Data Protection Act
This Data Protection Notice (“Notice”) sets out the basis which EBOS SG Pte Ltd (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of our customers in accordance with the Personal Data Protection Act (“PDPA”). EBOS SG Pte Ltd (“us”, “we”, or “our”) is committed to protecting the privacy of the users (“user”,”you or “your”) of EBOS Cloud Accountant, EBOS SG PTE LTD (the “Site”). Our related companies include the following :
INTELLINZ PTE LTD ( Brand Name, Intellinz is a brand under EBOS SG PTE LTD focusing on Merger and Acquisition & Due Diligence ” )
EBOS ADVISORY PTE LTD. ( Brand Name, EBOS Advisory is a brand under EBOS SG PTE LTD focusing on Corporate Secretarial Services. )
There are a few ways you can use our services – to incorporate company, to instruct any corporate secretary assignment, to search for opportunities, to share your company information, to communicate with other people or to create new content.
This notice will inform you of our policies regarding the collection, use and disclosure of Personal Information we receive from users of the Site. This Data Protection Notice will be continuously assessed against new technologies and business practices. 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. As used in this Notice:
“customer” and/or “user ” means an individual who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us; and
“personal data” means data, whether true or not, about a customer who can be identified:
- from that data; or
- from that data and other information to which we have or are likely to have access.
- Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include your name and identification information such as your passport number, identity number, contact information such as your address, email address or telephone number, nationality, gender, date of birth, marital status, photographs and other audio-visual information, employment information and financial information such as credit card numbers, debit card numbers or bank account information. We will also ask for company and financial information such as figures which can be found in the ‘business profile’, ‘awards’, ‘certificates’, ‘profit and loss statement’ or ‘balance sheet.
3. Collection of Personal Data
Generally, we collect Personal Data in the following ways:
when you submit any forms relating to any of our products and services;
- when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our services;
- when you interact with our staff, for example, via telephone calls, letters, face-to-face meetings, social media platforms and emails;
- when you interact with us via any of our websites or use services on any of our websites;
- when you request that we contact you or request that you be included in an email or other mailing list;
- when you respond to our promotions, initiatives or to any request for additional Personal Data;
- when your images are captured by us via CCTV cameras while you are within our premises, or via photographs or videos taken by us or our representatives when you attend events at our premises;
- when you are contacted by, and respond to, our marketing representatives;
- when we receive references from business partners and third parties, for example, where you have been referred by them;
- when you engage us through any social media on the Internet and on the social media itself;
- when we seek information from third parties about you in connection with the products and services you have applied for; and/or
- when you submit your Personal Data to us for any other reason.
4. If you provide us with any Personal Data relating to a third party (eg information of your spouse, children, parents, and/or employees), by submitting such information to us, you represent and warrant to us that you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes.
5. Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).
COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
1. We collect, use and disclose your Personal Data for the following purposes:
- responding to your queries, feedback and requests;
- verifying your identity and processing payments;
- facilitates the transactions and perform transactions with thirty party agency such as ACRA and IRAS when it is deemed to be necessary.
- managing our administrative and business operations and complying with internal control policies and procedures;
- providing updates and other communications on developments relating to us;
- facilitating business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving us;
- matching any Personal Data held which relates to you for any of the purposes listed herein;
- preventing, detecting and investigating crime and analyzing and managing commercial risks;
- facilities management (including but not limited to maintaining the security of our premises);
- managing the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance);
- in connection with any claims, actions or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution), and/or protecting and enforcing our contractual and legal rights and obligations;
- conducting investigations relating to disputes, billing or fraud;
- managing and preparing reports on incidents and accidents;
- meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which have jurisdiction over us (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies and conducting audit checks, due diligence and investigations);
- financial reporting, regulatory reporting, management reporting, risk management, audit and record keeping purposes such as ACRA and other Statutory Bodies.
- any other purpose reasonably related to the aforesaid.
In addition, we collect, use and disclose your Personal Data for the following purposes, depending on the nature of your relationship with us:
2. If you are our client:
- assessing and processing any applications or requests made by you for products and services offered by us, including incorporation, corporate secretarial, accounting, unaudited financial statement, employment pass application, tax and payroll.
- verifying your identity;
- responding to, handling, and processing queries, requests, applications, complaints, and feedback from you to operate, maintain and provide you with the features and functionality of the Service;
- managing your relationship with us by informing you about our services, such as letting you know about upcoming changes or improvements;
- processing payment or credit transactions;
- sending marketing information about our goods or services including notifying you of our marketing events, government initiatives, membership and rewards schemes;
- 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;
- any other purposes for which you have provided the information such as informing directors and shareholders on change of registered address, residential address, personal particulars, nationality, share issues, share transfer during and/or upon completion of the assignment;
- transmitting to any unaffiliated third parties including our third parties service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes;
- any information obtained for the use in incorporation and corporate secretary will be disclosed to ACRA’s system. ACRA is exempted from the PDPA. The ACRA Act provides for ACRA to disclose personal data in discharging its functions. Nevertheless, ACRA adheres to the Public Sector (Governance) Act and Government Instruction Manuals with respect to the way data is managed. To facilitate trade and interactions among business and members of the public, enhance transparency and enable the public to conduct checks on the Services performed; and
- any other incidental business purposes related to or in connection with the above.
