This Data Protection Notice (“Notice”) sets out the basis which Verticys 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.
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.
Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include your name and identification information such as your NRIC number, contact information such as your address, email address or telephone number, 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.
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
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 that has not been notified to you (except where permitted or authorised by law).
We may collect and use your personal data for any or all of the following purposes:
performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
verifying your identity;
responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
managing your relationship with us;
processing payment or credit transactions;
sending your marketing information about our goods or services including notifying you of our marketing events, initiatives and promotions, lucky draws, membership and rewards schemes and other promotions;
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;
any other purposes for which you have provided the information;
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; and
any other incidental business purposes related to or in connection with the above.
We may disclose your personal data:
where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods or services requested by you; or
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.
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
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.
Upon receipt of your written 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 ten (10) business days of receiving it.
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
Please note that withdrawing consent does not affect our right to continue to collect, use, and disclose personal data where such collection, use, and disclosure without consent is permitted or required under applicable laws.
ACCESS TO AND CORRECTION OF PERSONAL DATA
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.
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.
We will respond to your request as soon as reasonably possible. 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
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.
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
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
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 or permitted by applicable laws.
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
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.
When using cloud services, Verticys Pte Ltd is responsible for complying with all obligations under the PDPA in respect of personal data processed by the cloud service provider (“CSP”) on its behalf and for its purposes. Processing is defined in the PDPA as the carrying out of any operation or set of operations in relation to the personal data and includes recording, holding, organizing, adapting or altering, and retrieval of personal data. Where the CSP is processing personal data on behalf and for the purposes of another organization pursuant to a contract which is evidenced or made in writing, the CSP is considered a data intermediary and subject to the Protection and Retention Limitation Obligations under the PDPA. Its Protection and Retention Limitation Obligations extend to personal data that it processes or hosts for the organization in data centers outside Singapore. The CSP, as an organization in its own right, remains responsible for complying with all Data Protection Provisions in respect of its own activities which do not constitute processing of personal data under the contract.
Verticys Pte Ltd is responsible for complying with the Transfer Limitation Obligation in respect of any overseas transfer of personal data in using the CSP’s cloud services. This is regardless of whether the CSP is located in Singapore or overseas.
DATA PROTECTION OFFICER
You may contact our Data Protection Officer if you have any inquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:
EFFECT OF NOTICE AND CHANGES TO NOTICE
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.
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 acknowledgment and acceptance of such changes.
When you visit one of our websites, we will store information on your computer in the form of a cookie. Cookies are small text files that are sent by a web server to your browser and are stored on the hard disk of your computer. This information serves to automatically recognize you when you next visit our websites and to ensure a personalized experience for you.
You can also look at our websites without cookies. If you do not want us to recognize your computer, you can prevent the storage of cookies on your hard disk by selecting “do not accept cookies” in your browser settings. Please refer to your browser manufacturer for more information on how to reject or delete cookies. However, if you do not accept any cookies, the features of our webpage may be limited.
USE OF WEB ANALYTICS
Our website uses Google Analytics, open-source software for the statistical analysis of visitor accesses. Google Analytics also uses the so-called “cookies”, text files which are stored on your computer and allow an analysis of the use of the website by you. The information generated by the cookie regarding your use of this internet offer is stored on the provider’s server. The IP address is anonymized immediately after processing and prior to storage. You can prevent the installation of cookies by selecting the appropriate browser software settings; however, you may no longer be able to fully use all functions of this website.
If you wish to disable the tracking of your visits in the Google Analytics Web statistics, you will find options for deactivating Google Analytics in the browser add-on in the following link
We have implemented technical and organizational safety measures to protect your personal data against loss, destruction, manipulation, and unauthorized access. All of our employees and all third parties involved in the data processing are obliged to observe the Singapore Personal Data Protection Act (PDPA) and to treat all personal data confidentially. When personal data are collected and processed, the information is transmitted in encrypted form in order to prevent any misuse of the data by third parties. Our safety measures are constantly reviewed to keep up with technological progress.
GENERAL REMARK ON EXTERNAL LINKS
GENERAL REMARKS ON SOCIAL MEDIA/BOOKMARKS
Bookmarks (e.g. for LinkedIn etc.) are placed onto our website. These are bookmarks that enable the users of such a service to collect links and news reports. These appear on our websites only as links to the services concerned. After clicking on the image, you will be directed to the site of the provider concerned so that user information is transmitted only then to these providers. Information regarding the handling of your personal data when you use these websites is available in the various providers’ privacy policies.
RIGHT TO INFORMATION AND TO OBJECT
You can at any time obtain information about the data concerning you that we have stored and you can demand the correction, the deletion, or the limitation of the processing of these personal data. However, Verticys Pte Ltd can delete your personal data or restrict their use only if there is no legal obligation to retain or use the data in the context concerned and if Verticys Pte Ltd cannot assert a prior right regarding the retention or context-related use of these data. Furthermore, you can at any time revoke your consent to the collection and storage of your personal data by us. If you wish to do so, please send an email to our data protection officer mail to email@example.com.