PRIVACY POLICY
This Policy sets out the manner in which Starvision Information Technology Pte Ltd (hereafter called “Starvision”) collects, uses, manages and protects Personal Data (as defined below) in compliance with the provisions of the Personal Data Protection Act 2012.
This Policy applies to all Individuals (as defined below) who provide Starvision with Personal Data or whose Personal Data is otherwise collected, used and/or disclosed by Starvision in connection with and/or for the purposes of its operations.
This Policy supplements but does not supersede or replace any previous consent which an Individual may have provided to Starvision, nor does it affect any rights that Starvision may have at law in connection with the collection, use and/or disclosure of any Individual’s Personal Data. Subject to that, Starvision will not collect any Personal Data from an Individual unless the Individual has voluntarily chosen to provide us with it.
Starvision may from time to time update this Policy to ensure it is consistent with its future developments or business purposes or to accommodate future changes to applicable legal or regulatory requirements. Subject to an Individual’s rights at law, the prevailing terms of the Policy from time to time shall apply. By continuing their relationship with Starvision after any amendments have been introduced and published, Individuals shall be deemed to have accepted the Policy as amended.
For the avoidance of doubt, this Policy forms part of the terms and conditions, if any, governing an Individual’s specific relationship with Starvision (“Terms and Conditions”) and should be read in conjunction with such Terms and Conditions. In the event of any conflict or inconsistency between the provisions of this Policy and the Terms and Conditions, the provisions of the Terms and Conditions shall prevail to the fullest extent permissible by law.
DEFINITIONS
“Data Protection Officer” means the person designated to be responsible for ensuring that Starvision complies with the PDPA;
“Individuals” means natural persons, whether living or deceased, and “Individual” means any of them;
“Customers” mean the customers of Starvision from time to time;
“PDPA” means the Personal Data Protection Act 2012;
“Personal Data” means data that is capable of identifying a natural person, whether on its own or in conjunction with other data that is accessible to Starvision;
“Personnel” shall include any person engaged under a contract of service or contract for service with Starvision, management personnel, permanent or temporary employees, as well as trainees, interns and volunteers engaged by Starvision from time to time; and
“Potential Personnel” shall include any Individual who has submitted an application to be engaged by Starvision as Personnel.
PERSONAL DATA COLLECTED BY STARVISION
Starvision will only collect, use or disclose Personal Data about an Individual which it reasonably considers necessary for the relevant purposes underlying such collection, use or disclosure. Depending on the specific nature of an Individual’s interaction with Starvision, Personal Data which Starvision collects, uses or discloses concerning an Individual may variously include the following:
(a) the Individual’s name, gender and contact particulars, including telephone number(s), residential/mailing address(es) and email address;
(b) details of the Individual’s identification documents (such as, NRIC or passport numbers), and applicable visa or permits (such as employment pass, work permit, permanent residency status);
(c) details of the Individual’s employment history and academic qualifications;
(d) details of the Individual’s CPF, credit card or bank account;
(e) the name and contact particulars of the Individual’s next-of-kin;
(f) details of the Individual’s hobbies or special interest areas;
(g) the Individual’s network usage data and other information gathered automatically by our computer systems, including the Individual’s computer IP address, links visited and other activities conducted online or using our computer systems;
(h) photographs and video or CCTV recordings of the Individual; and
(i) other information which the Individual may provide to Starvision, from time to time, in the course of such Individual’s interaction with Starvision.
HOW STARVISION COLLECTS PERSONAL DATA
Generally, Starvision may collect Personal Data about an Individual in one or more of the following ways:
(a) through application or registration forms submitted by the Individual;
(b) through correspondence, emails or electronic messages submitted by the Individual to Starvision or otherwise posted on Starvision’s website(s);
(c) through the Individual’s interaction with Starvision Personnel in relation to our products and services, including customer service officers, for example via telephone calls (which may be recorded), direct mails, fax, face-to-face meetings, social media platforms, emails or any other means;
(d) through surveys conducted with and/or feedback received from an Individual;
(e) through the Individual’s access to and/or use or navigation of Starvision’s website(s) and its computer network and the use of cookies;
(f) when the individual submits their Personal Data to us when entering our premises or through recordings of the Individual when attending at Starvision’s premises or at any events or programmes organised by Starvision;
(g) through third party business partners or associates of Starvision;
(h) when we receive the Individual’s Personal Data from business partners, public agencies, Individual’s ex-employer, referral intermediaries, and any third parties or the relevant authorities, for example where the Individual has been referred by business partners or where we have sought information about in connection with the Individual’s relationship with us, including for our products and services or job applications; and/or
(h) when the Individual submits his/her Personal Data to Starvision for any other reason related to Starvision’s ordinary course of operations.
