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The purpose of this document (“Personal Data Protection Policy“) is to notify you of how Secura Group Limited and its subsidiaries (collectively, the “Group“) collect, use, store and/ or disclose your Personal Data (to be defined below) which is subject to the Personal Data Protection Act 2012 (the “Act“) https://sso.agc.gov.sg/Act/PDPA2012. Please take a moment to read this Personal Data Protection Policy so that you can understand the purposes for which we collect, use, store and/ or disclose your Personal Data.
When you provide us with your Personal Data, in person, by email, through this website or any of its sub-domains (collectively, “this website“) or through any of our various offices in Singapore and overseas, or use any products and services offered by us (collectively, “Offering“), you consent to the Group, as well as its respective representatives and/ or agents (collectively, referred to herein as “Secura“, “us“, “we” or “our“) collecting, using, storing and/ or sharing amongst themselves your Personal Data, and disclosing such Personal Data to the Group’s authorised service providers and relevant third parties in the manner set forth in this Personal Data Protection Policy. If you do not consent to our collection, usage, storage and/ or disclosure of your Personal Data as described herein, please do not use this website or any Offerings or provide us with your Personal Data.
This Personal Data Protection Policy supplements but does not supersede nor replace any other consent you may have previously provided or subsequently provided to Secura in respect of your Personal Data. Your consents herein are additional to any rights to which any of the entities within the Group may have at law to collect, use, store and/ or disclose your Personal Data.
1.1 In this Personal Data Protection Policy, “Personal Data” refers to any data, whether true or false, about an individual who can be identified:
1.2 Examples of such Personal Data include, without limitation, your name, NRIC number, passport number or other identification number such as work permit number; photographs and CCTV images, telephone number(s), mailing address, email address and any other information relating to any individuals which you have provided us in any forms you may have submitted to us, or via other forms of interaction with us.
2. Collection of Personal Data limited with Consent
2.1 When you visit this website, our third-party service providers’ websites, and/ or use our Offerings, we may collect certain types of information from you, including Personal Data, information about you, your computer, or devices (including mobile devices) voluntarily provide via forms, surveys, applications and through the use of various Offerings or participation in various events, programmes or services. We may also collect information about you from your online browsing and transactions, including your preferences, pages visited, and technical information regarding your computer, devices and operating systems.
2.2 If you are only browsing this website, Secura generally does not capture any data that will allow us to identify you individually. However, please refer to Section 11 – Cookies below for more details.
2.3 Personal Data may also be collected in the following ways when:
2.4 By providing us with your Personal Data in one of the above ways, you consent to provide us with your Personal Data for the respective purposes (to be discussed in Section 3 below). When you provide us with any Personal Data relating to a third party (e.g. information of your spouse, children, parents, and/ or employees), you represent to us that you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes.
In relation to particular products and services or in your interactions with us, we may also have specifically notified you of other additional purposes for which we collect, use, store and/or disclose your Personal Data. If so, we will collect, use, store and/or disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.
Usage and Processing
3. Usage of Personal Data limited by Consent and Purpose
3.1 We collect, use, store and/ or disclose your Personal Data for the following purposes:
(i) to contact the referee(s) and/ or guarantor(s) whose details have been provided by you;
(ii) to verify your academic and professional qualifications by contacting the school/ college/ university/ institute/ professional examination bodies; and/ or (iii) to disclose your Personal Data to Secura’s customers in connection with your job application;
3.2 Further, we may collect, use, store and/ or disclose your Personal Data in the following circumstances depending on the nature of our relationship:
(i) to facilitate your appointment;
(ii) to maintain statutory registers and manage the publication of shareholder or director statistics on annual reports and circulars; and/ or
(iii) purposes which are reasonably related to the aforesaid.
