We at Capital Radius ("organization", "us", "we" ) know our obligations beneath the Personal Data Protection Act 2012 (the “PDPA”) seriously. We also understand the importance of the Personal Data you have committed to us and believe that it is our accountability to properly manage, protect, and process your Personal Data.
This Policy refers to your access and use of our website https://www.capitalradius.com, the knowledge made available there plus the services accessible therein (the “Website”) including the company conducted, by the Company plus explains how we manage Personal Data plus comply with the obligations of Singapore’s PDPA. If you, at any time, have any questions on this Policy or any other queries in relation to how we may maintain, preserve and/or process your Personal Data, please do not wait to reach our Data Protection Officer at firstname.lastname@example.org
1. COLLECTINGOF YOURPERSONALDATA
1.2. We may gather Personal Data from you by numerous means, including yet not limited to
instances when you:
(a) render your Personal Data for the objective of registering and creating an account in our Site or requesting to get our direct marketing materials ("Newsletters");
(b) engage in a promotion, campaign either another Website highlight;
(c) send us any interrogations, questions or other kinds of communications;
(d) execute acquisitions by the Website; and/or
(e) equip us with your Personal Data for purposes as otherwise published by us from time to time.
- 1.3. You have no responsibility to render any of the Personal Data requested by us. Though, depending on conditions, it may be the case that if you do not render the requested Personal Data, we may not be able to render you with particular Services or with access or usage of certain highlights of the Website, where these depend on the gathering, use or disclosure of your Personal Data.
- 1.4. Where practical, we will assemble Personal Data directly from you. If we get Personal Data about you from someone else, we will take prudent steps to assure you are aware that we have assembled such Personal Data about you including the conditions of the collection.
2. PURPOSES FOR GATHERING, USE & DECLARATION OF PERSONAL DATA
2.1. The Personal Data which we accumulate from you may be collected, used and/or revealed for the following purposes:
(a) promoting and/or processing the creation of your user account;
(b) to manage, facilitate, method and/or deal in any matters comparing to your usage of the Website or any transactions or activities carried out through you on or through the Website;
(c) promoting, processing, dealing with, administering, managing also/or regulating your transactions and/or relationship with us, involving but not limited to the provision of Services;
(d) to promote, administer, process plus entire payments by you for any purchase of the Services, which may include the acquisition, use, disclosure also processing of your billing information, so as billing address, credit card information, including transaction IDs by our third-party merchants who treat such payments on our behalf.
(e) taking out your guidance or acknowledging to any inquiry given by (or purported to be given by) you or on your behalf;
(f) sending you invites to functions held by us;
(g) reaching you or interacting with you through phone/voice call, text message and/or fax message, the email also/or postal mail for the prospects of administering and/or regulating your use of the Website and/or helping your relationship with us or any transactions made by you with us. You acknowledge and agree that such communication by us could be by way of the mailing of equivalence, documents or notifies to you, which could include the declaration of certain Personal Data about you to bring about delivery of the same as well as on the outside cover of envelopes/mail Packages;
(h) the convoying investigation, analysis plus development activities (including still not limited to data analytics, reviews and/or profiling) to promote our services plus facilities in order to improve your relationship with us or for your advantage, or to correct any of our products or services for your advantage;
(i) bringing out due diligence or other screening movements (including background checks, know-your-client checks also anti-money laundering due to diligence checks) in accordance with legal or regulatory responsibilities (whether Singapore or foreign country) appropriate to us or our subsidiaries/associated companies, the obligations or guidelines of government administrations (whether Singapore or foreign country) which we define are applicable to us or our affiliates/associated corporations, and/or our risk management procedures that may be needed by law (whether Singapore or foreign country) or that may have been placed in place by us or our affiliates/associated Organizations;
(j) to deter or investigate any cheating, unlawful activity or omission or misconduct, whether or not there is any doubt of the aforementioned; trading with and/or investigating charges;
(k) complying with or as needed by any applicable law, court order, the order of a the regulatory body, governmental or regulatory obligations of any jurisdiction applicable to us or our subsidiaries/associated corporations, including meeting the obligations to make disclosure under the obligations of any law binding on us or our subsidiaries/associated corporations, and/or for the purposes of any guidelines declared by regulatory or other authorizations (whether of Singapore or elsewhere), with which we or our subsidiaries/associated corporations are presumed to comply;
