BSL Corporate Services

Privacy Policy

PRIVACY POLICY OF BSL CORPORATE ("POLICY")

This Policy sets out the manner in which BSL Corporate collects, uses, manages and protects Personal Data (as defined below) in compliance with the provisions of the Personal Data Protection Act 2012 ("PDPA").

This Policy applies to all Individuals (as defined below) who provide BSL Corporate with Personal Data or whose Personal Data is otherwise collected, used and/or disclosed by BSL Corporate in connection with and/or for the purposes of its operations.

This Policy supplements but does not supersede or replace any previous consent which an Individual may have provided to BSL Corporate, nor does it affect any rights that BSL Corporate may have at law in connection with the collection, use and/or disclosure of any Individual’s Personal Data. Subject to that, BSL Corporate will not collect any Personal Data from an Individual unless the Individual has voluntarily chosen to provide the Personal Data or as required for the purposes of providing services to the Individual or by law.

This Policy does not apply to the following categories of Personal Data:

a) Personal data that is contained in a record that has been in existence for at least 100 years; and
b) Personal data about a deceased Individual who has been dead for more than 10 years.

BSL Corporate may from time to time update this Policy to ensure it is consistent with its future developments or business purposes or to accommodate future changes to applicable legal or regulatory requirements. All updates to this Policy will be published at www.bslcs.com.sg ("BSL Corporate Website") and appropriate notifications of any material revisions will be published on the BSL Corporate Website and may be issued separately to relevant persons such as may be determined by BSL Corporate. Subject to an Individual's rights at law, the prevailing terms of the Policy from time to time shall apply. By continuing their relationship with BSL Corporate after any amendments have been introduced and published on the BSL Corporate Website, Individuals shall be deemed to have accepted the Policy as amended.

For the avoidance of doubt, this Policy forms part of the terms and conditions, if any, governing an Individual's specific relationship with BSL Corporate ("Terms and Conditions") and should be read in conjunction with such Terms and Conditions. In the event of any conflict or inconsistency between the provisions of this Policy and the Terms and Conditions, the provisions of the Terms and Conditions shall prevail to the fullest extent permissible by law.

Definitions:
For purposes of this Policy:

"Individual" means a natural person, whether living or deceased and "Individuals" shall be construed accordingly;

"CCTV" means Closed-circuit Television;

Personal Data means data that is capable of identifying an Individual, whether on its own or in conjunction with other data accessible to BSL Corporate;

"Potential Personnel" means any Individual who has submitted an application to be engaged by BSL Corporate as Personnel; and

“PDPC” means Personal Data Protection Commission.

Personal Data collected by BSL Corporate
BSL Corporate will only collect, use or disclose Personal Data about an Individual which it reasonably considers necessary for the relevant purposes underlying such collection, use or disclosure. Depending on the specific nature of an Individual’s interaction with BSL Corporate, Personal Data which BSL Corporate collects, uses or discloses concerning an Individual may variously include but is not limited to the following:
1. the Individual's name, gender and contact particulars, including telephone number(s), residential/mailing address(es) and email address;
2. details of the Individual’s identification documents (such as, NRIC or passport numbers), and applicable visa or permits (such as employment pass, work permit, permanent residency status);
3. details of the Individual’s employment history and academic qualifications;
4. the name and contact particulars of the Individual’s next-of-kin;
5. the Individual's network usage data and other information gathered automatically by our computer systems, including the Individual’s computer IP address, links visited and other activities conducted online or using our computer systems;
6. photographs and video, CCTV or voice recordings of the Individual; and
7. other information which the Individual may provide to BSL Corporate, from time to time, in the course of such Individual’s interaction with BSL Corporate.

How BSL Corporate collects Personal Data
Generally, BSL Corporate may collect Personal Data from an Individual in one or more of the following ways or circumstances:
1. when the Individual interacts with BSL Corporate's staff via telephone calls, emails, other correspondence and/or face-to-face meetings;
2. when the Individual visits BSL Corporate’s premises;
3. when the Individual specifically requests that BSL Corporate contact him or her or requests to be included in an email or any mailing list maintained by BSL Corporate;
4. when the Individual responds to any request by BSL Corporate for the provision of Personal Data;
5. when BSL Corporate receives references or referrals from its business partners or other third parties;
6. when the Individual attends or participates in any event organised by BSL Corporate;
7. when the Individual submits his or her Personal Data to BSL Corporate pursuant to a job application;
8. when the Individual subscribes to BSL Corporate’s publication(s); and/or
9. when the Individual submits his or her Personal Data to BSL Corporate for any other reason related to BSL Corporate's ordinary course of business operations.

