Personal Data Protection Policy
We are committed to protecting your Personal Data. The purpose of this Personal Data Protection Policy (“Policy”) is to inform you of how we manage Personal Data in compliance with the Personal Data Protection Act in Singapore (“PDPA”). This Policy applies to Surbana Jurong Private Limited and its subsidiaries (collectively, “Surbana Jurong”, “we”, “us” or “our”).
By submitting information to us, engaging our services or otherwise interacting with us, you agree and consent to us collecting, using and disclosing your Personal Data in accordance with the terms of this Policy. This Policy supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your Personal Data, and your consents herein are additional to any rights which we may have at law to collect, use and disclose your Personal Data.
In this 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.
1. How We Collect Personal Data
1.1 Generally, we may collect Personal Data in various ways including:
(a) in the course of your engaging our products or services, or your providing documentation or information to us;
(b) when you communicate or interact with us via telephone calls (which may be recorded), letters, fax, face-to-face meetings, our websites, email or other modes of contact;
(c) when you visit our websites;
(d) when you contact us or request that we contact you;
(e) when you respond to our request for additional Personal Data;
(f) when you respond to our initiatives or market research or surveys;
(g) CCTV recordings while you are within our premises;
(h) when you participate in events organised by us;
(i) when you request that you be included in an email or other mailing list, alerts or newsletters;
(j) when you submit application for employment or any other appointment with us (including scholarships and attachments) or provide documents or information to us such as your resume, including from recruitment agencies and employment references;
(k) in the course of conducting interviews;
(l) from public information sources, search services and other third parties; and
(m) when you submit your Personal Data to us for any other reason.
1.2 If you provide third party Personal Data to us such as the Personal Data of your family members, by doing so, you confirm and represent that you have obtained their respective consents to the collection, use and disclosure of their Personal Data on these terms.
2. Purposes for which We Collect, Use and Disclose Personal Data
2.1 Generally, the purposes for which we collect, use and disclose Personal Data include:
(a) to provide you with our products or services or provide customer support;
(b) to verify your identity and conduct background checks;
(c) to help us manage the delivery of and improve our products and services, including conducting market research or surveys, performing market analysis and identifying customer needs, and developing new products and services;
(d) to compile, manage and track profile of our clients and vendors in our database;
(e) to communicate or interact with you and to handle and respond to your queries and requests;
(f) to contact you or provide you with information about our products and services or in relation to matters concerning Surbana Jurong or which we believe may be of interest to you, including sending you alerts, newsletters and marketing materials;
(g) to handle claims and disputes, conduct and facilitate investigations and proceedings, and to protect and enforce our contractual and legal rights and obligations;
(h) to prevent, detect and investigate crime, including fraud and money-laundering, and to analyze and manage other commercial risks;
(i) to manage the administrative and business operations of Surbana Jurong and to comply with internal policies and procedures;
(j) to facilitate business asset transactions, including merger, acquisition or asset sale, involving Surbana Jurong;
(k) to facilitate attendance at events organised by us or that which we are involved in;
(l) to comply with applicable laws and regulations, rules, codes of practice or guidelines, or to assist in law enforcement by relevant authorities;
(m) to manage the security of our premises, facilities and technology infrastructure, including carrying out CCTV surveillance and conducting security clearances; and/or
(n) any other purpose relating to any of the above.
2.2 In addition, if you are seeking employment or any other appointment with us (including scholarships and attachments) or are an existing employee with us, the purposes for which we collect, use and disclose your Personal Data include:
(a) to evaluate, administer and process your application and suitability;
(b) to conduct background checks, verify your credentials and qualifications, and obtain references;
(c) to manage our talent pool, including compiling and maintaining information database on job/scholarship/attachment applicants and existing employees with us;
(d) to manage or terminate your employment relationship with us;
(e) to facilitate the business operations of Surbana Jurong, including compiling and maintaining an employee resume/CV database for purposes of project tender submissions and providing products and services to clients;
(f) to organize staff training and development programs;
(g) to assess and evaluate your performance;
(h) to administer benefits and payroll processing;
(i) to provide you with tools and/or facilities to enable or facilitate the performance of your duties;
(j) to communicate with you to comply with our policies and processes, including for business continuity purposes, compiling and publishing internal directories and contact lists;
(k) to conduct analysis and survey for human resource planning and management; and/or
(l) any other purpose relating to any of the above.
