About this Policy
For the purposes of this Policy, “Personal Data” refers to any information, whether true or not, relating to an identified or identifiable natural person.
Our role in processing your Personal Data
Under this Policy, a “Data Controller” is an individual or entity (such as a company, public authority, agency or other body) which determines the purposes and means of the processing of your Personal Data.
A “Data Processor” is an individual or entity (such as a company, public authority, agency or other body) which processes Personal Data on behalf of the Data Controller. The terms “process” or “processing” and other similar terms have a broad meaning and include any operation concerning your Personal Data such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
We are the Data Controller of the Personal Data that we hold about you in relation to the Services and will only process the Personal Data in accordance with this Policy. We may from time to time engage third parties to facilitate the administration and provision of our Services. When engaging such third parties, we will only disclose your Personal Data where it is necessary, and provide that they work strictly in accordance with our instructions. These third parties will not use any Personal Data for their own purposes except as permitted under any applicable law. Where appropriate, we shall also ensure that the third parties have in place appropriate technical and organizational security measures to protect your Personal Data and undertake to comply with all their obligations as a Data Processor of your Personal Data
How we collect Personal Data
Depending on the nature of your interaction with us, we use different methods to collect Personal Data from and about you, including without limitation, through:
(a) Direct Interactions
We may collect your Personal Data when you engage us for and in relation to any of our Services, whether in writing, orally or through our website, and/or attend any event we participate or support (e.g. registration forms, provision of business cards, subscribe to our mailing list, and photographs, videos and/or audio recordings taken by us or our representatives at these events). We may also collect Personal Data to comply with any Services you request, to correspond with you and/or where you submit your Personal Data to us for any other reason (whether voluntary or otherwise).
(b) Automated Interactions
We may automatically collect your Personal Data when you interact with us (e.g. via the use of our website or electronic communications). For more information on cookies, please refer to Clause 10 below. Additionally, we may capture your image through photoshoot / video recordings when you participate at events we participated or supported.
(c) Third Parties
We may collect your Personal Data from third parties (e.g. vendors, business partners, regulatory authorities, your employer / colleagues, industry associations, event organisers or other organizations with whom you have dealings with) for the purposes of providing our Services, including Personal Data in publicly available sources.
What Personal Data we collect
The type and quantity of Personal Data we collect and how we use it depends on the purpose for which you provided such Personal Data. We will seek to minimise our collection to what is needed to perform each relevant function or service.
Generally, we may collect, use, process, store and transfer different kinds of Personal Data about you when you engage us for our Services, including the following:
· Identification information (including photographs, videos and audio recordings);
· Contact information;
· Business or employment information;
· Payment information;
· Information relating to the usage of our Services ; and
· Other information you may choose to provide us.
How do we use your Personal Data
We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
To the extent permitted under the PDPA, we may process your Personal Data based on consent. Such consent may be express, based on your agreement to any agreement which incorporates these terms or deemed based on the circumstances by which we interact with you. We may also process your Personal Data where permitted by any exception in the relevant schedules to the PDPA.
Notwithstanding the above and where permitted under any other applicable law, and where the GDPR applies, we will generally process your Personal Data in accordance with one or more of the followings:
(a) it is necessary for the performance of a contract with you;
(b) it is necessary in connection with a legal obligation;
(c) you have provided us with consent;
(d) it is necessary to establish, exercise or defend a legal claim;
(e) the information is available in the public domain; and/or
(f). it is necessary for our legitimate interest (or those of a third party).
The particular legitimate interest upon which we rely on includes, without limitation, the following:
(a) to perform our obligations in the course of providing our Services;
(b) to manage our relationship with you and facilitate the provision of our Services;
(c) to monitor, analyse and protect our business, including the activities of individuals who subscribes to our services;
(d) to facilitate our internal business operations;
(e) to comply with any requests from you;
(f) to comply with any legal, regulatory or professional obligation; and/or
(g) to personalize your customer experience, develop our business and/or improve on our Services.
Please note that if you choose not to provide us with your Personal Data or choose not to consent to our processing of your Personal Data, we may not be able to provide some or all of our Services to you or respond to your other requests.
These purposes may continue to apply even in situations where your relationship with us has been terminated or altered in any way. In such cases, we may still retain personal data relating to you and use or disclose such information for legal or business purposes, including for compliance with the PDPA, GDPR and/or other applicable laws.
Disclosing your Personal Data
We may disclose your Personal Data to third parties from time to time, but will only transfer such Personal Data in these circumstances where we are satisfied that it will be subject to an appropriate level of protection and in accordance with any safeguards that may be legally required. Some of these parties may include:
(a) third party service providers (e.g. event venues, IT services, data analytics, payment providers);
(b) our affiliates or partners;
(c) advertisers / sponsors; and/or
(d) regulatory or supervisory authorities.
Data Protection and Retention
(a) Protection and Security
As part of our commitment to protecting your privacy, we implement appropriate technical and organization measures to protect your Personal Data against accidental, unauthorized or unlawful use, disclosure, access, destruction, loss, change or damage. Some of the measures we have taken may include pseudonymization, encryption, limited access and robust retention policies.
Nevertheless, do note that while we will endeavor to take all reasonable measure to protect your Personal Data, you should similarly take all necessary precautions, such as implementing strong passwords, limiting access to your computer and avoiding misplacing any documents or access passes.