Purposes of collection, use and disclosure of Personal Data
Generally, BSL Corporate collects, uses and/or discloses Personal Data from Individuals for one or more of the following purposes:
1. Provision of services
  1. administering and managing the Individual’s relationship with BSL Corporate;
  2. providing the Individual with information about BSL Corporate’s services and/or the services of any external vendor that is providing services or products in partnership or collaboration with BSL Corporate;
  3. responding to the Individual’s complaints, queries and/or requests;
  4. facilitating and/or organising events;
  5. informing the Individual of changes and/or updates to BSL Corporate’s policies, terms and conditions and/or other administrative information;
2. Security measures
  1. verifying the Individual's identity or monitoring the Individual's activities, including without limitation via CCTV observation and/or recording;
  2. preventing, detecting and investigating fraud, misconduct, any unlawful action, omission or dispute, and whether or not there is any suspicion of the aforementioned; and
  3. access to the Individual’s Personal Data is only available to Personnel who require it to perform their duties. All Personnel have entered into non-disclosure agreements with BSL Corporate to treat the Personal Data as confidential information.
3. General business operations of BSL Corporate
  1. Provision of corporate secretarial services and related services;
  2. record-keeping and meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines which are binding on BSL Corporate (including but not limited to responding to regulatory complaints, disclosure to regulatory bodies and conducting background checks, due diligence and investigations);
4. Managing Personnel
  1. administering, managing and/or terminating BSL Corporate's relationship with Personnel;
  2. evaluating the performance of Personnel;
  3. undertaking staff training and quality assurance activities;
  4. providing Personnel with services, facilities and/or other benefits being offered or made available by BSL Corporate to Personnel as well as information about such services, facilities and benefits;
5. Managing Potential Personnel
  1. administering and managing BSL Corporate's relationship with Potential Personnel;
  2. evaluating the suitability and eligibility of Potential Personnel to be engaged by BSL Corporate;
6. Marketing
  1. where BSL Corporate circulates BSL Corporate's publications or marketing information to an Individual or to any person which may be disseminated to an Individual relating to services offered by BSL Corporate (whether by BSL Corporate or BSL Corporate's business partners) which BSL Corporate thinks is or may be of benefit or interest to him/her via postal mail, electronic transmission to his or her or any email address(es), and/or voice call or phone call and/or fax to his or her or any telephone number(s);
  2. for promotional and publicity purposes, including recording or taking photographs of participants at events or functions organised, hosted or participated by BSL Corporate;
7. Others
  1. for transfer to third party intermediaries such as third party service providers and agents to facilitate any of the aforesaid purposes;
  2. for any purpose reasonably related to any of the above purposes; and
  3. for any other purpose in relation to which BSL Corporate has obtained or received the Individual's consent.
Retention of Personal Data
BSL Corporate will cease to retain Personal Data after 5 years or as required by the relevant laws and regulations if it is no longer required to fulfil the purpose for which the Personal Data was collected.
Consent
Unless otherwise authorised under the PDPA or any other applicable law, BSL Corporate will not collect, use or disclose an Individual's Personal Data without his or her consent.

BSL Corporate will take reasonable steps to highlight the purposes relevant to an Individual, by appropriate means, at the point or time of collection of the Personal Data from such Individual, including:
1. via express provisions in contracts, application forms and/or registration forms to be signed with or submitted to BSL Corporate;
2. via notifications on BSL Corporate's websites; and
3. in the course of verbal communication;
Where feasible, BSL Corporate will inform the Individual of purposes that are intrinsic to the relationship between BSL Corporate or to the provision of services to such Individual, as well as purposes that are optional.

In so far as any purpose is intrinsic to the relationship or provision of services, BSL Corporate reserves the right to decline to engage in the relevant relationship or to provide the relevant services to the Individual if he or she does not consent to BSL Corporate's collection, use or disclosure of his or her Personal Data for such purpose.

Individuals who:
1. voluntarily provide their Personal Data to BSL Corporate for the specified purposes;
2. use or access BSL Corporate's website(s) or computer network;
3. enter BSL Corporate's premises or using any of the facilities thereon; and/or
4. attend or participate in events or programmes organised by BSL Corporate.
will be deemed to agree and consent to BSL Corporate collecting, using and/or disclosing their Personal Data in the manner and for the purposes set forth in this Policy.

An Individual who provides BSL Corporate with Personal Data relating to a third party (e.g. information of his or her spouse or children) for any particular purpose, represents to BSL Corporate that he/she has obtained the consent of the relevant third party to BSL Corporate collecting, using or disclosing such Personal Data for the relevant purpose.

In so far as BSL Corporate collects Personal Data of an Individual from any third party, BSL Corporate will take reasonable steps to inform the relevant third party of BSL Corporate's purposes for collecting the Personal Data and to verify that consent from the Individual has been obtained by the relevant third party to such disclosure for the intended purpose.
Disclosure of Personal Data
In carrying out one or more of the above Purposes, BSL Corporate may need to disclose an Individual’s Personal Data to the following third parties for one or more of the above Purposes:
1. to BSL Corporate's third-party service providers or agents;
2. any external vendor that is providing services or products in partnership or collaboration with BSL Corporate;
3. to BSL Corporate’s professional advisors;
4. any person to whom disclosure is permitted or required by any statutory provision or law;
5. any permitted assigns; and/or
6. to any local or foreign regulatory body, government agency, statutory board, ministry, department or other government body and/or its officials.

