At PINC Interactive Pte. Ltd. (“PINC”), we respect the privacy and confidentiality of the personal data of our Clients, Associates and others with whom we interact within 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.
We have developed this Data Privacy Notice to assist you in understanding how we collect, use, disclose, process, protect and retain your personal data that is in our possession.
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 personal data so long as it is used strictly for business-to-business (B2B) transactions.
We collect your personal data when you:
The types of personal data we collect about you include:
We use the personal data you provide us for one or more of the following purposes:
We disclose some of the personal data you provide us to the following entities or organisations outside PINC in order to fulfil our services to you:
Where required to do so by law, we may disclose your personal data to the relevant authorities or law enforcement agencies.
Before we collect, use or disclose your personal data, we will notify you of the purpose why we are doing so. We will obtain written confirmation from you on your expressed consent. We will not collect more personal data than is necessary for the stated purpose. We will seek fresh consent from you if the original purpose of collecting, using or disclosing your personal data has changed.
Under certain circumstances, we may assume deemed consent from you when you voluntarily provide your personal data for the stated purpose, e.g. when you apply for a job with us by sending in your resume/CV containing personal information.
We may rely on exceptions to the need for consent under the PDPA to collect, use or disclose your personal data under the following circumstances (only those relevant to PINC are included):
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 “Unsubscribe” feature in an online service.
We use “cookies” to collect information about your online activity on our website. A cookie is a small text file created by the website stored on your computer to allow the website to recognise you and keep track of your preferences. The cookie makes it convenient for you such that you do not have to retype the same information again when you revisit the website or in filling out electronic forms.
Most cookies we use are “session cookies”, which will be deleted automatically from your computer’s hard disk at the end of the session.
You may choose not to accept cookies by turning off this feature in your web browser. Note that you may not be able to use some of the features and functions in our web applications by doing so.
We do not get consent on behalf of another individual. We only get consent from the individual who will be dealing directly with us.
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.
From time to time, we may do a data verification exercise for you to update us on any changes to the personal data we hold about you. If we are in an ongoing relationship with you, it is important that you update us on any changes to your personal data (such as a change in your mailing address).
We have implemented appropriate information security and technical measures to protect the personal data we hold about you against loss, misuse, destruction, unauthorised alteration/modification, access, disclosure, or 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.
When we engage third-party data processors to process personal data on our behalf, we will ensure that they provide sufficient guarantees to us to have implemented the necessary organisational and technical security measures and have taken reasonable steps to comply with these measures.
We have a document retention policy that keeps track of the retention schedules of the personal data you provide us, in paper or electronic forms. We will not retain any of your personal data when it is no longer needed for business or legal 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.
You may write to us to find out how we have been using or disclosing your personal data over the past one year. Before we accede to your request, we may need to verify your identity by checking your NRIC or other legal identification documents. We will respond to your request as soon as possible, or within 30 days from the date, we receive your request. If we are unable to do so within 30 days, we will let you know and give you an estimate of how much longer we require. We may also charge you a reasonable fee for the cost involved in processing your access request.
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.
Where there is a need to transfer your personal data to another country outside Singapore, we will ensure that the standard of data protection in the recipient country is comparable to that of Singapore’s PDPA. If this is not so, we will enter into a contractual agreement with the receiving party to accord similar levels of data protection as those in Singapore.
In the unlikely event that we suffer a data breach is pertaining to unauthorised access or disclosure of personal data being stored or processed by us, we will meet the PDPA’s breach notification timelines and requirements to perform the needful, including but not limited to informing relevant authorities and affected individuals, based on the Significant Harm or Significant Scale definitions as set out by the PDPA.
If you have any queries or feedback regarding this Notice or any complaints about how we manage your personal data, you may contact our Data Protection Officer (DPO) at dpo@thepeoplesinc.org.
Any query or complaint should include at least the following details:
We treat such queries and feedback seriously and will deal with them confidentially and within a reasonable time.
We may update this Data Privacy Notice from time to time. We will notify you of any changes by posting the latest Notice on our website. Please visit our website periodically to note any changes.
Changes to this Notice take effect when they are posted on our website
Last updated: April 1, 2022