1. Introduction

At Straits Interactive Pte Ltd and/or Data Protection Excellence Network (“DPEX”) (collectively “Straits”) we respect the privacy and confidentiality of the personal data of our Customers, Associates and others whom we interact with in the course of providing our services. Being Data Protection Trustmark (DPTM) certified, we are committed to implementing policies, practices and processes to safeguard the collection, use and disclosure of the personal data you provide us, in compliance with the Singapore Personal Data Protection Act (PDPA) 2012. 

We have developed this Data Protection Notice to assist you in understanding how we collect, use, disclose, process, protect and retain your personal data that is in our possession.

For information on how we collect, use, disclose, process, protect and retain your personal data in relation to our Capabara suite of capability-as-a-platform services (“Capabara”), please refer to: https://capabara.com/privacy_notice/.

2. How We Collect Your Personal Data

Personal data refers to any information that can uniquely identify an individual person (a) on its own, or (b) when combined with other information. Under the PDPA, business contact information (e.g. full 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. 

We generally collect personal data that you knowingly and voluntarily provide:

• When you sign up as a member of the DPEX community or interact with our services
• When you visit or connect with us through our websites, webinars and through social media platforms
• When you enquire, register or enrol in any of the events, training courses and certification programmes (including our online e-learning courses)
• When you register for any of the competitions that we conduct
• When you respond to our electronic direct mails (EDMs) sent by us as part of our marketing or promotion campaigns through an authorised third party EDM service provider
• When you send us enquiries, complaints or feedback about our courses, events, services, or any other matters
• When you agree to be featured in photos, videos, testimonials, or any other forms of marketing or promotional media
• When you are referred to us for our training programmes and/or services by one of our clients
• When you enter into an agreement or contract with us to provide you with our consultancy and advisory services
• When you register for a Capabara account through our Capabara website and use the relevant services
• When you submit your CV and job application form (via email, in response to our recruitment advertisements and via a job portal)
• When you join our company as an employee, on a contract basis, or as an associate
• When you submit your visa and employment pass application forms through us to apply to the relevant government agencies on your behalf

3. Types of Personal Data We Collect About You

 The types of personal data we collect about you include (but are not limited to) the following:

• Your contact information (Name, Address, Phone No., Email Address)
• Your personal details (e.g. Name, Email Address, Organisation, School/Institution Name)
• Your personal and professional details contained in your curriculum vitae when you apply to us for a job
• Your courses taken with us (traditional and online)
• Your IP addresses and pages visited while using our online services
• Your bank account details and NRIC/Passport No (for employees, associates, contractors)
• Your account login details (for Capabara)

4 How We Use Your Personal Data

 We use the personal data you provide us for one or more of the following purposes:

 Enrolling you into government funded programmes

• Conduct training courses and certification programmes (including our online e-learning training programmes) that you have signed up for and/or purchased
• Provide our consultancy and advisory services
• Administer and maintain your DPEX network membership
• Analyse your visits to our websites and social media platforms
• Monitor the Capabara platform for any operational or technical errors/issues that may arise during user interactions with the platform, and taking appropriate action in the event such issues amount to a violation of the Capabara Terms of Use
• Processing your registration and administration of a competition that you registered for
• Conduct direct marketing and lead generation activities through analysing and tracking of your responses to our sales proposals, advertisements and EDMs in our events, conferences, seminars and workshops
• Conduct joint events, conferences, seminars and workshops with other companies and service providers
• Communicate with customers, members and website visitors (including when you leave a comment on our websites)
• Be featured on our website or any of our social media accounts as part of our promotional or marketing materials 
• Produce articles on data protection for publishing on our website
• Investigating and respond to your complaints, inquiries and feedback to improve our quality of service
• Analyse the use of our products, services or websites
• Process account payables/receivables
• Process billing, payment and other credit-related activities
• Process employment passes of our employees with the relevant government agencies
• Process visa applications of our employees with the relevant government agencies
• Process job applications, recruitment and selection
• Carry out our obligations arising from any contracts entered into between you and us
• Comply with or fulfil legal obligations and regulatory requirements

Please note that if you send us feedback or a complaint regarding a particular individual within Straits or associated with Straits, we may have to disclose your identity, as well as your feedback or complaint, to the individual concerned in order for us to carry out our investigations. If you do not wish for such information to be made known to the individual, please state so explicitly in your communications with us. However, please be aware that if you choose not to allow such information to be disclosed to the individual concerned, then it may hamper our investigations, and we may not be able to effectively resolve the issues raised by you. This paragraph does not apply in instances of whistleblowing.

5. Who We Disclose Your Personal Data To

 We disclose some of the personal data you provide us to the following entities or organisations outside Straits in order to fulfil our services to you:

• External and overseas Certification Authorities and educational institutions
• External professional service providers 
• EDM/Email Service Vendors 
• Cloud Service Providers
• Government Agencies – such as the Ministry of Manpower, CPF Board, IRAS, and IMDA
• External judges / partners for any competitions / events we conduct 
• Third Parties for the purposes of providing awards/prizes to winners for any competitions we conduct

 
Where required to do so by law, we may disclose personal data about you to the relevant authorities or to law enforcement agencies.

6. How We Manage the Collection, Use and Disclosure of Your Personal Data

6.1 Obtaining Consent

Before we collect, use or disclose your personal data, we will notify you of the purpose(s) why we are doing so. We will obtain written confirmation from you on your expressed consent. We will not collect more personal data than is necessary for the stated purpose. We will seek fresh consent from you if the original purpose for the collection, use or disclosure of your personal data has changed.

