Data Protection Policy
This data protection policy applies to PleoData Pte Ltd established in Singapore (“PleoData” or “us”). This policy governs the collection, use and disclosure of personal data submitted to PleoData and explains how we collect and handle personal data of individuals and comply with the requirements of the Personal Data Protection Act 2012 of Singapore and its regulation(s) (“PDPA”). In this policy, “personal data” shall have the meaning ascribed to it in the PDPA.
This Policy governs personal data collected through our website, online forms and our softwares, communication platforms (e.g., emails), digital services and product interactions, online or offline interactions with PleoData representatives. This Policy does not extend to third-party websites or applications linked from our site.
Personal Data
1. As used in this Policy:
“person” 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 enter or has entered into a contract with us for the supply of any products or services by us, or (c) has submitted a job or internship application with us; and
“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, contact information such as your address, email address or telephone number, nationality, gender, date of birth, marital status, photographs and other audio-visual information, employment information, education background, and information about your usage of and interaction with our website.
3. Other terms used in this Notice shall have the meanings given to them in the Singapore Personal Data Protection Act (where the context so permits).
Collection, Use and Disclosure of Personal Data
4. We may collect personal data from employees, job applicants, customers, clients, business contacts, partners, contractors, and other individuals who interact with PleoData. Such personal data may be provided voluntarily (e.g., through forms or enquiries) or indirectly (e.g., through cookies, analytics tools, or referrals). We will only collect, hold, process, use, communicate and/or disclose such personal data in accordance with this policy. If any party is acting as an intermediary or otherwise on behalf of a third-party individual (such as a friend, colleague, or employee) or supplying us with information regarding such individual, that intermediary undertakes that they are an authorized representative or agent of such third-party individual and have obtained all necessary consents.
5. We use personal data for the following purposes:
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To process job applications and recruitment activities
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To provide our services and/or products to you.
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To fulfil obligations under applicable laws
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For audit, investigation, and compliance purposes
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For follow-up action regarding any complaints, feedback, queries or requests received via our website or any other communication channels
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For business continuity and operational purposes, including engagement with suppliers and contractors
6. We do not disclose personal data to third parties except when required by law, when we have the individual’s consent or deemed consent or in cases where we have engaged third parties such as data intermediaries or subcontractors specifically to assist with our firm’s activities. Any such third parties whom we engage will be bound contractually to keep all information confidential.
7.. We may disclose personal data to our subsidiaries, where it is necessary
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to meet the purpose for which such individual has submitted the information; or
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to enable such individual to be provided with information at a later date which may be of relevance and interest to such individual based on the nature and purpose of such individual’s voluntary requests.
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to comply with any applicable laws, regulations, codes of practice, guidelines or rules (e.g. in an emergency or when we receive a subpoena to disclose your personal data)
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with your consent, to third party service providers, agents and other organisations we have engaged to perform any of the functions listed in Paragraph 6 above for us. Any third parties engaged by us will be contractually bound to keep all personal data confidential.
8. You have choices regarding our collection, use or disclosure of your personal data. If you choose not to provide us with your personal data for the purposes listed in paragraph 4,5,6,7 you may submit a request in writing to our Data Protection Officer. Depending on the complexity of the request and its impact to our relationship with you, we will not collect or, within thirty (30) days of our receipt of your request, cease using and/or disclosing your personal data in accordance with your request.
9. The purposes listed in Paragraph 4 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).
10. We may collect, disclose or use your personal data pursuant to an exception under the Personal Data Protection Act or other written law such as during the following situations:
a) To respond to an emergency that threatens your life, health and safety or of another individual; and
b) Necessary in the national interest, for any investigation or proceedings.
Access to and Correction of Personal Data
11. 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.
12. 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 in writing (including both electronic and non-electronic methods), we will inform you in writing within ten (10) business 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).
13. If your request relates to personal data which we are processing on behalf of another organisation, we will instead forward your request to the relevant organisation for their necessary action..
Withdrawal of Consent
14. 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 your 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 to our Data Protection Officer.
15. 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 and effect your request within ten (10) business days of receiving it. Should we require more time to give effect to a withdrawal notice, we will inform you of the time frame by which the withdrawal of consent will take effect.
Accuracy of Personal Data
16. We will make every reasonable effort to ensure that personal data collected by us or on our behalf is accurate and complete.
17. We will verify the personal data with the identification documents provided by you. 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 Officers at the contact details provided in paragraph 22.
Security and Protection of Personal Data
18. 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 unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks. All PleoData personnel follow a network-wide security policy. Only authorized PleoData personnel are provided access to personally identifiable information, and these personnel have agreed to ensure confidentiality of this information.
Retention of Personal Data
19. We will cease to retain personal data, as soon as it is reasonable to assume that the purpose for collection of such personal data is no longer being served by such retention, and such retention is no longer necessary for legal or business purposes.
Transfer of Personal Data outside of Singapore
20. We will ensure that any transfers of personal data to a territory outside of Singapore will be in accordance with the PDPA so as to ensure a standard of protection to personal data so transferred that is comparable to the protection under the PDPA.
Cookies and Tracking Technologies
21. These technologies apply specifically to users of our website and online platforms. We use cookies and related technologies to enhance our website functionality and personalization, track user behavior and site performance (e.g., Google Analytics) and store user preferences and session information. Users may manage cookies through their browser settings. Disabling cookies may limit some site functionality.
Third-Party Websites
22. Our website may contain links to third-party websites. PleoData is not responsible for their content, security, or privacy practices. You are encouraged to review their respective privacy policies before sharing personal data.
Updates to This Policy
23. PleoData may revise this Privacy Policy from time to time to reflect legal, technological, or operational changes. The latest version will always be available on our website. We encourage you to review this Policy periodically to remain informed on how we protect your data.
Contact Us
24. You may contact our Data Protection Officer if you have any enquiry, feedback or complaint regarding our personal data protection policies and procedures, if you wish to make any request, or if you believe that information we hold about you is incorrect or out-dated.You may contact our DPO (Data Protection Officer) at dpo@pleodata.com