(l) complying with or as needed by any request or direction of any governmental authority (whether Singapore or foreign country) which we are supposed to comply with; or acknowledging to requests for knowledge from public companies, ministries, statutory boards or other alike authorities (whether Singapore or foreign country). For the delay of doubt, this means that we may/will uncover your Personal Data to such parties upon their application or direction;
(m) monitoring, processing and/or following your use of the Website in order to render you with a seamless practice, facilitating or administering your utilization of our Website, and/or to support us in enhancing your experience in using our Website;
(n) collecting, hosting, backing up (whether for emergency recovery or otherwise) of your Personal Data, whether within or outside Singapore;
(o) promoting, dealing with and/or administering external audit(s) or internal audit(s) of the market of the Company or that of its subsidiaries/related organizations;
(p) if you have distinctly shown that you consent to such a faith, for marketing goals and in this regard, we would be rendering you with marketing, advertising including promotional information, elements and/or documents relating to products, campaigns, services and/or events (including those of third-party companies whom we may cooperate with) that we (including our subsidiaries/related corporations) or such third party companies may be selling, marketing, offering, organizing, included in or advertising, whether such products, services, campaigns also/or events exist now or are built in the future:
(i) by way of postal mail, electronic device to your email address(es), push
information, other forms of browser-based notifications or providing other
automation(such as geo-location automation) on your computers, and/or
by other modes of interaction that is not the 3 DNC Modes (described
below), in compliance with the PDPA. You may opt-out of this or withdraw
from this at any moment by sending an email to our Data Protection Officer. For
the avoidance of uncertainty, unlike (ii) under, the application of or your
approval of or your consent to, this Policy, establishes your consent to this
subparagraph (i); and/or
(ii) if you have distinctly expressly consented to one or more of the subsequent 3 DNC Modes, by way of the 3 modes of interactions of voice calls, text letters or faxes (the “3 DNC Modes” ) to your Singapore telephone number, in agreement with the obligations of the PDPA. For the delay of doubt, this subparagraph is without detriment to subparagraph (f) above for which you have thus agreed to us contacting you for a survey, which you may consequently opt-out of by sending our Data Protection Officer notice;
- (i) by way of postal mail, electronic device to your email address(es), push information, other forms of browser-based notifications or providing other automation(such as geo-location automation) on your computers, and/or by other modes of interaction that is not the 3 DNC Modes (described below), in compliance with the PDPA. You may opt-out of this or withdraw from this at any moment by sending an email to our Data Protection Officer. For the avoidance of uncertainty, unlike (ii) under, the application of or your approval of or your consent to, this Policy, establishes your consent to this subparagraph (i); and/or
(q) to create reports with respect to our transactions with you, and/or producing statistics
including research of such Transactions for internal and/or statutory reporting and/or
(r) to record statistical data for marketing report;
(s) dealing with and/or promoting a company asset transaction or a potential company assert transaction, where such activity includes the Corporation as a participant or requires only a related corporation or associated company of the Company as a participant or requires the Company and/or anyone or more of the Business’s linked companies or affiliated businesses as the participant(s), and there may be other third party organizations who are associates in such transaction. “business asset the transaction” means the purchase, sale, lease, merger or amalgamation or any other purchase, disposal or financing of an association or a portion of an association or of any of the company, shares or assets of an organization;
(t) to reply to your customer service requests and complaints or render you with a service that you have demanded; and/or
(u) to perform and manage our information technology systems, including to store and prepare Personal Data in computer databases and servers located within plus outside Singapore. (collectively, the “Ideas”).
2.2. In order to conduct our company operations more easily, we may also be revealing the Personal Data you have presented to us to our third-party vendors, agents, our subsidiaries or associated corporations also such other third party services providers who may be qualified for implementing any of the Services (the “Third Party Service Providers”), which may be sited external of Singapore, for one or more of the above-stated Ideas. This is because such third party merchants, agents, subsidiaries or related corporations and/or Third Party Service Providers would be treating your Personal Data for one or more of the high-stated Purposes.