Under certain circumstances, we may assume deemed consent from you when you voluntarily provide your personal data for the stated purpose, e.g. when you apply for a job with us using our job application forms or when you attend our events and knowingly allow us to take your photographs or videos after being notified of the same.

We may rely on exceptions to the need for consent under the PDPA for the collection, use or disclosure of your personal data under the following circumstances (only those relevant to Straits are included):

• The personal data is publicly available
• The personal data is disclosed by a public agency or disclosed to a public agency
• The personal data is necessary for any investigation or proceedings
• The personal data is necessary for evaluative purposes (e.g. determining the suitability of a job applicant for the job applied for)
• The personal data is necessary for the purpose of managing or terminating an employment relationship
• The personal data is necessary for a business asset transaction
• To respond to an emergency that threatens your life, health and safety or of another individual

In circumstances where we collect the personal data of our minors (such as students, for our competitions), we will also request for the contact information of an authorised adult (such as a parent or a school teacher). This is an additional safeguard to ensure that an authorised adult is aware of the provision of information by the minors.

6.2 Withdrawal of Consent

You have choices regarding our collection, use or disclosure of your personal data. If you choose not to provide us with the personal data described in this Notice, we may not be in a position to process your required services. You have the right to withdraw your consent in the manner described in this section 6.2.

If you wish to withdraw consent, you should give us reasonable advance notice. We will advise you of the likely consequences of your withdrawal of consent, e.g. without your personal contact information we may not be able to inform you of future services offered by us. For any competitions that we conduct, a request for the withdrawal of your consent to the processing of your personal data will also amount to a request for your withdrawal from the competition.

Your request for withdrawal of consent can take the form of an email or letter to us, or through the “UNSUB” feature in an online service.

6.3 Use of Cookies

We use “cookies” to collect information about your online activity on our website. A cookie is a small text file created by the website that is stored in your computer to provide a way for the website to recognise you and keep track of your preferences. The cookie makes it convenient for you such that you do not have to retype the same information again when you revisit the website or in filling electronic forms.

Most cookies we use are “session cookies”, which will be deleted automatically from the hard disk of your computer at the end of the session.

You may choose not to accept cookies by turning off this feature in your web browser. Note that by doing so, you may not be able to use some of the features and functions on our websites or Capabara platform.

6.4 Third-Party Consent 

We do not obtain consent on behalf of another individual. We only obtain consent from the individual who will be dealing directly with us.

7. How We Ensure the Accuracy of Your Personal Data

We will take reasonable steps to ensure that the personal data we collect about you is accurate, complete, not misleading and kept up-to-date.

From time to time, we may do a data verification exercise for you to update us on any changes to the personal data we hold about you. If we are in an ongoing relationship with you, it is important that you update us of any changes to your personal data (such as a change in your mailing address).

8. How We Protect Your Personal Data

We have implemented appropriate information security and technical measures (such as data encryption, firewalls and secure network protocols) to protect the personal data we hold about you against loss, misuse, destruction, unauthorised alteration/modification, access, disclosure, or similar risks. These are governed by our internal data protection and information security policies, and other relevant SOPs.

We have also put in place reasonable and appropriate organisational measures to maintain the confidentiality and integrity of your personal data, and will only share your data with authorised persons and third parties on a ‘need to know’ basis. 

When we engage third-party data processors to process personal data on our behalf, we will ensure that they provide sufficient guarantees to us to have implemented the necessary organisational and technical security measures, and have taken reasonable steps to comply with these measures. 

9 How We Retain Your Personal Data

We have a document retention policy that keeps track of the retention schedules of the personal data you provide us, in paper or electronic forms. We will not retain any of your personal data when it is no longer needed for any business or legal purposes. 

We will dispose of or destroy such documents containing your personal data in a proper and secure manner when the retention limit is reached.

10 How You Can Access and Make Corrections to Your Personal Data 

You may write in to us to find out how we have been using or disclosing your personal data over the past one year. Before we accede to your request, we may need to verify your identity by sighting your NRIC or other legal identification documents. We will respond to your request as soon as possible, or within 30 days from the date we receive your request. If we are unable to do so within the 30 days, we will let you know and give you an estimate of how much longer we require. We may also charge you a reasonable fee for the cost involved in processing your access request. 

If you find that the personal data we hold about you is inaccurate, incomplete, misleading or not up-to-date, you may ask us to correct the data. Where we are satisfied on reasonable grounds that a correction should be made, we will correct the data as soon as possible, or within 30 days from the date we receive your request.

11 Transfer of Personal Data

Where there is a need to transfer your personal data to another country outside Singapore, we will ensure that the standard of data protection in the recipient country is comparable to that of Singapore’s PDPA. If this is not so, we will enter into a contractual agreement with the receiving party to accord similar levels of data protection as those in Singapore. 

12 Contacting Us

If you have any query or feedback regarding this Policy, or any complaint you have relating to how we manage your personal data, you may contact our Data Protection Officer (DPO) at: dpo@straitsinteractive.com.

Any query or complaint should include, at least, the following details:

• Your full name and contact information 
• Brief description of your query or complaint

We treat such queries and feedback seriously and will deal with them confidentially and within a reasonable time.

13 Changes to this Data Protection Notice

We may update this Data Protection Notice from time to time. We will notify you of any changes by posting the latest Notice on our website. Please visit our website periodically to note any changes.

Changes to this Notice take effect when they are posted on our website.

Last updated on 16 Dec 2024.