disclosure and processing of your Personal Data. Effective date: 16 Feb 2015