PT ESTATE PLANNING PTE LTD
PRIVACY POLICY
PT Estate Planning Pte Ltd (“PTEEPL”) is committed to meet fully the data protection principles and all relevant provisions of the Personal Data Protection Act 2012 (“PDPA”). PTEPPL will ensure full compliance by its staff with the strictest standards of security and confidentiality. The privacy policy (“Policy”) outlines how your Personal Data will be managed in accordance with the PDPA. Please read this Policy carefully so that you know and understand the purposes for which PTEPPL may collect, use and/or disclose your Personal Data.
1. APPLICATION
This Policy applies to all persons who disclose their personal data to PTEPPL in connection with services provided by PTEPPL to such persons.
2. TYPES OF PERSONAL DATA PTEEPL COLLECTS
2.1 You consent to PTEPPL collecting the following personal data from you:
(a) name or alias, gender, date of birth, nationality and country / city of birth;
(b) NRIC / unique identification number / passport number, photograph;
(c) email address, postal address, telephone number, mobile number and other contact details;
(d) credit card number and expiry date; and
(e) employment, income range and social and lifestyle preferences,
(collectively, “Personal Data”).
2.2 When you use PTEPPL’s services, you may be required to provide evidence of your identity for the purposes of identity verification. Such evidence shall state the last four alphanumeric characters of your unique identification number (i.e. 123A), your photograph and residential address, redacting all other information that is not required. Examples of such evidence include but are not limited to NRIC, passport or driving license. PTEPPL reserves the right to request additional evidence of your identity in order to comply with all applicable laws and regulations.
2.3 When you visit the PTEPPL’s website, a record of your visit is made as a “hit”, which may show your domain name server address and the pages you have visited. No personally identifiable information is collected. The “hit” information allows PTEPPL to compile statistics about the number and types of visitors to the website.
3. COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
3.1 PTEPPL generally collects, uses and discloses Personal Data that you knowingly and voluntarily provide in the course of or in connection with PTEPPL’s provision of services to you, which are services relating to concierge services, marketing and training.
3.2 For the avoidance of doubt, Personal Data with respect to the making of payment for PTEPPL’s services (e.g. credit card number) are collected by PTEPPL solely for the purposes of processing payment. PTEPPL does not store such Personal Data. PTEPPL will protect such Personal Data by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal, or similar risks.
3.3 In order for PTEPPL to deliver its products and services to you, PTEPPL may provide certain necessary details about you to its authorised agents, authorised service providers, related and/or associated companies, distributors and relevant third parties (“Authorised Parties”). Please note that certain services may be unavailable to you if you do not wish to disclose certain Personal Data requested.
3.4 PTEPPL will use, and you consent to PTEPPL’s usage of, the Personal Data for the following purposes (“Purposes”):
(a) to administer your accounts with PTEPPL;
(b) to process orders and/or applications submitted by you;
(c) to send you information about our products and services;
(d) to communicate to you, whether directly or indirectly through Authorised Parties, information about products and services which are related to and/or complementary to PTEPPL’s products and services;
(e) to send you information about products and services which are provided by PTEPPL’s authorised agents, authorised service providers, related and/or associated companies and relevant third parties;
(f) to offer benefits to you, including without limitation promotions, loyalty and reward programmes and sending to you details of products, services, special offers and rewards, or materials which may be of interest to you;
(g) to verify your identity;
(h) to carry out marketing analysis and make general improvements to PTEPPL’s website;
(i) to process and administer benefits or entitlements in connection with PTEPPL’s products and services which you have applied for, including the administration of loyalty and rewards programme;
(j) to conduct market research for statistical profiling and other purposes to understand and determine customer preferences and demographics;
(k) to comply with any applicable local or foreign statute, rule, law, regulation, judgment, decree, directive, code of practice, guideline and/or administrative requirement; and
(l) to obtain your views or comments on the products and services that PTEPPL provides.
3.5 The Purposes listed in the above clauses may continue to apply even in situations where your relationship with PTEPPL has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable PTEPPL to enforce its rights under any contract with you).
3.6 You agree and warrant that all Personal Data submitted to PTEPPL is complete, accurate, true and correct. Failure on your part to do so may result in PTEPPL’s inability to provide you with the products and services that you have requested.
3.7 You consent to receiving information about PTEPPL’s products, promotions and offers as well as products, promotions and offers from PTEPPL’s Authorised Parties through voice calls, SMS, electronic mail, fax or other means.