- 2.1. The Personal Data which we accumulate from you may be collected, used and/or revealed for the following purposes:
3. PARTICULAR ISSUES FOR THE DISCLOSURE OF PERSONAL DATA TO THIRD
3.1. We appreciate the confidentiality of the Personal Data you have rendered to us.
3.2. In that respect, we will not expose any of your Personal Data to any third parties without first receiving your express consent permitting us to do so. Though, please note that we may uncover your Personal Data to third parties without first receiving your consent in particular situations, including, without restriction, the following:
(a) cases in which the declaration is needed based on the applicable laws and/or Regulations;
(b) cases in which the idea of such declaration is clearly in your concerns, and if consent cannot be achieved in a timely way;
(c) cases in which the declaration is necessary to respond to an emergency that endangers the life, wellness or protection of yourself or another person;
(d) circumstances in which there are reasonable grounds to consider that the health or safety of yourself or another individual will be seriously harmed and consent for the declaration of the data cannot be received in a timely way, rendered that we shall, as soon as may be practical, notify you of the declaration also the purposes of the disclosure;
(e) cases in which the exposure is necessary for any investigation or proceedings;
(f) cases in which the Personal Data is exposed to any officer of a prescribed law implementation agency, upon production of written authorization signed by the head or director of that law enforcement agency or a person of a similar rank, verifying that Personal Data is essential for the purposes of the functions or duties of the officer; and/or
(g) cases in which the declaration is to a public agency also such disclosure is necessary for the public interest.
3.3. The examples listed above in paragraph 3.2 are not indicated to be exhaustive. For an an exhaustive list of exceptions, you are inspired to peruse the Second, Third plus Fourth Schedules of the PDPA which is openly available at http://statutes.agc.gov.sg.
3.4. In all other cases of revealing of Personal Data to third parties with your express consent, we will attempt to render adequate supervision over the approach and administration of your Personal Data by such third parties, as well as to render for adequate forms of security over such Personal Data.
3.5. Where Personal Data is assigned by us to any third parties outside of Singapore, we will assure that such transfers are submissive with the obligations under the PDPA. In this regard, we will take such important measures to assure that such overseas beneficiaries are bound by legally enforceable responsibilities to ensure that these overseas recipients render a standard of protection to the Personal Data so transferred that is comparable to the protection under the PDPA.
- 3.1. We appreciate the confidentiality of the Personal Data you have rendered to us.
4. APPLICATION FOR ACCESS AND/OR CORRECTION OF PERSONAL DATA
4.1. You may ask to access and/or correct the Personal Data currently in our hold at any
time by presenting your request through the subsequent methods set out under in paragraph
4.2. For an application to access Personal Data, once we have enough information from you to deal with this request, we will attempt to render you with the relevant Personal Data within 30 days.Where we are inadequate to respond to you within the said 30 days, we will inform you of the soonest achievable time within which we can render you with the information requested. The PDPA exempts specific kinds of Personal Data from being subject to your access demand.
4.3. For a request to review Personal Data, once we have enough information from you to deal with the request, we will deal with your application in compliance with the PDPA, including accurate your Personal Data within 30 days. Where we are unable to do so within the said 30 days, we will inform you of the soonest functional time within which we can make the improvement. Note that the PDPA exempts specific kinds of Personal Data from being subject to your improvement request as well as renders for the situation(s) when correction requirements are not made by us despite your request.
4.4. We may also impose you a moderate fee for the handling including the processing of your requests to obtain your Personal Data. If so, we will render you with a written estimate of the fee. Please note that we are not needed to respond to or deal with your access request except you have allowed paying the fee.
- 4.1. You may ask to access and/or correct the Personal Data currently in our hold at any time by presenting your request through the subsequent methods set out under in paragraph
5. ORDER TO WITHDRAW CONSENT
- 5.1. You may revoke your consent for the gathering, use and/or declaration of your Personal Data in our possession or under our limitation at any time by submitting your application to the contact details posted below in section 9.2.
- 5.2. We will prepare your application within a reasonable time from such a demand for withdrawal of approval being made, and will consequently refrain from obtaining, using and/or revealing your Personal Data in the manner declared in your request.
