Data Protection Policy
This Data Protection Policy applies to all personal data collected by the Information Officer Pte. Ltd. Singapore (referred to herein as the “IO”, “us”, “we” or “our”).
The purpose of this Data Protection Policy is to inform you of how IO manages Personal Data which is subject to personal data protection principles applicable to government agencies. Please take a moment to read this Data Protection Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data.
By interacting with us, submitting information to us, or signing up for any products and services offered by us, you agree and consent to IO, as well as our respective representatives and/or agents collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to IO’s authorised service providers and relevant third parties in the manner set forth in this Data Protection Policy.
This Data Protection Policy supplements but does not supersede nor replace any other consent you may have previously provided to IO in respect of your Personal Data, and your consent herein are additional to any rights which IO may have at law to collect, use or disclose your Personal Data.
IO may from time to time update this Data Protection Policy to ensure that this Data Protection Policy is consistent with our future developments, industry trends, and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of this Data Protection Policy as updated from time to time on our websites, applications, and digital services. Please check back regularly for updated information on the handling of your Personal Data.
1. Personal Data
1.1 In this Data Protection Policy, “Personal Data” refers to any data, whether true or not, about an individual who can be identified (a) from that data; or (b) 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 you may provide to us include (depending on the nature of your interaction with us) your name, NRIC, passport or other identification number, 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 you.
2. Collection of Personal Data
2.1 Generally, we collect Personal Data in the following ways:
(a) when you submit an application form or registration form, or other forms relating to any of our products and services;
(b) when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our services;
(c) when you interact with our employees, for example, via telephone calls, letters, face-to-face meetings, social media platforms and emails;
(d) when you use our electronic services, or interact with us via any of our websites or use services on any of our websites;
(e) when you request that we contact you or request that you be included in an email or other mailing list;
(f) when you respond to our initiatives or to any request for additional Personal Data;
(g) when your images are captured by us via 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;
(h) when you are contacted by, and respond to, our employees;
(i) when we receive references from business partners and third parties, for example, where you have been referred by them;
(j) when you fill up surveys administered by our third party surveying service providers;
(k) when we seek information from third parties about you in connection with the products and services you have applied for; and/or
(l) when you submit your Personal Data to us for any other reason.
2.2 When you browse our websites, or use our applications and/or digital services, you generally do so anonymously but please see the section below on cookies. We do not, at our websites, applications and digital services, automatically collect Personal Data unless you provide such information or login with your account credentials.
2.3 If you provide us with any Personal Data relating to a third party (e.g. information of your spouse, children, parents, and/or employees), by submitting such information to us, you represent and warrant to us that you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes.
2.4 You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with the products and services you have requested.
3. Purposes for the Collection, Use and Disclosure of Your Personal Data
3.1 Generally, IO collects, uses and discloses your Personal Data for the following purposes:
(a) responding to your queries, feedback, complaints and requests;
(b) verifying your identity;
(c) managing the administrative and business operations of IO and complying with internal policies and procedures;
(d) facilitating business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving IO;
(e) matching any Personal Data held which relates to you for any of the purposes listed herein;
(f) requesting feedback or participation in surveys, as well as conducting market research and/or analysis for statistical, profiling or other purposes for us to review, develop and improve the quality of our products and services;
(g) preventing, detecting and investigating crime and analysing and managing commercial risks;
(h) facilities management (including but not limited to maintaining the security of our premises);
(i) managing the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances);
(j) monitoring or recording phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes;
(k) in connection with any claims, actions or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution), and/or protecting and enforcing our contractual and legal rights and obligations;
(l) conducting investigations relating to disputes, billing or fraud;
(m) meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on IO (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies and conducting audit checks, due diligence and investigations);
(n) any other purpose reasonably related to the aforesaid.