- requesting feedback or participation in surveys, as well as conducting market research and/or analysis for statistical, profiling or other purposes for us to review, develop and improve the quality of our products and services;
- facilitating the continuation or termination of the relationship and the provision of services to you in accordance with the mandate that you have agreed with us;
- any other purpose reasonably related to the aforesaid.
3. If you submit an application to us as a candidate for an employment position:
- managing and verifying your application;
- performing background checks, and verifying all your employment details and qualifications;
- providing or obtaining employee references and for background screening;
- assessing your suitability for the position applied for; and/or
- any other purposes relating to any of the above.
4. For legal reasons;
We will share personal information with companies, organizations or individuals outside of EBOS SG Pte Ltd under good-faith that access, use, preservation or disclosure of the information is reasonably necessary for investigation of potential violations, detect, prevent, or otherwise address fraud, security or technical issues. It would also be used to detect, prevent, or otherwise address fraud, security or technical issues. To protect against harm to the rights, property or safety of EBOS SG Pte Ltd, users or the public as required or permitted by law.
5. If you do not interact with us in the manners specified above, we may collect, use and/or disclose your Personal Data for the following purposes, in accordance with the Act:
- the purposes for which we have specifically obtained your consent; and/or
- the purposes for which you have provided your Personal Data to us.
When the need arises for Personal Data to be collected, used or disclosed for purposes other than the ones originally consented for, we will obtain your fresh consent in that regard, where necessary, in accordance with the Act.
6. As we rely on your Personal Data to provide products and services to you, you should ensure that all Personal Data submitted to us is complete, accurate, true and correct.
7. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us 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 a contract with you).
We may disclose your personal data:
- where such disclosure is required for performing obligations during or in connection with our provision of the goods or services requested by you; or
- to third party service providers, agents and other authorised organisations we have engaged to perform any of the functions listed above which is legally required under the law.
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, which is usually 1 year thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).
LOG IN INFORMATION
1. When you use our services or view content provided by EBOS SG Pte Ltd, we automatically collect and store certain information in the server logs. This includes details which are as follows, and not limited to, how you used our service such as your search opportunities, telephone log information, how you interact with links on the Service and cookies that may uniquely identify your browser. Akin to many site operators, we collect information that your browser sends whenever you visit our Site (“Log Data”).
1. We may directly collect analytics data, or use third-party analytics tools and services, to help us measure traffic and usage trends for the Service. These tools collect information sent by your browser or mobile device, including the pages you visit and other information that assists us in improving the Service. We collect and use this analytics information in aggregate form such that it cannot be reasonably manipulated to identify any particular individual user.
1. When you visit the Site, we may send one or more cookies — a small text file containing a string of alphanumeric characters — to your computer that uniquely identifies your browser and lets EBOS SG Pte Ltd help you log in faster and enhance your navigation through the site. A cookie may also convey information to us about how you use the Service (e.g., the pages you view, the links you click and other actions you take on the Service), and allow us or our business partners to track your usage of the Service over time. A persistent cookie remains on your hard drive after you close your browser. Persistent cookies may be used by your browser on subsequent visits to the site. Persistent cookies can be removed by following your web browser’s directions. A session cookie is temporary and disappears after you close your browser. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, some features of the site may not function properly if the ability to accept cookies is disabled.
UNIQUE APPLICATION NUMBERS
1. Certain services include a unique application number. This number and information about your installation (for example, the operating system type and application version number) may be sent to EBOS SG Pte Ltd when you install or uninstall that service or when that service periodically contacts our servers, such as for automatic updates.
WITHDRAWING YOUR CONSENT
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 firstname.lastname@example.org
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 fifteen (15) business days of receiving it.
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.
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.
ACCESS TO AND CORRECTION OF PERSONAL DATA
1. you wish to make (a) 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, you may submit your request in writing or via email to our Data Protection Officer at email@example.com
2. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request. 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).
PROTECTION OF PERSONAL DATA
1. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced commercially acceptable means to protect your Personal and Company Information and we encrypt many of our services using SSL. 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.
2. We restrict access of personal information to EBOS SG Pte Ltd employees, contractors and agents who need to know that information in order to process it for us, and who are subject to strict contractual confidentiality obligations. All employees are briefed the importance of PDPA and NDA. Every employees will go through a training and acknowledge via signing a Non Disclosure Act on the use of data with EBOS Sg Pte Ltd. They may be disciplined or terminated if they fail to meet these obligations. We do not accept liability for unintentional disclosure, to the extent permitted under applicable law.
3. 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.
ACCURACY OF PERSONAL DATA
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 firstname.lastname@example.org
RETENTION OF PERSONAL DATA
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.
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. A reasonable period is to keep the data collected for 1 year upon the cessation of services. Once the data is deleted, we will not be able to retrieve it by any means in our cloud storage system. Hence, it is important that you must keep the accounting recording for 5 years based on Singapore Companies Acts, ACRA and IRAS in a safe and secure location.
EFFECT OF NOTICE AND CHANGES TO NOTICE
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.
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.
You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner: email@example.com
Last updated: 1 June 2021
ACKNOWLEDGEMENT AND CONSENT
I acknowledge that I have read and understood the above Data Protection Notice, and consent to the collection, use and disclosure of my personal data by EBOS SG Pte Ltd for the purposes set out in the Notice.