Withdrawal of Consent

Any Individual who wishes to withdraw his or her consent to any use or disclosure of his or her Personal Data by BSL Corporate as set out in this Policy may do so by contacting BSL Corporate’s Personal Data Protection Officer at:

Email address :	PDPA-dpo@bslcs.com.sg
Mailing address :	BSL Corporate Services Pte Ltd/BSL Advisory Services Pte Ltd 220 Orchard Road #05-01 Midpoint Orchard Singapore 238852
Attention :	The Personal Data Protection Officer

Depending on the extent to which an Individual withdraws consent to the use or disclosure of his or her Personal Data by BSL Corporate, such withdrawal of consent may result in BSL Corporate’s inability to provide services to the Individual and may be considered as a termination by the Individual of any agreement between BSL Corporate and the Individual. BSL Corporate’s legal rights and remedies are expressly reserved in such event.

In so far as an Individual’s data is being collected by cookies, the Individual may disable the use of cookies on his or her internet browser when accessing BSL Corporate’s website. However, this may result in the loss of functionality, restrict the Individual’s use of the website and/or delay or affect the way in which BSL Corporate’s website operates.

Verification of Personal Data & Notification of Changes
Where feasible, BSL Corporate will take reasonable steps to verify the accuracy of Personal Data received at the point of collection but Individuals remain primarily responsible and liable to ensure that all Personal Data submitted by them to BSL Corporate is complete and accurate. Information voluntarily provided by an Individual to BSL Corporate shall prima facie be deemed complete and accurate.

BSL Corporate will also take reasonable steps to periodically verify Personal Data in its possession, taking into account the exigencies of its operations, but Individuals are nonetheless responsible for notifying BSL Corporate, from time to time, of any applicable changes to such Personal Data.

BSL Corporate shall not be held liable for any inability on its part to provide services to an Individual who fails to ensure that his or her Personal Data submitted to BSL Corporate is complete and accurate or who fails to notify BSL Corporate of any relevant changes to such Personal Data.

Activities undertaken prior to 2 July 2014

BSL Corporate may continue to use Personal Data of an Individual that was collected before 2 July 2014 for purposes for which the Personal Data was collected unless consent is withdrawn by that Individual. Individuals who wish to withdraw their consent to BSL Corporate’s use of their Personal Data may contact BSL Corporate’s Personal Data Protection Officer at

Email address :	PDPA-dpo@bslcs.com.sg
Mailing address :	BSL Corporate Services Pte Ltd/BSL Advisory Services Pte Ltd 220 Orchard Road #05-01 Midpoint Orchard Singapore 238852
Attention :	The Personal Data Protection Officer

Protection of Personal Data

BSL Corporate shall make reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks to Personal Data in its possession.

If BSL Corporate transfers Personal Data outside Singapore, BSL Corporate will take reasonable steps to ensure that such Personal Data transferred receives a standard of protection comparable to the protection received under the PDPA and such transfer shall be subject to this Policy.

BSL Corporate will ensure that third parties who receive Personal Data from BSL Corporate protect such Personal Data in a manner consistent with this Policy and not use such Personal Data for any purposes other than those specified by BSL Corporate, by incorporating appropriate contractual terms in its written agreements with these third parties.

BSL Corporate is not responsible in any way for the security and/or management of Personal Data shared by Individuals with third party websites accessible via links on BSL Corporate’s website.

Contacting BSL Corporate-Access and Correction of Personal Data

Any Individual who:

has questions or feedback relating to this Policy or would like to know the compliance of BSL Corporate with the data protection laws;
would like to obtain access to his or her Personal Data held by BSL Corporate;
would like to obtain information about the ways in which his or her Personal Data held by BSL Corporate has been or may have been used or disclosed by BSL Corporate in the year preceding the request; and/or
would like to update or make corrections to his or her Personal Data held by BSL Corporate,

should contact BSL Corporate’s Personal Data Protection Officer at:

Email address :	PDPA-dpo@bslcs.com.sg
Mailing address :	BSL Corporate Services Pte Ltd/BSL Advisory Services Pte Ltd 220 Orchard Road #05-01 Midpoint Orchard Singapore 238852
Attention :	The Personal Data Protection Officer

Individuals should note that BSL Corporate is not required, under the PDPA, to provide access and correction to Personal Data in certain exempted situations as set out in the PDPA.

The PDPA allows and BSL Corporate reserves the right to charge a reasonable fee for the handling and/or processing of access requests by an Individual pursuant to paragraphs (b) or (c) above.

Data Breach Notification

When a data breach poses risk of impact or harm to the affected Individual, BSL Corporate will as soon as practicable, not later than 48 hours from the time it is aware of the data breach, notify the affected Individual and PDPC. It will inform PDPC if the scale of the data breach is significant, even if the breach does not pose any risk of impact or harm to the affected Individuals.
Governing Law

This Policy shall be governed by and construed in accordance with the laws of Singapore. Any dispute arising out of or in connection with this Policy including any question regarding its existence, validity or termination, shall be referred to and finally resolved by the Courts of Singapore.

Note:
BSL Corporate: BSL Corporate Services Pte Ltd and BSL Advisory Services Pte Ltd.

Privacy Policy

PRIVACY POLICY OF BSL CORPORATE ("POLICY")

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