DTec Industries Personal Data Protection Policy
This is the Personal Data Protection Policy (this Policy) of DTec Industries Pte Ltd and its affiliates and subsidiaries (we, us or our). We comply with the Singapore Personal Data Protection Act (PDPA), the EU General Data Protection Regulation (GDPR) and other applicable data protection laws relating to your Personal Data. This Policy sets out the purposes for which we collect, use, and disclose your Personal Data and includes information concerning your rights relating to your Personal Data.
1. Your Personal Data
Personal Data refers to any data about you from which you can be identified from that data or from that data combined with other information, which may include (a) your name, passport number, national registration or other identification number, telephone number, address, email address, facial image in a photograph/video recording, fingerprint and any other information relating to you; (b) information about your use of our website; and (c) information about you as a candidate for employment with us or as our employee. In respect of our activities in the EU, Personal Data also refers to personal data concerning racial or ethnic origin, political opinions, religious philosophical beliefs, trade union membership, and genetic data or biometric data processed for uniquely identifying a natural person e.g. facial images, fingerprints, data concerning health or data concerning a natural person’s sex life or sexual orientation, and criminal convictions or offences.
2. Collection of Personal Data
We need to collect Personal Data about you for the purposes of conducting our business. We collect your Personal Data when you (or you on behalf of your organisation, as applicable) (a) submit requests for our products or services;
(b) communicate with our employees through meetings, business events, calls, letters, email, our Contact Us form or social media; (c) propose to contract with us, or contract with us, for services or products; (d) submit online enquiries, browse our website or request we contact you; (d) respond to our request for other Personal Data; (f) ask to be added to our mailing lists; (g) respond to our marketing initiatives; (h) apply for employment with us; or (i) submit your Personal Data to us for any other reason. In respect of our activities in the EU, DTec Industries Pte Ltd is the ultimate primary data controller for processing Personal Data.
3. Use and Disclosure of Personal Data
We will use and disclose your Personal Data to (a) provide you or your organisation with the products or services you or your organisation have requested or are seeking to provide to us; (b) deliver our products and services to you or your organisation; (c) communicate with you and respond to your enquiries; (d) provide ongoing information about our products and services; (e) protect and enforce our legal rights; (f) prevent, detect and investigate crime, including fraud and money-laundering; (g) manage our business and our risks; and (h) comply with our internal policies and procedures and with applicable laws and regulations. Where the GDPR applies, we may process your Personal Data where we have obtained your consent (where this is required), or where processing is necessary: (a) before entering into or for performing a contract for the supply of products and services; (b) for our legitimate interests or those of a third party below (provided those interests are not overridden by your interests or fundamental rights and freedoms); or (c) to allow us to comply with applicable laws and regulations. We will also use and disclose your Personal Data if (a) you or your organisation is a prospective vendor, contractor or third-party services provider in order to evaluate your or your organisation’s products or services and to conduct background and other checks on you or your organisation (as applicable), or (b) you apply for employment with us or become an employee: (i) to progress your employment application including pre-recruitment checks, (ii) to provide or obtain references, (iii) to collect information about your suitability for the position, (iv) to organise training programs for our employees; (v) to assess your performance as an employee, (vi) to administer employee payroll and other benefits, (vii) to submit mandatory tax or employment-related reports, (viii) to communicate with you about our policies and processes, and (ix) to fulfil any other related purposes.
Your Personal Data will also be disclosed (but only to the extent necessary) to (a) our affiliates or subsidiaries; (b) our vendors, contractors and service providers for administrative, technical, financial, accounting, credit, due diligence, KYC, research, operational, IT or other services; (c) our professional advisors e.g. auditors; lawyers and lawyers; (d) public or regulatory authorities where we are required to comply with applicable laws and regulations; and (e) our banks, financial services providers and insurance companies. If you provide Personal Data to us concerning a third party, you undertake that the collection, use and disclosure of that Personal Data is lawful.
4. Transfer of Personal Data
Your Personal Data may be stored in external servers located overseas. In carrying out our business, it may be necessary for us to share information about you with (a) our affiliates and subsidiaries and (b) vendors, contractors, third party service providers and professional advisors, some of which may be located in countries outside your own country. Such countries may afford a lower standard of data protection to that in your own country. However, we will take reasonable steps to ensure that your Personal Data transmitted outside of your country is adequately protected, and that such transfers comply with applicable data protection laws.
5. Retention of Personal Data
We may retain your Personal Data for as long as necessary for the purposes it has been collected, and (i) in most cases, up to 7 years; or (ii) in respect of our activities in the EU, up to 10 years, unless otherwise permitted by applicable laws and regulations or in order to defend legal claims.
6. Your Rights
You have the rights (which can be exercised by contacting the Data Protection Officer) to: (a) obtain confirmation whether your Personal Data is being processed and to request a copy; (b) ensure that your Personal Data is accurate; (c) in certain circumstances, request that your Personal Data is deleted or that its processing is restricted; (d) cease processing your information unless we have compelling legitimate grounds to continue processing or where it is necessary for legal or regulatory purposes; (f) prevent any processing of Personal Data that is causing or is likely to cause unwarranted and substantial damage or distress to you; and (g) lodge a complaint about the way in which your Personal Data is being used to the relevant supervisory authority. Where we rely on your consent to process your Personal Data, you may withdraw that consent at any time; but this will not affect the lawfulness of processing based on your consent before any withdrawal. If you wish to exercise your rights or make a complaint on how we handle your Personal Data, please contact the Data Protection Officer.
8. Contact us
If you have any questions about this Policy or your Personal Data, please contact the Data Protection Officer at firstname.lastname@example.org.
9. Governing Law & Updates
This Policy is governed by the laws of Singapore. This Policy will be updated from time to time by us to take account of legal, regulatory and market developments. The most recent version of this Policy is published on our website.
Compliance Policy Statement
DTec Industries, its Group companies, its management, employees and contractors will conduct business in strict accordance with all applicable laws and regulations and will adhere to the following four key rules:
- Obeying the Law
DTec Industries, its Group companies, its management, employees and contractors will obey the laws and regulations of the countries in which they operate.
- Business Ethics
DTec Industries and its Group companies will not allow bribery and other forms of illegal business practice by its or its Group employees and contractors.
- Export/Import Control
DTec Industries and its Group companies will comply with all applicable trade laws and regulations in the countries in which they operate e.g. export/import controls and licences; embargoes against countries and persons.
- Financial Compliance
DTec Industries and its Group companies will keep complete and accurate records of all business transactions and payments in accordance with recognised accounting principles and will adhere strictly to all applicable laws and regulations (including without limitation those relating to Anti Money Laundering and Combating the Financing of Terrorism).