ASSURITY TRUSTED SOLUTIONS’ DATA PROTECTION POLICY
The purpose of this document (“Data Protection Policy”) is to inform you of how ATS manages Personal Data which is subject to the Personal Data Protection Act 2012 (the “Act”). Please take a moment to read this Data Protection Policy so that you know and understand the purposes for which we collect, use, and disclose your Personal Data.
Please note that this Data Protection Policy does not govern the collection, use, and disclosure of information by companies and/or entities that we do not control, nor by individuals not employed or managed by us.
By submitting information to us, or signing up for any of our products and/or services offered by us, you agree and consent to ATS and its representatives/agents (collectively referred to herein as “we” or “us” or “our”) collecting, using, disclosing and sharing your Personal Data, and disclosing such Personal Data to ATS’ authorised service providers and relevant third parties for the purposes and in the manner set forth in this Data Protection Policy.
- Personal Data
- Collection of Personal Data
- Purposes for the Collection, Use, and Disclosure of your Personal Data
- Protection & Disclosure of Personal Data
- Contacting Us – Withdrawal of Consent, Access to and Correction of Personal Data
- Retention of Personal Data
- Transfer of Personal Data
- Governing Law
1.1 In this Data Protection Policy, “Personal Data” means any data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which we have or are likely to have access, including data in our records as may be updated from time to time.
1.2 Examples of such Personal Data may include your name, NRIC, passport or other identification number, telephone number(s), email address, residential address, network data, and any other information relating to you or any individuals.
2.1 Generally, ATS collects Personal Data in the following ways:
(a) when you (“User”) submit an application to use ATS’ services;
(b) when you interact with our customer service officers/OneKey helpdesk - for example via telephone calls, email, letters, face-to-face meetings etc.;
(c) when you use ATS’ services;
(d) when you respond to any request from us for your Personal Data;
(e) when you are contacted by, and respond to our customer service officers;
(f) when you submit your Personal Data to us for any other reasons.
2.2 When you browse our website, we do not capture Personal Data that allows us to identify you individually.
2.3 If you provide us with any Personal Data relating to any third-party individual (e.g. information of your spouse, children, parents etc.), by submitting such information to us, you represent to us that you have obtained the consent of the relevant third-party to such collection, use and disclosure by ATS.
2.4 You should ensure, and you represent and warrant to us that all Personal Data submitted to us is complete, accurate, true, and correct. Failure on your part to do so may result in our inability to provide you with the products/services you have requested.
3.1 In General, we use and disclose your Personal Data for the following purposes:
(a) providing you with the products/services you have requested/subscribed to;
(b) responding to your queries and/or requests;
(c) matching any Personal Data held which relates to you in provision of the services;
(d) resolving complaints and handling requests and enquiries;
(e) legal purposes (including but not limited to obtaining legal advice and dispute resolution);
(f) conducting investigations;
(g) meeting or complying with any order or request of any court or government;
(h) meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on us (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies and conducting audit checks, due diligence and investigations);
(i) generating internal reports (including but not limited to annual, operational and management reports);
(j) analyzing your use of our products and/or services so as to help us improve, review, develop and efficiently manage the products/services offered to you; and
(k) purposes which are reasonably related to the aforesaid.
3.2 If you choose to make an application or send us an e-mail for which you provide us with Personal Data, we may share the necessary data with Government agencies, so as to serve you in a most efficient and effective way, unless such sharing or disclosure is prohibited by legislation. We will not share your Personal Data with non-Government entities except where such entities have been authorised to carry out specific Government services.
3.3 We may also display to you data you had previously supplied to us or Government agencies. This will speed up the transaction and save you the trouble of repeat submissions. Should any Personal Data be out-of-date, please supply us with the latest data. We will retain your Personal Data only as necessary for the effective delivery of services to you.
4.1 The security of your Personal Data is important to us, and ATS takes all reasonable steps to safeguard your Personal Data. All electronic storage and transmission of Personal Data is secured with appropriate security technology.
4.2 ATS maintains security arrangements in respect of Personal Data to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks. However, ATS cannot guarantee the security of information transmitted over the internet is impenetrable. ATS implements technical and organizational measures in accordance with good industry practices such as encryption, alphanumeric passwords, and user controls customizable by you. You are solely responsible for keeping all passwords confidential and configuring the appropriate access control settings.
4.3 Subject to the provisions of any applicable law, your Personal Data may be disclosed to the following recipients, who may then use and disclose your Personal Data for the purposes listed under paragraph 3.1(a) to (k) where applicable:
(a) agents, contractors or third party service providers who provide operational services to ATS and/or us including but not limited to courier services, telecommunications, information technology, technical services, payment, call centre, security, or other services to ATS;
(b) service providers to facilitate their provision of content or services to you, or for interconnection, inter-operability, system operation and maintenance and billing between service providers.
5.1 If you:
(a) have any questions or feedback relating to your Personal Data;
(b) would like to withdraw your consent to any use of your Personal Data as set out in this Data Protection Policy; or
(c) would like to obtain access and make corrections to your Personal Data Records, please contact us at the following:
Write in: Data Protection Officer
Assurity Trusted Solutions Pte Ltd
460 Alexandra Road
#28-04 PSA Building
5.2 Please note that if your Personal Data has been provided to us by a third party, you should contact that organisation or individual to make such queries, complaints, and access and correction requests to ATS on your behalf.
5.3 If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, ATS may not be in a position to continue to provide any products and /or services to you, administer any contractual relationship in place, which in turn may also result in the termination of any agreements with ATS, and your being in breach of your contractual obligations or undertakings. ATS’ legal rights and remedies in such event are expressly reserved.
6.1 We will cease to retain personal data, as soon as it is reasonable to assume that the purpose for 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.
7.1 Your personal data may be accessed by or transferred to our servers anywhere in the world, as is necessary to facilitate the provision of Services to you. Your personal data may also be accessed by or transferred to our affiliates, data processors and/or intermediaries, or subcontractors for the purposes of providing you with the Services. When transferring personal data outside of your jurisdiction, we will take reasonable steps to ensure that the privacy and security of your personal data is accorded a standard of protection comparable to the protection under your local data protection laws. By providing us with personal data, you consent to such transfer and/or access.
8.1 This Data Protection Policy and your use of our website shall be governed in all respects by the laws of the Republic of Singapore.