This privacy policy (this “Policy”) sets out the manner in which Yare & Hark Pte. Ltd. (the “Company”) may collect, use, disclose or otherwise process the data, whether true or not, about an individual who can be identified either (a) from that data; or (b) from that data and other information to which we have or are likely to have access (“Personal Data”) in accordance with the Personal Data Protection Act 2012 of Singapore, as may be amended from time to time (“PDPA”).
1. COLLECTION OF INFORMATION
1.1 We provide management consultancy services. In order for us to render the services, it is necessary for us to collect and use certain Personal Data.
1.2 While the specific types of Personal Data you submit to us may vary depending on the relevant services enquired or provided, there are a few broad categories of Personal Data which are collected by us and/or our affiliates:
(a) Name;
(b) Identity data, which includes your country of residence, job title, age, marital status and/or gender;
(c) Contact data, which includes your residential address, e-mail address, fax and/or telephone number;
(d) Transaction data, which includes your payment details and other details of services that you have engaged us for;
(e) Usage data, which includes information about how you use our website (including the time you visit our website, the duration of your visit, the types of services you are searching for and/or how you are searching for such services);
(f) Marketing and communications data, which includes your interests, feedback, survey responses, preferences in receiving marketing materials from us and your communication preferences, as well as your preferences for particular services; and
(g) Technical data, which includes your Internet Protocol (IP) address, the internet device identity or media access control address of your device, information regarding the manufacturer, model or operating system of the device that you use and/or information about the web browser that you use to access our website.
1.3 How we collect your Personal Data
We collect your Personal Data:
(a) Directly from you. You may give us your identity, contact, profile and transaction data when you do any of the following (whether on your own behalf or on behalf of your organisation):
(i) use our website;
(ii) enquire about our services;
(iii) engage our services;
(iv) participate in a survey, event or other marketing campaign organised by us;
(v) subscribe to our newsletters or alerts;
(vi) request marketing materials to be sent to you; or
(vii) contact us.
(b) From your authorised representatives. We may also collect your identity, contact, profile and transaction data from your authorised representatives. These include persons whom you have authorised and persons who have been validly identified as acting on your behalf pursuant to our security procedures.
(c) When you interact with our website. As you interact with our website, we may automatically collect your technical data. We may collect such personal data by using website cookies.
(d) Third parties or publicly available sources. We may receive your Personal Data from third parties which are located in various countries. These include:
(i) Technical data from analytics providers such as Google, advertising networks and social media platforms such as LinkedIn and Facebook; and
(ii) Contact and transaction data from providers of technical, payment and delivery services.
2. PURPOSES FOR PROCESSING YOUR PERSONAL DATA
2.1 We may collect and use your Personal Data for any or all of the following purposes:
(a) To register you as a new client;
(b) To verify your identity;
(c) To process and deliver documents to you;
(d) To manage your account, including managing payments, fees and charges and collecting and recovering money owed to us;
(e) To manage our relationship with you;
(f) To administer, operate, provide, maintain and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data, as well as ensuring that unauthorised users do not access the information on our website);
(g) To make suggestions and recommendations to you about services that may be of interest to you;
(h) To send you relevant information about our events or news announcements;
(i) To enable you to participate in a survey, event or other marketing campaign organised by us;
(j) To contact you in relation to all of the above;
(k) To comply 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;
(l) Any other purposes for which you have provided the information; and
(m) Any other incidental business purposes related to or in connection with the above.
2.2 The purposes listed above 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).
2.3 Promotional offers and marketing
If you supply us with your contact data, you may receive periodic mailings, calls, e-mails, messages or faxes from us with information about new products and services or upcoming events. We will always obtain your consent to direct marketing communications where we are required to do so by law and if we intend to disclose your Personal Data to any third party for such marketing.
If you no longer wish to receive such mailings, faxes, messages, e-mails or calls, you may withdraw your consent by logging into our website and updating your preferences by e-mailing us at the address provided in Section 10 of this Policy.
