This data privacy policy (“Data Privacy Policy”) sets out how Walden International Singapore Pte. Ltd. and its representatives and/or agents (collectively referred to herein as “WIS”, “us”,“we” or “our”) will manage Personal Data (as defined below) in compliance with the Personal Data Protection Act 2012 and its regulation(s) (“the Act” or “PDPA”).
Please take a moment to read this Data Privacy Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data.
By interacting with us and submitting information to us, you agree and consent to WIS collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to their authorized service providers and relevant third parties in the manner set forth in this Data Privacy Policy.
This Data Privacy Policy supplements but does not supersede nor replace any other consents you may have previously provided to WIS in respect of your Personal Data, and your consents herein are additional to any rights which any of the Companies may have at law to collect, use or disclose your Personal Data.
We may from time to time update this Data Privacy Policy to ensure that this Data Privacy Policy is consistent with our future developments and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of the Data Privacy Policy as updated from time to time on our website [www.waldenintl.com.sg]. Please check back regularly for updated information on the handling of your Personal Data.
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Personal Data
1.1 |
In this Data Privacy Policy, “Personal Data” refers to any data, whether true or not, about an individual 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, including data in our records as may be updated from time to time. |
1.2 |
Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us) your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address and any other information relating to any individuals which you have provided us in any methods of interaction with you. |
1.3 |
Please note that the data protection provisions of the PDPA do not apply to business contact information (“BCI”). BCI is defined in the PDPA as an individual’s name, position name or title, business telephone number, business address, business electronic mail address or business fax number and any other similar information about the individual, not provided by the individual solely for his personal purposes. |
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Collection of Personal Data
2.1 |
Generally, we may collect Personal Data in the following ways:
(a) |
when you request for funding through emails or telephone calls; |
(b) |
when you enter into any agreement or provide other documentation or information in respect of your interactions with us; |
(c) |
when you submit any form or application to us; |
(d) |
when you interact with our staff, for example, via telephone calls (which may be recorded), letters, face-to-face meetings, and emails; |
(e) |
when you request that we contact you or request that you be included in an email or other mailing list; |
(f) |
when you respond to our initiatives or to any request for additional Personal Data; |
(g) |
when we seek information about you and receive your Personal Data in connection with your relationship with us; and/or |
(h) |
when you submit your Personal Data to us for any other reasons. |
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2.2 |
When you browse our website, you generally do so anonymously but please see the section below on cookies. |
2.3 |
If you provide us with any Personal Data relating to a third party (e.g. information of your spouse, children, parents, and/or employees), by submitting such information to us, you represent to us that you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes. |
2.4 |
You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to fulfil your requests, or delays in processing your requests. |
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Purposes for the Collection, Use and Disclosure of Your Personal Data
3.1 |
Generally, WIS collects, uses, processes and discloses your Personal Data for the following purposes:
(a) |
responding to your queries, feedback and requests; |
(b) |
verifying your identity; |
(c) |
managing the administrative operations of WIS and complying with internal policies, reporting requirements and procedures; |
(d) |
managing the safety and security of our premises and systems; |
(e) |
facilitating business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving any of our entities; |
(f) |
conducting marketing and communication activities, including posting on our websites or social media platforms or inclusion into videos and marketing collaterals; |
(g) |
monitoring or recording phone calls for quality assurance, employee training and performance evaluation and identity verification purposes; |
(h) |
matching any Personal Data held which relates to you for any of the purposes listed herein; |
(i) |
hosting, storing or backing-up your Personal Data, which may be on third party servers or data clouds; |
(j) |
legal purposes in connection with any claims, actions or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution), and/or protecting and enforcing our contractual and legal rights and obligations; |
(k) |
meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal, statutory or regulatory bodies which are binding on WIS (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies, disclosures required in the public interest or emergencies and conducting audit checks, due diligence and investigations which may be carried out by statutory authorities); and/or |
(l) |
purposes which are reasonably related to the aforesaid. |