PURPOSES FOR WHICH STARVISION MAY COLLECT, USE AND/OR DISCLOSE PERSONAL DATA
Generally, Starvision may collect, use and/or disclose Personal Data about an Individual for one or more of the following purposes:
CUSTOMERS
(a) administering and managing customer relationships with Starvision, including the provision of services to Customers by Starvision’s staff in Singapore and overseas to carry out their job obligations with appropriate technical and organizational measures in place and to assist with the resolution of technical support issues relating to the Software, whether via ticketing system, telephone calls or otherwise;
(b) providing Customers with information about services, facilities and/or other benefits being offered or made available by Starvision to Customers;
(c) providing Customers with information about third party and/or external vendor/supplier promotions, deals and/or other services being offered or made available to Customers, through partnerships, associations and/or other collaborations involving such third parties or external vendors/suppliers and Starvision;
(d) organising and/or facilitating events or programmes involving Customers and/or verifying the eligibility of such Customers to participate in such events or programmes;
(e) tailoring activities or services available to match Customers’ preferences; and
(f) transmitting Personal Data to third parties engaged by or working in collaboration with Starvision to facilitate any of the above-mentioned purposes.
PERSONNEL
(a) administering and managing Personnel relationships with Starvision, including the provision of services to Personnel;
(b) evaluating the performance of Personnel;
(c) undertaking staff training and quality assurance activities;
(d) providing Personnel with services, facilities and/or other benefits being offered or made available by Starvision to such Personnel as well as information about such services, facilities and benefits; and
(e) transmitting Personal Data to third parties engaged by or working in collaboration with Starvision to facilitate any of the above-mentioned purposes.
POTENTIAL PERSONNEL
(a) administering and managing Starvision’s relationship with Potential Personnel; and
(b) evaluating the suitability and eligibility of Potential Personnel to be engaged by Starvision;
VISITORS AND USERS OF STARVISION’S FACILITIES
(a) recording and verifying the identity of visitors to Starvision’s premises and users of Starvision’s facilities; and
(b) monitoring the activities of visitors to Starvision’s premises and users of Starvision’s facilities.
GENERAL BUSINESS PURPOSES
(a) managing the administrative and business operations of Starvision;
(b) facilitating the completion of transactions with Individuals;
(c) responding to complaints, queries and/or requests;
(d) safety and security purposes;
(e) record-keeping purposes;
(f) accounting or auditing purposes;
(g) legal purposes (including but not limited to obtaining legal advice and dispute resolution); and
(h) complying with laws, regulations, codes or guidelines binding on Starvision, including disclosures to regulatory authorities or other public bodies; and
(i) transmitting Personal Data to third parties engaged by or working in collaboration with Starvision to facilitate any of the above-mentioned purposes.
PURPOSES REASONABLY RELATED TO ANY OF THE ABOVE PURPOSES
(a) for any purposes reasonably related and/or ancillary to any of the abovementioned purposes.
PURPOSES FOR WHICH SPECIFIC CONSENT WAS OBTAINED
(a) for any other purposes for which the Individual’s consent was specifically given or obtained.
CONSENT
Unless otherwise authorised under the PDPA or any other applicable law, Starvision will not collect, use or disclose an Individual’s Personal Data without his/her consent.
Starvision will take reasonable steps to highlight the purposes relevant to an Individual, by appropriate means, at the point or time of collection of the Personal Data from such Individual, including:
(a) via express provisions in contracts, application forms and/or registration forms to be signed with or submitted to Starvision;
(b) via notifications on Starvision’s websites; and
(c) in the course of verbal communications.
Where feasible, Starvision will inform the Individual of purposes that are intrinsic to the relationship between Starvision or to the provision of services to such Individual, as well as purposes that are optional.
In so far as any purpose(s) are intrinsic to the relationship or provision of services, Starvision reserves the right to decline to engage in the relevant relationship or to provide the relevant services to the Individual if he or she does not consent to Starvision’s collection, use or disclosure of his/her Personal Data for such purpose.
Individuals who:
(a) voluntarily provide their Personal Data to Starvision for the specified purposes;
(b) use or access Starvision’s website(s) or computer network;
(c) enter Starvision’s premises or using any of the facilities thereon; and/or
(d) attend or participate in events or programmes organised by Starvision.
will be deemed to agree and consent to Starvision collecting, using and/or disclosing their Personal Data in the manner and for the purposes set forth in this Privacy Policy.
An Individual who provides Starvision with Personal Data relating to a third party (e.g. information of his/her spouse or children) for any particular purpose, represents to Starvision that he/she has obtained the consent of the relevant third party to Starvision collecting, using or disclosing such Personal Data for the relevant purpose.
