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 https://www.ebos-sg.com (the “Site”).
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.
- 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:
(a) from that data; or
(b) 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.
- 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
- We collect information to provide a Service and perform accurate Business Intelligence KYC Report and create business opportunities for the user. While using our Site, we may ask you to provide us with certain information that can be used to contact or identify you. This information may include but is not limited to any information relating to an identified or identifiable individual (“Personal Information”).
(a) such information is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or
(b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
- Most of our services let you share information with others. Remember that when you share information publicly, it may be index-able by search engines, including Google. Our services provide you with different options on sharing and removing your Information we share. We do not share personal information with companies, organizations and individuals outside of EBOS SG Pte Ltd unless one of the following circumstances applies:
(a) With Master User or Consultant: If your EBOS SG Pte Ltd Account is managed for you by a Master User whom you have assigned for or our consultant whom we have assigned to take on your case, then your Master User or assigned consultant will have access to your Personal Account information (including your email and other data) and company information (such as Financial details). Your Master User may be able to access the financial report, change your account password, suspend or terminate your account access, access or retain information stored as part of your account, restrict your ability to delete or edit your information or privacy settings, receive your account information in order to satisfy applicable law, regulation, legal processes or enforceable governmental requests.
(b) For external processing: We provide personal information to our trusted businesses or persons to process it for us, based on our instructions and in compliance with our Data Protection Policy and any other appropriate confidentiality and security measures.
(c) 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.
- Internally, we may collect and use your personal data for any or all of the following purposes:
(a) performing obligations during or in connection with our provision of the goods and/or services requested by you to provide, update, protect and conclude a more accurate Business Intelligence KYC Report. We also use this information to offer you tailored content：for example, giving you a more relevant search opportunity results and accurate profile, which may be seen by other users of the EBOS SG Pte Ltd.
(b) verifying your identity;
(c) 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;
(d) managing your relationship with us by informing you about our services, such as letting you know about upcoming changes or improvements;
(e) processing payment or credit transactions;
(f) sending 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 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;
(i) use information collected from cookies and other technologies, like pixel tags, to improve your user experience and the overall quality of our services.
(j) 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;
(k) 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
(l) any other incidental business purposes related to or in connection with the above.
- We may disclose your personal data:
(a) where such disclosure is required for performing obligations during 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 functions listed in clause 5 above for us.
- 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).
INFORMATION WE GET FROM YOUR USES OF OUR SERVICES
- We collect information about the services that you use and how you use them. They are as follows: when you search for opportunities, create an opportunities profile or connect to our service through a third-party connection. Some other mediums are when you log-in, for example, through Facebook Connect, by “following”,“liking” or linking your account to the EBOS SG Pte Ltd site etc.
- These third parties may pass certain information about your use of its service at EBOS SG Pte Ltd. This information could include, but is not limited to, the user ID associated with your account (for example, your Facebook ID), an access token necessary to access that service, any information that you have permitted the third party to share with us, and any information you have made public in connection with that service. If you allow us access to your friends’ list, your friends’ user IDs and your connection to those friends may be used and stored to make your experience more social. This information may be used to allow you to invite your friends to use our Service as well as provide you with updates if and when your friends join EBOS SG Pte Ltd. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to the EBOS SG Pte Ltd Service. You may also unlink your third party account from the Service by adjusting your settings on the third party service.
LOG IN INFORMATION
- 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”).
- 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.
- When you visit the Service, 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
- 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
- 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 email@example.com
- 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.
- 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 8 above.
- 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
- If 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 firstname.lastname@example.org
- 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
- 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.
- 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. 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.
- 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
- 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 email@example.com
RETENTION OF PERSONAL DATA
- 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.
- 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.
TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
- We may transfer your personal data to countries outside of Singapore as EBOS SG Pte Ltd is a global Business Intelligence Risk Reporting Platform. 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.
- 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: firstname.lastname@example.org
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.
Last updated: 1 February 2020
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.