Your privacy is important to us!!!
This is the Personal Data Protection Policy of Aquarius Soft Pte Ltd (AS) which sets out how we and our affiliated associations (“Organisation”, “us”, “we” or “our”) comply with the provisions of the Personal Data Protection Act of Singapore (“PDPA”). This Personal Data Protection Policy sets out:
a. our policies on how we manage your Personal Data;
b. the types of Personal Data we collect, use, disclose and/or retain;
c. how we collect, use, disclose and/or retain your Personal Data; and
d. the purpose(s) for which we collect, use, disclose and/or retain your Personal Data.
AS and each affiliated organisation have different channels of collecting personal data, but each is committed to complying with this Policy in its collection, use and disclosure of personal data, to ensure that there is accountability and uniformity in the way we protect your personal data. Although this Policy is in common use by AS and the affiliated organisations, each is responsible to you to the extent of its own collection, use and disclosure of your personal data, and its own actions.
You agree and consent to us, the Organisation, and our authorised service providers and third parties to collect, use and disclose and/ or retain your Personal Data in the manner set forth in this Personal Data Protection Policy.
This Personal Data Protection Policy supplements but does not supersede nor replace any other consent which you may have previously provided to us nor does it affect any right that we may have at law in connection with the collection, use, disclosure and/ or retention of your Personal Data.
From time to time, we may update this Personal Data Protection Policy without your notice to ensure that our Policy is consistent with any regulatory changes. The updated Policy will supersede earlier versions and will apply to personal data provided to us previously. Should any revision(s) be made to this Personal Data Protection Policy, updates will be published on our website(www.aquariussoft.com).
This Personal Data Protection Policy forms a part of the terms and conditions governing your relationship with us and should be read in conjunction with such terms and conditions (“Terms and Conditions”). In the event of any inconsistency between the provisions of the Personal Data Protection Policy and the Terms and Conditions, the provisions of the Terms and Conditions shall prevail.
2. Your Personal Data
The Personal data we collect depends on the purposes for which we require the personal data and what you have chosen to provide. In this Personal Data Protection Policy, “Personal Data” refers to any data and/or information about you from which you can be identified by, either (a) from that data; or (b) from that data and other information to which we may have legitimate access to. Examples of such Personal Data include but are not limited to:
a. your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address and any other information relating to you which you have provided in any forms you may have submitted to use, or in other forms of interaction with you;
b. your photos;
c. your employment history, education background, and income levels;
d. personal Data of your family members, such as next of kin, spouses, and children;
e. information relating to payments, such as your bank account number or credit card information;
f. information about your usage of and interaction with our website and/or services including computer and connection information, device capability, bandwidth, statistics on page views and traffic to and from our website
3. Collection of your Personal Data
Generally, we may collect your Personal Data directly or indirectly through the following ways:
a. when you access our websites or perform an online registration / transaction
b. when you interact with any of our employees;
c. when you submit an application to us for services
d. when you respond to our request for additional Personal Data;
e. when you ask to be included in an email or other mailing list;
f. when you request that we contact you through various communication channels, for example, through social media platforms, messenger platforms, face-to-face meetings, telephone calls, emails, fax and letters; your images are captured via photographs or videos taken by us or our representatives when you are within our premises or attend events organised by us;
g. when you respond to our initiatives or promotions;
• We seek information about you and receive your personal data in connection with your relationship with us, for example, if you are a customer, investor or shareholder when you submit your Personal Data to us for any other reason.
• When you browse our website, you generally do so anonymously, but please see the section below on cookies.
• If you provide us with any personal data of a third party (eg: information of spouse, children, relatives, employees or any other authorised parties), by submitting such information to us, you agree to us that you have obtained their prior permission.
