(Last updated: 25 April 2020)
As used in this Policy:
1.1. “Client” and "Professional" means an individual who (a) has contacted us through any means to find out more about our business, (b) may, or has, entered into a contract with us for the supply of any services, or (c) may, or has, entered into a contract with us to receive any services, and;
1.2. “Personal data” means data, whether true or not, about the Client/Professional 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.
1.3. Some examples of personal data which we may collect may include, but are not limited to, an individual’s full name and identification information such as your NRIC number; contact information such as address, email address or telephone number; personal information such as nationality, gender, date of birth, marital status, photographs and other audio-visual information, employment information, information regarding your health and wellbeing, and financial information such as credit card numbers, debit card numbers or bank account information.
1.4. Some examples of data pertaining to organizations which we may collect may include, but are not limited to, an entity’s incorporation details such legal entity name, registration number, country of incorporation, date of incorporation, current good standing; an organization’s procurement and payment information; individual information which may include but are not limited to the aforementioned 1.3., of the relevant persons in charge or to whom and/or from whom services are being rendered.
1.5. Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context so permits).
2.COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
2.1. Your personal data may generally be collected in the following circumstances:
2.1.1. where it is provided to us voluntarily by you directly or via a third party who has been duly authorised to disclose your personal data to us either by you, the PDPA, or other laws (your “authorised representative”);
2.1.2. where collection and use of personal data without consent is permitted or required by the PDPA or other laws
2.2. Clause 2.1. does not purport to be exhaustive and sets out the most common instances where we may collect your personal data.
2.3. The purposes for which we collect and use your personal data may include, but not limited to, the following:
2.3.2. Identification and/or verification;
2.3.3. Maintaining and administering required software, applications, or any other updates;
2.3.4. Responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
2.3.5. Managing your relationship with us;
2.3.6. Processing payment, debit and/or credit transactions;
2.3.7. Sending you marketing information and/or promotional materials on behalf of the Company, including notifications regarding our events, initiatives and other promotions;
2.3.8. Conducting research, analysis, data and development activities, including but not limited to, data analytics, surveys, product and service improvements and developments, analysis relating to application usage;
2.3.10. Auditing our services and/or our business;
2.3.11. 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;
2.3.12. Transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
2.3.13. Any other incidental business purposes related to or in connection with the above or for any other purposes for which you have provided the information.
2.4. The circumstances under which we may disclose your data may include, but not limited to, the following:
2.4.2. to third party service providers, agents and other organisations we have engaged to perform any of the functions listed in clause 2.3. above for us; or
2.4.3. where required by the law, including in times of emergency and/or crisis where it is deemed that there is an immediate risk of harm to you and/or others.
2.5. Clause 2.4 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).
3. WITHDRAWING YOUR CONSENT
3.1. 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 listed in clause 9.1.
3.2. 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.
3.3. 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 and/or services to you and we shall, in such circumstances, notify you 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 3.1. above.
3.4. Please note that withdrawing consent does not affect our right to continue to collect, retain, use and disclose personal data where such collection, retention, use and disclosure without consent is permitted or required under applicable laws.
4. ACCESS TO AND CORRECTION OF PERSONAL DATA
4.1. If you wish to make (a) an access request for access to a copy of the personal data which we hold about you, 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 listed in clause 9.1.
4.2. Please note that a reasonable fee may be charged for an access request. If applicable, we will inform you of the fee prior to processing your request.
4.3. We will respond to your request as soon as reasonably possible. 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 within a reasonable timeframe (except where we are not required to do so under the PDPA). Please also note that our obligations to provide access and correct personal data are subject to the exceptions set out in Sections 21 and 22 of the PDPA.
5. PROTECTION OF PERSONAL DATA
5.1. Safeguarding your data and privacy is of utmost importance to us and we go to great lengths to protect client data and privacy. 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 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.
5.2. Our mobile application is designed to incorporate data privacy and protection measures in both front-end and back-end. On the front-end, two-factor authentication is adopted to provide extra security for client and professional accounts. Clients also have the option to be identified only by their pseudonym on the application for an added layer of confidentiality. On the back-end, all messages between clients and professionals and our databases are secured and encrypted by banking-grade 256-bit encryption. All data connection between our mobile application, our website and our server are encrypted with SSL following best practices.
5.3. While we aspire to do our best in this regard, kindly note that no method of transmission over the Internet or method of electronic storage is completely secure. Although security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
6. ACCURACY OF PERSONAL DATA
6.1. We generally rely on personal data provided by you (or your authorised representative) to provide the goods and/or services required of us. In order to ensure that your personal data is current, complete and accurate, you may update your particulars either in the mobile application itself or notify us of the changes to your personal data by writing to our Data Protection Officer at the contact details listed in clause 9.1.
7. RETENTION OF PERSONAL DATA
7.1. 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.
7.2. 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, regulatory or business purposes or for such time obligated by any laws.
8. CROSS-JURISDICTIONAL TRANSFERS OF PERSONAL DATA
8.1. If data is to be transferred across jurisdictions, it will only be done in accordance with the PDPA of the jurisdictions involved. Appropriate steps will be taken to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.
9. DATA PROTECTION OFFICER
9.1. 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 following manner:
To the attention of the Data Protection Officer for ThoughtFull
Email address: firstname.lastname@example.org
10. EFFECT OF NOTICE AND CHANGES TO NOTICE
10.1. This Policy 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.
10.2. We may revise this Policy 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 Policy was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.
11. ACKNOWLEDGEMENT AND CONSENT