We keep your Personal Data only for as long as necessary to provide you with the Services, to fulfil our processing purposes, in accordance with our legal obligations and for legitimate business purposes.
The retention period for your Personal Data may vary based on the specific circumstances. Nevertheless, in determining the appropriate period to lawfully retain your Personal Data, we will consider inter alia, the:
(i) amount, nature and sensitivity of Personal Data;
(ii) purposes for which Personal Data is retained;
(iii) appropriate security measures and, if any, relevant technical constraints; and
(iv) applicable legal requirements.
Kindly note that if you request that we stop sending you marketing materials, we may keep a record of your contact details and appropriate information to enable us to comply with your request not to be contacted by us. In such instances, we will endeavor to retain only minimal Personal Data to effect the above.
Nonetheless, if you withdraw your consent (where we rely on consent as our legal basis) or object to our processing of your Personal Data, you may at any time request that we erase or delete your Personal Data. Upon receipt of such request, we shall, within a reasonable time, delete or anonymize your Personal Data unless we are legally permitted or required to retain such Personal Data (e.g. ongoing dispute, tax or obligations, accounting purposes, compliance with any legal obligations).
Transfer to other countries
In the provision of our Services, the Personal Data we collect may be transferred to and processed by third parties in other countries. In all such instances, we shall ensure that the transfer of your Personal Data is carried out in accordance with any applicable laws and that appropriate safeguards (e.g. contractual, technical and organizational measures) are put in place before such transfer takes place.
Cookies and Website
For the purposes of this Policy, a “cookie” is a small piece of information sent by a web server to a web browser, which enables the server to collect information from the browser.
If you wish not to receive cookies, kindly change your cookie setting in your browser under the “options” or “preferences” tool selection. As the process to disable cookies through your browser may vary from browser-to-browser, please visit your browser’s help menu for further information.
Please note that if you choose not to receive cookies, you may still continue to use our website, although we may not be able to provide you with the full functionality of our website.
(b) Website & mobile application
On our website, we may, from time to time, display advertisements from third parties or provide links to third party websites. In these instances, kindly note that we cannot be held responsible or liable for the privacy practices and policies of the third party. As such, please read the privacy policies of such third parties to find out how they process and collect your Personal Data.
The above also applies to TradeCards Global mobile application and its web portal version.
How to Access and Control your Personal Data
Individuals are given rights in relation to their Personal Data pursuant to the applicable law. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. Where we are Data Processors, we will assist the Data Controller as far as reasonably possible to help them respond to your requests.
For security reasons, kindly note that, in relation to certain rights, we may request for information to verify your identity before processing your request.
In general, the rights afforded to individuals are:
(a) Right to Access
The right to be informed of and request access to the Personal Data that we process about you. This will enable you to check what Personal Data we are processing and whether the processing is lawful.
(b) Right of Correction/Rectification
The right to request that we amend or update your Personal Data where it is inaccurate or incomplete. Kindly note that while we shall make a reasonable effort to ensure that the Personal Data we collect is accurate and complete, you are responsible for ensuring the accuracy of the Personal Data that you provide to us directly.
(c) Right to Withdrawn Consent
You have right to withdraw your consent at any time, where consent is the legal basis of the processing of your Personal Data. Kindly note that depending on the nature and scope of your request, we may not be in a position to continue performing our obligations in the course of or in connection with our Services to you.
For individuals covered by the GDPR, they also have the following rights (as available and subject to any applicable law):
(d) Right to Erasure
The right to request that we temporarily or permanently stop processing all or some of your Personal Data.
(e) Right to Object
The right to object to your Personal Data being processed by us for direct marketing purposes, or to, at any time, object to us processing your Personal Data on grounds relating to your particular situation
(f) Right to Data Portability
The right to request a copy of your Personal Data in electronic format and the right to transmit that Personal Data for use in another party’s service.
(g) Right not to be subject to Automated Decision-making
The right to not be subject to a decision based solely on automated decision-making where the decision would have a legal effect on you or produce a similarly significant effect.
If we send you electronic marketing messages based on your consent or as otherwise permitted by applicable law, you may, at any time, respectively withdraw such consent or declare your objection at no cost. The electronic marketing messages you receive from us will also include an “unsubscribe” option within the message itself to enable you to manage your Personal Data. Please note that if you opt-out of receiving direct marketing materials, we may still send you non-promotional messages, such as receipts or information about the Services we are providing to you.
In order to enable you to exercise these rights with ease and to record your preferences in relation to how we use your Personal Data, you may manage your privacy preferences at any time by contacting us at email@example.com
Changes to this Policy
Kindly note that from time to time, we may amend the terms of this Policy in order to respond to changes in any applicable law or where we develop or offer new Services. Where the terms of this Policy change, we will provide you with notice as appropriate under the circumstances, including by displaying the notice within our website or by sending you an email. To the extent permitted under applicable law, by engaging us for our Services after such notice, you consent to our updates to this Policy.
If you have any questions about your privacy, your privacy rights, or how to exercise them, please feel free to contact us at firstname.lastname@example.orgWe will respond to your request within a reasonable period of time upon verification of your identity (if applicable).