Personal Data Protection Policy
Artan Consulting Pte Ltd, Singapore
(SINGAPORE)
VERSION 1.0
Effective date:15/05/2023 Last updated: 23/07/2023
We at Artan Consulting Pte. Ltd., Singapore, take our customers’ privacy seriously, and we only collect and use your personal information as outlined below.
1. Purpose of the policy
This Personal Data Protection Policy, in compliance with PDPA, outlines the obligations and best practices we will follow in protecting clients’, customers’, members’ personal data. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our clients’, customers’, members’ personal data and allowing our clients or customers or members to request access to, and correction of, their personal data.
This Data Protection Notice (“Notice”) sets out the basis on which Artan Consulting (“we”, “us”, or “our”) may collect, use, disclose or otherwise process the personal data of our customers in accordance with the Personal Data Protection Act (“PDPA”) of Singapore.
This Notice applies to personal data in our possession or under our control, including personal data in the possession of firms or organizations which we have engaged to collect, use, disclose or process personal data for our purposes.
2. Personal Data
[a]. As used in this Notice:
“customer” or “client” means an individual who (a) has contacted us through any means to find out more about any products or services we provide, or (b) may, or has, entered into a contract with us for the supply of any products or services by us; and
“personal data” means information about an identifiable individual whether as standalone (Unique Identifier) or when combined, 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.
[b]. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include:
• First, middle and last name, previous names
• Street address, city, state, country, postal code
• Date of birth
• Place of birth
• Gender
• Race
• Ethnicity
• Country of origin
• Employment history
• Native language
• Identification Number (e.g., Passport number)
• Address type
• Email address
• Valid day or evening telephone number
• Mobile phone number
• Citizenship
• Military affiliation
• Prior education history
• Social Networking content
[c]. Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).
3. Scope of this policy
This Personal Data Protection Policy applies to Artan Consulting Pte Ltd, Singapore and its subsidiaries. (If applicable; meaning the Data flow processes are similar).
The audience of this policy is for all relevant departmental heads to work with their subordinates and integrate it into their various SOPs, so as to comply with the PDPA and better protect the personal data in their possession.
This policy also applies to any service providers collecting, using or disclosing personal data on behalf of Artan Consulting Pte Ltd, Singapore.
• We will only use your email for newsletter, webinar, and any update on our upcoming courses or any changes in our course schedule.
• If you don’t wish to receive our newsletter update, please unsubscribe from our email list or kindly send us the email to delete your email from our newsletter list.
• We do not provide any software to our trainers and trainees (participants/students). All trainers and participants must bring their own laptops for hands on practice sessions.
• We are not liable to the software installed on trainers’ and participants’ laptops and computers.
• Trainers and participants are liable to the software installed on their own laptops and computers.
Collection, Use And Disclosure Of Personal Data
4. We generally do not collect your personal data unless:
(a) Personla data 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 of the following purposes:
• To provide requested products and services
• Performing obligations in the course of or in connection with our provision of the products and/or services requested by you;
• Verifying your identity;
• Responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
• For our internal marketing purposes, which include, but are not limited to, sending you material about products, services, updates, etc. that we think may be of interest to you
• Managing your relationship with us;
• Processing payment or credit transactions;
• 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;
• 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; and
• Any other incidental business purposes related to or in connection with the above.