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3.2 |
In addition, WIS collects, uses and discloses your Personal Data for the following purposes:
(a) |
if you are a vendor of WIS:
(i) |
assessing your suitability as vendor (i.e. external service provider, consultant, contractor etc.); |
(ii) |
managing requests for proposals or quotations, processing orders or managing supply of goods and/or services; |
(iii) |
processing and payment of invoices; and/or |
(iv) |
purposes which are reasonably related to the aforesaid. |
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(b) |
if you submit an application to us as a candidate for an employment or other post:
(i) |
evaluation and assessment of your suitability; |
(ii) |
conducting interviews; |
(iii) |
processing your application (including but not limited to pre-recruitment checks involving your qualifications and facilitating interviews); |
(iv) |
providing or obtaining references and for background screening; |
(v) |
assessing your suitability for the position applied for; |
(vi) |
onboarding successful candidates and facilitating human resource planning and management; and/or |
(vii) |
purposes which are reasonably related to the aforesaid. |
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Disclosure of Personal Data
4.1 |
Subject to the provisions of any applicable law, your Personal Data may be disclosed, for the purposes listed above (where applicable), to the following entities or parties, whether they are located overseas or in Singapore:
(a) |
WIS’ related corporations and employee(s); |
(b) |
agents, contractors or third-party service providers who provide services to WIS, such as courier services, telecommunications, information technology, payment, printing, billing, payroll, processing, technical services, security, or other services to WIS; |
(c) |
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 any of our entities; |
(d) |
external banks and their respective service providers; |
(e) |
share registrars; |
(f) |
companies which provide corporate secretarial services; |
(g) |
our professional advisers such as consultants, auditors and lawyers; |
(h) |
relevant government ministries, regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and/or |
(i) |
any other party to whom you authorize us to disclose your Personal Data to. |
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Use of Cookies
5.1 |
When you interact with us on our websites, we automatically receive and record information on our server logs from your browser. We may employ cookies in order for our server to recognize a return visitor as a unique user including, without limitation, monitoring information relating to how a visitor arrives at the website, what kind of browser a visitor is on, what operating system a visitor is using, a visitor’s IP address, and a visitor’s click stream information and time stamp (for example, which pages they have viewed, the time the pages were accessed and the time spent per web page). |
5.2 |
Cookies are small text files stored in your computing or other electronic devices which allow us to remember you. The cookies placed by our server are readable only by us. Cookies are not programs and therefore cannot access, read or modify any other data on an electronic device. All web-browsers offer the option to refuse any cookie, and if you refuse our cookie then we do not gather any information on that visitor. |
5.3 |
Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser. However, you may not be able to use certain services or enter certain part(s) of our website. |
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Data Security
6.1 |
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. |
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Contact Us
7.1 |
If you:
(a) |
have any questions or feedback relating to your Personal Data or our Data Privacy Policy; |
(b) |
would like to withdraw your consent to any use of your Personal Data as set out in this Data Privacy Policy; |
(c) |
would like to obtain access and make corrections to your Personal Data records, please write to us at:
Data Protection Officer
31 Rochester Drive
Level 2, Suite 52
Singapore 138637
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7.2 |
Please note that if your Personal Data has been provided to us by a third party, you should contact that organization or individual to make such queries, complaints, and access and correction requests to WIS on your behalf. |
7.3 |
If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, WIS may not be in a position to continue to provide its products and services to you, administer any contractual relationship in place, which in turn may also result in the termination of any agreements with WIS, and your being in breach of your contractual obligations or undertakings. WIS’s legal rights and remedies in such event are expressly reserved. |
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Links to Third-Party Website(s)
8.1 |
Our companies’ websites may contain links to other third-party operated websites over which we have no control over. We are not responsible for the privacy and/or data protection practices of such third-party operated websites that are linked to our websites. Once you have left our website by clicking a relevant link, your use of that third-party website will be governed by the privacy or data protection policy of that website. |
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Governing Law
9.1 |
This Data Privacy Policy and your use of this website shall be governed and construed in all respects by the laws of Singapore. |