Personal Data Protection Policy
The privacy of your Personal Data is important to us and we are committed to accord the information the due level of care in compliance with the Personal Data Protection Act of Singapore (the “Act”). This Data Protection Notice (“Notice”) sets out the basis which Ezra & Macquarie Group and its related corporations and affiliates (collectively referred to herein as “we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of our customers in accordance with the Act. This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.
1. As used in this Notice:
“customer” means an individual who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us; and
“personal data” means personal data, whether true or not, about a customer who can be identified: (a) from that data; or (b) from that data and other information to which is obtained by us in the course of and as a result of the provision of any products and services by us to you.
2. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include, but not limited to, your name, residential address, personal email address, telephone number(s), your images taken by us, gender and any other information which you may have provided in any form to us.
3. Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).
COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
5. We may collect and use your personal data for the purposes stated in this Policy.
These purposes include, but are not limited to:
a. performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
b. verifying your identity;
c. responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
d. managing your relationship with us;
e. processing orders, administering accounts, payment or credit transactions;
f. offering you updated marketing and promotional packages you can benefit from, including products and services offered by our partners;
g. research and surveys;
h. 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;
i. any other purposes for which you have provided the information;
j. 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
k. any other incidental business purposes related to or in connection with the above.
l. any other purpose that may be made known by you.
We may disclose your personal data:
a. where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods and services requested by you; or
b. to third party service providers, agents and other organisations we have engaged to perform any of the functions with reference to the above mentioned purposes.
WITHDRAWING YOUR CONSENT
6. 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 collecting, 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 provided below.
7. 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. In general, we shall seek to process your request within five (5) business days of receiving it.
8. 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 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 7 above.
9. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
ACCESS TO AND CORRECTION OF PERSONAL DATA
10. If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, 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 provided below.
11. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
12. We will respond to your request as soon as reasonably possible. In general, our response will be within three (3) business days. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. 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 (except where we are not required to do so under the PDPA).
PROTECTION OF PERSONAL DATA
13. 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 such as minimised collection of personal data.
14. 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.
ACCURACY OF PERSONAL DATA
15. We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.
RETENTION OF PERSONAL DATA
16. 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.
17. 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 or business purposes.
TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
18. We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.
19. We have established a protocol to respond to any requests from individuals whose Personal Data is possessed by us or we have control over, to another organisation specified by the individual in a commonly used machine-readable format.
20. In the event of a data breach, we will refer to the [Data Breach Management Plan] for the steps to mitigate the impact of the breach and assess whether breach is notifiable under PDPA, by carrying out an assessment whether the breach is likely to result in significant harm to the individuals and/or on a significant scale. If the breach is assessed to be notifiable, we have 72 hours from the time it makes it assessment to notify.
DATA PROTECTION OFFICER
21. 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:
Name : Mr Kelvin, Data Protection Officer
Email Address : firstname.lastname@example.org
EFFECT OF NOTICE AND CHANGES TO NOTICE
22. This Notice 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.
24. We may revise this Notice 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 Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.
Effective date : [23/8/2022]
Last updated : [23/8/2022]
constitute your acceptance of all such changes. Ezra & Macquarie Group and its related corporations and affiliates has used its best commercial efforts to obtain the most accurate and timely information available. Accordingly, we do not guarantee the accuracy, timeliness, reliability or completeness of any of the information contained on, downloaded or accessed from this website.