Data Protection Policy
Last updated: [3rd Aug 2020]
This Data Protection Notice (“Notice”) sets out the basis which Inventrik Pte Ltd (“we”, “us”, or
“our”) may collect, use, disclose or otherwise process personal data of our customers, employees 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.
- Under the Singapore Personal Data Protection Act (PDPA), business contact information (e.g. name, company address, company telephone number) is not considered as personal data so long as it is used strictly for business-to-business (B2B) transactions.
- 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 collect data that you voluntarily provide to us when you enquire about our services via email, telephone or through our website. The information you provide will be handled according to this Data Protection Policy.
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 contact details, email address or telephone number.
You have choices regarding our collection, use or disclosure of your personal data. You have the right to object to the processing of your personal data and withdraw your consent in a manner described in clause 8 of this Policy.
We may collect, disclose or use your personal data pursuant to an exception under the Personal Data Protection Act or other written law.
In general, subject to the applicable exceptions permitted in the PDPA, before we collect personal data from you, we will notify you of the purposes for which your personal data may be collected, used and/or disclosed, as well as obtain your consent for the collection, use and/or disclosure of your personal data for the intended purposes. If you choose not to provide us with the personal data described in this Policy, we may not be able to fulfil our contractual duties towards you or facilitate your request or provide goods and/or services to you.
Any unsolicited personal data received by us will be returned to the sender immediately. If received by email or through our website, these unsolicited personal data will be deleted right away. If received by telephone, these will not be recorded.
- We may collect and use your personal data for any or all of the following purposes:
(a) performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
(b) verifying your identity;
(c) responding to, handling, and processing queries, requests, applications, complaints,
and feedback from you;
(d)managing your relationship with us;
you of our marketing events, initiatives and promotions, lucky draws, membership
and rewards schemes and other promotions;
(e) 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;
(f) any other incidental business purposes related to or in connection with the above.
(g) any other purposes for which you have provided the information;
- We may disclose your personal data:
(a) 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
(b) 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).
OUR RESPONSIBILITIES AS A ‘DATA INTERMEDIARY (DI)’ UNDER PDPA
Where we are a DI, we have agreements, documents containing certain prescribed terms in our contracts with data controllers (DC), including:
- to ensure the security of data processing;
- to keep records of processing activities;
- to notify any personal data breaches to the data controller; and
- to appoint a data protection officer
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 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. Should we require more time to give effect to a withdrawal notice, we will inform you of the time frame by which the withdrawal of consent will take effect.
- 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 or services to you and we shall, in such circumstances, review and notify you on the consequences of the withdrawal before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 8 above.
- Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose 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.
- An administration fee may be charged for the handling and processing of your request to access your personal data. If so, we will inform you of the fee beforehand.
- We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) calendar days after receiving your request, we will inform you in writing within 30 calendar 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 SSL, 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. 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, taking into account its intended use. Where possible, we will validate the information provided by you using generally accepted practices and guidelines.
RETENTION OF PERSONAL DATA
- We may retain your personal data for as long as it is necessary to fulfil 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.
DATA PROTECTION OFFICER
- You may contact our Data Protection Officer if you have any enquiries or feedback on our
personal data protection policies and procedures, or if you wish to make any request, in the
Name: Neha Lad
DID: +65 66533279
EFFECT OF NOTICE AND CHANGES TO NOTICE
22. 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 acknowledgement and acceptance of such changes.