The purpose of this Privacy & Personal Data Protection Policy (this “Privacy Policy”) is to inform you of how Estellion & Associates LLP (a Singapore registered limited liability partnership bearing UEN: T13LL1000E) (and all its respective associated organizations, branches, and/or affiliate offices) (collectively, “EST”), as well as EST’s service providers and third parties appointed by EST on your behalf (collectively, “us“, “we” or “our“) collect, use and disclose your Personal Data.
We value the information you have provided us or permitted us to collect. We strive to protect your privacy while providing you with the best service and experience we can provide. All such personal information in our possession is valued, and is collected, used, disclosed and protected in accordance with the Singapore Personal Data Protection Act (No. 26 of 2012) (“PDPA“).
For the purposes of this Policy, the term “Personal Data” refers to any data, whether true or not, about an individual who can be identified from that data or 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, but excludes “business contact information” as defined under the PDPA.
This Policy supplements but does not supersede or replace any other consent(s) you may have previously provided to EST in respect of your Personal Data, and your consent(s) herein are additional to any rights which EST may be legally allowed to collect, use or disclose in regard to your Personal Data.
By using our website, communicating or submitting information to us, or through the engagement of our services, you agree and consent to us collecting, using and disclosing your Personal Data in the manner set forth in this Policy.
If you wish to opt-out of this Privacy Policy, amend or remove any of your personal data in our possession, please read the below paragraph 6 for the required procedure.
1. PERSONAL INFORMATION AND OTHER DATA WE COLLECT
Personal data is collected where reasonably necessary for our functions and activities, which include without limitation to the following:
(A) through the engagement of our services, which entails you providing documentation or information to us, including without limitation to your name, address, contact details, date of birth, NRIC, FIN, driver’s license and/or passport number (and/or copies of the same), employment and income details and bank account details;
(B) details of services provided to an individual by us;
(C) subscription to any of our services (whether through print, online or social media) and such ancillary mailing lists;
(D) details of an individual’s dealings with us, including interactions via telephone (which calls may be recorded), facsimile, letters, email communication face-to-face meetings, our online presence including our website, and/or other modes of contact;
(E) when you submit personal particulars to us for an application for employment in EST which may include documents or information such as your resume and references;
(F) credit-related personal information;
(G) CCTV recordings within our premises, or photographs and videography which may be taken at our seminars and events (or joint-events); and
(H) any other personal data as may be provided by an individual from time to time for any other purposes.
Collection of personal data
Wherever possible, we will collect personal data directly from you. We will only collect, use and disclose personal data with your consent, your deemed consent or as may be otherwise permitted under the PDPA or other applicable laws.
Where you have provided us with any Personal Data relating to a third party, by virtue of submitting such Personal Data to us, you represent as well as taken all reasonable steps in ensuring that you have notified the third party of the terms of this Policy and obtained his/her/its consent thereto.
In addition to the personal data you provide to us, certain information related to you that is not considered Personal Data under the PDPA may also be collected. We collect this information to improve our website. Such non-personal data may include information such as your IP address, the internet browser you use, details of your interaction with our website and other types of non-personal data.
2. USE OF YOUR PERSONAL DATA
We collect and retain your Personal Data for the following purposes (the below is not an exhaustive list):
(A) the provision of our services to you;
(B) complying with applicable laws and regulations, codes of practice or guidelines, policies, procedures, regulatory requirements (which may extend to know-your-client and related AML/CFT audits and reviews), as well as for the purposes of complying with directions issued by the relevant authorities);
(C) providing updates and other communications on developments relating to the law and in respect of EST, as well as sending you information about any administrative changes, updates and/or amendments to our policies, terms and conditions;
(D) responding to your complaints, queries and/or requests;
(E) providing customer support;
(F) supplying you with information that is relevant to your existing relationship with us, including invitations to talks and seminars organized by us, events and/or other marketing / promotional materials and activities;
(G) processing your employment applications (including the verification of your credentials and references and the performing of the necessary background checks);
(H) for fraud prevention and detection, as well as to manage the security of our premises and infrastructure; or
(I) storing, hosting, backing up (whether for disaster recovery or otherwise) of your Personal Data whether within or outside of Singapore;
(J) at our sole discretion, in exceptional circumstances such as national emergency, security concerns, or other situations in which we deem that such disclosure is prudent.
We may, for the above purposes, contact you via mail, electronic mail, telephone, SMS, facsimile or other forms of communication through mobile applications. Should you wish to opt-out of our contact list for any reason, please refer to the below paragraph 6 for the relevant procedure.
3. SHARING YOUR PERSONAL DATA
In the course of providing our services and products to you, we may need to disclose your Personal Data with external organisations, for which your deemed consent is herein given. The reasons for which we may disclose your Personal Data are set out under the paragraph 2 above. The possible parties we may share your Personal Data with include:
(A) our associated firms, agents, contractors, technical consultants, experts, third-party service providers and external law firms assisting with/in your matters;
(B) external vendors such as courier services, telecommunications, information technology, payment, payroll processing, training, market research, storage, archival, client support services;
(C) our bankers, insurers and professional advisors such as external legal counsel, accountants and auditors;
(D) relevant authorities or to any court having competent jurisdiction; and/or
(E) to any other party whom you authorise us to disclose your Personal Data.
In the event that any of the above parties receiving your Personal Data are located or are operating outside of Singapore, we will take reasonable steps to ensure that the overseas recipient provides a standard of protection to your Personal Data so transferred that is comparable to the protection under the PDPA.
4. SECURITY
We will protect your Personal Data using industry standard precautions. While the transference of electronic data over the internet has inherent risks, we use reasonable precautions to ensure your Personal Data is not subject to unnecessary risks. Appropriate security arrangements will be taken to prevent any unauthorized access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your Personal Data. However, we cannot assume responsibility for any unauthorized use of your Personal Data by third parties which are wholly attributable to factors beyond our control.
5. RETENTION
We will retain your Personal Data for as long as necessary in order to fulfil the purpose for which it was collected, or as required by the relevant laws.
We have in place measures such that your Personal Data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that the purpose for which that Personal Data was collected is no longer being served by the retention of such personal data, as well as where such retention is no longer necessary for any other legal or business purposes.
6. ACCESS, UPDATE, WITHDRAWAL OF CONSENT
You must obtain, fill out, and submit to us the prescribed form if you subsequently decide to request access of, update or withdraw your consent for us to collect, use and/or disclose your personal data. Please note that it may take up to thirty (30) business days after receipt of your form for us to process your request. For details on how to obtain such a form, please contact us.
We will take reasonable efforts to ensure that your Personal Data is accurate and complete. However you must ensure that you update us of any changes in your Personal Data that was initially provided to us, as we will not be responsible for relying on inaccurate or incomplete Personal Data arising from your failure or omission in updating us of any changes in your Personal Data.
7. RIGHTS TO AMEND THIS PRIVACY POLICY
We reserve the right to amend this Privacy Policy at any time. If material changes are made to this Privacy Policy, they will be posted on this page and date stamped. We encourage you to review this page periodically in order for you to stay notified of any such changes.
Your continued use of this website and acceptance of our services after any changes to this Privacy Policy constitutes your consent to any such changes, to the extent such consent is not otherwise provided.
8. CONTACT US
If you have questions about this Privacy Policy statement, wish to report a complaint or grievance, or wish to obtain a form mentioned in paragraph 6, please contact our Data Protection Officer at:
By Email:
mailto:dpo@estellion.com
By Post:
Estellion & Associates LLP
1 North Bridge Road
#10-01 High Street Centre
Singapore 179094
Attention: Data Protection Officer
Last updated 1 April 2020