Transcend Solutions Pte Ltd does not collect your personal data other than those that individuals voluntarily provide. We are committed to protecting the privacy and confidentiality of any personal information you share with us in accordance with the Singapore Personal Data Protection Act 2012 and all associated regulations and guidelines which may from time to time be issued by the Personal Data Protection Commission of Singapore.
“Personal Data” means data, whether true or not, about an individual 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.
“Business Contact Information (BCI)” is defined as an individual’s name, position name or title, business telephone number, business address, business email address and any other similar information about the individual, not provided by the individual solely for his personal purposes.
1.3. Under the Singapore Personal Data Protection Act (PDPA), business contact information (e.g. name, business address, business telephone number) is not considered as Personal Data so long as it is used strictly for business-to-business (B2B) transactions.
2. Collection of Personal Data
2.1. We collect Personal Data when:
• You voluntarily provide to us, for example when you communicate with us via email, telephone or other channels. The data we collect includes contact information (your name, phone no., email address), company name, relevant department and position/job title and will be used strictly for B2B transactions.
• You have choices regarding our collection, use or disclosure of your personal data. You have the right to object to the processing of your personal data and withdraw your consent in a manner described in section 3 of this Policy.
• We may collect, disclose or use your personal data pursuant to an exception under the PDPA or other written law.
• In general, subject to the applicable exceptions permitted in the PDPA, before we collect personal data from you, we will notify you of the purposes for which your personal data may be collected, used and/or disclosed, as well as obtain your consent for the collection, use and/or disclosure of your personal data for the intended purposes. If you choose not to provide us with the personal data described in this Policy, we may not be able to fulfil the purposes listed in section 4 of this Policy.
• Any unsolicited personal data received by us will be returned to the sender immediately. If received by email or through our website, these unsolicited data will be deleted right away. If received by telephone, these will not be recorded.
3. Withdrawing Your Consent and its Consequences
3.1. Providing us with your Personal Data is voluntary. However, if you choose not to provide us with the Personal Data described in this Policy, we may not be able to fulfil our contractual duties towards you or facilitate your request or provide the service to you, or the company you may be representing.
3.2. You may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed in section 4 by submitting your request to our Data Protection Officer at the contact details provided in section 12.
3.3. Upon receipt of your 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 10 business days of receiving it. Should we require more time to give effect to a withdrawal notice, we will inform you of the time frame by which the withdrawal consent will take effect.
3.4. 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 services to you and we shall, in such circumstances, notify you on the consequences of the withdrawal before completing the processing of your request.
3.5. Please note that withdrawing your consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclosure without consent is permitted or required under applicable laws.
4. Use of Personal Data
4.1. We use the Personal Data you provide us for one or more of the following purposes:
• Provide you with information that you request from us or which we think may interest you;
• Respond to your enquires and feedback;
• Carry out obligations arising from any contracts entered into between you and us;
• Enter into a contract with you or manage our existing business relationship; and
• Comply with or fulfil legal obligations and regulatory requirements.
5. Disclosure of Personal Data
5.1. We may disclose your Personal Data to third party providers, agents and other organizations we have engaged to perform any of the functions listed in section 4 above for us; and
5.2. Where required to do so by law, we may disclose Personal Data about you to the relevant authorities or to law enforcement agencies.
6. Accuracy of Personal Data
7. Protection of Personal Data
7.1. We employ appropriate administrative, physical, technical and organizational security measures to help protect your Personal Data against loss and to guard against access by unauthorized persons.
7.2. If there is a need to disclose your Personal Data to third parties in the manner described in section 5, we will ensure that they provide sufficient guarantees to us to have implemented the necessary security measures to protect your Personal Data.
8. Retention of Personal Data
8.1. We will not retain any of your Personal Data when it is no longer needed for any business or legal purposes.
8.2. We will dispose of or destroy such documents containing your Personal Data in a secure manner as soon as it is reasonable to assume that the permitted purpose is no longer being served by their retention.
8.3. You may write in to us at the contact details provided in section 12 to find out how you can request for information about data retention period and how we destroy personal data after the end of the retention period.
9. Access and Correction to Your Personal Data
9.1. You have the right to know what Personal Data we have and process about you. You may write in to us at the contact details provided in section 12 to find out how we have been using or disclosing your Personal Data over the past one year.
9.2. You are also entitled to have incorrect Personal Data about you corrected and you may in some cases ask us to delete your Personal Data. You can also object to certain Personal Data about you being processed and request that processing of your Personal Data be limited.
9.3. Before we accede to your access or correction request, we may need to verify your identity by checking identification document, and the legitimacy of your request.
9.4. We will respond to your access or correction request as soon as reasonably possible, or within 30 calendar days from the date we receive your request. If we are unable to do so within 30 calendar days, we will let you know and give you an estimate of how much longer we require.
9.5. 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.
10. Transfer of Personal Data Outside of Singapore
10.1. We do not transfer personal data outside of Singapore.
10.2. In case transfer is necessary in line with the purposes listed in section 4, we will ensure that the standard of data protection in the recipient country is comparable to that of the Singapore Personal Data Protection Act 2012. If this is not so, we will enter into an agreement with the receiving party to accord similar levels of data protection as those in Singapore.
11. Data Breach Notification
11.1. In the event of a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data, we shall promptly assess the impact and if appropriate report this breach within 3 calendar days to the Personal Data Protection Commission (PDPC). We will notify you when the data breach is likely to result in significant harm to you after our notification to PDPC. We may also notify other relevant regulatory agencies, where required.
12. Contacting Us
Any query or complaint should include, at least the following details:
• Your Name and Contact Information
We treat such queries and feedback seriously and will deal with them confidentially and within reasonable time.
13. Effect of Policy and Changes to Policy
13.1. This Policy applies in conjunction with any other sources, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your Personal Data by us.
13.2. We may revise this Policy from time to time. Please visit our website periodically to note any changes. Changes to this Policy take effect when they are posted on our website.
13.3. Your continued use of our services constitutes your acknowledgment and acceptance of this Policy and any such changes.