2. Collection, Use and Disclosure of Personal Data

2.1 We may collect personal data from our customers, business partners, contractors, employees and other individuals such as job applicants. We would only collect, use and disclose data that (a) has been 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 (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional 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).

2.2 These personal data may be furnished to us in forms filled out by you, face to face meetings, email messages, or telephone conversations. We may also keep a record of any contact you have with us. These data would be collected only for business purposes or for the purpose(s) stated by us when we gather the personal data from you.

2.3 The personal data collected may be used for any or all of the following purposes:

2.3.1 to provide our services and/or products to you;

2.3.2 as part of our business operations;

2.3.3 for job application and recruitment purposes;

2.3.4 for billing and reporting, such as for invoicing and account management purposes;

2.3.5 for follow-up action regarding any complaints, feedback, queries or requests received via our website or any other communication channels; and

2.3.6 assisting in law enforcement and investigations conducted by any governmental and/or regulatory authority.

2.4 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:

2.4.1 To respond to an emergency that threatens your life, health and safety or of another individual; and

2.4.2 Necessary in the national interest, for any investigation or proceedings.

2.5 We may disclose your personal data:

2.5.1 with your consent, where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods or services requested by you;

2.5.2 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); or

2.5.3 with your consent, to third party service providers, agents and other organisations we have engaged to perform any of the functions listed in paragraph 3 above for us. Any third parties engaged by us will be contractually bound to keep all personal data confidential.

2.6 You have the right of choice regarding the collection, usage and/or disclosure of your personal data. If you choose not to provide us with the personal data described in this notice, we may not be able to perform our obligations as stated in this notice. You have the right to object to the processing of your personal data and withdraw your consent in the manner described below.

2.7 If you choose not to provide us with your personal data for the purposes listed in paragraphs 3 and 2.4, you may submit a request in writing or via email to our Data Protection Officer at the contact details provided below or indicate in the personal data collection form submitted to us (if any). By choosing not to provide us with your personal data, depending on our relationship, we may not be able to provide services to you or process your job application. Depending on the complexity of the request and its impact to our relationship with you, we will not collect or, within 30 days of our receipt of your request, cease using and/or disclosing your personal data in accordance with your request.

2.8 The purposes listed in paragraph 3 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).

2.9 In the case where we receive unsolicited personal data via email or any other communication channels, the unsolicited personal data will not be retained and will be securely disposed of immediately.