Minor: If you are a child, minor or not of legal age, please inform and seek the consent of your parent or guardian, before you provide your personal data to us. If you are a parent or guardian and you have reason to believe your child or ward has provided us with their personal data without your consent, please contact us to request for erasure of their personal data.
from your family members or friends who provide your personal data to us on your behalf
4. Purposes for the Collection, Use and Disclosure of Your Personal Data
Generally, we may collect, use, disclose and/ or retain your Personal Data for the following purposes:
a. to provide you with services / training / funding purposes;
b. to assist you with your enquiries, requests and feedback.
c. to process payment for your services rendered or any other purchases;
d. to improve customer services, such as resolving complaints and handling requests and enquiries; security and safety purposes, g. protecting our platforms from unauthorised access or usage and to monitor for security threats, and your image may be captured by security cameras;
e. to conduct research, surveys and interviews;
f. to keep you updated on our events; and
g. to comply with applicable laws and regulations.
h. Job application and related matters; engaging you as an associate trainer or matters relating to training;
i. preventing, detecting and investigating crime, including fraud and money-laundering etc.
j. conducting any promotions , offers, contests etc
k. to comply with our legal or regulatory obligations (eg Ministry of Manpower etc)
l. for our legitimate business interests, provided that this does not override your interests or rights
Note: As an individual your consent is deemed under the PDPA to cover these circumstances:
• Where the collection, use, or disclosure of personal data is reasonably necessary to conclude or perform a contract or transaction.
• Where individuals have been notified of the purpose of the intended collection, use, or disclosure of his or her personal data and are given a reasonable opportunity to opt out (and have not opted out).
• OR you allow us to collect, use, or disclose personal data without having to obtain consent from the individuals in these circumstances:
o Where it is in the legitimate interests of the organisation and the benefit to the public is greater than any adverse effect on the individual.
o Where it is for business improvement purposes. As a business organization, we are committed to safeguard any such data that may be used.
5. Marketing/ Optional Purposes
a. From time to time, we may contact you via mail, electronic mail, telephone (call or SMS-Text), facsimile or social media platforms, to inform you about our courses / services and events that we think may be of interest to you.
b. You can let us know at any time if you no longer wish to receive marketing materials (by informing us through our email to firstname.lastname@example.org) and we will remove your details from our direct marketing database. Analyzing and/or profiling your purchases, transactions and/or likes or dislikes so as to be better able to send you relevant or targeted news (including events and product launches), promotion and marketing information from us (and/or our affiliates or related entities) and on our group products
c. Please note that we may still send you non-marketing messages such as surveys, customer-service notices and other service related notices.
d. Videos and photos will be taken during the classes and events to be used for marketing and related purposes.
6. Disclosure of your Personal Data
We may disclose your Personal Data to the following groups of external organisations for purposes mentioned above, subjected to the requirements of applicable laws:
a. our professional advisers such as our auditors;
b. relevant government regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any government authority;
c. business partners that provides any membership services and benefits; and
d. any other person in connection with the purposes set forth above.
e. third parties who are appointed to provide services to us, e.g. IT vendors, marketing companies and event organisers;
a. We may collect or analyse anonymised information from which individuals cannot be identified (“Aggregate Information”), such as number of users and their frequency of use, the number of page views (or page impressions) that occur on our websites and common entry and exit points into our websites.
b. We make use of “cookies” to store and track Aggregate Information about you when you enter our website(s). Such cookies are used to track information such as the number of users and their frequency of use, profiles of users and their online preferences.
c. Such aggregate Information collected may be used to assist us in analysing the usage of our website(s) so as to improve your online experience with us.
d. Should you wish to disable the cookies associated with these technologies you may do so by changing the setting on your browser. However, please note that this may affect the functionality of the website(s).
8. Third-Party Sites
a. Our website(s) may contain links to other websites operated by third parties independent of the Organisation. We are not responsible for the privacy practices of such website(s) operated by third parties even though it is linked to our website(s).
b. We encourage you to learn about the privacy policies of such third party website(s) by checking the policy of each site you visit and contact its owner or operator if you have any concerns or questions.
9. Protection of your Personal Data
We maintain appropriate security safeguards and practices to protect your Personal Data unauthorised access, collection, use, disclosure, copying, modification disposal or similar risks, in accordance with applicable laws.
