This Data Protection Notice (“Notice”) sets out the basis on which Borderless360 Pte Ltd (“we”, “us”, or “our”) may collect, use, disclose or otherwise process your personal data in accordance with the Singapore Personal Data Protection Act (“PDPA”) and, where applicable, the EU’s General Data Protection Regulation (GDPR). 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. PERSONAL DATA
1.1 As used in this Notice, “personal data” means 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.
1.2 Depending on the nature of your interaction with us, the personal data which we may collect from you include your name, identification information, and contact information, such as, your residential and/postal address, email address or telephone number, as well as your nationality, country of residence, gender, date of birth, photographs and other audio-visual information that may identify you (e.g., music videos).
1.3 Other terms used in this Notice 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 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 to disclose your personal data to us (your “authorised representative”) after
(ii) you (or your authorised representative) have consented to the collection and usage of your personal data for those purposes, including by continuing to use our website or having a business relationship with us, or
(b) collection and use of personal data without consent is permitted or required by the PDPA or other laws.or
2.2 We may collect and use your personal data for any or all of the following purposes:
(a) performing obligations in the course of or in connection with our provision of the 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) sending you updates about our services
(f) 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;
(g) any other purposes for which you have provided your personal data;
(f) 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 purposes mentioned in clause 2.2(a) to (f).
We will seek your consent before collecting any other personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
2.3 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 services requested by you; or
(b) to third party corporate service providers and affiliate organisations we have engaged to perform any of the functions listed in clause 2.2 above for us.
2.4 The purposes listed in the above clauses 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 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 provided below.
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. In general, we shall seek to process your request within ten (10) business days of receiving it. If we require more time, we will advise you in writing and state the reasons why. In general, we will endeavour to complete your request within 30 days.
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 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, use and disclose personal data where such collection, use and disclose 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 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 to our Data Protection Officer at the contact details provided below.
4.2 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.
4.3 We will respond to your request as soon as reasonably possible. 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 that period 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).
5. PROTECTION OF PERSONAL DATA
5.1 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
5.2 We use the Cloud Service Providers listed below to store and transfer information. We have satisfied ourselves that these service providers offer an acceptable level of security. Links to these providers’ information on their security arrangements are provided below:
(a) Google Workspace
5.3 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.
6. ACCURACY OF PERSONAL DATA
6.1 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 at the contact details provided below.
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 or business purposes.
8. TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
8.1 We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, 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.
9. EU GENERAL DATA PROTECTION REGULATION (GDPR)
9.1 Where we collect, use or disclose the personal data of residents of the EU, we will also comply with any specific requirement of the GDPR:
- We will not collect sensitive data, such as, race, ethnicity, political, religious or philosophical beliefs, trade union membership, genetic or biometric data.
- The right to erasure: You have the right to request that we erase your personal data under certain conditions.
- The right to restrict processing: You have the right to request that we restrict the processing of your personal data under certain conditions.
- The right to object to processing: You have the right to object to our processing of your personal data under certain conditions.
- The right to data portability: You have the right to request that we transfer the data that we have collected to another organisation, or directly to you, under certain conditions.
10. DATA PROTECTION OFFICER
10.1 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. Please contact us at firstname.lastname@example.org.
11. EFFECT OF NOTICE AND CHANGES TO NOTICE
11.1 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.
11.2 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.
Last updated: April 27, 2022