Last updated: Dec 2018
By using the Site and/or our other services and/or products, you express your agreement with this Policy and the conditions of processing your Personal Data contained herein; if you do not agree with these conditions, you should not use the Site and/or our other services and/or products.
2. Data we collect
Personal Data: While using the Site, and/or our services and/or our products we may ask you to provide us Personal Data that can be used to contact or identify you. “Personal Data” is defined to mean data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access provided that to the extent you reside in, or are otherwise subject to the personal data laws of, a jurisdiction the relevant laws or other applicable rules of which provide for a different definition of personal data, the definition of “Personal Data” hereunder shall be construed to also encompass any other types of data that are included in such different definition. The Personal Data that we may collect from you includes, but is not limited to, your salutation, name, company, designation, industry, gender, country of residence, contact number and one or more email addresses.
Log Data: Like many site operators, we automatically collect information that your browser sends whenever you visit our Site (“Log Data”). This Log Data includes information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of the Site that you visit, the time and date of your visit, the time spent on those pages and other statistics. We may use this information to monitor server errors, server administration or to monitor visitor behaviour on our Site. It is from a technical perspective not possible for the single user to disable the collection of the aforementioned data, so in case the user disagrees with this data processing, the user must not use the Site.
Other Information: To enable us to deliver our services and products to you, we use third party services to integrate with our Site. Third party services typically are applications and/or software that integrate with our services. The provider of a third party service may share certain information with us. For example, when using a payment service/application on our Site, we may receive your user name and email address, along with additional information that the third-party application has elected to make available to us to facilitate the integration. You should check the privacy settings and notices in these third party services/applications to understand what data may be disclosed to us. We are authorized to connect and access information made available to us in accordance with our agreement with the third party provider. We do not, however, receive or store passwords for any of these third party services when connecting them to our Site.
3. Purposes for Collection, Use & Disclosure of Personal Data
The Personal Data set out in Section 2 above which we collect from you may be collected, processed, used and/or disclosed to the recipients mentioned below for the following purposes:
a) operate our business;
b) maintain and improve your access and/or use of the Site;
c) providing you with information and/or updates on products, services and promotions offered by us and selected third parties, including personalised content and information such as online advertisements or other forms of marketing to you;
d) facilitating, processing, dealing with, administering, managing and/or maintaining your relationship with us;
e) carrying out your instructions or responding to any enquiry given by (or purported to be given by) you or on your behalf; and
f) to meet with regulatory requirements imposed by our regulators and the regulators of the countries we operate in.
(collectively, the “Purposes”)
We process your Personal Data based on your consent according to Article 6 paragraph 1 (a) GDPR, in the event of a contract being concluded, according to Article 6 paragraph 1 (b) of the GDPR and for the purposes of our legitimate interests according to Article 6 paragraph 1 (f) GDPR.
In order to conduct our business operations more smoothly, we may also be disclosing the personal data you have provided to us to our third party service providers, agents and/or our affiliates or related corporations (as mentioned in Section 1 above) (some of which may be situated outside of the country in which you live or of which you are a passport holder), for one or more of the above-stated Purposes. The level of data protection in another country may not be equivalent to that in your country. However, we only transfer your personal data to countries where the Commission of the European Union has decided that they have an adequate level of data protection or we take measures to ensure that the recipients provide an adequate level of data protection. We do this for example by entering into appropriate data transfer agreements based on standard contractual clauses. Such third-party service providers, agents and/or affiliates or related corporations would be processing your Personal Data on our behalf for one or more of the above-stated Purposes. Therefore, we, in our capacity as controller have entered into appropriate data transfer agreements to ensure the processing by the above-mentioned categories of processors in accordance with GDPR.
Currently, we disclose the personal data you have provided us only to Content Capital Solutions Pte. Ltd., a third-party service provider based in Singapore under a current service agreement, who processes information on our behalf. As our business grows and evolves, the processors we engage may also change. We will endeavour to provide you with notice of any new processors to the extent required under the agreement, along with posting such updates here. Please check back frequently for updates.