(i) to conduct background screening;
(ii) to provide remuneration, reviewing salaries and bonuses, conducting salary benchmarking reviews, staff appraisals and evaluation (including recognising individuals for their services and conferring options and awards);
(iii) to administer administrative and support processes relating to your employment, including its management and termination, as well as staff benefits (including manpower, business continuity and logistics management or support, processing expenses claims, medical insurance applications, leave administration, training, learning and talent development, bank loans and visa applications, and planning and organising corporate events);
(iv) to provide you with tools and/ or facilities to enable or facilitate the performance of your duties;
(v) to compile and publish internal directories and emergency contact lists for business continuity;
(vi) to facilitate overseas travel arrangements (including but not limited to setting up travel accounts);
(vii) to conduct internal or external audits;
(viii) to manage facilities (including but not limited to maintaining the security of our premises, maintaining proper key access control and recording entries and exits);
(ix) to conduct analytics, surveys and research for human resources planning and management, and for us to review, develop, optimise and improve work-related practices, environment and productivity;
(x) to ensure that the administrative and business operations or Secura functions are in a secure, efficient and effective manner (including but not limited to providing internal communications and maintenance);
(xi) to administer cessation processes; and/ or(xii) purposes which are reasonably related to the aforesaid.
(i) to facilitate your course enrollment, administration and certification at Secura Training Academy;
(ii) upon certification, to engage you as alumnus of Secura Training Academy, which includes but is not limited to notification on Secura Training Academy and alumni-related initiatives and activities, invitation to Secura Training Academy and alumni-related events, updating of alumni information, invitation to participate in alumni surveys and sending of communication collaterals; and/ or
(iii) purposes which are reasonably related to the aforesaid. Refer to the Personal Data Protection Policy of Secura Training Academy for more details at: https://securagroup.com.sg/secura-training/personal-data-protection-policy/.
we may also collect, use, store and/or disclose such Personal Data if so authorised or required by law or the relevant law enforcement authorities, or exempted under the Act to do so. For example, where permitted under the Act or with your consent, Secura may also collect, use, store and/ or disclose your Personal Data for the following “Additional Purposes”:
(i) to provide or market products, services and benefits (including invitations to special events and for promotional, loyalty and reward programmes by Secura);
(ii) for leads generation and management for marketing Secura products and services;
(iii) to communicate to your advertisements involving details of our products and services, special offers and rewards, either to our customers generally, or which we have identified may be of interest to you;
(iv) to conduct market research and surveys to enable us to understand and determine customer location, preferences and demographics for us to offer you products and services as well as special offers and marketing programmes which may be relevant to your preferences and profile; and/ or
(v) purposes which are reasonably related to the aforesaid.
3.3 If you have provided your Singapore telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your Singapore telephone number(s), then from time to time, Secura may contact you using such Singapore telephone number(s) (including but limited to via voice calls, sms, fax or other means) with information about our products and services.
3.4 You may withdraw your consent for receiving marketing or promotional materials/ communication. You may contact us using the contact details found in Section 14 – Contact Us below.
3.5 Please be aware that once we receive confirmation that you wish to withdraw your consent for marketing or promotional materials/ communication, it may take up to 30 working days for your withdrawal to be reflected in our systems. Therefore, you may still receive marketing or promotional materials/ communication during this period of time. Please note that even if you withdraw your consent for the receipt of marketing or promotional materials/ communication, we may still contact you for other purposes in relation to the products and services that you have requested from Secura.
4.1 We need your assistance and cooperation to ensure that your Personal Data is current, complete and accurate.
4.2 When you provide Personal Data about yourself to us, you are responsible for providing accurate, not misleading, complete and up-to-date information about yourself and any other person whose Personal Data you provide us to your best knowledge, and to contact us to update this Personal Data as and when it becomes inaccurate, misleading, incomplete or out-of-date.
4.3 In certain circumstances, you may need to provide us with Personal Data about someone other than yourself (for example, your referee in relation to your job application). If so, we rely on you to inform these individuals that you are providing their Personal Data to Secura, to make sure that they consent to you giving us their information and to advise them about where they can find a copy of this Personal Data Protection Policy.