• To respond to your inquiries and provide customer support
• For fostering communication and collaboration among users of our Sites through Social Networks
• To analyse how Sites and services are being accessed and used
• To administer promotions in which you have indicated an interest
• For sharing with our Business Associates or employees who are performing services on our behalf
• For investigation of information security and information asset protection-related incidents
• To test, correct and improve our content, applications and services
• To develop new applications, products and services
• To improve Site and service performance and delivery
• To prevent potentially illegal activities (including illegal downloading of copyrighted materials in accordance with our Copyright Infringement policy)
• To investigate suspicious information that denotes illegal activity such as financial aid fraud
• To analyse academic and learning outcomes and preferences
• To obtain payment for services that we provide to you
• To provide you with information concerning arrangements and other options for the repayment of funds loaned to you for your education
• To maintain business records for reasonable periods
• To enforce our Terms of Use
• To provide to Business Associates or Unrelated Entities in connection with the contemplated or actual reorganization, merger, acquisition, financing, securitization, insuring, sale or other disposal of all or part of our business or assets, including for the purposes of determining whether to proceed with such transaction or fulfilling any records or other reporting requirements to such parties. In the event of any actual reorganization, merger or acquisition, such Information may be transferred as part of the transaction to the acquirer
• And/or as may be required or permitted by legal, regulatory, industry self-regulatory, insurance, audit or security requirements applicable to Artan Consulting Pte Ltd and its parent company, or our Business Associates
6. We may disclose your personal data:
(a) where such disclosure is required for performing obligations in the course of or in connection with our provision of the products and services requested by you; or
(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.
7. 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
8. We may collect or use your personal data, or disclose 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 Artan Consulting intends to rely on deemed consent by notification for such secondary purposes, Artan Consulting will notify you of the proposed collection, use, or disclosure of his personal data through appropriate mode(s) of communication.
9. In particular, we may rely on deemed consent by notification to collect, use or disclose your personal data for the following purposes:
i. Website
ii. Mobile app
iii. Mobile/phone
10. Before relying on deemed consent by notification, Artan Consulting will assess and determine that the collection, use, and disclosure of the personal data will not likely have an adverse effect on you.
11. 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.
12. After the lapse of the opt-out period, you may notify us that you no longer wish to consent to the purposes for which your consent was deemed by notification by withdrawing your consent for the collection, use, or disclosure of your personal data in relation to those purposes.
Reliance On The Legitimate Interests Exception
13. In compliance with the PDPA, we may collect, use or disclose your personal data without your consent for the legitimate interests of Artan Consulting or another person. In relying on the legitimate interests exception of the PDPA, Artan Consulting will assess the likely adverse effects on the individual and determine that the legitimate interests outweigh any adverse effect.
14. 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.
How You Can Withdraw Your Consent
15. 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 of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer (“DPO”) at the contact details provided in the section below.
16. Once we receive 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 three (3) business days of receiving it.
17. Though 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 products 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.
18. 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
19. 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 the contact details provided below.
20. Please note that we may charge you a reasonable fee for an access request. If this case, we will inform you of the fee before we process your request.
21. We will respond to your request as soon as reasonably possible. In general, our response will be within three (3) business days. 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
22. 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,
• Data encryption and data anonymisation,
• Having authentication, identification, and access controls (such as sound password usage practices, implementing need-to-basis for data disclosure, and handleing etc.),
• Up-to-date antivirus protection,
• Regular patching of operating system and other software,
• Web security measures against any data privacy risks,
• Securely erase storage media in devices before disposal,
• And, performing security review and testing on a regular basis.
23. 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 Or Correctness Of Personal Data
24. 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.
Retention Of Personal Data
25. 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.
26. 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.
Personal Data Transfers Outside Of Singapore
27. 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 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.
Collection and Use of Cookies
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. By continuing to browse the site, you are agreeing to our use of cookies. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree. Cookies contain information that is transferred to your computer’s hard drive.
We use the following cookies:
• Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
• Advertisement cookies. These cookies are from various other websites to record the customer visits
Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
Our website uses Google Analytics, a web traffic analysis service provided by Google Inc. (“Google”) and other similar tools.
Please refer to http://www.google.com/policies/privacy/partners to find out more about how Google uses data when you use our website and how to control the information sent to Google. You can block the cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site. Furthermore, you can prevent Google’s collection and processing of data by using the Google Ads Settings page or downloading and installing their browser plug-in (https://tools.google.com/dlpage/gaoptout).
Data Protection Officer
28. 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:
Name of DPO : Data Protection Officer
Email Address : contact@artanconsulting.com
Effect Of Notice And Changes To Notice
29. 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.
30. 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.