Hesed Advisory Web

Data Protection Notice

1. Introduction

1.1. This Data Protection Notice ("Notice") sets out the basis which Hesed Advisory LLP (or "we", "our" or "us"), including members 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 consent 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.

2. Personal Data

2.1 Definition and Terms
  1. Data is recorded information whether stored electronically, on cloud or any electronic device such as a computer, or in certain paper-based filing systems.
  2. Personal data means any data relating to a living individual who can be identified from that data.
  3. Processing is any activity that involves use of the data, including obtaining, recording, holding, organising, amending, retrieving, using, disclosing, erasing or destroying data.
2.2 Personal data which we may collect include but are not limited to:
  1. Your personal information such as your name, NRIC/FIN/Passport number, date of birth, marital status and gender.
  2. Your contact information such as postal addresses, email addresses, telephone, mobile phone and fax numbers.
  3. Your employment information such as organisation name, industry sector, job function, responsibilities, designation and remuneration.
  4. Your academic qualifications such as schools attended, courses of study and academic results.
  5. Your professional qualifications and memberships with professional bodies.
  6. Your billing and payment information.
2.3 Other information collected may include:
  1. Professional interest and subscription preferences.
  2. Training records.
  3. Details of complaints.
  4. Disciplinary or criminal records.
  5. Medical certificates.
  6. Proof of income and financial details.
  7. Photographs, videos and/or audio recordings.

3. General

Your consent given pursuant to this Notice is additional to and does not supersede any other consents that you have provided to us.

In circumstances where Singapore personal data protection law permits an organisation to collect, use or disclose personal data without consent, such permission shall continue to apply.

Our websites, portals, applications and digital channels may contain links to third-party websites with different privacy practices. We recommend reviewing their privacy statements.

4. Collection, Use and Disclosure of Personal Data

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.

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

Examples include the internet protocol (IP) address used to connect your computer or device to the Internet, browser type and version, operating system and platform, URL clickstream information, cookie identifier, and activity on our website(s), including pages visited and searches made.

4.3 Cookies

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

  1. A cookie is a small file of letters and numbers stored on your browser or the hard drive of your computer or device.
  2. You can block or deactivate cookies through your browser settings.
  3. We use login cookies to remember you when you have logged in for a seamless experience.
  4. We use session cookies to track your movements from page to page and store your selected inputs.
  5. By continuing to use our website(s), you agree to the use of cookies as described. We do not control cookies used by third parties.
  6. For further information on cookies, please refer to relevant cookie information resources.

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

4.5 Purposes of Collection, Use and Disclosure

We may collect and use your personal data for any or all of the following purposes:

  1. Performing obligations in connection with our provision of goods and/or services requested by you.
  2. Verifying your identity.
  3. Responding to and processing queries, requests, applications, complaints and feedback.
  4. Managing our relationship with you.
  5. Processing payment or credit transactions.
  6. Sending marketing information about our goods or services.
  7. Complying with applicable laws, regulations, codes of practice, guidelines, rules or assisting authorities.
  8. Any other purposes for which you have provided the information.
  9. Transmitting information to third party service providers, agents and relevant authorities.
  10. Other incidental business purposes related to the above.
  11. Conducting research, analysis and development activities to improve our goods and/or services.

We may share your information with members of our group for one or more of these purposes.

We may disclose your personal data where such disclosure is required for providing requested services or to third-party service providers, agents and organisations engaged by us.

The purposes listed above may continue to apply even after your relationship with us has ended, for a reasonable period thereafter.

5. Withdrawing Your Consent

Your consent for the collection, use and disclosure of your personal data remains valid until withdrawn by you in writing.

You may withdraw your consent and request that we stop using or disclosing your personal data by submitting a written request or contacting our Data Protection Officer.

Upon receiving your request, we may require reasonable time depending on the complexity of the request and its impact on our relationship with you.

We will generally seek to process your request within ten (10) business days.

Depending on the nature and scope of your request, we may not be able to continue providing certain goods or services to you.

Withdrawal of consent does not affect our right to continue collecting, using or disclosing personal data where permitted or required under applicable laws.

6. Access to and Correction of Personal Data

You may submit a written request or email our Data Protection Officer if you wish to:

  1. Access a copy of the personal data we hold about you or information about how we use or disclose your personal data.
  2. Correct or update your personal data held by us.

We require sufficient information to verify your identity and understand the nature of your request.

We reserve the right to charge a reasonable fee for processing a data access request.

We will respond as soon as reasonably possible. If we cannot respond within thirty (30) days, we will inform you of the expected response timeframe.

7. Protection of Personal Data

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.

These measures include up-to-date antivirus protection, encryption, privacy filters, secure storage and transmission of personal data, and restricting access to personal data on a need-to-know basis.

You should be aware 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 continually review and enhance our security measures.

Where we have provided you with a password to access certain parts of our website(s), portal(s) or application(s), you are responsible for keeping the password confidential. We ask that you do not share your password with anyone.

8. Accuracy of Personal Data

We generally rely on personal data provided by you or your authorised representative.

To ensure that your personal data remains current, complete and accurate, please update us if there are any changes by informing our Data Protection Officer in writing or via email.

9. Retention of Personal Data

We may retain your personal data for as long as necessary to fulfil the purposes for which it was collected, or as required or permitted by applicable laws.

We will cease retaining your personal data, or remove the means by which the data can be associated with you, when it is reasonable to assume that retention no longer serves the purpose for which the data was collected and is no longer necessary for legal or business purposes.

10. Transfer of Personal Data Outside of Singapore

We generally do not transfer your personal data to countries outside of Singapore.

However, if we do transfer your personal data outside Singapore, we will obtain your consent where required and take reasonable steps to ensure that your personal data continues to receive a standard of protection comparable to that provided under the Personal Data Protection Act.

11. Complaint Process

If you have any complaint or grievance regarding how we handle your personal data or how we comply with applicable data protection requirements, we welcome you to contact our Data Protection Officer.

Where you submit a complaint by email, indicating "PDPA Complaint" in the email subject header will assist us in directing your complaint to the appropriate person for review.

We will strive to deal with any complaint or grievance promptly and fairly.

12. Enquiries

For any enquiries regarding our privacy policy or this Data Protection Notice, please contact our Data Protection Officer using the contact details below.

13. Data Protection Officer

The Data Protection Officer
Hesed Advisory LLP
8 Ubi Rd 2,
#08-08 Zervex
Singapore 408538
Email: enquiry@heseadadvisory.com

14. Effect of Notice and Changes to Notice

This Notice applies together with any other notices, contractual clauses and consent clauses relating to the collection, use and disclosure of your personal data by us.

We may revise this Notice from time to time without prior notice. You may determine whether any 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.

This Data Protection Notice was last updated on 25 March 2024.