Our Privacy Policy

This Privacy Policy is intended to assist you to understand how we at Aspri Associates (S) Pte. Ltd. (the “Company”, “we”, “our”, “us”) collect, use, disclose and/or process any personal data that we collect from you (“Personal Data”) in compliance with the Personal Data Protection Act 2012 of the Singapore statutes (“PDPA”).

It is also intended to help you in making an informed decision before providing us with any Personal Data.

Personal Data refers to data, whether true or not, about an individual who can be identified from that data (such as a combination of: your name, contact details, date of birth, gender, identity card/passport number and e-mail address); or from that data and other information to which an organization has or is likely to have access.

Further, your access and use of our Website, the information made available there and the services we provide on our Website (the “Website”) are all subject to this Privacy Policy.

Should you, at any time, require any further information or clarification on this Privacy Policy or how we may manage, protect and/or process your Personal Data, please do not hesitate to contact our Data Protection Officer at dpo@aspri.sg.

Your acceptance of our Privacy Policy

When you provide any Personal Data to us, you are deemed to signify your acceptance of our Privacy Policy. Therefore, before you do so, please read this Privacy Policy to understand how we collect, use, disclose (including transfer), process and manage Personal Data in compliance with PDPA.

Please do not provide any Personal Data to us if you do not accept this Privacy Policy.

If you are under 18 years of age, please do not provide any Personal Data to us about yourself.

Collection, Use and Disclosure of Personal Data

Please take note that Personal Data can be collected in the many ways you may provide them to us. For instance, Personal Data may be collected by us in instances such as, but not limited to the following, namely, when you:

Browse this Website;
Register yourself on this Website for the purpose of creating an account in this Website or receiving information or downloadable brochures (including Newsletters) and marketing materials from us;
Make enquiries with us;
Place orders for our services and/or transacting with us;
Use our services;
Wish to communicate with us, whether via online, or otherwise like postal mail, telephone or by OTT messaging, or any combination of the foregoing, for purposes such as but not limited to the engagement and delivery of our services, as well as other service enquiries;
Apply for potential employment with us, or enquire about possible opportunities to work with us or collaborate;
Provide Personal Data on this Website for any other purposes as you may consent to, from time to time.

You are under no obligation to provide Personal Data, and you are entirely at liberty not to provide any Personal Data to this Website. However, should you decide not to provide Personal Data, such as your name and contact details, then we may not be able to attend to your interest or answer your queries which you may have on this Website or you may not be able to access or use certain features of this Website, if and where related Personal Data are required for such actions.

Personal information which you provide to us may be used, disclosed , and/or processed by us, for the purposes of facilitating your business requirements with us and to keep you informed of updates, changes, and developments relating to us, the scope of which may include:

Carrying out identity checks;
Deciding whether to engage in a business relationship with you;
Providing services based on your required business profileand any other services (if and where so applicable);
Administering and maintaining your account with us;
General management and reporting purposes, such as invoicing and account management;
Communicating with you on matters relating to your account with us;
Keeping clients and other contacts informed of the services we offer, industry development, services offering, seminars and other events we are holding that may be of interest to them, if they/you have separately indicated your consent;
In connection with any claims, actions or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution), and/or protecting and enforcing our contractual and legal rights and obligations;
Responding to queries or feedback from you;
Coaching employees for customer service quality assurance;
For recruitment purposes;
For purposes related to the employment of our personnel;
Notifying you about important changes to our Privacy Policy, Terms of Service and any other service delivery matters which may affect you.

In compliance with the PDPA, we will not send marketing messages to a Singapore telephone or facsimile number belonging to you unless you have given us clear and unambiguous consent to do so – as reiterated in “Other Uses”. If you have previously given us consent, we may send you marketing messages until you advise us in writing that you wish to withdraw your consent.

Other Uses

Apart from such uses as mentioned above, Personal Data may be used to:

Compile statistical information, create reports, and to conduct research (including but not limited to data analytics, surveys and/or profiling) for market analysis, and/or for the purposes of improving our product, services and facilities;
Perform due diligence checks (including know-your-client checks and anti-money laundering due diligence checks) in accordance with legal or regulatory obligations (whether Singapore or a foreign country), and risk management procedures, which we determine are applicable to us or our affiliates/associated companies;
Detect and prevent any fraud, unlawful activity, misconduct or complaints, and/or investigate into any such acts or even any suspicion thereof;
Initiate and/or pursue any form of legal redress;
Comply with orders, directions, requirements, guidelines and/or requests made or existing under any applicable laws, and/or by or from any courts, governmental, statutory or regulatory bodies, (whether of Singapore or elsewhere), with which we or our affiliates/associated companies are expected to comply;
Conduct direct marketing via email, telephone and/or other means of communication if you have separately indicated your consent to receiving such direct marketing materials;
Facilitate services from third party service providers to whom such Personal Data as may be relevant has to be disclosed for such services provided you have previously consented to such disclosure.

