DATA PROTECTION NOTICE FOR CUSTOMERS
This Data Protection Notice (“Notice”) sets out the basis on which Tembusu Global Trust 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 organizations we have engaged to collect, use, disclose, or process personal data for our purposes.
PERSONAL DATA
- Definitions
- “Customer” refers to an individual who (a) has contacted us to inquire about our services, or (b) has entered into a contract with us for the provision of services.
- “Personal data” means data, true or otherwise, that can identify a customer, either directly or in conjunction with other information we have access to.
- Examples of Personal Data
Depending on your interaction with us, we may collect personal data such as your name, email address, contact number, and nationality.
COLLECTION, USE, AND DISCLOSURE OF PERSONAL DATA
- We generally collect personal data directly from you or your authorized representative, or where collection and usage without consent are permitted by law.
- Purposes for Collection and Use
We may collect and use your personal data for the following purposes:- Providing our services;
- Verifying your identity;
- Handling queries, feedback, or complaints;
- Managing our relationship with you;
- Compliance with legal or regulatory obligations;
- Transmission to third-party service providers and agents, as needed;
- Other incidental business purposes.
- Disclosure of Personal Data
We may disclose your personal data:- For fulfilling service obligations;
- To third-party service providers and agents performing functions related to the above purposes.
LEGITIMATE INTERESTS EXCEPTION
- In certain cases, we may collect, use, or disclose your personal data based on our legitimate interests, including:
- Fraud detection and prevention;
- Misuse prevention of services;
- Network analysis to prevent fraud or financial crime;
- Data protection on company-issued devices.
WITHDRAWING YOUR CONSENT
- You may withdraw your consent for the collection, use, or disclosure of your personal data at any time by contacting our Data Protection Officer. We will process your request within a reasonable timeframe and inform you of any potential consequences.
- Withdrawing consent may affect our ability to provide services, and we will inform you accordingly if that is the case.
ACCESS TO AND CORRECTION OF PERSONAL DATA
- You may request access to or correction of your personal data by contacting our Data Protection Officer. A fee may apply for access requests, and we will notify you of this fee prior to processing.
- We will strive to respond within thirty (30) business days.
PROTECTION OF PERSONAL DATA
- To safeguard your personal data, we implement administrative, physical, and technical measures such as data minimization, access controls, encryption, and regular security testing.
- While security cannot be guaranteed, we are committed to continually enhancing our security measures.
ACCURACY OF PERSONAL DATA
- We rely on you to ensure your personal data is complete and up-to-date. Please inform us promptly of any changes to your personal data.
RETENTION OF PERSONAL DATA
- We retain your personal data only as long as necessary for the purposes for which it was collected or as required by law.
- When no longer needed, we will take steps to securely dispose of or anonymize your personal data.
TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
- Generally, we do not transfer personal data outside Singapore. If we do, we will ensure that your data remains protected under standards comparable to Singapore’s PDPA.
DATA PROTECTION OFFICER
- If you have questions, feedback, or wish to make any request related to your personal data, you may contact our Data Protection Officer at:
- Email Address: info@tembusu.org
EFFECT OF NOTICE AND CHANGES TO NOTICE
- This Notice applies in conjunction with other notices and terms related to the collection, use, and disclosure of your personal data.
- We may update this Notice from time to time. Please refer to the date below for the last update. Continued use of our services indicates your acceptance of any changes.
Last Updated: 28/09/2024