4. Specific issues for the disclosure of personal data to third party
We respect the confidentiality of the personal data you have provided to us. In this regard, apart from the Purposes set out above, we will not disclose any of your personal data to any third parties without first obtaining your express consent permitting us to do so. However, please note that we may disclose your personal data to third parties, including to parties and third-parties located outside your jurisdiction, without first obtaining your consent in certain situations, including, without limitation, the following:
a) cases in which the disclosure is required based on the applicable laws and/or regulations;
b) cases in which the purpose of such disclosure is clearly in your interests, and if consent cannot be obtained in a timely way;
c) cases in which the disclosure is necessary to respond to an emergency that threatens the life, health or safety of yourself or another individual;
d) cases in which there are reasonable grounds to that the health or safety of yourself or another individual will be seriously affected and consent for the disclosure of the data cannot be obtained in a timely way, provided that we shall, as soon as may be practicable, notify you of the disclosure and the purposes of the disclosure;
e) cases in which the disclosure is necessary for any investigation or proceedings;
f) cases in which the personal data is disclosed to any officer of a prescribed law enforcement agency, upon production of written authorisation signed by the head or director of that law enforcement agency or a person of a similar rank, certifying that the personal data is necessary for the purposes of the functions or duties of the officer;
g) cases in which the disclosure is to a public agency and such disclosure is necessary in the public interest; or
h) cases where such provision is required for your use of any of our services or products or the performance of any agreement or contract with us.
Kindly note that the instances listed above are not intended to be exhaustive and would include other exceptions based on applicable laws.
In all other instances of disclosure of personal data to third parties with your express consent, we will endeavour to provide adequate supervision over the handling and administration of your personal data by such third parties, as well as to provide for adequate forms of protection over such personal data.
Where personal data is transferred by us to any third parties outside of the country in which you live or of which you are a passport holder, we will ensure that such transfers are compliant with the requirements under applicable laws. In this regard, we will take necessary measures to ensure that such overseas recipients are bound by legally enforceable obligations to ensure that these overseas recipients provide a standard of protection to the personal data so transferred that is comparable to the protection under the personal data protection laws of the country which we transfer the personal data out from.
5. Request for access and/or correction of personal data
Under applicable law, you have among others, the rights (under the conditions set out in applicable law):
You may request to access and/or correct your personal data currently in our possession or under our control at any time by submitting your request to the contact details listed below at section 9.
6. Request to withdraw consent
You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control at any time by submitting your request to the contact details listed below.
We will process your request within a reasonable time from such a request for withdrawal of consent being made, and will thereafter refrain from collecting, using and/or disclosing your personal data in the manner stated in your request.
The security of your Personal Data is important to us but remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security.
8. Administration and management of personal data
We will take appropriate measures to keep your personal data accurate, complete and updated.
We will also take commercially reasonable efforts to take appropriate precautions and preventive measures to ensure that your personal data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorised access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data. However, we cannot assume responsibility for any unauthorised use of your personal data by third parties which are wholly attributable to factors beyond our control.
We will also take commercially reasonable efforts to ensure that the personal data in our possession or under our control is destroyed and/or anonymised 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.
We will, in any case, retain your Personal Data for as long as there are statutory retention obligations or potential legal claims that are not yet time-barred.
9. Complaint Process
If you have any complaint or grievance regarding about how we are handling your personal data, we welcome you to contact us with your complaint or grievance.
Please contact us through one of the following methods with your complaint or grievance.
Email address: email@example.com
(Attention it to the ‘Data Protection Officer’)
Office address: Content Capital Solutions Pte. Ltd.
10 Anson Road, #27-15 International Plaza Singapore 079903
(Attention it to the ‘Data Protection Officer’)
Where it is an email or a letter through which you are submitting a complaint, your indication at the subject head that it is a Personal Data complaint would assist us in attending to your complaint speedily by passing it on to the relevant staff in Content Capital Solutions Pte. Ltd. to handle. For example, you could title the subject header as “Personal Data Complaint”.
We will certainly strive to deal with any complaint or grievance that you may have speedily and fairly.
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