Last updated: 29 August 2019
This Data Protection Privacy Statement (“Privacy Statement”) sets out the basis which Jordans Group (hereinafter “we”, “us”, or “our”) may collect, use, disclose or otherwise process your personal data in accordance with the Personal Data Protection Act 2012 (“PDPA”). This Privacy Statement applies to personal data in our possession or under our control, including personal data in the possession of organizations which we have engaged to collect, use, disclose or process personal data for our purposes.
When you visit our websites or request a service from any entity within Jordans Group, your use or continued use of our services shall be deemed as your acceptance and agreement to be bound by the provision of this Privacy Statement
For the purposes of the Act, we are a data intermediary when we process personal data on behalf of and for the purposes of another organisation. At the same time, we also collect, use and disclose personal data for purposes that are reasonable and appropriate.
This Privacy Statement forms part of the terms and conditions, if any, governing your specific relationship with any entity within Jordans Group and should be read in conjunction with such terms of engagement. In the event of any conflict or inconsistency between the provisions of this Privacy Statement and the terms of engagement, the terms of engagement shall prevail to the fullest extent permissible by law.
This Privacy Statement applies to the companies within Jordans Group except as otherwise specified with special arrangement with client.
1. As used in this Privacy Statement:
a. “customer” means an individual who (i) has contacted us through any means to find out more about any services we provide, or (ii) may, or has, entered into a contract with us for the supply of any goods or services by us; and
b. “personal data” means data, whether true or not, about a customer who can be identified: (i) from that data; or (ii) from that data and other information to which we have or are likely to have access.
c. “Jordans Group” refers to the following companies within the group of affiliated companies:
i. K.C. Chan & Co PAC
ii. Accountancy Hub
iii. Jordans Management Pte. Ltd.
iv. Jordans Business Pte. Ltd.
v. XBRL Services Pte. Ltd.
vi. Jordans Corporate Pte. Ltd
vii. AG Corporate Pte. Ltd.
viii. Waterwell1 Pte. Ltd.
ix. Jordans Info Pte. Ltd.
x. Jordans Insolvency Unit Pte. Ltd.
2. Some examples of personal data which we may collect from you include:
a. Your name and identification information such as your NRIC number;
b. Contact information such as your address, email address or telephone number;
c. nationality, gender, date of birth, marital status, photographs and other audio-visual information, employment information and financial information such as credit card numbers, debit card numbers or bank account information;
d. Investment information such as such as rented properties.
3. Other terms used in this Privacy Statement shall have the meanings given to them in the PDPA (where the context so permits).
COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
4. 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).
5. We may collect and use 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 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. processing payment or credit transactions;
f. 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;
g. transmitting to any unaffiliated third parties including our third-party service providers and agents, whether in Singapore or abroad, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
h. any other incidental business purposes related to or in connection with the above.
6. We may disclose your personal data:
a. where such disclosure is required for performing obligations in the course of or in connection with our provision of the services requested by you; or
b. to third party service providers, agents and other organisations we have engaged to perform any of the functions listed in clause 5 above for us (who may in turn disclose such data to their agents, employees or other third parties with our prior written consent).
7. 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 any contract with you).
WITHDRAWING YOUR CONSENT
8. 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 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.
9. 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 ten (10) business days of receiving it.
10. 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 providing our 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 8 above.
11. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
PROTECTION OF PERSONAL DATA
12. 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 such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis.
13. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
ACCURACY OF PERSONAL DATA
14. 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.
15. We may, upon written request, allow you to view stored personal information subject to legal requirements. We reserve the right to charge a reasonable administrative fee for this service. We will respond to such request within 30 days of receipt of your written request.
RETENTION OF PERSONAL DATA
16. 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 and 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.
TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
18. To fulfil the purposes for which your personal data has been collected, we have adopted a cloud-based solution that will store and analyse the personal data provided by you (or your authorised representative). The personal data as stored in the cloud-based solution may be accessed by our third-party service providers and agents, whether overseas or in Singapore. We shall ensure that the third-party service providers and agents are legally bound to provide a standard of protection that is at least comparable to that provided under the PDPA for your personal data in the overseas countries and territories that your personal data will be transferred to and shall require such third-party service providers and agents to impose similar obligations of protection on such third parties they deal with.
19. If we process personal data on your behalf and for your purposes as a data intermediary, we shall:
a. Observe the relevant obligations under the Act in the performance of our services
b. Process the personal data we receive from you only to the extent necessary for the purposes specified in the engagement and in accordance with your instructions from time to time given in writing and shall not process the personal data for any other purpose;
c. Ensure that access to the personal data is limited to employees who need to access to perform the services under the engagement.
d. In order to perform the services, we may share the personal data with our affiliates, whether in Singapore or elsewhere. When doing so, we will require them to ensure that the personal data are kept secure and confidential;
e. Use reasonable degree of professional care to prevent unauthorised use, dissemination or disclosure of personal data, and shall implement any generally applicable physical, technical and administrative measures to protect the personal data from accidental or unauthorized disclosure, alteration, loss or destruction;
f. Notify you promptly if we become aware of any accidental or unauthorised disclosure, alteration, destruction or loss of personal data unless prohibited from doing so by law
g. Take reasonable action within reasonable time, and investigate the security incident, and use its best efforts to mitigate the impact and scope of any security incident, and to carry out such recovery or other action we determined necessary in the circumstance to remedy the security incident; and
h. Not hold personal data any longer than required by law for the purpose of performing or having performed the services for legal or business purposes
20. In the same regard, if we process personal data on your behalf and for your purposes, you;
a. Will provide us with specific written instructions with regard to the processing of personal data. Oral instructions given by your authorised representatives will be accepted by us in case of emergency only and subject to immediate written confirmation
b. Undertake and warrant that you have lawfully obtained personal data of your employees and have sufficient legal grounds, including all necessary authorizations, consents or permissions to provide us with the personal data, and that the same are accurate and provided in any form, to us in a secured way;
c. Will inform us immediately in writing of any change, including any error or omission, with regard to the lawful processing and use of any of the personal data; and
d. Will inform us as soon as reasonably possible of any access request, request for correction or blocking or deletion of personal data or any objection made by the employees related to the processing of their personal data.
DATA PROTECTION OFFICER
21. You may contact our Data Protection Officer 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:
Data Protection Officer
105 Cecil Street #15-00 The Octagon
Tel: 6324 7718/20
If your personal data was provided to us by a third party, kindly contact that organisation to make such request or query on your behalf.
EFFECT OF PRIVACY STATEMENT AND CHANGES TO PRIVACY STATEMENT
22. This Privacy Statement applies in conjunction with any other notice, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
23. We may revise this Privacy Statement from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Privacy Statement was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.