“PDPA” means the Personal Data Protection Act 2012 of Singapore.
“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 a party has or is likely to have access.
“Process”, in relation to Personal Data, means the carrying out of any operation or set of operations in relation to the Personal Data, including without limitation to recording, holding, organising, adapting, altering, modifying, retrieving, combining, transmitting, erasing, or destroying.
2. Personal Data we collect
- We may collect the following Personal Data about you in the course of your interactions with Aquilius, including via our Website:
- Identity information. This is the Personal Data needed to identify you as a customer (or representative of a customer) of Aquilius and/or user of the Website. This may include your name, email address, and phone number, as well as other information we might require to comply with our know-your-customer requirements under applicable law.
- Contact information. This is the Personal Data that is provided by you or collected by us for the purposes of contacting you.
- Service usage information. This can be Personal Data and other information that is collected about you when you are using the Website, and this may include:
- Information about your interactions with the Website, which includes the date and time of any information you enter into the Website and/or use the Website.
- Your interactions with our representatives.
- Technical data, which may include URL information, cookie data, web beacons and other tracking technology information, your IP address, the types of devices you are using to access or connect to the Website, unique device IDs, device attributes, network connection type (e.g., Wi-Fi, 3G, LTE, Bluetooth) and provider, network and device performance, browser type, language, and operating system.
- Your location data. We may collect your location data to provide location-based and traffic-based products and services.
3. How we may use your Personal Data
- We may collect, use, disclose and/or Process your Personal Data for any or all of the following purposes:
- providing our products and/or services and performing obligations in the course of or in connection with the provision of our products and/or services;
- providing you with access to the Website;
- managing your relationship with us;
- facilitating, processing, dealing with, administering, and/or managing the products and/or services we provide, including payment for our products and/or services;
- processing and/or administering any service-related inquiries, consultations, or customer support in relation to our products, services or the Website;
- carrying out your instructions or responding to any enquiry given by (or purported to be given by) you or on your behalf;
- processing your registration and/or participation for meetings, seminars, exhibitions, and other events organised or co-organised by Aquilius;
- conducting customer due diligence or other screening and personal identification in accordance with laws, regulations or our risk management procedures that may be required by law or that may have been put in place by us;
- preventing or investigating any fraud, unlawful activity or omission or misconduct, whether or not there is any suspicion of the aforementioned;
- complying with or as required by any applicable law, governmental or regulatory requirements of any relevant jurisdiction, including meeting the requirements to make disclosure under the requirements of any law binding on us and/or for the purposes of any guidelines issued by regulatory or other authorities, whether in Singapore or elsewhere, with which we are expected to comply;
- complying with or as required by any request or direction of any governmental authority, or responding to requests for information from public agencies, ministries, statutory boards or other similar authorities. For the avoidance of doubt, this means that we may/will disclose your personal data to the aforementioned parties upon their request or direction;
- storing, hosting, backing up (whether for disaster recovery or otherwise) of your personal data, whether within or outside Singapore;
- administering security matters and/or arrangements;
- conducting research, analysis and development activities (including but not limited to data analytics, surveys and/or profiling) to improve our services in order to enhance your relationship with us or for your benefit;
- processing and/or administering requests for access and/or correction of your personal data; and
- achieving any other incidental business purposes related to or in connection with the above.
(collectively, the “Purposes”).
3.2. The purposes listed above may continue to apply even in situations where your relationship with us has been terminated or altered in any way, for a reasonable period thereafter, in accordance with the PDPA.
4. Third parties with whom we may share your Personal Data
- You acknowledge and agree that Personal Data provided to us by you may be disclosed and/or transferred to the following third parties, and used or Processed by such third parties, whether within or outside Singapore, for the Purposes set out above or otherwise as permitted / required by applicable law:
- Our affiliates. We may share your Personal Data with our affiliates that Process Personal Data on our behalf.
- Our service providers. We may share your Personal Data with our service providers, including our IT vendors and cloud service providers.
- Governmental and regulatory authorities. We may share your personal information with third parties, including law enforcement agencies and governmental or regulatory authorities, whether in Singapore or abroad, where required by applicable laws (including to respond to valid legal process such as a search warrant or a court order), where it is necessary in connection with the Website or where we have another legitimate interest in doing so.
- Buyer or successor of our business. We may share your Personal Data with any buyer or successor in the event of a merger, reorganisation, dissolution, or other sale or transfer of title.
- Our advisors, including auditors and lawyers. We may share your Personal Data with or disclose your Personal Data to our advisors in the course of seeking professional advice.
- You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can modify your browser settings to manage the types of cookies you wish to accept or decline. However, please note that you may not be able to use certain features of the Website if one or more cookies are disabled.
6. Your rights and options regarding your Personal Data
6.1. Withdrawing consent.
- You may withdraw your consent and request us to stop collecting, using, disclosing and/or Processing your Personal Data for any or all of the purposes listed above by submitting your request via email to our Data Protection Officer at the contact details provided above.
- Upon receipt of your written request to withdraw your consent, we may require a reasonable period of time to process and respond to your request.
- Do note that if you withdraw your consent, we may not be able to provide you with certain products and/or services or allow you to continue accessing or using the Website.
- Please note that withdrawing consent does not affect our right to continue to collect, use, disclose or Process your Personal Data where such collection, use, disclosure, and Processing without consent is permitted or required under the PDPA or other applicable law.
6.2. Accessing and Correcting your Personal Data
- If you wish to make
- 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 had used or disclosed your Personal Data in the one (1) year prior to the date of your request, or
- a correction request to correct or update any of your Personal Data which we hold about you,
you may submit your request via email to our Data Protection Officer at the contact details provided above.
- 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.
- 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 applicable laws).
7. Personal Data of Third Party Individuals
- In the event that you provide Personal Data of any individual other than yourself (“third party individual”), you hereby represent and warrant to us that you are validly acting on behalf of such third party individual and that you have obtained their consent to disclose their Personal Data to us for the purposes which we will be collecting and using their Personal Data, as stated under Paragraph 3 above.
8. Protection of Personal Data
- We will take appropriate administrative, physical, and technical measures to safeguard your Personal Data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, and the loss of any storage medium or device on which Personal Data is stored.
- 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 Personal Data, and are constantly reviewing and enhancing our security measures.
9. Accuracy of Personal Data
- Where you submit Personal Data to us, you should ensure such Personal Data is accurate. You should also review your Personal Data from time to time and let us know if there are changes or updates to your Personal Data so that we do not hold any inaccurate Personal Data about you.
10. How long we retain your Personal Data
- 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.
- 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.