UIB DATA PROTECTION POLICY
This Data Protection Policy (“Policy”) sets out the basis which UIB Holdings Pte. Ltd. (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data in accordance with the Personal Data Protection Act (“PDPA”). This Policy 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 Policy, “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.
2. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include your name and contact information such as your email address, mailing address, phone number, preference information such as marketing preferences, business information such as company name, company phone number, company address, company size, business type, payment information such as credit card numbers, debit card numbers, billing address, and unique identifier information such as user name, account number, password.
3. We may collect “website data” related to your use of our website with cookies or other similar technologies for collecting website visit information such as: date and time of visits, pages viewed, IP address, browser type and version, operating system and referral source.
4. We may also collect “message service data” that is created or provided by you in utilizing our services, such as: dates, timestamps and number of messages sent or received, as well as the content and context of a message intended for us to execute a request and then provide a response.
5. Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context so permits).
COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
6. We generally may collect and use your personal data for any or all of the following purposes:
(a) Fulfilling your order;
(b) Sending you an order confirmation;
(c) Assessing the needs of your business to determine suitable products and solutions;
(d) Sending you requested product or service information;
(e) Sending product updates or warranty information;
(f) Responding to customer service requests;
(g) Administering your account;
(h) Invoicing and managing payments;
(i) Engaging Partners to provide necessary services on our behalf;
(j) Using 3rd party service providers to host our cloud-based services
(k) Sending you a newsletter;
(l) Sending you marketing communications;
(m) Responding to your questions and concerns;
(n) Improving our website and marketing efforts;
(o) Conducting case studies, research or analysis;
(p) Displaying content based upon your interests;
(q) To any business partner or investor (actual or prospective) to facilitate business transactions
(which may extend to any merger, acquisition or sale) involving us, under relevant confidentiality
(r) Other purposes that we believe are necessary: (i) under applicable law, including laws outside your country of residence; (ii) to comply with legal process; (iii) to enforce our terms and conditions; (iv) to protect our operations or those of any of our Partners; (v) to protect our rights, privacy, safety or property, and/or those of our Partners, yourself or others; and (vi) to allow us to pursue available remedies or to limit our damages.
7. The instances listed above at paragraph 6 are not intended to be exhaustive. For more information on the exceptions, you are encouraged to peruse the Second, Third and Fourth Schedules of the PDPA which is publicly available at https://sso.agc.gov.sg . More information can be found at the PDPC website at https://www.pdpc.gov.sg/Overview-of-PDPA/The-Legislation/Personal-Data-Protection-Act .
8. 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).
REQUEST TO WITHDRAW CONSENT
9. 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 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.
10. 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.
11. 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 paragraph 9 above.
12. 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
13. 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.
14. 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.
15. 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 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
16. We have implemented generally accepted standards of technology and operational security to protect the personal data in our possession or under our control and to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks.
17. 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
18. 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
19. 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.
20. 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.
DATA PROTECTION OFFICER
21. If you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, you may contact our Data Protection Officer at:
(a) E-mail: email@example.com
(b) Office address: UIB Holdings Pte Ltd, 3 Temasek Avenue, Level 18, Centennial Tower, Singapore 039190.
UPDATES ON DATA PROTECTION POLICY
22. As part of our efforts to ensure that we properly manage, protect and process your personal data, we will be reviewing our policies, procedures and processes from time to time. We reserve the right to modify or amend this Policy at any time deemed necessary.
Last updated on 15 May 2020