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Privacy Policy

Effective date: 16 January 2024  ·  Last updated: 16 January 2024

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Overview Personal Data Collection & Use Legitimate Interests Withdrawing Consent Access & Correction Data Protection Accuracy Retention International Transfers Data Protection Officer Changes to Notice
Privacy & Data Protection Notice for Customers · Data Cynical Pte Ltd · Singapore PDPA Compliant

Overview

This Privacy & Data Protection Notice ("Notice") sets out the basis which Data Cynical Pte Ltd ("we", "us", or "our") may collect, use, disclose or otherwise process personal data of our customers in accordance with the Personal Data Protection Act ("PDPA"). 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.

Personal Data

  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 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 we have or are likely to have access.
  2. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include name, email address, telephone number and employment information.
  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

  1. We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you, after you have been notified of the purposes for which the data is collected and have provided written consent, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws.
  2. We may collect and use your personal data for any or all of the following purposes:
    • Performing obligations in the course of or in connection with our provision of the goods and/or services requested by you
    • Verifying your identity
    • Responding to, handling, and processing queries, requests, applications, complaints, and feedback from you
    • Managing your relationship with us
    • Processing payment or credit transactions
    • Complying with any applicable laws, regulations, codes of practice, guidelines, or rules
    • Any other purposes for which you have provided the information
    • Transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities
  3. We may disclose your personal data: (a) where such disclosure is required for performing obligations 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 listed above.

Reliance on the Legitimate Interests Exception

  1. In compliance with the PDPA, we may collect, use or disclose your personal data without your consent for the legitimate interests of Data Cynical Pte Ltd or another person. Data Cynical Pte Ltd will assess the likely adverse effects on the individual and determine that the legitimate interests outweigh any adverse effect.
  2. In line with the legitimate interests exception, we will collect, use or disclose your personal data for the following purposes: (a) Fraud detection and prevention; and (b) Detection and prevention of misuse of services.

Withdrawing Your Consent

  1. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is withdrawn by you in writing. You may withdraw consent by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.
  2. Upon receipt of your written request to withdraw your consent, we may require reasonable time for your request to be processed. In general, we shall seek to process your request within ten (10) business days of receiving it.
  3. 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

  1. If you wish to make an access request or correction request regarding personal data 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.
  2. 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.
  3. We will respond to your request as soon as reasonably possible. In general, our response will be within ten (10) business days.

Protection of Personal Data

  1. 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
    • Authentication and access controls (good password practices, need-to-basis for data disclosure)
    • Encryption of data and data anonymisation
    • Up-to-date antivirus protection and regular patching of operating systems
    • Usage of OTP / 2FA / MFA to secure access
    • Security review and testing performed regularly
  2. You should be aware that no method of transmission over the Internet 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

  1. 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.

Retention of Personal Data

  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.
  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 or business purposes.

Transfers of Personal Data Outside of Singapore

  1. 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.

Data Protection Officer

  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.

Name of DPO: Peter Lye

Email Address: peter.l@datacynical.com

Address: 160 Robinson Road, #14-04, Singapore 068914

Effect of Notice and Changes to Notice

  1. 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.
  2. We may revise this Notice from time to time without any prior notice. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.