2.4 Cookies
We use cookies to provide visitors with a personalised experience on our website. Cookies are pieces of information that a website transfers to the memory or hard drive of a visitor’s computer for record-keeping purposes. We use cookies to allow access without re-entering the visitor’s user ID, to make improvements, and to better tailor our website to our visitors’ needs. We also use this information to verify that visitors meet the criteria required to process their requests. Most browsers used by visitors have options that allow the visitor to control whether the browser will accept cookies, reject cookies, or notify the visitor each time a cookie is sent. However, if you disable or refuse cookies, please note that some parts of our website may become inaccessible or not function properly. In addition, you can delete your Yare & Hark cookies from your browser program at any time.
2.5 Change of purpose
We will only process your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If there is any change in the purposes for which we collect your Personal Data, we will inform you of such change. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at the address provided in Section 10 of this Policy. If we need to use your Personal Data for an unrelated purpose, we will notify you and will explain the legal basis which allows us to do so as well as obtain your consent to the use of your Personal Data for such purpose where we are required to do so by law.
3. DISCLOSURE OF INFORMATION
3.1 We may disclose your Personal Data to our affiliates and third parties in limited circumstances as set out below:
(a) We may share your Personal Data with our suppliers, agents or contractors in connection with services they perform for us or pursuant to agreements with our suppliers.
(b) We may share your Personal Data with third parties to comply with a legal obligation, when we believe in good faith that an applicable law requires it, at the request of government authorities conducting an investigation, to verify or enforce our contractual rights or other applicable policies, to detect and protect against fraud or any technical or security vulnerabilities, to respond to an emergency, or otherwise to protect the rights, property, safety or security of third parties and visitors to our website or the public.
(c) As we continue to develop our business, we may sell or purchase assets. If another entity acquires or merges with us, your Personal Data will be disclosed to such entity.
(d) Also, if any bankruptcy or reorganisation proceeding is brought by or against us, all such information will be considered an asset of ours and as such it is possible they will be sold or transferred to third parties.
3.2 We do not disclose your Personal Data to unaffiliated third parties for their independent use unless we have obtained your express consent to do so and pursuant to executing confidentiality agreements with such unaffiliated third parties. We also require all third parties to respect the security of your Personal Data and to treat it in accordance with the law.
4. RETENTION OF INFORMATION
4.1 We only retain your Personal Data for as long as is necessary for us to process your Personal Data as described above. However, please be advised that we may retain some of your Personal Data after you cease to use our services, for instance if the data is necessary to meet our legal obligations, such as retaining the information for tax and accounting purposes.
4.2 In some circumstances we may anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
5. INTERNATIONAL TRANSFERS OF INFORMATION
We do not transfer your Personal Data outside of Singapore. If we need to transfer your Personal Data to countries outside of Singapore, 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.
6. SECURITY
We take commercially reasonable precautions to keep all information obtained from our online visitors secure against unauthorised access, collection, use, disclosure, copying, modification, or disposal, or similar risks, and we periodically review our security measures. Although there is no way that any website can absolutely guarantee the security of your Personal Data, we are committed to employing reasonable security measures, regularly reviewing our security practices, and providing regular awareness training.
7. MAKING CHANGES TO YOUR PERSONAL DATA
You can access, correct, and edit any of the personal data that you have provided by contacting us through the address provided in Section 10 of this Policy.
8. LINKS TO OTHER SITES
Our website may contain links to other sites. These sites are not covered by this Policy, and we are not responsible for the privacy practices or the content of these sites.
9. CHANGES TO THIS POLICY
We reserve the right to modify this Policy and related business practices at any time by posting updated text on this page. Please check this page periodically for updates. Your continued use of our website and services constitutes your acknowledgement and acceptance of such changes.
10. CONTACT US
If you have any comments, questions or complaints about this Policy, please contact us through:
Yare & Hark Pte. Ltd.
7 Temasek Boulevard
#12-07 Suntec Tower One
Singapore 038987
Attention: Data Protection Officer
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