The purpose of this document ("Policy") is to inform you of how WongPartnership LLP handles personal data which is subject to the Personal Data Protection Act (No. 26 of 2012) of Singapore ("PDPA").
By interacting with us, submitting information to us, or engaging our services, you agree and consent to WongPartnership LLP (including its branches, associate offices and affiliates) ("the Firm"), as well as our service providers and third parties appointed by us on your behalf (collectively, "us", "we" or "our") collecting, using and disclosing your Personal Data in the manner set forth in this Policy.
This Policy supplements but does not supersede nor replace any other consents you may have previously provided to the Firm in respect of your Personal Data, and your consents herein are additional to any rights which to the Firm may have at law to collect, use or disclose your personal data.
We may from time to time update this Policy. Updates will be posted on our Firm website. By continuing to interact with us, subject to applicable law, you agree to be bound by the prevailing terms of the Policy as so updated from time to time.
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, but excludes "business contact information" as defined in the PDPA.
1. How We Collect Personal Data
1.1 Generally, the Firm may collect Personal Data in various ways including:
(a) in the course of your engaging our services, or your providing documentation or information to us;
(b) when you communicate or interact with us via telephone, letters, fax, face-to-face meetings, our website, email or other modes of contact. Telephone calls may be recorded;
(c) CCTV recordings while you are within our premises;
(d) when you attend a seminar or other event organised by us;
(e) photographs or videos taken by us or our representatives when you attend events hosted by us;
(f) when you request that you be included in an email or other mailing list;
(g) when you submit an employment application or provide documents or information such as your resume, from recruitment agencies and employment references;
(h) from public information sources, search services and other third parties; and
(i) when you submit your Personal Data to us for any other reason.
1.2 If you provide us with any Personal Data relating to a third party, by submitting such Personal Data to us, you also represent to us and must ensure that you have notified the third party of the terms of this Policy and obtained his consent thereto.
2. Purposes for which we Collect, Use and Disclose Personal Data
2.1 Generally, the purposes for which the Firm collects, uses and discloses Personal Data include:
(a) providing our services;
(b) responding to, processing and handling your queries, feedback and suggestions;
(c) verifying your identity, processing payments as well as managing our administrative and business operations;
(d) managing the security of our premises, facilities and technology infrastructure;
(e) providing updates and other communications on developments relating to the law and in respect of our Firm;
(f) to improve our services and communications to you;
(g) complying with applicable laws and regulations, codes of practice or guidelines, policies, procedures, regulatory requirements (which may extend to know-your-client and related reviews) and directions issued by relevant authorities;
(h) the establishment, exercise or defence of any legal or equitable claim; and
(i) any other purpose relating to any of the above.
2.2 In addition, if you are seeking employment or any other appointment with the Firm, the purposes for which the Firm collects, uses and discloses Personal Data include:
(a) processing and assessing your application;
(b) performing background checks, verifying your credentials and qualifications as well as obtaining employment references; and
(c) any other purpose relating to any of the above.
2.3 In relation to particular services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.
3. Disclosing your Personal Data
3.1 The Firm may disclose Personal Data as follows:
(a) to technical consultants, experts and foreign law firms assisting with your matters;
(b) to agents, contractors or third party service providers who provide operational or administrative services, such as courier services, telecommunications, information technology, payment, payroll processing, training, market research, storage, archival, client support services;
(c) in connection with professional indemnity policies, and to our professional advisers including auditors;
(d) to any relevant authorities, including professional regulatory bodies and/or law enforcement agencies, whether local or overseas;
(e) to the extent necessary to comply with any laws, regulations, rules, directions, guidelines and other similar requirements;
(f) where permitted under law, external business and charity partners in relation to the Firm’s promotional events and seminars; and
(g) any other party to whom you authorise us to disclose your Personal Data.
3.2 You further understand, acknowledge and agree that where you have engaged us to carry out any work in any jurisdictions outside Singapore, the transfer of your personal data records to these jurisdictions may be necessary to give effect to your instructions and that you request and consent to our so transmitting your personal data outside Singapore. Personal data may therefore be exported to, processed and accessed in countries whose laws provide a different level of protection, which may not necessarily be comparable to that provided in Singapore.
4. Our Website
4.1 When you browse our website, you generally do so anonymously and we do not at our website automatically collect Personal Data, including your email address unless you provide such information. You may however wish to note the following:
(a) Your IP Address
An IP address is a number that is automatically assigned to your computer when you are connected to the Internet.
When you visit our website, your IP address is automatically logged in our server. We use your IP address to help diagnose problems with our server, and to administer our website. From your IP address, we may identify the general geographic area from which you are accessing our website; however, we will not be able to pinpoint the exact geographic location from which you are accessing our website. Generally we do not link your IP address to anything that will enable us to identify you unless it is required by applicable laws and regulations.
You can adjust settings on your browser so that you will be notified when you receive a cookie. Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser. However, your ability to use our website or the functionality thereof may be affect.
Please refer to your browser documentation to check if cookies have been enabled on your computer or for adjusting your browser settings to not to receive cookies.
4.2 Our website may contain links to other sites that are operated by third parties with different privacy practices. We have no control over and do not take any responsibility for these third party websites and their personal data handling practices, and you are encouraged to review the personal data policies of web sites you choose to visit which are linked from our website.
5. Withdrawal of Consent, Access and Correction of your Personal Data
5.1 If you:
(a) have any questions or feedback relating to your Personal Data or our Policy;
(b) would like to withdraw your consent to any use of your Personal Data as set out in this Policy; or
(c) would like to obtain access and make corrections to your Personal Data records, please contact our Data Protection Officer, as follows:
Telephone: +65 6416 8000
Address: 12 Marina Boulevard Level 28, Marina Bay Financial Centre Tower 3, Singapore 018982.
If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, we may not be in a position to continue to provide our services to you.
Last Updated on 1 July 2014.