ACCESS AND CORRECTION OF PERSONAL DATA
(a) Under the PDPA, an Individual has the right to make an
- access request for access to a copy of the Personal Data that we hold about them or information about the ways in which we use or disclose their Personal Data; or
- correction request to correct or update any of their Personal Data held by us, by submitting the request in writing or via email to our Data Protection Officer (“DPO”) at the contact details provided below. Subject to the provisions of Data Protection Laws, we will endeavour to respond to the access and/or correction request within 30 days after receiving such request. If we are unable to respond to the access and/or correction within 30 days after receiving such request, we will inform the Individual in writing within 30 days of the time by which we will be able to respond to the request.
(b) Depending on the scope and nature of the work required to process the access and/or correction request, we may be required to impose a fee to recover our administrative costs. This will be assessed on a case-by-case basis by our DPO. Where such a fee is to be imposed, we will inform the Individual of the fee before processing the request. We will only process the request once payment of the fee has been agreed by the Individual. In certain cases, we may also require a deposit from the Individual before we process the access request.
WITHDRAWAL OF CONSENT
(a) The consent that an Individual provides for the collection, use and disclosure of their personal data will remain valid until such time it is being withdrawn by in writing. The individual may withdraw consent and request us to stop collecting, using and/or disclosing their personal data for any or all of the purposes listed above by submitting their request in writing or via email to our Data Protection Officer at the contact details provided below.
(b) Upon receipt of the Individual’s written request to withdraw consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with the Individual) for their request to be processed and for us to notify the Individual of the consequences of us acceding to the same, including any legal consequences which may affect their rights and liabilities to us. In general, we shall seek to process the request within five (5) business days of receiving it.
(c) Whilst we respect the decision to withdraw consent, depending on the nature and scope of the request, we may not be in a position to continue providing our goods or services to the Individual or administer any contractual relationship in place, which in turn may also result in the termination of any agreements with Starvision, and the Individual being in breach of their contractual obligations or undertakings. Starvision’s legal rights and remedies in such event are expressly reserved. Starvision shall, in such circumstances, notify the Individual before completing the processing of the request. Any decision to cancel the withdrawal of consent will have to be sent in to Starvision in writing.
(d) 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.
PROTECTION OF PERSONAL DATA
Starvision shall make reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, modification, copying, disposal or similar risks to Personal Data in its possession.
Starvision will ensure that third parties who receive Personal Data from Starvision protect such Personal Data in a manner consistent with this Policy and not use such Personal Data for any purposes other than those specified by Starvision, by incorporating appropriate contractual terms in its written agreements with these third parties.
Starvision is not responsible in any way for the security and/or management of Personal Data shared by Individuals with third party websites accessible via links on Starvision’s website.
Transfers of Personal Data outside of Singapore
Where applicable, the Individual’s Personal Data may be stored in external servers located overseas. In addition, as described above, in the course of our business operation needs, we may be required, from time to time, to transfer the Personal Data with and between our related corporations and/or organisations and their affiliates, and third-party service providers, some of which may be located in countries outside of Singapore. For example, the personal data stored in the Software may be transferred overseas for support functions. The personal data transfer will be in accordance with requirements prescribed under the PDPA or applicable data protection law to ensure that organization provide a standard of protection to personal data. Rest assured, where we disclose personal data to a third party in another country, we put safeguards in place to ensure the personal data remains protected.
Requests for Information or Complaints
(a) Any question relating to an Individual’s Personal Data held by Starvision or request for information relating to our Privacy Policy can be sent via email to our Data Protection Officer at the contact details below.
(b) Where it is an email or a letter relating to a complaint, an indication, such as inserting “PDPA Complaint” at the subject header, that it is a PDPA complaint would assist the relevant staff in our organization to attend to the complaint speedily.
(c) If an Individual’s Personal Data has been provided to us by a third party (e.g. the Individual’s employer), the respective third party should be contacted to make such queries, complaints, and access and correction requests to Starvision on behalf of the Individual.
GOVERNING LAW
This Policy shall be governed by and construed in accordance with the laws of Singapore. Any dispute arising out of or in connection with this Policy including any question regarding its existence, validity or termination, shall be referred to and finally resolved by the Courts of Singapore.
DATA PROTECTION OFFICER CONTACT DETAILS :
Data Protection Officer
Starvision Information Technology Pte Ltd
Address : 8 New Industrial Road, #03-03 LHK3 Building, Singapore 536200
Contact No. : +065 6293 4828
Email Address : dpo@starvisionit.com