Storage and Disposal
5. Security and Protection
5.1 As required under the Act, we will take reasonable care to secure and protect your Personal Data from unauthorised access, collection, copying, improper use or disclosure, unauthorised modification, unlawful destruction or accidental loss and other similar risks.
5.2 The Internet is not always a secure channel for transmitting information. Accordingly, while we seek to secure and protect your Personal Data, Secura cannot accept responsibility for the security of information transmitted over the Internet channel or for any unauthorised access or use of that information.
6. Retention for Business and Legal Reasons
6.1 Secura will retain your Personal Data for the duration of time to carry out the purposes for which your Personal Data was collected, for the other purposes set out in this policy, for business purposes and as required by relevant laws. We will cease to retain your Personal Data or remove the means by which it can be associated individually with you as soon as it is reasonable to assume that:
(i) the purpose for which that Personal Data was collected is no longer being served by retention of the Personal Data; and
(ii) retention is no longer necessary for business and legal reasons.
Disclosure and Transfer
7. How to Access and Correct your Personal Data, or Withdraw your Consent
7.1 If you wish to:
7.2 Please allow us a reasonable period of time to respond to any request and effect any change. We may ask you to verify your identity and for more information about your request. Where we are legally permitted to do so, we may refuse your request and give you reasons for doing so. When you request your Personal Data to be updated and there is a dispute about the facts, we will make a note of your Personal Data of such dispute. When permitted to do so, we may charge you an administrative fee for access requests.
8.1 If we are transferring your Personal Data overseas, such as storing the data in the cloud, we shall ensure that the country to which the data is being transferred offers a comparable level of data protection as is provided by the Act.
8.2 If we are transferring your Personal Data to third parties who are contracted by us to assist us in delivering part or all of the products and services ordered by you; and/ or who provide services to us such as professional advisors, IT consultants, etc., we will use all commercially reasonable endeavours to ensure that these third parties comply with similar undertaking of privacy under the Act.
9. Accountability and Openness
9.1 We are accountable for your Personal Data in our possession or under our control. We have appointed a full-time dedicated Chief Data Protection Officer to be responsible for ensuring that we comply with the Act. We have developed and implemented policies and procedures that are necessary for us to meet the obligations of the Group under the Act.
9.2 We are open to sharing information about our data practices, policies and complaints processes upon request.
9.3 We welcome any comments or queries on this policy contact us using the contact details found in Section 14 below.
10. Third Party Websites
This website may contain links to third party websites whose data protection and privacy practices may differ from ours. We are not responsible for the contents and privacy practices of these third-party websites and encourage you to consult the privacy policies of those websites. Secura is not responsible for any information that is submitted to or collected by these third-party websites which may lead to a data breach under this Act.
11.2 If you choose to disable the cookies, you may do so by changing the settings on your browser. However, you may not be able to experience all of the features of this website.
12. IP Addresses
When you visit this website, our server may record your IP address together with the date, and duration of your visit. An IP address is an assigned number, similar to a telephone number, which allows your computer to communicate over the Internet. We may use this information to compile statistical data on the use of this website to track how users navigate through this website. We may do this so we can evaluate and improve our website.
13. Updates on Personal Data Protection Policy
13.1 Our Chief Data Protection Officer at Secura will from time to time review and update this Personal Data Protection Policy to ensure that it is consistent with our future developments, industry trends and/ or any changes in legal or regulatory requirements. Subject to your rights at law, you consent to be bound by the prevailing terms of this Personal Data Protection Policy as updated from time to time and can be viewed publicly at our website: https://securagroup.com.sg.
13.2 We reserve the right to amend the terms of this Personal Data Protection Policy at our absolute discretion. Any amended Personal Data Protection Policy will be publicly posted on our website. Please check back regularly for updated information on the handling of your Personal Data.
14. Contact Us
If you have any comments or queries on this policy, please contact our Chief Data Protection Officer in writing at the address below referencing “Personal Data Protection Act“:
Secura Group Limited
38 Alexandra Terrace
Attn: Chief Data Protection Officer
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