We respect the confidentiality of Personal Data and privacy of individuals and are committed to complying with the Singapore Personal Data Protection Act (Act 26 of 2012) (“PDPA”) and other applicable data protection laws. Please read this Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data.
You agree and consent to us, collecting, using, storing, processing, disclosing and sharing amongst ourselves your Personal Data as data controllers, and disclosing such Personal Data to our authorised service providers and relevant third parties as data controllers and/or data processors as appropriate in the manner set forth in this Policy.
By accessing and using this website, interacting with us, or providing your data to us, and subject to your rights at law, you accept and agree to these terms and conditions without any limitation or qualification.
Please note that depending on the jurisdiction in which your Personal Data is being collected, used, disclosed or processed by us, different country-specific addenda may apply. If your Personal Data has been collected, used or disclosed by us in a particular country, you should check the terms of the country-specific addenda to see if there is a country-specific addendum applicable to you and the collection, use, disclosure and processing of your Personal Data. The terms set out in the addenda are in addition to the terms set out in this Policy and form a part of this Policy.
This Policy supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your Personal Data, and your consents herein are additional to any rights which any member of Avarga may have at law to collect, use or disclose your Personal Data. This Policy does not affect any rights which we may have at law in connection with the collection, use or disclosure of your Personal Data.
For the avoidance of doubt, nothing in this Policy establishes any joint and several liability on the part of the Avarga Group members.
1. Your Personal Data
1.1. “Personal Data” refers to any data or information about you from which you can be identified either (a) from that data; or (b) from that data and other information to which we have or are likely to have access. Examples of such Personal Data which you may provide us include (depending on the nature of your interaction with us):
- your name, NRIC number, passport number or other identification number, telephone number(s), mailing address, email address and any other information relating to you which you have provided us in any form you may have submitted to us, or in other forms of interaction with you; and
- information about your use of our websites and services, including cookies, IP addresses.
2. Collection of Personal Data
2.1. Generally, we collect your Personal Data in the following ways:
- when you submit forms relating to any of our products or services, or submit any online queries;
- when you interact with our customer service officers or any of our staff, for example, via letters, online forms (such as any “Contact Us” forms on our websites), social media platforms and emails;
- when you request that we contact you;
- when you respond to our request for additional Personal Data;
- when you ask to be included in an email or other mailing list;
- when you submit a job application;
- when we receive references from business partners and third parties, for example, where you have been referred by them;
- when you submit your Personal Data to us for any other reason; and
- when you browse our website.
2.2. If you provide Personal Data of a third party (e.g. information of your dependent, spouse, children and/or parents) to us, you represent and warrant that the consent of that third party has been obtained for the collection, use and disclosure of the Personal Data for the purposes set out above.
3. Use and Disclosure of Data
3.1 In general, we use and disclose your Personal Data for the following purposes:
- to provide you with the products or services that have been requested;
- to help us review, develop, improve, manage the delivery of and enhance our products and services, including analysing future customer needs, conducting market research and data analytics;
- to communicate with you and respond to your queries, requests and complaints;
- to provide ongoing information about our products and services which may be of interest to you;
- to handle disputes and conduct and facilitate investigations and proceedings;
- to protect and enforce our contractual and legal rights and obligations;
- to prevent, detect and investigate crime, including fraud and money-laundering, and to analyze and manage other commercial risks;
- to manage our infrastructure and business operations and to comply with internal policies and procedures;
- to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving any Avarga Group entity; and
- to comply with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities.
3.2. Additionally, we may also use and disclose your Personal Data for the following purposes, depending on the nature of our relationship with you:
- If you are a shareholder or unitholder of our shares:
- to administer the relationship, including the verification of your identity and/or the identity of your proxy (as may be applicable);
- to inform you of our performance and the products and services that we provide to our customers through the sending of circulars, reports, newsletters and communications;
- to communicate with you changes and development to our policies, terms and conditions and other administrative information; and
- any other purpose directly relating to any of the above.
- If you are a vendor, a prospective vendor or a contractor:
- to evaluate your proposal and to conduct background checks on you;
- to communicate with your deployed staff, after award of contract, who are in our properties to carry out work or services, and for any emergency or/and security concerns; and
- any other purpose directly relating to any of the above.
- If you submit an application to us as a candidate for employment:
- to process your application including pre-recruitment checks;
- to provide or to obtain references for background screening/vetting;
- to collect information about your suitability for the position applied for;
- to organise training and staff development programs;
- to assess your performance;
- to administer benefits and payroll processing;
- to provide you with tools to facilitate or as required for you to do your job;
- to communicate with you to comply with our policies and processes, including for business continuity purposes; and
- any other purposes relating to the aforesaid.
3.3 The above purposes are not exhaustive, and depending on the nature of your relationship with us, we may collect, use and disclose your Personal Data for additional purposes which you will be notified of, in accordance with applicable terms and conditions.
3.4 Your Personal Data will be protected and kept confidential, but subject to the provisions of any applicable law, your Personal Data may, depending on the products or services concerned, be disclosed to the following third parties:
- other divisions or entities within Avarga Group;
- our joint venture/ alliance partners;
- our agents, contractors, third party service providers and specialist advisers who have been contracted to provide us with administrative, financial, research, operational or other services, such as telecommunications, information technology, payment, payroll, processing, training, market research, storage and archival;
- any third party business partners who offer goods and services, whether in conjunction with us or not;
- insurers or insurance investigators and credit providers;
- the Credit Bureau, or in the event of default or disputes, any debt collection agencies or dispute resolution centres;
- any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving Avarga Group;
- our professional advisors such as our auditors and lawyers;
- relevant government regulators or authority or law enforcement agency to comply with any laws or rules and regulations imposed by any governmental authority;
- anyone to whom we transfer or may transfer our rights and obligations;
- banks, credit card companies and their respective service providers; and
- any other party as may be consented to by you, as specified by that individual or in the applicable contract.
We require that organisations outside the Avarga Group which handle or obtain Personal Data as service providers to us acknowledge the confidentiality of this data, undertake to respect any individual’s right to privacy and comply with the PDPA. We also require that these organisations use this information only for our purposes and follow our reasonable directions with respect to this information.
3.5. In carrying out our business, it may be necessary to share information about you with and between our related corporations and third party service providers. Some of these related corporations and third party service providers may be located in countries outside Singapore that may not afford an adequate protection to personal data or have protections in place which are similar to those in your country of residence. However, we will take reasonable steps to ensure that your Personal Data transmitted outside of your country of residence is adequately protected.
4. Keeping Your Personal Data Accurate and Up-To-Date
We strive to ensure that all Personal Data we have about you is accurate and up-to-date. We understand that this information changes frequently with changes of address and other personal circumstances. We encourage you to contact us as soon as possible to enable us to update any Personal Data we have about you.
5. Third-Party Sites
6. Withdrawal of Consent
You may withdraw your consent given for any or all purposes set out in this Policy in writing by contacting us in accordance with paragraph 7 below. If you withdraw your consent to any or all purposes and depending on the nature of your request, we may not be in a position to continue to provide our products or services to you.
7. How to contact us
If you have any questions about this Policy or any complaints relating to your Personal Data, or you would like to obtain access and make corrections to your Personal Data records (for which we may charge a fee to cover the cost of verifying the application and locating, retrieving and copying any material requested), please email to firstname.lastname@example.org
8. Governing Law
This Policy and your use of this website shall be governed in all respects by the laws of Singapore.
9. Review of the Policy
This Policy will be reviewed from time to time by us. We may also from time to time update this Policy to take account of new laws and technology, changes to our operations and practices and the changing business environment.
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