3.2 Furthermore, where permitted under the Act and/or where you have provided your consent to IO separately, IO may also collect, use and disclose your Personal Data for the following additional purposes:
(a) providing or marketing services, products and benefits to you, including but not limited to special events and promotions from IO;
(b) matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision, marketing or offering of products and services by IO;
(c) conducting market research, analytics and surveys to enable IO to understand and determine customer 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
(d) any other purpose reasonably related to the aforesaid.
3.4 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, IO may continue to contact you using such Singapore telephone number(s) (including via voice calls, text, fax, or other means) with information about our products and services, unless you have withdrawn your consent.
3.5 In relation to particular products and services or in your interactions with IO, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.
4. Disclosure of Personal Data
4.1 IO will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, your Personal Data may be disclosed by IO, for the purposes listed above (where applicable), to the following entities or parties, whether they are located overseas or in Singapore:
(a) Information Officer LLC.;
(b) companies providing services relating to insurance, marketing and consultancy to IO;
(c) agents, contractors or third party service providers who provide operational services to IO, such as courier services, telecommunications, information technology, payment, printing, billing, payroll, processing, technical services, training, market research, security or other services to IO;
(d) agents, contractors or third party service providers who provide services in connection with the programmes and events organised, conducted and administered by IO;
(e) any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving IO;
(f) external banks, credit card companies and their respective service providers;
(g) our professional advisers such as consultants, auditors and lawyers;
(h) relevant government ministries, regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority;
(i) any other party whom you authorise us to disclose your Personal Data to.
5.1 A cookie is a small piece of information that is placed on your computer when you visit certain websites. The cookies placed by the servers hosting our websites are readable only by us, and cookies cannot access, read or modify any other data on an electric device, nor does it capture any data which allows us to identify you individually. All web-browsers offer the option to refuse any cookie, and if you refuse our cookie then we do not gather any information on that visitor.
5.2 Should you wish to disable the cookies associated with these browsers, you may do so by changing the setting on your browser. However, you may not be able to enter certain part(s) of our websites.
6. Data Security
6.1 IO will take reasonable efforts to protect Personal Data in our possession or our control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. However, we cannot completely guarantee the security of any Personal Data we may have collected from or about you, or that for example no harmful code will enter our websites, applications, and digital services (for example viruses, bugs, trojan horses, spyware or adware). You should be aware of the risks associated with using websites, applications, and digital services.
6.2 While we strive to protect your Personal Data, we cannot ensure the security of the information you transmit to us via the Internet, when you browse our websites, or use our applications and/or digital services, and the method of electronic storage. We urge you to take every precaution to protect your Personal Data when you are on the Internet, when you browse our websites, or use our applications and/or digital services. We recommend that you change your passwords often, use a combination of letters and numbers, and ensure that you use a secure browser.
6.3 If applicable, you undertake to keep your username and password secure and confidential and shall not disclose or permit it to be disclosed to any unauthorised person, and to inform us as soon as reasonably practicable if you know or suspect that someone else knows your username and password or believe the confidentiality of your username and password has been lost, stolen or compromised in any way or that actual or possible unauthorised transactions have taken place. We are not liable for any damages resulting from any security breaches, on unauthorised and/or fraudulent use of your username and password.
7. Contacting Us – Feedback, Withdrawal of Consent, Access and Correction of your Personal Data
7.1 You can contact us at firstname.lastname@example.org or call (65) 6994 3060 if you:
(a) have any questions or feedback relating to your Personal Data or our Data Protection Policy;
(b) would like to withdraw your consent to any use of your Personal Data as set out in this Data Protection Policy; or
(c) would like more information on or access and make corrections to your Personal Data records.
7.2 If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, IPOS may not be in a position to administer any contractual relationship in place, which in turn may also result in the termination of any agreements with IPOS, and your being in breach of your contractual obligations or undertakings. IPOS’s legal rights and remedies in such event are expressly reserved.
8. Governing Law
8.1 This Data Protection Policy, your browsing of our websites, and use of our applications and/or digital services shall be governed in all respects by the laws of Singapore.