3.8 If you are submitting Personal Data on behalf of another individual or concerns another individual other than yourself, you represent and warrant to PTEPPL that all the necessary consents (procured in accordance with all applicable data protection legislation, including without limitation the PDPA, for such purposes stated in the relevant sections of this Policy) have been obtained from the relevant individuals and that you have proof of these consents.
3.9 PTEPPL may transfer your Personal Data to a third party as part of a sale of some or all of our business and assets to any third party or as part of any business restructuring or reorganisation, but PTEPPL will take steps with the aim of ensuring that your privacy rights continue to be protected.
3.10 PTEPPL will cease to use your Personal Data for any purposes if you request PTEPPL to do so by email to: enquiry@pteppl.com.
3.11 Other than as set out above in this Clause 3, PTEPPL will not disclose any of your Personal Data without your permission unless PTEPPL is required by law to do so (for example, if required to do so by a court order or for the purposes of prevention of fraud or other crime).
4. RETENTION PERIOD
PTEPPL will only retain your Personal Data for as long as any one or more of the Purposes for which it was collected exist. If you wish to delete your Personal Data held by PTEPPL, please notify PTEPPL by email to enquiry@pteppl.com, and accordingly your Personal Data will be erased and/or destroyed.
5. SECURITY
PTEPPL will take all reasonable security measures to protect your Personal Data from unauthorised access, collection, use, disclosure, copying, modification, disposal, or similar risks. Other than as mentioned above for the Purposes and in the manner specified, PTEPPL will not disclose your Personal Data to any third parties without obtaining your prior consent.
6. TRANSFERRING YOUR INFORMATION OUTSIDE OF SINGAPORE
As part of the services offered to you by PTEPPL, the information you provide to PTEPPL may be transferred to countries outside Singapore. By way of example, this may happen if any of its servers are located in a country outside Singapore or one of PTEPPL’s service providers is located in a country outside Singapore. PTEPPL may also share information between its group companies in connection with its provision of products and services, which may be located in countries outside Singapore. These countries may not have similar data protection laws to Singapore. If PTEPPL transfers your information outside Singapore in this way, PTEPPL will take steps with the aim of ensuring that your Personal Data continue to be protected to a standard that is comparable to that provided under the PDPA.
7. CONTROL OR UPDATES TO YOUR PERSONAL DATA
7.1 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. If you wish to withdraw your consent to any use or disclosure of your Personal Data as set out in this Policy, you may submit your request in writing or via email to PTEPPL’s data protection officer (“Data Protection Officer”) at: enquiry@pteppl.com.
7.2 Upon receipt of your written request to withdraw your consent, PTEPPL may require reasonable time (depending on the complexity of the request and its impact on PTEPPL’s relationship with you) for your request to be processed and for PTEPPL to notify you of any consequences of PTEPPL acceding to the same, including any legal consequences which may affect your rights and liabilities to PTEPPL. In general, PTEPPL shall seek to process and effect your request within thirty (30) days from your date of notification.
7.3 Please note that if you withdraw your consent to any or all use or disclosure of your Personal Data, depending on the nature of your request, PTEPPL may not be in a position to continue to provide its products or services to you or fulfill any contractual obligations in place where the continuation of such products and/or services and/or contractual relationship would reasonably require your Personal Data. Such withdrawal may also result in the termination of any agreement you may have with PTEPPL at the relevant time. PTEPPL’s legal rights and remedies are expressly reserved in such event.
7.4 PTEPPL aims to keep its information about you as accurate as possible. If you would like to access, review or change the details you have supplied PTEPPL with, you may contact PTEPPL’s Data Protection Officer (contact details are set out in Clause 9 below).
7.5 If you have any questions or complaints relating to the use or disclosure of your Personal Data, or if you wish to know more about PTEPPL’s data protection policies and practices, you may PTEPPL’s Data Protection Officer (contact details are set out in Clause 9 below).
8. EFFECT OF POLICY AND CHANGES TO POLICY
8.1 This Policy applies in conjunction with any other policies, notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your Personal Data to PTEPPL.
8.2 PTEPPL may revise this Policy from time to time without any prior notice. Your continued use of PTEPPL’s services constitute your acknowledgement and acceptance of such changes.
9. HOW TO CONTACT PTEPPL
The contact details of PTEPPL’s Data Protection Officer are set out as follows:
Address: 10 Anson Road, #06-17 International Plaza, Singapore 079903
Tel: +65 9847 3542
Email: enquiry@pteppl.com
PT Estate Planning Pte Ltd
8 December 2020