Last updated 1 October 2021
In accordance with The Personal Data Protection Act (“PDPA”), this Personal Data Protection Policy (“Policy”) describes how we may collect, use, disclose and manage your personal data. For general information on Personal Data Protection, please visit the Personal Data Protection Commission (“PDPC”) website (https://www.pdpc.gov.sg).
In this Policy, “Personal Data” refers to any 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, including data in our records as may be updated from time to time.
1. TYPES OF PERSONAL DATA WE COLLECT
Personal data which we may collect include but are not limited to :
a. your personal information such as your name, NRIC/FIN/Passport number, date of birth, marital status, gender;
b. your contact information such as postal addresses, email addresses, telephone, mobile phone and fax numbers;
c. your past and present employment information such as organisation name, organisation type, industry sector, job function and responsibilities, designation, business telephone and fax numbers, business email addresses;
d. your past and present academic qualifications such as schools attended, courses of study, period of study and academic results;
e. your billing and payment information such as credit card numbers, debit card numbers or bank account information;
f. photographs and other audio-visual information.
-> If you provide us with any Personal Data relating to a third party (eg. information of your spouse, children, parents, and/or employees), by submitting such information to us, you represent and warrant to us that you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes.
-> If you are residing in Europe, including the UK, we will process personal data in accordance with the General Data Protection Regulation 2016/679 and similar European and UK data protection and data security laws (the “European and UK Data Protection Laws”).
-> Lanturn collects information about you when you use our website(s), website/IT portal(s)/mobile application(s), forms, surveys, and/or other channels and throughout other interactions, communications and services you have with us.
-> We may receive information about you from third parties if you use any websites or social media platforms operated by third parties (for example, Linkedin, Facebook, Instagram, Twitter etc.) and, if such functionality is available, you have chosen to link your profile on our website(s) or website/IT portal(s)/mobile application(s) with your profile on those other websites or social media platforms.
2. PURPOSES FOR WHICH THE PERSONAL DATA IS COLLECTED, USED AND DISCLOSED
We will/may collect, use, disclose and/or process your personal data for one or more of the following purposes :
-> To perform obligations in the course of or in connection with our provision of the goods and/or services requested by you;
-> To verify your identity;
-> To carry out due diligence or other screening activities (including security and background checks) in accordance with legal or regulatory obligations or our risk management procedures that may be required by law or that may have been put in place by us;
-> To contact you or communicate with you via various modes of communication such as phone/voice call, text message and/or fax message, forms, task manager, website, email and/or postal mail for the purposes of processing queries, requests, applications, complaints, and feedback from you;
-> To manage your relationship with us;
->To facilitate and/or deal with payment or credit transactions;
-> For marketing purpose where we send you news, information, materials and/or updates about events, marketing campaigns, products and/or services that we and/or our business partners provide, or on our behalf. In this regard, we will be doing so by way of postal mail and/or electronic transmission to your email address(es). You may unsubscribe from this service in the manner set out in Clause 8 below;
-> 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;
-> To prevent or investigate any fraud, unlawful activity or omission or misconduct, whether or not there is any suspicion of the aforementioned; dealing with conflict of interests or dealing with and/or investigating complaints;
-> For financial reporting, regulatory reporting, management reporting, risk management, audit and record keeping purposes;
-> Any other purposes for which you have provided the information; (i) 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.
In addition, Lanturn Pte.Ltd. collects, uses and discloses your Personal Data for the following purposes, depending on the nature of your relationship with us:
If you are an existing employee
-> administrative and support processes, including management and termination, staff benefits, remuneration, processing expense claims, medical insurance, training and organising corporate events;
-> staff orientation and entry processing;
-> providing you with tools and/or facilities to enable or facilitate the performance of your duties;
-> conducting analytics and research for human resource management, and for us to review, develop, optimise and improve work-related practices, environment and productivity;
-> any other purpose reasonably related to employment practices.
If you submit an application to us as a candidate for an employment position:
-> background checks, and verifying all your employment details and qualifications;
-> obtaining employee references;
-> assessing your suitability for the position applied for;
-> work pass applications; and
-> any other purposes relating to employment practices.
We will/may disclose your personal data for the following purposes, depending on the nature of your relationship with us:
-> where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods or services requested by you; or
-> to third party service providers, agents and other organisations including to banks, payment service providers and/or other payment gateways, whether located within or outside Singapore, for one or more of the above Purposes, as such third parties, would be processing your personal data for one or more of the above Purposes.
-> to liquidator, receiver, official assignee/trustee, judicial manager or any other person appointed under or pursuant to any applicable law or court order in connection with the bankruptcy, liquidation, winding up, judicial management or any other analogous process in respect of any individual, company or business;
-> any judicial, administrative or regulatory body, any government or public agency, statutory boards or authorities or law enforcement bodies;
-> our existing or future related companies;
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 any contract with you).
3. STORAGE OF PERSONAL DATA
Security of your personal data is important to us. We take appropriate action to protect personal data from loss, misuse, unauthorised access or disclosure, alteration or destruction using the same safeguards as we use for our own proprietary information. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our website(s) or website/IT portal(s)/mobile application(s), you are responsible for keeping this password confidential.
We will put in place measures such that your personal data in our possession or under our control is destroyed and/or anonymised as soon as it is reasonable to assume that (a) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (b) retention is no longer necessary for any other legal or business purposes.
4. TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
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.
5. ACCURACY OF PERSONAL DATA
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.
6. DATA PROTECTION OFFICER
The Data Protection Officer
160 Robinson Road
160 Robinson Road #24-09 SBF Centre, Singapore 068914
7. LINK TO OTHER WEBSITES
Our websites may contain links to other websites operated by third party companies with different privacy practices. You should remain alert and read the privacy statements of other sites. We have no control over personal data that you submit to or receive from these third parties.
WITHDRAWAL OF CONSENT
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 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 at the contact details provided below.
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 services to you and we shall, in such circumstances, notify you before completing the processing of your request. 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.