Your personal information is important to us and it is our policy to respect and protect your personal information.
1.What personal information do we collect about you?
Personal information is any information that can be used to identify you or that we can link to you and which we have in our possession or control.
The types of personal information that we collect about you, directly or indirectly, typically include: your name, contact details, your employer or organisation that you represent and certain details related to your employment, e.g. your job designation and work related contact details.
We collect or receive personal information in a few different ways:
Information you provide to us: We collect personal information from your interactions with us via the Platform (for example, when you register as a user, when you communicate with us or other parties on our Platform or where you have consented to our Customer providing such information to us) or personal information that you otherwise give to us (for example, when you email us or contact us via other channels). Often, you choose what personal information to provide to us, but sometimes we require certain information in order for you to use, and for us to provide you and/or the organisation you represent with, the Platform and our services.
Information we obtain from other sources: From time to time, we may also collect or receive information about you from third party sources such as publicly available databases, credit reference agencies and other lawful sources. We may collect this information to assist us in providing, evaluating and improving our Platform, products and services, or to help us comply with legal and compliance requirements including but not limited to compliance with anti-money laundering and sanctions regulations. We will only collect information from third party sources where these third parties have represented that you gave your consent to disclose your personal information with us or that they are otherwise legally permitted or required to disclose your personal information to us.
Information collected automatically through your use of our Platform: We will also collect information on an automated basis when you use our Platform or our services. We log usage data when you visit or otherwise use our Platform. Specifically, the information we collect automatically may include information like internet protocol (“IP”) address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location) and other technical information. We may also collect information about how your device has interacted with our Platform, including the pages accessed and links clicked.
We may also collect precise geolocation data pertaining to your device, if you have consented to providing this to us through your device settings. We may use this information to provide, promote, and improve our services (for example, understanding the country you reside in) and for related reasons, such as sanctions, fraud prevention and security purposes. Please note that if you do not consent to providing your geolocation data, certain features of the Platform may not work.
The information we collect automatically enables us to better understand the visitors who come to our Platform, where they come from, and what content on our Platform is of interest to them. This enables us to improve the quality and relevance of our Platform to our visitors.
The links listed below provide more information about what cookies are installed, how to allow, block or remove installation from your computer. Depending on which browser you use, the user may follow these links:
In addition to collecting and processing personal information, the following types of data about your use of the Platform and/or your use of our services, may also be collected for the following purposes:
- metadata (ancillary usage data, e.g. IP address) may be used for providing services and related internal or regulatory compliance uses, such as the provision of service performance statistics);
- anonymised data and anonymised aggregated data (anonymised data aggregated with anonymised data from other service provider users) may be used for providing, maintaining and supporting the service provider services, compiling statistical reports, performance tracking, transaction categorisation and merchant identification services.
2.How do we use your personal information?
We rely on one or more of the following lawful grounds to collect, use, process and disclose your personal information:
- Purposes of collection: We may use your personal information for the purposes described in this Policy or of which you have otherwise been notified of.
- Consent: We may use your personal information for the purposes you have consented to.
- Performance of a contract: We may need to collect and use your personal information to fulfil the contract between us and our Customer for the services requested and/or to perform our obligations under such contract.
- Compliance with law or regulation: We may use your personal information as necessary to comply with applicable law/regulation.
We may collect, use, process and disclose your personal information for the following purposes (and subject to your further consent if required by applicable law):
- providing you and/or the organisation you represent with products and services as subscribed to or requested by you, including products and services provided by our affiliates, joint venture partners, business alliance partners, Customers, and other relevant third party providers
- processing applications for products and services and completing instructions or requests;
- providing customer service, customer support and technical support, including in relation to product updates;
- market research and surveys with the aim of improving our products and services;
- marketing, business development and promotional purposes;
- for our legitimate business interests, such as undertaking business research and analysis, managing our operation of the Platform and our business;
- investigating any complaints or queries you may have;
- to comply with and monitor compliance with applicable laws and regulations, including without limitation laws and regulations relating to anti-money laundering, anti-bribery and trade sanctions), voluntary codes, internal policies (including that of our affiliates’), contractual obligations (including between us and our affiliates) and other requirements;
- preventing and responding to actual or potential fraud or illegal activities;
- To seek professional advice, including in connection with any legal proceedings (including any prospective legal proceedings), for obtaining legal advice or for establishing, exercising or defending our legal rights;
- where you have applied for a position with us, to review and process your job application.
We may also record or monitor your use of our Platform and services for our business purposes which may include analysis of usage, measurement of site performance and generation of reports.
We may also collate, process and share any statistics based on an aggregation of information held by us provided that any individual is not identified from the resulting analysis and the collation, processing and dissemination of such information is permitted by law.
3.How do we share your information with third parties?
Depending on the purpose of processing your personal information, personal information may be disclosed to:
- our affiliates anywhere in the world, including any officer, employee, agent or director of any affiliate;
- our professional advisers and other service providers in order to provide administrative, financial, legal, accounting, information technology, authentication, research or other services;
- anyone authorised by you or the employer or organisation you represent, as specified by you or the employer or organisation you represent or in any contract with you or the employer or organisation you represent;
- any person to whom disclosure is required or permitted under applicable laws or regulations;
- anyone we consider necessary to facilitate requests for services or applications for products in relation to the Workspace you access; and
- anyone we consider necessary in order to provide services in connection with a product or service, including our Customer and their nominated Users.
4.Keeping your data secure
The security of your personal information is important to us. We use appropriate technical and organisational measures to protect the personal information that we collect and process about you, designed to provide a level of security appropriate to the risk of processing your personal information. While we monitor our systems for possible vulnerabilities and attacks, we cannot guarantee 100% security of any information that you send us. Accordingly, you will not hold us liable for any unauthorised disclosure, loss or destruction of your personal information arising from such risks.
When using external service providers, we require that they adhere to security standards mandated by us. We may do this through contractual provisions, including any required by relevant privacy regulators, and oversight of the service provider.
Personal information may be transferred to, or stored at, locations outside of Singapore or the place of original data collection. In all cases, however, any transfer of your personal information to another location will be compliant with applicable data protection law. Regardless of where personal information is transferred, we will take steps to ensure that appropriate technical and organisational measures are put in place to protect your personal information.
We retain your personal information in line with our legal and regulatory obligations and for business and operational purposes. The period of retention will vary in accordance with the data type, the purpose for which are processing your personal information and our legal obligations. Subject to applicable law, we will cease to retain your personal information when we no longer require such personal information for the purposes we originally notified you of or for any business or legal needs.
You may have a variety of data protection rights, depending on your geographical location and applicable law. These rights may include:
- the right to request access to the personal information we hold about you (please note that there may be circumstances in which we are entitled to refuse requests for access to copies of personal information);
- the right to request that we correct or update your personal information if it is inaccurate or incomplete;
- the right to request withdrawal of consent to process your personal information (please note that in certain circumstances it may be lawful for us to continue processing without your consent).
You can exercise your rights by contacting the Data Protection Officer using the contact details set out below.
7.Updates to this Policy
8.Third party websites and services
You may contact us by writing to our Data Protection Officer at firstname.lastname@example.org.