6. ADMINISTRATION AND MANAGEMENT OF PERSONAL DATA
- 6.1. We will make generous efforts to assure that your Personal Data is reliable and complete, if your Personal Data is liable to be used by us to obtain a decision that concerns you, or disclosed to another company. Though, this intends that you must also modernize us of any changes in your Personal Data that you had originally given us with. We will not be accountable for relying on incorrect or inadequate Personal Data arising from you not modernizing us of any changes in your Personal Data that you had originally rendered us among.
- 6.2. We will also take commercially feasible efforts to take suitable precautions and precautionary measures to assure that your Personal Data is appropriately preserved and secured. Relevant security organizations will be taken to limit any illegal access, gathering, use, exposure, copying, alteration, leakage, loss, damage and/or alteration of your Personal Data. Though, we cannot assume any obligation for any unlawful use of your Personal Data by third parties which are entirely attributable to circumstances beyond our Control.
- 6.3. We will also take commercially conscious efforts to assure that the Personal Data in our possession or under our control is terminated and/or anonymized as soon as it is feasible to assume that (i) the idea for which that Personal Data was obtained is no longer being obeyed by the preservation of such Personal Data; and (ii) preservation is no longer important for any other legal or business goal
- 7.1. For users of the Website, please note that the Organization may deposit “cookies” on your computer in the system to recognize you. Cookies are small data text files that are transferred from a server computer through a browsing session. Cookies are typically collected on the computer’s hard drive and are also used by web-sites to assume a continuous association to the site. Security measures have been applied to restrict unauthorized access to visitant data. Though, you recognize that the Company does not manage the transfer of data over telecommunication amenities including the Internet. Hence, we will not be accountable for any breach of security or the unauthorized revelation or use of any such data on the Internet. Not all cookies receive Personal Data and you may configure your browser to reject cookies. Though, this may mean you may not be able to take full benefit of the Services or highlights on the Website.
8. ACCOUNT REGISTRATION INFORMATION
- 8.1. Our Website includes areas where you can submit data to us (such as our registration service), and we also have highlights (such as cookies and display tracing technology) that automatically gather information from the visitants to our Website. Throughout the registration process, you must render us with a password, your name, address, also a valid email address. It is your accountability to keep your password rigorously confidential.
9. COMPLAINT PROCESS
9.1. If you have any objection or grievance regarding how we are managing your Personal
Data or about how we are complying with the PDPA, we embrace you to contact us with
your accusation or grievance.
9.2. Please reach us through one of the subsequent methods with your complaint or grievance:
(a) Singapore phone number: +65 31588341.
(b) E-mail: email@example.com. Notice it to the ‘Data Protection Officer’.
(c) Office address: 20 Collyer Quay, #09-01,Singapore 049319 Attention it to the ‘Data Protection Officer’
9.3. Where it is an email or a letter by which you are presenting a complaint, your indication at the subject header that it is a PDPA objection would support us in attending to your accusation speedily by passing it on to the appropriate staff in the Corporation to handle. For for instance, you could enter the subject header as “PDPA Complaint”.
9.4. We will absolutely strive to trade with any accusation or grievance that you may have quickly and fairly.
- 9.1. If you have any objection or grievance regarding how we are managing your Personal Data or about how we are complying with the PDPA, we embrace you to contact us with your accusation or grievance.
10. UPDATES ON DATA SECURITY POLICY
10.1. As part of our endeavors to ensure that we accurately manage, preserve also process your Personal Data, we will be evaluating our policies, procedures, and methods from time to time.
10.2. We hold the right to change the terms of this Policy at our complete discretion. Any improved Policy will be posted on our Website and can be observed at CorporateServices.com.
10.3. You are inspired to visit the above Website from time to time to assure that you are well notified of our latest policies in association with Personal Data protection.
- 10.1. As part of our endeavors to ensure that we accurately manage, preserve also process your Personal Data, we will be evaluating our policies, procedures, and methods from time to time.
11.1. Your approval that is given agreeable to this Policy is additional to and does not supersede any other approvals that you rendered to the Company with concern to the processing of your Personal Data.
11.2. For the delay of doubt, in the event that the PDPA permits a company such as us to collect, use or uncover your Personal Data externally your approval, such permission allowed by the law shall prevail to apply. Last Updated on June 19, 2020.
- 11.1. Your approval that is given agreeable to this Policy is additional to and does not supersede any other approvals that you rendered to the Company with concern to the processing of your Personal Data.