1 – Introduction
AceCom Technologies Pte Ltd (“AceCom”) 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. 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.
By submitting your information to us, or signing up for any products and/or services offered and/or distributed by us, you agree and consent to AceCom, and where appropriate our respective representatives, third party service providers, and/or contractors, collecting, using, disclosing personal data in the manner set forth in the prevailing terms of this Privacy Notice, including any future amendments. You acknowledge and agree that AceCom may, from time to time, amend and update this Privacy Notice in order to ensure it is consistent with future developments, industry trends and/or any changes in legal or regulatory requirements.
Please note that the purposes set forth in this Privacy Notice supplement but do not supersede any other consents you may have previously provided to us or which you may provide to us in the future.
2 – How We Collect Your Personal Data
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 collect your personal data when you:
- Enter into an agreement or contract with us to provide you with our consultancy and services offered and/or distributed by us or provide other documentation or information in respect of your interactions and transactions with us, or when you use our services;
- when you interact with our customer service representatives, sales personnel or appointed service providers (for example, via telephone calls, letters, face-to-face meetings, social media platforms, surveys, workshops and/or e-mails);
- Enquire about our range of products and services;
- Respond to our electronic direct mails (EDMs) sent by us as part of our marketing or promotion campaigns through an authorised third party EDM service provider;
- Are referred to us for our services by one of our clients or business partners;
- Request us to contact you (whether pursuant to a request for more information, complaints, or any other purposes);
- Use our electronic services, or interact with us via mobile services, social media accounts, digital platforms, any of our websites or web services and register an account with us;
- when we receive information from third parties about you when you make payment through (including but not limited to physical and digital payment kiosks);
- Images are captured by us via CCTV cameras while you are within any of our premises, or via photographs or videos taken by us, our representatives or our agents when you attend our events;
- submit your personal data to us for any other reason; and/or
- Other publicly available sources where relevant and appropriate.
Please note that if you provide us with any personal data relating to a third party, you represent and warrant to us that you have obtained the consent of the third party to provide us with their personal data for the relevant purposes.
3 – Types of Personal Data We Collect About You
The types of personal data we collect about you include:
- Your contact information (Name, telephone number(s), e-mail address)
- Your personal details (Name, company name, date of birth, driving license number, vehicle number, profile picture, video image)
- Purchasing on our website (Name, credit card number, billing address, shipping address, and telephone number
In addition to the information we collect from you directly, we may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly available sources.
4 – Use of Personal Data
We use the personal data you provide us for one or more of the following purposes:
- Provide our products and services and carry out obligations from any contracts entered into between you and us;
- Responding to your queries, complaints, feedback and requests and/or otherwise communicating with you in relation to your contracts;
- Process, account payables/receivables, billing, payment and other credit-related activities;
- to respond to the individual’s request or for the purposes for which it was provided to us as stated at the time of the collection (or as is obvious from the context of collection)
- Conduct direct marketing and lead generation activities through analysing and tracking of our sales proposals, advertisements and EDMs on our events, conferences, seminars and workshops;
- Customer care, enhance customer experience and account management;
- Analyse the use of our products, services or websites;
- Analyse your visits to our websites, social media platforms;
- Conduct joint marketing with other companies and service providers;
- Comply with or fulfil legal obligations and regulatory requirements.
Any individual may choose to unsubscribe from mailing lists, registrations, or elect not to receive further marketing information from us by contacting our Data Protection Officer, or if we have contacted such individual by email, such individual may use the unsubscribe function in that email to notify us. Such requests will be processed within 30 days.
5 – Disclosure of Personal Data
We do not disclose personal data to third parties except when required by law, when we have the individual’s consent or deemed consent or in cases where we have engaged third parties such as data intermediaries or subcontractors specifically to assist with our Company’s activities. Any such third parties whom we engage will be bound contractually to keep all information confidential. We may also transfer all data in our possession to a successor-in-interest to our business or assets.
6 – Data Accuracy
We will also take reasonable efforts to ensure that any personal data we have about you is true, accurate and complete. However, this means that you must also update us of any changes to the personal data that you had initially provided to us in a timely fashion. Any failure on your part to do so may result in our inability to provide you with the products and services you have requested.
7 – Access to and Correction of Personal Data
Upon request, we will provide the individual with access to their personal data or other appropriate information on their personal data in accordance with the requirements of the PDPA. Before we accede to your request, we may need to verify your identity by checking your NRIC or other legal identification document. Upon request, we will correct an error or omission in the individual’s personal data that is in our possession or control in accordance with the requirements of the PDPA. We may charge for a request for access in accordance with the requirements of the PDPA.
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.
8 – Withdrawal of Consent
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.
As you interact with our website or mobile site, we may automatically collect technical data about your devices, browsing actions and patterns. We collect this data by using cookies, server logs and other similar technologies. If you do not wish for us to collect such technical data from you, you can change your cookie settings of your web browser at any time. 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.
10 – How We Protect Your Personal Data
We will take reasonable efforts to protect the personal data in our possession by making reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or any similar risks. 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.
We have policies in place to ensure that the personal data in our possession is destroyed and/or anonymized as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes.
11 –Retention of Personal Data
We will cease to retain personal data, as soon as it is reasonable to assume that the purpose for collection of such personal data is no longer being served by such retention, and such retention is no longer necessary for legal or business 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.
12 – Transfer of Personal Data outside of Singapore
We generally do not transfer your personal data to countries outside of Singapore. We will ensure that any transfers of personal data to a territory outside of Singapore will be in accordance with the PDPA so as to ensure a standard of protection to personal data so transferred that is comparable to the protection under the PDPA.
13 – Contacting Us (Feedback, Access, Correction and Withdrawal of your Personal Data)
Provide your feedback on any issues relating to your personal data or this Privacy Notice; withdraw your consent to any collection, use or disclosure of your personal data; or request to access and/or correct the personal data currently in our possession, you may wish to contact us at firstname.lastname@example.org
We treat such queries and feedback seriously and will deal with them confidentially and within reasonable time.
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