1.1 We, PEOPLE MATTERS PTE LTD “the Company”, and references herein to "we", "us" and "our" are to the Company, are committed to ensuring the safety and security of personal data.
1.2 The purpose of this Privacy Policy (“Privacy Policy”) is to inform you as to how we manage, collect, use and disclose personal data. In Singapore, such activities are subject to the Personal Data Protection Act (No. 26 of 2012) (the “PDPA”). We conduct our business in compliance with the PDPA and have implemented various measures to ensure that any personal data we collect, use and/or disclose remains safe and secure.
1.3 Unless otherwise defined, capitalised terms used in this Privacy Policy shall bear the same meanings ascribed to them in our Terms of Use, where applicable.
1.4 Subject to paragraph 1.5 below, your continued access and use of the Platform and/or the Services shall constitute your agreement to our collection, use and/or disclosure of your Personal Data in accordance with this Privacy Policy and the applicable laws.
1.5 If you are a Minor, your parent or legal guardian’s consent shall be required to consent to our collection, use and/or disclosure of your Personal Data.
In this Privacy Policy, “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.
3.1 The Personal Data that we may collect may include an individual’s name, email address, phone number, date of birth, residential address, personal identification number, information from the individual’s device or equipment used to access and/or use the Platform (including network activity and IP address) and any other Personal Data necessary for us to provide our services, including access and use of the Platform and/or Services.
3.2 Typically, we will collect Personal Data from Users, business contacts, business partners, companies that we may invest in or any other third parties that we work with or from publicly available sources.
4.1 We may use and/or disclose Personal Data for:
(Collectively, the “Purposes” and each, a “Purpose”).
4.2 We will not use Personal Data for purposes which we are not permitted to or required under the applicable personal data protection law and regulations.
4.3 Notwithstanding the above, we may collect, use and/or disclose any Personal Data without your consent provided that such collection, use and/or disclosure is in accordance with any applicable laws, including but not limited to the PDPA.
5.1We may share and disclose Personal Data with:
5.2 Personal Data is disclosed to the above only for the Purposes or otherwise in accordance with the applicable personal data protection laws.
5.3 In exceptional circumstances, we may also be required to disclose Personal Data where, amongst others, there are grounds to believe that disclosure is necessary to prevent a threat to life or health, or for law enforcement purposes.
5.4 In some cases, we shall encrypt, anonymize, and aggregate the information before sharing it. Anonymizing means stripping the information of personally identifiable features. Aggregating means presenting the information in groups or segments e.g. age groups.
5.5 We will also ensure that overseas organisations we work with observe strict confidentiality and data protection obligations, and shall ensure that any personal data transferred overseas will be made in accordance with the PDPA.
6.1 We will strive to keep your Personal Data accurate. You will be given the ability to review and update your Personal Data that we have in our possession.
6.2 You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Further, when you provide us with any Personal Data relating to a third party (including your spouse, children, parents and/or employees), you represent and warrant to us that you have obtained the consent of the third party to provide us with their Personal Data unless otherwise provided in the PDPA.
6.3 If there is any Personal Data relating to you that you are unable to update and which you wish to make corrections to, you may contact our Data Protection Officer (whose contact is set out below) and we will be happy to help you as best as we can.
7.1 If you wish to access the Personal Data that we have relating to you, inquire about the way in which Personal Data relating to you has been used or disclosed by us in the past year, or wish to withdraw your consent to our use of such Personal Data, you may contact our Data Protection Officer (whose contact is set out below) and we will seek to attend to your request as best as we reasonably can. Please note that:
7.2 For the avoidance of doubt, if we refuse to grant you access to your Personal Data, we shall preserve a complete and accurate copy of the Personal Data for a period of 30 days after the date which we notify you of our refusal to do so.
8.1 Safeguarding and respecting the confidentiality of Personal Data is important to us. We will use our best efforts to protect Personal Data.
8.2 The Personal Data provided to us are stored on secure servers. We also have security measures in place to protect against unauthorized access, loss, misuse and alteration of Personal Data under our possession and/or control. However, to the extent permissible under the applicable laws, we will not be held liable or responsible for any loss, misuse or alteration of Personal Data that may be caused by third parties.
9.1 We will only retain Personal Data for only as long as:
9.2 In the event that retention of Personal Data is no longer necessary for any business or legal purposes or when the purpose for which the Personal Data was collected is no longer being served by the retention of the Personal Data, we will remove, destroy or anonymise the Personal Data.
10.1 Your Personal Data may be transferred to, stored or processed outside of Singapore.
10.2 We will only transfer your information overseas in accordance with the PDPA and will ensure that overseas organisations we work with observe strict confidentiality and are subject to data protection obligations.
10.3 In particular, we will ensure that the overseas organisations we transfer your Personal Data to will provide a standard of protection comparable to the protection under the PDPA.
In the event of a data breach of your Personal Data (“Breach”), we will promptly conduct an assessment of whether the Breach is notifiable to the Personal Data Protection Commission (“PDPC”) in accordance with the PDPA. If the Breach is notifiable to the PDPC, we will also notify you of the occurrence of the Breach in accordance with the PDPA.
12.1 If you believe that we have breached this Privacy Policy, or any other applicable privacy or data protection laws or regulations which may apply to us, you should make a complaint to us in the first instance. You should address your complaint in writing to our Data Protection Officer (whose contact is set out below), and you should include as much detail as you can about the Personal Data affected, and the circumstances that you believe amount to a breach of this Privacy Policy or the PDPA.
12.2 If you have any questions about our Privacy Policy or concerns about our commitment to your privacy, please feel free to email or write to the Data Protection Officer (whose contact details are set out below).
Please feel free to contact our Data Protection Officer at 38 Beach Road, #29-11, South Beach Tower Singapore - 189767.
We reserve the right to modify and update this Privacy Policy at any time to ensure it is consistent with industry trends and/or any changes in legal or regulatory requirements.
This Privacy Policy shall be governed in all respects by the laws of Singapore.
