Last revised on 06 November 2015
This data protection policy applies to Alma Contract Singapore Pte Ltd, which is established in Singapore (“Alma Contract”, “Mondecasa” or “we”) and also its subsidiary firms overseas. This policy governs the collection, use and disclosure of personal data submitted to Mondecasa pages of Mondecasa.com.sg, and explains how we collect and handle personal data of individuals and complies with the requirements of the Personal Data Protection Act 2012 of Singapore and its regulation(s) (“PDPA”). In this policy, “personal data” shall have the meaning ascribed to it in the PDPA.
For more information about our marketing data protection policy, please refer to the respective sections below.
Main Data Protection Policy
We will collect, use or disclose personal data for reasonable business purposes only if there is consent or deemed consent from the individual and information on such purposes have been notified. We may also collect, use or disclose personal data if it is required or authorised under applicable laws.
Collection of Personal Data
We collect personal data from clients, customers, business contacts, partners, personnel, contractors and other individuals. Such personal data may be provided to us in forms filled out by individuals, face-to-face meetings, email messages, telephone conversations, through our websites or provided by third parties. If you contact us, we may keep a record of that contact.
We collect these personal data when it is necessary for business purposes or to meet the purposes for which you have submitted the information.
We will only collect, hold, process, use, communicate and/or disclose such personal data, in accordance with this policy. If you are acting as an intermediary or otherwise on behalf of a third party or supply us with information regarding a third party (such as a friend, a colleague, an employee etc), you undertake that you are an authorised representative or agent of such third party and that you have obtained all necessary consents from such third party to the collection, processing, use and disclosure by us of their personal data. Because we are collecting the third party’s data from you, you undertake to make the third party aware of all matters listed in this policy preferably by distributing a copy of this policy to them or by referring them to our website.
Use of Personal Data
We use personal data for the following purposes:
- to provide our services
- to respond to the individual’s request or for the purposes for which it was provided to us as stated at the time of the collection (or as is obvious from the context of collection)
- to maintain contact with clients and other contacts
- to keep clients and other contacts informed of the services we offer, industry developments, service offerings, seminars and other events we are holding, that may be of interest to them
- for general management and reporting purposes, such as invoicing and account management
- all other purposes related to our business.
You may choose to unsubscribe from mailing lists, registrations, or elect not to receive further marketing information from us by contacting our Marketing Officer via email at email@example.com, or if we have contacted you by email, you may use the unsubscribe function in that email to notify us. Please allow 28 days for your request to be processed.
Disclosure of Personal Data to Third Parties
We do not disclose personal data to third parties except when required by law, when we have your consent or deemed consent or in cases where we have engaged the third party such as data intermediaries or subcontractors specifically to assist with our firm’s activities. Any such third parties whom we engage will be bound contractually to keep all information confidential.
We may disclose personal data to Alma Contract and other associate and supporting firms, Novox Inc. Pte Ltd (“Novox Inc.”) and Puzzle Hive Pte Ltd (“Puzzle Hive”), where it is necessary (i) to meet the purpose for which you have submitted the information; or (ii) to enable you to be provided with information at a later date which may be of relevance and interest to you based on the nature and purpose of your voluntary requests. We may also transfer all data in our possession to a successor-in-interest to our business or assets.
Access to and Correction of Personal Data
Upon request, we will provide the individual with access to their personal data or other appropriate information on their personal data in accordance with the requirements of the PDPA. Upon request, we will correct an error or omission in the individual’s personal data that is in our possession or control in accordance with the requirements of the PDPA. We may charge for a request for access in accordance with the requirements of the PDPA.
Withdrawal of Consent
Upon reasonable notice being given by an individual of his withdrawal of any consent given or deemed to have been given in respect of our collection, use or disclosure of his personal data, we will inform the individual of the likely consequences of withdrawing his consent. We will cease (and cause any of our data intermediaries and agents to cease) collecting, using or disclosing the personal data unless it is required or authorised under applicable laws.
Accuracy of Personal Data
We will make a reasonable effort to ensure that personal data collected by us or on our behalf is accurate and complete.
Security and Protection of Personal Data
We have implemented generally accepted standards of technology and operational security to protect the personal data in our possession or under our control and to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. All Alma Contract personnel follow a network-wide security policy. Only authorised Alma Contract personnel are provided access to personally identifiable information and these personnel have agreed to ensure confidentiality of this information. Alma Contract’s policy is to use secure socket layer technology for the protection of credit card information submitted through web forms. This policy is also required for any fulfilment agents of Alma Contract.
Retention of Personal Data
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.
Transfer of Personal Data outside of Singapore
We will ensure that any transfers of personal data to a territory outside of Singapore will be in accordance with the PDPA so as to ensure a standard of protection to personal data so transferred that is comparable to the protection under the PDPA.
Privacy on Our Web Sites
This Policy also applies to any personal data we collect via our websites. Cookies may be used on some pages of our websites. “Cookies” are small text files placed on your hard drive that assist us in providing a more customised website experience. Cookies are now used as a standard by many websites to improve users’ navigational experience. If you are concerned about cookies, most browsers permit individuals to decline cookies. In most cases, a visitor may refuse a cookie and still fully navigate our websites, however other functionality in the site may be impaired. After termination of the visit to our site, you can always delete the cookie from your system if you wish.
We reserve the right to modify or amend this Policy at any time. The effective date will be displayed at the beginning of this Policy.
Marketing Data Protection Policy
The privacy of information you provide in our subscription form is important to us. The following privacy statement governs the collection and, use and disclosure of personal data submitted to Alma Contract Singapore Pte Ltd and associate firms, which are established in Singapore (the “Firm”, “Alma Contract” or “Mondecasa”) and associate firm’s overseas regional offices. The Firm’s information handling practices are in accordance with current privacy and data protection legislation in Singapore.
For more general information about the privacy practices of Alma Contract Singapore Pte Ltd, please refer to our main Data Protection Policy.
Why do we collect personal data and how do we use it?
The personal data submitted on our subscription form will be used by the Firm for the purposes of any relevant promotional activities organised by the Firm such as, but not limited to, seminars, firm events and alerts on publications. We may also send you communications from time to time, for example, to advise you of technical updates or ask you to participate in surveys, which may be of interest to you. By submitting the information in our subscription form, you acknowledge that you have consented to our processing data in accordance with the privacy statement for the purposes described.
Retention of Personal Data
Personal data that is kept by us will be destroyed after a reasonable period from the time when it becomes outdated or is no longer required for the purpose for which it was collected or when we receive your request to delete it.
How is this personal data secured?
The personal data submitted to us is stored in our contacts database or similar system and is available to only authorised partners and staff, and contractors. Accesses to Your Personal Data If you wish to access, delete or correct your personal data provided to us or if you have any concerns about how we handle information about you, please send your request to our Marketing Officer via email at firstname.lastname@example.org.
Disclosure of Data to Third Parties
Personal data collected may be transferred and shared internationally We may disclose personal data with other associate and supporting firms, Novox Inc. Pte Ltd (“Novox Inc.”) and its subsidiaries and Puzzle Hive Pte Ltd (“Puzzle Hive”), in order to meet the purpose for which you have submitted the information and activities directly related to it.
By submitting personal data in our subscription form, you are providing explicit consent to trans-border transmission of such data as described above.
The personal data submitted will not be disclosed to third parties except when required by law, when we have your explicit consent or in cases where the third party is a contractor or supplier whom we have engaged specifically to assist with the Firm’s activities. All such contractors will be bound contractually to keep all information confidential.