1. IntroductionAt Novitee Pte Ltd (“Novitee”) we respect the privacy and confidentiality of the personal data of our clients, end users and others whom we interact with in the course of providing our services. We are committed to implementing policies, practices and processes to safeguard the collection, use and disclosure of the personal data you provide us, in compliance with the Singapore Personal Data Protection Act (PDPA) 2012.
We have developed this Data Privacy Notice to assist you in understanding how we collect, use, disclose, process, protect and retain your personal data that is in our possession.
This Notice supplements but does not supersede nor replace any other consents you may have previously provided to the Firm in respect of your Personal Data, and your consents herein are additional to any rights which to the Firm may have at law to collect, use or disclose your Personal Data.
In this Notice, "Personal Data" refers to any 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, including data in our records as may be updated from time to time, but excludes "business contact information" as defined in the PDPA.
Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).
2. Types of Personal Data we collect
We may collect Personal Data from you in the course of our business, including through your use of our Sites, when you contact or request information from us, when you engage our services or as a result of your relationship with one or more of our staff and customers.
Depending on the nature of your interaction with us, the Personal Data that we may collect includes:
- Unique identifiers (e.g. full name, National Registration Identification Card (“NRIC”) number, Foreign Identification Number (“FIN”), passport number, personal mobile telephone number;
- Employment details (e.g. occupation, directorships and other positions held, employment history, salary, and/or benefits);
- Contact information (e.g. residential address, email address and/or telephone number);
- Financial information (e.g. account numbers and/or banking transactions);
- Technical information (e.g. information from your visits to our website or applications or in relation to materials and communications we send to you electronically);
- Personal opinions made known to us (e.g. feedback or responses to surveys);
- Any other information relating to you or any individuals which you have provided us in any forms you may have submitted to us, or via other forms of interaction with you.
We use “cookies” to collect information about your online activity on our website. A cookie is a small text file created by the website that is stored in your computer to provide a way for the website to recognise you and keep track of your preferences. The cookie makes it convenient for you such that you do not have to retype the same information again when you revisit the website or in filling electronic forms.
Most cookies we use are “session cookies”, which will be deleted automatically from the hard disk of your computer at the end of the session.
You may choose not to accept cookies by turning off this feature in your web browser. Note that by doing so, you may not be able to use some of the features and functions in our web applications.
4. Use and Processing of Information
Generally, the purposes for which the Firm collects, uses and discloses personal data include:
- Generally, the purposes for which the Firm collects, uses and discloses personal data include:
- Providing updates and other communications on development relating to the firm
- To send administrative email notifications (regarding security, support and/or maintenance notices)
- To improve our services and communications to you and the quality of your interaction with our Sites, include auditing and monitoring its use.
- Send promotional communications, such as providing you with information about products and services, features, surveys, newsletters, offers, promotions, contests, and events
- Personalise the sites and services, including by providing features or advertisements that match your interest and preferences
- For the purpose of recruitment
- Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose. As a result, our collection and processing of your information is based in different contexts upon your consent, our need to perform a contract, our obligations under law, and/or our legitimate interest in conducting our business.
5. Sharing Of Information
In addition to the specific situations discussed elsewhere in this policy, we disclose information in the following situations:
Affiliates and Acquisitions. We may share information with our corporate affiliates (e.g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control). If another company acquires, or plans to acquire, our company, business, or our assets, we will also share information with that company, including at the negotiation stage.
Other Disclosures with Your Consent. We may ask if you would like us to share your information with other unaffiliated third parties who are not described elsewhere in this policy.
Other Disclosures without Your Consent. We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request for the shipment of products to or the provision of services by a third party intermediary.
Service Providers. We share your information with service providers. Among other things service providers help us to administer our website, provide technical support, process payments, etc.
6. Your Choices
You can make the following choices regarding your information:
Marketing Emails. You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you. You can stop receiving promotional emails by following the unsubscribe instructions in e-mails that you receive. If you decide not to receive promotional emails, we may still send you service related communications.
Access To Your Personal Information. You may request access to your personal information by contacting us at the address below. If required by law, upon request, we will grant you reasonable access to the personal information that we have about you.
Changes To Your Personal Information. You can contact us at the address described below in order to request that your information be modified.
Deletion Of Your Personal Information. Typically we retain your personal information for the period necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law. You may, however, request information about how long we keep a specific type of information, or request that we delete your personal information by contacting us at the address below. In addition, we may keep your personal information as needed to comply with our legal obligations, resolve disputes, and/or enforce any of our agreements.
Revocation Of Consent. If you revoke your consent for the processing of personal information then we may no longer be able to provide you services. In some cases, we may limit or deny your request to revoke consent if the law permits or requires us to do so, or if we are unable to adequately verify your identity. You may revoke consent to processing (where such processing is based upon consent) by contacting us at the address below.
7. How We Protect Personal Information
No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of unauthorized access to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.
The following additional information relates to our privacy practices:
Where there is a need to transfer your personal data to another country outside Singapore, we will ensure that the standard of data protection in the recipient country is comparable to that of Singapore’s PDPA. If this is not so, we will enter into a contractual agreement with the receiving party to accord similar levels of data protection as those in Singapore.
9. Contacting UsIf you have any query or feedback regarding this Notice, or any complaint you have relating to how we manage your personal data, you may contact our Data Protection Officer (DPO) at: firstname.lastname@example.org
Any query or complaint should include, at least, the following details:
We treat such queries and feedback seriously and will deal with them confidentially and within reasonable time.
- Your full name and contact information
- Brief description of your query or complaint
10. Changes to this Data Privacy Notice
We may update this Data Privacy Notice from time to time. We will notify you of any changes by posting the latest Notice on our website. Please visit our website periodically to note any changes.
Changes to this Notice take effect when they are posted on our website.
Last updated: 04 January 2022