Exceptions to the Requirement of Consent

Notwithstanding anything to the contrary in the foregoing, the Second, Third and Fourth Schedules of the PDPA (which are publicly available at https://sso.agc.gov.sg/Act/PDPA2012) set out the exceptions that permit the collection, use and disclosure of Personal Data without your consent.

Disclosure and Transfer of Personal Data to Third Parties and/or Outside of Singapore

We do not disclose Personal Data to third parties except when required by law; when we have the individual’s consent or deemed consent; or in cases where we have engaged third parties such as data intermediaries or subcontractors specifically to assist us. Any such third parties whom we engage will be bound contractually to keep all information confidential.

We will endeavour to provide adequate protection and supervision over the handling of your Personal Data that is transferred by us to third parties.

In the event any such third party is outside of Singapore, we will take such measures to ensure that such overseas recipients are legally bound to provide a standard of protection to the Personal Data so transferred that is comparable to the protection under the PDPA.

Access, Withdrawal of Consent, and Updates

You may request access to your Personal Data collected by us, at any time, by notifying our Data Protection Officer.

Within a reasonable time upon receipt of your request for access, we will provide you with access to your Personal Data or other appropriate information on your Personal Data in accordance with the requirements of the PDPA.

Within a reasonable time upon receipt of your notification of withdrawal of consent, we will cease (and cause any of our data intermediaries and agents, if applicable, to cease) to collect, use and/or disclose your Personal Data, unless required or authorised under applicable law, in accordance with your notification.

If you believe that any information, we hold about you is incorrect, incomplete and/or outdated, please contact our Data Protection Officer.

Within a reasonable time upon receipt of your notification of any incorrect, incomplete and/or outdated information, we will correct and/or update the information in your Personal Data in accordance with the requirements of the PDPA.

We may charge a fee for requests for access to your Personal Data in accordance with the requirements of the PDPA.

You may choose to unsubscribe from our mailing lists or registrations, or elect not to receive further marketing information from us by contacting our Data Protection Officer. Where applicable, you may also “unsubscribe” from receiving automated e-mails from us by using the “unsubscribe” function provided.

Security and Management of Personal Data

We have implemented generally accepted standards of technology and operational security to protect the Personal Data that we collect. We will take appropriate security measures to protect such Personal Data from any unauthorised access, modification, use or disclosure, and from any other similar risks. However, we shall not be responsible or liable for any such unauthorised access, modification, use (such as the collection or copying of Personal Data), or disclosure of Personal Data by third parties where such acts are attributable to factors beyond our control.

Whilst we will make reasonable efforts to ensure that the Personal Data you provide are collected and recorded faithfully, accurately and without modification, we will not be responsible for the accuracy, truthfulness, and completeness of the Personal Data which you provide. In the event of any changes or inaccurate details, you must update us accordingly.

Retention of Personal Data

We will cease to retain Personal Data as soon as it is reasonable to assume that the purpose of collection of such Personal Data is no longer being served by such retention, and such retention is no longer necessary for legal or business purposes.

Further to the above, we will make reasonable efforts to destroy such Personal Data that have become redundant.

Data Protection Officer

We have appointed a Data Protection Officer who can be reached via e-mail at dpo@aspri.sg.

In the event you have any queries, complaints or grievance regarding our collection, handling, use or disclosure of Personal Data, or should you wish to withdraw your consent with respect thereto, you may contact our Data Protection Officer.

Browser Data and Cookies

We automatically collect information sent by your computer when you browse our Website. This information includes your browser type, IP address and the pages you visit. This information may be collected for analysis and evaluation for us to improve our Website. This information will not be used in association with your personal information.

We may use “cookies” to store and track information about you when you use this Website. Cookies are small data text files that are sent to your browser to track information such as the number of users and their frequency of use, profiles of users and their usage.

You can choose to accept or decline cookies. While web browsers automatically accept cookies, you can usually modify your browser setting to decline cookies. Declining cookies, however, may prevent you from taking full advantage of the features or services available on this Website.

Updates on our Privacy Policy

We reserve our right to review and make changes to our Privacy Policy from time to time, at our absolute discretion. The most current version of the Privacy Policy will govern our collection, use, and disclosure of Personal Data. Any such changes to this Privacy Policy will be posted on this Website. Your continued use of our Website or services constitutes your agreement to this Privacy Policy and any future updates thereon. You are encouraged to visit this Privacy Policy regularly.

General

Your consent that is given pursuant to this Policy is additional to and does not supersede any other consents that you provided to the Company with regard to processing of your Personal Data.

In the event that the PDPA permits us to collect, use or disclose your Personal Data without your consent, such permission granted by law shall continue to apply.

Last updated on 3 August 2020