Data Protection Notice

1. Introduction

1.1. This Data Protection Notice (“Notice”) sets out the basis which Hesed Advisory LLP (or “we” or “our” or “us”), including member of our group, may collect, use, disclose or otherwise process personal data of our customers in accordance with the Personal Data Protection Act (“PDPA”).

1.2. Please refer to Appendix 1 for the list of members of our group.

1.3. This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.

1.4. By providing your personal data to us, you acknowledge and agree that you have fully read and understood this Notice, and are consenting to the collection, use, processing and disclosure of your personal data as described in this Notice.

1.5. If you provide the personal data of any other third party to us, you warrant and agree that such third party has fully read and understood this Notice and has consented to you disclosing his/her personal data to us for the collection, use and disclosure by us as described in this Notice.

2. Personal Data

2.1. Definition and Terms:

(a) Data is recorded information whether stored electronically, on cloud or any electronic device such as a computer, or in certain paper-based filing systems.

(b) Personal data means any data relating to a living individual who can be identified from that data. Personal data can be factual (such as a name, address or date of birth) or it can be an opinion (such as a performance appraisal). It can even include a simple e-mail address. It is important that the information has the data subject as its focus and affects the individual's privacy in some way.

(c) Processing is any activity that involves use of the data. It includes obtaining, recording or holding the data, or carrying out any operation or set of operations on the data including organising, amending, retrieving, using, disclosing, erasing or destroying it. Processing also includes transferring personal data to third parties.

2.2. Personal data which we may collect include but are not limited to:

(a) your personal information such as your name, NRIC/FIN/Passport number, date of birth, marital status, gender;

(b) your contact information such as postal addresses, email addresses, telephone, mobile phone and fax numbers;

(c) your past and present employment information such as organisation name, organisation type, industry sector, job function and responsibilities, designation, remuneration, business telephone and fax numbers, business email addresses;

(d) your past and present academic qualifications such as schools attended, courses of study, period of study and academic results;

(e) your professional qualifications and memberships with other professional bodies; and/or

(f) your billing and payment information, including name of the credit/debit cardholder, credit/debit card number, security code and expiry date.

2.3. Other information collected may include:

(a) professional interest and subscription preferences;

(b) training records;

(d) disciplinary or criminal records;

(e) medical certificates;

(f) proof of income and financial details;

(g) photographs, videos and/or audio recordings.

2.4. Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).

3. General

3.1. Your consent that is given pursuant to this Notice is additional to and does not supersede any other consents that you had provided to us with regard to processing of your personal data.

3.2. For the avoidance of doubt, in the event that Singapore personal data protection law permits an organisation such as us to collect, use or disclose your personal data without your consent, such permission granted by the law shall continue to apply.

3.3. Our website(s), website/IT portal(s)/mobile application(s) and other digital and telecommunication channels may contain links to other sites that are operated by third party companies with different privacy practices. You should remain alert and read the privacy statements of other sites. We have no control over personal data that you submit to or receive from these third parties.

4. Collection, Use and Disclosure of Personal Data

4.1. We collect information about you when you use our website(s), website/IT portal(s)/mobile application(s), forms, surveys, and/or other channels and throughout other interactions, communications and services you have with us.

4.2. We may collect and store certain information automatically when you visit our website(s) or use our website(s)/IT portal(s)/mobile application(s).

Examples include the internet protocol (IP) address used to connect your computer or device to the Internet, connection information such as browser type and version, your operating system and platform, a unique reference number linked to the data you enter on our system, login details, the full URL clickstream to, through and from the website(s) or website/IT portal(s)/mobile application(s) (including date and time), cookie identifier and your activity on our website(s) or website/IT portal(s)/mobile application(s), including the pages you visited, the searches you made and, if relevant, the services you purchase.

4.3. We use cookies to identify you from other users on our website(s) or website/IT portal(s)/mobile application(s).

4.3.1. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer or device.

4.3.2. You can block or deactivate cookies in your browser settings.

4.3.3. We use log-in cookies to remember you when you have logged in for a seamless experience.

4.3.4. We use session cookies to track your movements from page to page and in order to store your selected inputs, so you are not constantly asked for the same information.

4.3.5. By continuing to use our website(s) or website/IT portal(s)/mobile application(s), you are agreeing to the use of cookies on the site as outlined above. However, please note that we have no control over the cookies used by third parties.

4.3.6. For further information on types of cookies and how they work, visit www.allaboutcookies.org.

4.4. We may also collect your personal data from other sources and combine with information collected from you.

4.5. 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 goods and/or services requested by you;

(b) verifying your identity;

(d) managing your relationship with us;

(e) processing payment or credit transactions;

(f) sending you marketing information about our goods or services including notifying you of our marketing events, initiatives and promotions, lucky draws, membership and rewards schemes and other promotions;

(g) 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;

(h) any other purposes for which you have provided the information;

(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;

(j) any other incidental business purposes related to or in connection with the above; and

(k) conducting research, analysis and development activities to improve our goods and/or services.

(collectively, referred to as the “Purposes”)

4.6. We may share your information with any member of our group from time to time for one or more of the Purposes.

4.7. 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 goods or services requested by you; or

(b) to third party service providers, agents and other organisations we have engaged to perform any of the Purposes.

4.8. 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).

5. Withdrawing Your Consent

5.1. 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 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.

5.2. 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 ten (10) business days of receiving it.

5.3. 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 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 5.1. above.

5.4. 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.

6. Access to and Correction of Personal Data

6.1. You may submit your request in writing or via email to our Data Protection Officer at the contact details provided below if you wish to:

(a) make 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.

6.2. We will need enough information from you in order to ascertain your identity as well as the nature of your request, so as to be able to deal with your request.

6.3. We reserve the right, or may, charge a reasonable fee for the processing of any data access request.

6.4. We will respond to your request as soon as reasonably possible. 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).

7. Protection of Personal Data

7.1. 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.

7.2. 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.

7.3. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website(s) or website/IT portal(s)/mobile application(s), you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

8. Accuracy of Personal Data

8.1. 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.

9. Retention of Personal Data

9.1. 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.

9.2. 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.

10. Transfer of Personal Data Outside of Singapore

10.1. We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.

11. Complaint Process

11.1. If you have any complaint or grievance regarding about how we are handling your personal data or about how we are complying with the PDPA, we welcome you to contact our Data Protection Officer in writing or via email at the contact details provided below.

11.2. Where you are sending an email in which you are submitting a complaint, your indication at the subject header that it is a PDPA complaint would assist us in attending to your complaint speedily by passing it on to the relevant staff in our organisation to handle. For example, you could insert the subject header as “PDPA Complaint”.

11.3. We will certainly strive to deal with any complaint or grievance that you may have speedily and fairly.

12. Enquiries

12.1. For any enquiries on our privacy policy, please contact our Data Protection Officer in writing or via email at the contact details provided below.

13. Data Protection Officer

The Data Protection Officer
Hesed Advisory LLP
10 Anson Road
#30-01 International Plaza
Singapore 079903
Email : kwanghan@heseadadvisory.com

14. Effect of Notice and Changes to Notice

14.1. This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.

14.2. We may revise this Notice 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 Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.