This Data Protection Policy (“Policy”) sets out the basis on which GEX Ventures Group and its affiliated companies (the “Group”,“we”, “us”, or “our”) may collect, use and disclose or otherwise process your Personal Data, and share your Personal Data within the Group, in accordance with the Personal Data Protection Act 2012 (the “Act”).
GEX Ventures Group consists of the following legal entities:
(a) GEX Ventures Pte. Ltd.;
(b) GEX Academy Pte. Ltd.;
(c) GEX Global Assets Pte. Ltd.; and
(d) GEX Global Capital Pte. Ltd.
This Policy applies to Personal Data in our possession or under our control including Personal Data in the possession of organisations which we have engaged to collect, use, disclose or process Personal Data for our purposes.
By using our websites and services, you consent to the use, collection and disclosure of your Personal Data as set out in this Policy from time to time.
1. PERSONAL DATA
1.1 “Customer” (or “you”, “your”) means an individual who has:
(a) contacted us through any means to find out more about any goods or services we provide, or
(b) may, or has, entered into a contract with us for the supply of goods and services by us.
1.2 “Personal Data” means data, whether true or not, about a customer who can be identified from:
(a) that data; or
(b) that data and other information which we have or are likely to have access to.
1.3 The following are examples of Personal Data which may be collected from you, depending on the nature of your interactions with us:
(a) your name;
(b) your identification information, such as your NRIC Number,
(c) contact information such as your residential address, email address, or telephone number;
(d) personal particulars such as your nationality, gender, date of birth, marital status,
(e) photographs and other audio-visual information;
(f) employment information; and
(g) financial information such as credit card numbers, debit card numbers or bank account information.
2. COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
2.1 Your Personal Data may be collected by us generally only where:
(a) you have provided it to us voluntarily, either directly or via a third party who has been duly authorised by you to disclose your Personal Data to us (your “Authorised Representative”) and;
(i) you, or where applicable, 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 your consent is permitted or required by the Act or other laws.
2.2 We will seek your consent before collecting any Personal Data and before using your Personal Data for purposes which have not been notified to you, except where permitted or authorised by law.
3. PURPOSES OF COLLECTION AND USE OF PERSONAL DATA
3.1 We may collect and use your Personal Data for any or all of the following purposes:
(a) performing obligations in the course of in connection with our provision of the goods and/or services requested by you;
(b) verifying your identity;
(c) responding to, handling, and processing queries, requests, applications, complaints and feedback from you;
(d) managing your relationship with us;
(e) processing payment or credit transactions;
(f) sending you marketing information about our goods and/or services including notifying you of our marketing events, initiatives and promotions, lucky draws, memberships, reward schemes and other promotions;
(g) complying with any applicable laws, regulations, codes of practice, guidelines, or rules to assist in law enforcement, and investigations conducted by any governmental and/or regulatory authority;
(h) transmitting to any unaffiliated third parties, including our third-party service providers and agents, and
(i) any other incidental business purposes related to or in connection with the above.
4. DISCLOSURE OF PERSONAL DATA
4.1 We may disclose your Personal Data in the following situations:
(a) 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;
(b) to improve on the provision of our goods or services to you; or
(c) to third party service providers, agents and other organisations we have engaged to perform any of the functions listed in clause 4.1(a) above for us.
4.2 The purposes listed in the above clauses 3 and 4 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).
5. COLLECTION, USE AND DISCLOSURE OF PHOTOGRAPHS AND OTHER AUDIO-VISUAL INFORMATION
You agree that we may collect, use and disclose Personal Data consisting of photographs and other audio-visual information for marketing and publicity purposes, such as for publication on our websites or advertisements.
6. WITHDRAWING YOUR CONSENT
6.1 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.
6.2 You may withdraw consent and request us to stop using and/or disclosing your Personal Data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.
6.3 Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us.
6.4 In general, we shall seek to process your request within ten (10) business days of receiving it.
6.5 Whilst we respect your decision to withdraw your consent, please note that depending on the
nature and scope of your request, we may not be able to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 6.2 above.
6.6 Please note that withdrawing consent does not affect our right to continue to collect, use and disclose Personal Data where such collection, use and disclose without consent is permitted or required under applicable laws.
7. ACCESS TO AND CORRECTION OF PERSONAL DATA
7.1 If you wish to make:
(a) 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 use or disclose your Personal Data; or
(b) a correction request to correct or update any of your Personal Data which we hold about you,
you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
7.2 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.
7.3 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.
7.4 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 Act).
8. PROTECTION OF PERSONAL DATA
8.1 To safeguard your Personal Data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us, and disclosing Personal Data both internally and to our authorised third party service providers and agents only on a need-to-know basis.
8.2 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 information and are constantly reviewing and enhancing our information security measures.
9. ACCURACY OF PERSONAL DATA
We generally rely on Personal Data provided by you (or your authorised representative). In order to ensure that your Personal Data is current, complete and accurate, please update us if there are changes to your Personal Data by informing our Data Protection Officer in writing or via email at the contact details provided below.
10. RETENTION OF PERSONAL DATA
10.1 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.
10.2 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.
11. TRANSFER OF PERSONAL DATA OUTSIDE SINGAPORE
We generally do not transfer your Personal Data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your Personal Data continues to receive a standard of protection that is at least comparable to that provided under the Act.
12. DATA PROTECTION OFFICER
You may contact our Data Protection Officer if you have any enquiries or feedback on our Personal Data protection policies and procedures, or if you wish to make any request (e.g. to correct or access your Personal Data): Please contact us by sending an email to firstname.lastname@example.org
13. EFFECT OF DATA PROTECTION POLICY AND CHANGES TO DATA PROTECTION POLICY
13.1 This Data Protection 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 by us.
We may revise this Data Protection Policy from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Data Protection Policy was last updated below.
This policy was last modified on 22/03/2019.
13.2 Your continued use of our service constitutes your acknowledgement and acceptance of such changes. Please contact our Data Protection Officer if you do not wish to accept such changes.
14.1 We may use “cookies”, where a small data file is sent to your browser to store and track information about you when you enter our websites. The cookie is used to track information such as the number of users and their frequency of use, profiles of users and their preferred sites. While this cookie can tell us when you enter our sites and which pages you visit, it cannot read data off your hard disk.
14.2 You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.
15. THIRD-PARTY WEBSITES
Our website may from time to time contain links to and from other websites whose data protection policies and practices may differ from ours. We are not responsible for the content and privacy practices of these other websites. You should take note of the data protection policies of these websites.