2.3 In relation to particular products and services or in your interactions with us, 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.
3. Disclosing your Personal Data
3.1 Personal Data may be disclosed to:
(a) entities within the Surbana Jurong group or related companies and affiliates of Surbana Jurong;
(b) our joint venture or alliance partners;
(c) our clients, vendors, sub-contractors and business partners;
(d) agents, contractors, third party service providers and specialist advisers who provide operational, administrative, financial, research or other services, such as courier services, telecommunications, information technology, payment, payroll, processing, training, event organizing, market research, storage, archival, client support services;
(e) our professional advisers such as our lawyers and auditors;
(f) insurers or insurance investigators and credit providers;
(g) any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions, including merger, acquisition or asset sale, involving Surbana Jurong;
(h) any relevant authorities, including regulatory bodies and/or law enforcement agencies, whether local or overseas;
(i) to the extent necessary to comply with any laws, regulations, rules, directions, guidelines and other similar requirements;
(j) anyone to whom we transfer or may transfer our rights and obligations; and
(k) any other party as may be consented to by you.
3.2 If you engage us for any work outside of Singapore or use our products and services outside of Singapore, you further acknowledge and agree that your Personal Data may be transferred outside of Singapore for those work, products or services to be provided, and you consent to our so transferring your Personal Data outside Singapore. If you are a job/scholarship/attachment applicant or existing employee with us, you further acknowledge and agree that your Personal Data may be transferred outside of Singapore via our information database for purposes of managing our talent pool, and you consent to our so transferring your Personal Data outside Singapore. If you are an existing employee with us or with our vendor/sub-contractor/business partner, you further acknowledge and agree that your Personal Data may be transferred outside of Singapore to our overseas clients for purposes of providing our products and services to such clients, and you consent to our so transferring your Personal Data outside Singapore.
3.3 We require that parties to whom we disclose Personal Data implement adequate levels of protection in order to protect Personal Data, and to only process Personal Data strictly for our intended purpose.
4.1 A “cookie” is a small amount of data transferred to your browser and read by the web server that placed it there. It works as a sort of identification card, recording your preferences and previously entered information. By using cookies, the information you previously provided can be retrieved on your next visit to the website so that your navigation time is reduced and your use of the website is simplified. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie. Web beacons may be used to deliver the cookie and to compile the statistics about our website, such as how many people visited a particular page or clicked on certain links.
4.3 You can set your browser to decline cookies if you prefer. If you do so, you may not be able to get the benefit of some of the features of this website or other Surbana Jurong websites that you visit.
5. Data Protection and Security
5.1 At Surbana Jurong, protecting your Personal Data is a priority. We have appointed Data Protection Officers to oversee our management of Personal Data in accordance with the PDPA and we regard breaches of the PDPA very seriously. To prevent unauthorised access, maintain data accuracy and ensure the correct use of the Personal Data collected by us, we have put in place appropriate physical, electronic, and work flow procedures to safeguard and secure the information.
5.2 However, you will appreciate that it is not for us to perfectly secure your Personal Data from cyber attacks, such as hacking, spyware and viruses. Accordingly, you will not hold us liable for any unauthorized disclosure, loss or destruction of your Personal Data arising from such risks.
5.3 We will also cease to retain your Personal Data when the purpose for which the Personal Data was collected is no longer being served by retention and retention is no longer necessary for legal or business purposes.
6. Keeping Your Personal Data Accurate and Up-To-Date
6.1 We endeavour to ensure that the Personal Data we have about you is accurate and up-to-date. We realise that Personal Data changes frequently with changes of address and other personal circumstances. We encourage you to contact us as soon as possible to enable us to update any Personal Data we have about you.
7. Withdrawal of Consent, Access and Correction of your Personal Data, and Contacting Us
7.1 If you:
(a) have any questions or feedback relating to your Personal Data or our Policy;
(b) would like to withdraw your consent to any collection, use or disclosure of your Personal Data as set out in this Policy; or
(c) would like to obtain access or make corrections to your Personal Data,
please contact our Data Protection Officers, as follows:
Email: [email protected]
Telephone: +65-6248 1288
Address: 168, Jalan Bukit Merah, #01-01, Connection One, Singapore 150168
8. Updates to this Policy
8.1 This Policy will be reviewed from time to time to take into account new laws and technology, changes to our operations and practices and the changing business environment. If you are unsure whether you are reading the most current version, please contact us.