Effective Date: 26 May 2023
Last updated: 26 May 2023
1. COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
1.1 Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include:
(a) when you submit an inquiry through our Website or contact us using the contact details on our Website: [your name, your company/organisation, email address and contact number] and any other information you may voluntarily provide us;
(b) when you submit a job application to us: [your name, residential address, email address, telephone number, nationality, gender, date of birth, marital status, photograph, employment information, financial information, resume], [information from third party references that you include in your application] and any other information you may voluntarily provide us;
(c) when you visit our Website with a cookies-enabled browser, use the Website and/or Services, register for an account with us, update or add information to your account and/or user profile, sign up to receive our marketing communications, and/or download the App or any of our mobile application(s) (including any updates thereto);
(d) conduct any online transactions on our Services and/or Website;
(e) subscribe to our mailing lists for email, post or phone updates or any form of marketing
(f) sign up for a Trial, purchase any of our Subscription Plans, or make other purchases through the Services and/or Website;
(g) use third party payment gateways and payment processors to make payments on our Services and/or Website (save that we do not store any credit card information);
(h) grant us permission to access your information with third parties and/or grant them permission to share your information with us; and/or
(i) click on, visit or access third party services, sites or advertisements from links available from our Services and/or Website.
1.2 We generally do not collect your personal data unless:
(a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or
(b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
1.3 We do not knowingly collect or solicit personal data from persons below the age of eighteen (18). If you are under eighteen (18) years of age, please do not attempt to use the Website, or send us any personal data about yourself.
1.4 We may collect, use, retain and process your personal data for any or all of the following purposes:
(a) performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
(b) verifying your identity;
(c) responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
(d) managing your relationship with us;
(e) complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
(f) any other purposes for which you have provided the information;
(g) assessing and making a decision about your suitability for a job position;
(h) to enforce our contractual and/or legal rights, and/or allow us to pursue available remedies or limit the damages that we may sustain;
(i) transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
(j) any other incidental business purposes related to or in connection with the above.
1.5 We may disclose your personal data:
(a) for the purposes for which you provided the information;
(b) where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods and services requested by you; or
(c) to third party service providers, agents and other organisations we have engaged to perform any of the functions with reference to the above mentioned purposes.
1.6 The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under a contract with you).
2. WITHDRAWING YOUR CONSENT
2.1 The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.
2.2 Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within five (5) business days of receiving it.
2.3 Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue assisting you, or providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 2.1 above.
2.4 Please note that the withdrawal of your consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclosure without consent is permitted or required under applicable laws.
3. ACCESS TO AND CORRECTION OF PERSONAL DATA
3.1 If you wish to make:
(a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or
(b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
3.2 Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
3.3 We will respond to your request as soon as reasonably possible. In general, our response will be within five (5) business days. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).
4. PROTECTION OF PERSONAL DATA
4.1 Smarten Spaces is ISO 27001:2013 certified. In addition, to safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures including the implementation of a well-established information security management system (ISMS). Smarten Spaces’ Information Security & Privacy measures comprise of all the processes required to ensure confidentiality, integrity and availability in implementing the information security management system (ISMS) in order to ensure information assets are handled in total compliance with relevant security and privacy requirements, to reduce chances of a security breach, to encourage staff training to achieve a positive information security and privacy culture and to comply with applicable laws and regulations pertaining to Information Security and Privacy. Smarten Spaces employs robust data protection technical measures including encryption of data both in transit & at rest, instance termination protection, data classification and so on. In addition, our cloud storage encrypts data with AES-256 by default. We use Azure’s built-in backup service in the cloud along with geo-redundant storage & backup data at rest is also encrypted using AES-256 & is FIPS 140-2 compliant. Standard Operating Procedures (SOPs) are defined as per ISMS standards and access to data is protected using role-based access control. We also employ a SIEM tool for regular logging & monitoring purposes as well as use firewall protection & anti-malware solutions for our cloud assets. Additional measures include prevention of inbound transport layer access, disabling default ports, secure VPN connectivity, IP address whitelisting, use of bastion host for remote access and so on, along with compensatory controls such as segregation of data storage for each tenant, segregation of duties, environment segregation using VPC, cloud dB security, OS hardening, IDS/IPS, IAM, firewalls, anti-malware, backups & secure storage, key rotation, log & monitor, strong passwords, MFA, threat modelling, vulnerability assessment, penetration tests and so on. In addition, Smarten Spaces has adequate organisation security measures in place including appropriate policies, procedures, controls and other measures to manage technology risk and information security & data protection requirements. Accountability for information security & data protection, including communication of responsibilities for data protection is assigned to relevant personnel. We conduct regular risk and compliance reviews and appropriate testing including threat, vulnerability and penetration tests to verify compliance with polices and industry best practices. We also conduct these tests by a qualified third-party vendor annually and all the vulnerabilities are remediated in a timely manner.
4.2 Please be aware that no security measure that we take to protect your information is absolutely guaranteed to avoid unauthorised access or use of your personal data or is impenetrable, and no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we are constantly reviewing and enhancing our information security measures.
5. ACCURACY OF PERSONAL DATA
We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.
6. RETENTION OF PERSONAL DATA
6.1 We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
6.2 We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.
7. TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
To the extent that we may need to transfer your personal data outside of Singapore, we shall do so in accordance with the Personal Data Protection Act 2012 (“PDPA“) to ensure that we provide a standard of protection to personal data so transferred that is comparable to the protection under the PDPA, including by ensuring that the recipient is either in a jurisdiction which has comparable data protection laws, or is contractually bound to protect your personal data.
8. DATA PROTECTION OFFICER
You may contact our Data Protection Team if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:
Email Address: firstname.lastname@example.org
9. GOVERNING LAW AND JURISDICTION