Last updated 20 April 2022
DATA PROTECTION NOTICE FOR GENERAL PUBLIC
This Data Protection Notice (“Notice”) sets out the basis upon which Innoven Capital Group (“we”, “us” or “our”) may collect, use, disclose or otherwise process personal data of you or that you provide to us in accordance with the Personal Data Protection Act (“PDPA”). 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:
“general public” means an individual who (a) has contacted us through any means to find out more about 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.
2. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include name, residential address, email address, telephone number, nationality, gender, date of birth, marital status, photograph, employment information and financial information.
3. 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
4. We generally do not collect your personal data unless:
(a) it 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).
5. We may collect and use your personal data for any or all the following purposes:
(a) performing obligations in the course of or in connection with our provision of services requested by you;
(b) verifying your identity;
(c) responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
(d) managing your relationship with us;
(e) 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;
(f) any other purposes for which you have provided the information, including for events;
(g) transmitting to any unaffiliated third parties including our third-party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes;
(h) conducting research and analytics for business improvement purposes, including enhancing our services and website security purposes; and
(i) any other incidental business purposes related to or in connection with the above.
6. We may use “cookies”, where a small data file is sent to your browser to store and track information about you when you enter our website. Further information about cookies and how to manage them:
(a) The cookie is used to track information such as the number of users and their frequency of use, profiles of users and their preferred sites. While this cookie can tell us when you enter our site and which pages you visit, it cannot read data off your hard disk.
(b) You can choose to accept or decline cookies. Although most web browsers automatically accept cookies, you can choose whether to accept cookies via your browser setting (often found in your browser’s Tools or Preferences menu). You may also delete cookies from your device at any time. However, if declining cookies may prevent you from taking full advantage of the website.
7. We may disclose your personal data:
(a) where such disclosure is required for performing obligations in the course of or in connection with services requested by you;
(b) to third party service providers, agents and other organisations we have engaged to perform any of the functions with reference to the above mentioned purposes; or
(c) to assist with requests from regulatory bodies, including police investigations.
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 thereafter (including, where applicable, a period to enable us to enforce our rights under a contract with you).
DEEMED CONSENT BY NOTIFICATION
9. We may collect, use, and/or disclose your existing personal data for secondary purposes that differ from the primary purpose which it had originally collected for pursuant to clauses 5 and 6. If Innoven Capital Group intends to rely on deemed consent by notification for such secondary purposes, Innoven Capital Group will notify you of the proposed collection, use or disclosure of personal data through appropriate mode(s) of communication.
10. In particular, we may rely on deemed consent by notification to collect, use or disclose your personal data for the following purposes:
(a) Processing job applications
(b) Organising events
11. Before relying on deemed consent by notification, Innoven Capital Group will assess and determine that the collection, use and disclosure of the personal data will not likely have an adverse effect on you.
12. You will be given a reasonable period to inform us if you wish to opt-out of the collection, use and disclosure of your personal data for such purposes.
13. After the lapse of the opt-out period, you may notify us that you no longer wish to provide consent to the purposes for which it was obtained by notification, withdrawing your consent for the collection, use or disclosure of your personal data in relation to those purposes.
RELIANCE ON THE LEGITIMATE INTERESTS EXCEPTION
14. In compliance with the PDPA, we may collect, use, or disclose your personal data without your consent for legitimate interests of Innoven Capital Group or another person. In relying on the legitimate interests exception of the PDPA, Innoven Capital Group will assess likely adverse effects on the individual and determine whether legitimate interests outweigh any adverse effect.
15. In line with the legitimate interests’ exception, we will collect, use or disclose your personal data for the following purposes:
(a) Fraud detection and prevention;
(b) Detection and prevention of misuse of services;
(c) Network analysis to prevent fraud and financial crime, and perform credit analysis; and
(d) Collection and use of personal data on company-issued devices to prevent data loss.
The purposes listed in the above clause 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.
16. 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 collecting, using and/or disclosing your personal data for any or all purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below in clause 28.
17. 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 and effect your request within ten (10) days of receiving it.
18. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and extent of your request, we may not be in a position to process your job application (as the case may be). We shall, in such circumstances, notify you before completing the processing of your request (as outlined above). Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 8 above (Deemed Consent by Notification).
19. 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
20. 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, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below in clause 28.
21. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee prior to processing your request.
22. We will respond to your request as soon as reasonably possible. In general, our response will be within ten (10) business days. Should we not be able to respond to your access request within thirty (30) days after receipt, 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 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
23. 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 such as minimised collection of personal data, authentication and access controls (such as good password practices, need-to-basis for data disclosure, etc.), encryption of data, data anonymisation, up-to-date antivirus protection, regular patching of operating system and other software, securely erase storage media in devices before disposal, web security measures against risks, security review and testing performed regularly, and privilege account management.
24. 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
25. 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 contact details provided below in clause 29.
RETENTION OF PERSONAL DATA
26. We may retain your personal data for as long as it is necessary to fulfil the purposes for which they were collected, or as required or permitted by applicable laws, regulations, and internal data retention requirements.
27. 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 purposes for which the personal data were collected and are no longer necessary for legal or business purposes.
TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
28. We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and 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.
DATA PROTECTION OFFICER
29. If you have any enquiries or feedback on our personal data protection policies and procedures; or if you wish to make any request, you may contact our Data Protection Officer at [email protected].
EFFECT OF NOTICE AND CHANGES TO NOTICE
30. This Notice applies in conjunction with any other policies, notices, contractual clauses, and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
31. 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 employment and participation in our recruitment process constitute your acknowledgement and acceptance of such changes.