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PRIVACY POLICY & DATA PROTECTION UNDER PPDA

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PRIVACY POLICY

The policy explains our commitment to treat information received from its users with utmost care and confidentiality. The company shall endeavour that information is gathered, stored and data handled fairly, transparently and without impairing individual’s rights.

This policy applies to all users of the website who provide any personally identifiable information to the company. As part of its operations, the company needs to obtain and process information. This information includes any offline or online data that makes a person identifiable such as names, addresses, usernames and passwords, digital footprints, photographs, etc. The company collects this information in a transparent way and with the knowledge of interested parties.

Our data will be:

  • Kept reasonably up-to-date
  • Collected fairly and for lawful purposes only
  • Processed by the company within its legal and moral boundaries
  • Protected against any unauthorized or illegal access by internal or external parties

Our data will not be:

  • Communicated informally/formally unless required lawfully
  • Stored for more than a specified amount of time
  • Transferred to organizations, states or countries that do not have adequate data protection policies
  • Distributed to any party other than the ones agreed upon by the data’s owner (exempting legitimate requests from law enforcement authorities).

In addition to ways of handling the data, the company endeavours to take reasonable steps to protect the data, save and except any force majeure event beyond the reasonable control of the company.

DATA PROTECTION POLICY UNDER PPDA

Last update: 23 August 2018

This Data Protection Policy applies to Space Matrix Group of companies, particularly, the entities established in Singapore (“SMG” or “we” or “Company”). This policy governs the collection, use and disclosure of personal data submitted to SMG and explains how we handle personal data in order to comply with the requirements of the Personal Data Protection Act 2012 of Singapore (“PDPA”). We collect, use or disclose personal data for which there is consent or deemed consent from the individuals to whom such information relate and if required/authorized under applicable laws. The personal data shall mean and include the information about a natural person which can be used to identify such natural person (‘Personal Data’).

Collection of Personal Data:  While transacting its business, SMG may receive Personal Data from employees, customers, vendors, consultants and other individuals. We endeavour to ensure that we collect, hold, process, use, communicate and/disclose such Personal Data in accordance with this policy and use the same, purely for the purpose, for which the data is collected/provided. In case you are providing any third party’s individual data, you must ensure that you have their consent for providing their personal data to us and inform the individual of such disclosure to us including making available a copy of this policy to them or referring them to our website. 

Use of Personal Data: The Personal Data collected by the Company will be used for the following purposes only:

  • To provide our services;
  • To respond to an individual’s request or for the purposes for which it was provided;
  • Approaching/pitching services to prospective clients;
  • Engaging vendors/individual consultants for the provision of services to Company’s clients;
  • Recruitment purposes and for interacting with employees/consultants/vendors of clients;
  • Business promotions including applying for awards;  
  • Partnering with vendors to engage them to provide services to Company’s clients;
  • To maintain contact with clients, consultants, vendors and other business contacts;
  • As required by law enforcement authorities;
  • All other purposes related to our business.

Disclosure of Personal Data & Protection of Personal Data: The Personal Data collected, may be disclosed to employees, consultants, vendors of SMG and its group companies (‘Data Recipients’) as may be required in the course of their employment/engagement strictly to provide services to the clients of SMG. The personal data may only be disclosed to third parties after obtaining consent of concerned individual and ensuring that such third parties are obligated under suitable Agreement/Undertaking to maintain the confidentiality of such Personal Data. We have implemented, generally accepted standards of technology and operational security to protect the Personal Data from unauthorised disclosure, access, collection, use, modification, disposal or similar risks. Only authorized SMG personnel are provided access to Personal Data if required and these personnel have agreed to ensure confidentiality of this information.

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 including facilitate correction of Personal Data in SMG’s possession in accordance with the requirements of PDPA.

Accuracy of Personal Data: We will endeavour that the Personal Data collected by us or on our behalf is accurate and complete, as received from the individual or third party provider.

Withdrawal of Consent & Retention of Personal Data: Any individual who has provided Personal Data to SMG may withdraw his/her consent, in respect of collection, use and disclosure of such data and we will cease (and cause any of our data intermediaries and agents to cease) use or disclosure of such Personal Data unless mandated under applicable laws. We will cease retention of Personal data once the purpose of collection of such personal data is served and such retention is no longer required for legal or business purposes.

Transfer of Personal Data outside of Singapore: SMG will endeavour that any transfer of Personal Data outside Singapore will be in compliance with PDPA.

Data Protection Officer (DPO): Ms. Vanessa Lin is appointed as the DPO for SMG and is responsible for ensuring compliance by SMG of the obligations under PDPA. All queries, complaints, requests for access/correction relating to Personal Data under PDPA are to be addressed and directed to the aforementioned DPO. SMG DPO may be contacted @ vanessa.lin@spacematrix.com.

Modifications: SMG may from time to time update or amend this Data Protection Policy to ensure that this Policy is consistent with any changes in legal or regulatory requirements. To keep you informed, we will notify changes to this Policy in our website. The date of the last amendment will be reflected at the beginning of this Policy.

 

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