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.

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. from that data; or 
2. from that data and other information to which we have or are likely to have access,  including data in our records as may be updated from time to time. 

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. 

Collection  

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:

1.  you interact with our staff, including but not limited to via telephone calls,  teleconferencing & video-conferencing (which may be recorded), letters, physical  meetings, social media platforms and emails;
2. you submit any form, including but not limited to employment applications and  registration forms or when you provide documents or information including your resume  and/ or curriculum vitae in connection with any appointment as an officer or any other  position; 
3. you enter into any agreement or provide other documentation or information in respect  of your interactions with us, or when you purchase and/ or use our products and  services; 
4. you request that we contact you or request that you be included in an email or other  mailing list; 
5. you respond to our promotions, initiatives or to any request for additional Personal Data; 
6. your images are captured by us via closed-circuit television (CCTV) cameras while you  are within our premises, or via photographs or videos taken by us or our representatives  when you attend events at our premises; 
7. you are contacted by, and respond to, our marketing representatives and customer  service officers; 
8. we seek information about you and receive your Personal Data in connection with your  relationship with us, including for our products and services or employment applications,  for example, from business partners, public agencies, your ex-employer, referral  intermediaries and the relevant authorities; 
9. you submit your course application form to enroll for a course conducted by us which  contains your Personal Data; and/ or 
10. you submit your Personal Data to us for any other reason.

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.

2.5 Notification

1. By reading this Personal Data Protection Policy, it is deemed that you have been  informed of the general purposes of our Personal Data collection, usage, storage and/  or disclosure. 
2. We will also notify you of the specific purposes for which your Personal Data may be  collected, used, stored and/ or disclosed, as well as obtain your consent for such  intended purposes. 
3. When the Group may have at law or any legal requirements by relevant law  enforcement authorities to collect, use, store and/ or disclose your Personal Data, we  may or may not notify you, or if so, may not be able to notify you just in time for your  Personal Data is disclosed to such authorities on an urgent basis.

4. 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:

1. to verify your identity, update our records and generally maintain your accounts with  us; 
2. to respond to any queries, feedback, and requests that you may have submitted to us; 
3. to communicate with you on any of Secura’s products and services, announcements,  promotions or contests, and to process your order and deliver products and services  to you. If you are not currently participating or do not have an existing transaction with  Secura, we will seek your separate consent; 
4. to manage the administrative, business operations, and product development of  Secura (including compliance with internal policies); 
5. to provide customer service and support, creating and maintaining profiles in our  database management system; 
6. to communicate with you and/or to keep records in connection with a job application  and other job opportunities including:
   
   

   (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;

7. to facilitate events (including dialogue and distinguished lecture sessions); 
8. to facilitate business asset transactions (including any business transfers, mergers,  acquisitions or asset sales). In such transactions, customer information may be one of  the transferred business assets. Also, in the unlikely event that an entity of the Group  or substantially all of its assets are acquired, customer information may be one of the  transferred assets; 
9. to assess the suitability of external service providers or vendors; 
10. to manage project tenders and quotations, processing orders or manage the supply of  goods and services; 
11. to provide access controls; 
12. to manage the safety and security of our premises and services (including carrying out  CCTV cameras surveillance and conducting security clearances); 
13. to prepare, update and manage occurrence books and incident reports; n) to administer debt recovery management;
14. to detect and prevent fraudulent activities; and/ or 
15. to third parties:
    
    (i) contracted by us to assist us in delivering part or full products and services  ordered by you; and/ or
    
    (ii) who provide services to us such as professional advisors, IT consultants, etc.
    

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:

1. if you are a shareholder, authorised bank signatory of Secura or sit on the Board of  Directors of Secura:
   
   

   (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.

2. if you are an existing employee or associate of Secura:
   
   

   (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.

3.  if you are an existing student of Secura Training Academy:
   
   

   (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/.

4. 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. Accuracy 

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:

1. apply for a copy of the Personal Data we hold about you; 
2. request for your Personal Data to be updated or corrected; or 
3. withdraw consent you previously provided to us to collect, use, store and/ or disclose  the Personal Data we hold about you, please contact our Chief Data Protection Officer  at the contact details set out in Section 14 – Contact Us below.

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. Transfer

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. 

Accountability

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. 

Other Concerns

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. Cookies 

11.1 This website uses cookies to monitor browsing preferences and help us analyse data about  webpage traffic in order to make website improvements and for statistical analysis  purposes. A cookie does not give us access to your computer or any personally identifiable  information about you, other than the data you choose to share with us. Most Internet  browsers offer the option to turn off any cookie. 

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.

Public

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 

Singapore 119932 

Email: dpo@securagroup.sg  

Attn: Chief Data Protection Officer