9.1 Period of retention. We keep your personal data only for so long as we need the data to fulfil the purposes we collected it for, and to satisfy our business and legal purposes, including audit, accounting or reporting requirements. How long we keep your personal data depends on the nature of the data, e.g. we keep personal data for at least the duration of the limitation period for bringing claims if the personal data may be required to commence or defend legal proceedings. Certain information may also be retained for longer, e.g. where we are required to do so by law or to maintain a record of the certification you have obtained with us. Typically, our data retention period is from 6 years upwards, depending on the limitation period.
9.2 Anonymised data. In some circumstances we may anonymise your personal data so that it no longer identifies you, in which case we are entitled to retain and use such anonymised data without restriction, including for data analytics.
9.3 Unauthorised access and vulnerabilities. While we take reasonable precautions to safeguard your personal data in our possession or under our control, we cannot be held responsible for unauthorised or unintended access that is beyond our control, including hacking or cybercrimes. We also do not guarantee that our websites and applications are invulnerable to security breaches, or that your use of our websites and applications is safe and protected from viruses, worms, Trojan horses, and other vulnerabilities.
10. Accuracy of your Personal Data
a. We take all reasonable measures to ensure that your Personal Data remains accurate, complete and up-to-date. You must ensure that all personal data that you provide is true, accurate and complete
b. You may also keep us informed when there are any updates to your Personal Data by contacting us directly.
c. Any incorrect data provided will not hold us liable for any related consequences.
11. Withdrawal of Consent
a. If you wish to withdraw your consent to any use or disclosure of your Personal Data as set out in this Personal Data Protection Policy, you may contact us via email@example.com. Your withdrawal will take effect after your request is processed.
b. Please note that if you withdraw your consent to any or all use or disclosure of your Personal Data, depending on the nature of your request, we may no longer be in a position to continue to provide relevant services to you.
12. Access and Correction of your Personal Data
a. You may request access to or make corrections to your Personal Data records, but the Organisation has the right to charge a reasonable fee for processing your request. We may require that you submit certain forms or provide certain information to process your request. Upon receipt of your written request, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we will seek to process and effect your request within 30 days of receipt of your request. Where permitted by law, we may charge you a fee to process your request. We may also be permitted under applicable laws to refuse a request.
b. Please submit your request to our Data Protection Officer: support@ aquariussoft.com
c. We may be permitted under applicable laws to refuse your request to exercise your rights, for example, we may refuse (a) a request for erasure where the personal data is required for in connection with claims; or (b) an objection request and continue processing your personal data based on compelling legitimate grounds for the processing.
13. Retention Limitation
The Commission shall cease retention of personal data or remove the means by which the personal data can be associated with particular individuals when it is no longer necessary for any business or legal purposes.
14. Notification of Breach
Our Organisation is committed to notify the PDPC and affected individuals if any data breach is detected and results in, or is likely to result in, significant harm to the affected individuals (e.g., compromised NRIC numbers etc). Where the organisation has reason to believe that a data breach has occurred, we will conduct, in a reasonable and expeditious manner, an assessment as to whether it is a notifiable data breach. If the notification criteria is met, we will notify the PDPC as soon as practicable and also the affected individuals.
15. Portability Obligation
As a responsible organisation we will , at the request of an individual, transmit his or her personal data that is in the organisation’s possession or under our control to another organisation in a commonly used machine-readable format. However, our obligation only applies to data which is provided by the individual or is data about the individual created in the course of the individual’s use of our relevant product or service. Data which is derived by the organisation in the course of business from other personal data will not be covered. The individual exercising the right must also have an existing, direct relationship with our organisation, where the data is in electronic form, and the receiving organisation must have a presence in Singapore.
16. Contacting Us
If you have any questions or complaints relating to the use or disclosure of your Personal Data, or if you wish to know more about our data protection policies and practices, please contact our Data Protection Officers: firstname.lastname@example.org.