Privacy notice

The purpose of this document (the “Data Protection Policy”) is to inform you how Advertent Security Consultancy Pte. Ltd. (“Advertent”) manages data that is subject to the Singapore Personal Data Protection Act (No. 26 of 2012) (the “Act”). Please take a moment to read this Data Protection Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data.

Advertent may, from time to time, update this Data Protection Policy to ensure that this Data Protection Policy is consistent with changes in the legal or regulatory development, future developments and/or industry trends, without specific notice to you. Subject to your rights at law, the prevailing terms of this Data Protection Policy will apply, as updated from time to time.

Definition of Data

1. “Personal Data” is defined as data that can identify an individual.

2. The types of personal data we collect include, but is not limited to:

a. Name;

b. NRIC Number/ Foreign Identification Number/ Passport Number;

c. Residential Address;

d. Mobile Number/ Home Number;

e. Bank Details;

f. Vehicle Number;

g. Personal Email Address;

h. Thumbprint / fingerprint;

i. Photographs / Video and CCTV footage;

j. Specimen Signature; and/ or

k. Employment Details.

A.
Definition of Data

Purposes for which we use collected personal data

3. Clients – The purposes for which we use collected personal data from our clients include, but are not limited to:

a. Providing services pursuant to and related to our business contracts with you;

b. Acting as a data intermediary for you in accordance with the Personal Data Protection Act when we collect personal data on your behalf, for example when we take down particulars of visitors to your premises;

c. Enabling the use of our products and services, including where necessary, contacting you by SMS, email or otherwise;

d. Dealing with enquiries made;

e. Maintaining and updating collected data;

f. Providing administrative and/or operational services;

g. Corresponding with you on our business and related services;

h. Providing statistical analysis;

i. Collecting fees, charges and expenses for services and products provided by us;

j. Processing credit notes and refunds;

k. Providing warranty and maintenance services pursuant to and in relation to your business transactions with us.

4. Vendors – The purposes for which we use collected personal data from vendors include, but are not limited to:

a. Providing services pursuant to and related to our business contracts with you;

b. Evaluating your products and services for the purpose of our business needs;

c. Collecting fees, charges and expenses for services and products provided by us; and/ or

d. Facilitating the making and paying of claims, including payments by cheque, bank transfers or other means.

5. Employees/ Job applicants – The purposes for which we use collected personal data from our employees/ job applicants include, but are not limited to:

a. Administering and maintaining personal records;

b. Paying and reviewing salary and other remuneration;

c. Providing, administering and reviewing benefits;

d. Undertaking performance appraisals and reviews;

e. Maintaining records for annual, medical and other leave;

f. Making decisions about your fitness for work;

g. Providing references and information to future employers;

h. Providing information, where necessary, to government and quasi government bodies, including the Inland Revenue and Central Provident Fund;

i. Providing information to current and/or future partners and/or purchasers of the Company and/or its business and/or any company within the Group or any of their respective businesses;

j. Maintaining medical and dental records, including information about your physical and mental health or condition;

k. Disciplinary and grievance matters;

l. Recruitment activities;

m. Opening, maintaining and operating bank accounts;

n. Where necessary, for the purposes of obtaining access to facilities, buildings or installations;

o. Where necessary, for the arrangement of flights, accommodation and visas;

p. Carrying out billing, accounting, auditing and the maintenance of proper book-keeping to explain the Company’s operations and business;

q. Tax filing purposes;

r. Preparing of financial reports and disclosure of books, documents, records and information (in hard and/or soft copy) to the auditors, where necessary; and/ or

s. Assigning you to work in associate or affiliate companies, in Singapore or in other countries.

6. Persons accessing our website – The purposes for which we use collected personal data from persons accessing our website include, but are not limited to:

a. Reviewing online job applicants submitted by you;

b. Reviewing, responding or processing any queries submitted by you;

c. Enabling you to access or use a service on our Website;

d. Administering or carrying out our obligations in relation to any agreement we have with you; and/ or

e. Complying with a court order or legal obligation, in response to a law enforcement agency’s request where validly made under law, or when it is necessary to disclose your personal data to identify, contact or bring legal action against someone who may be infringing on our rights or causing damage to our property.

B.
Purposes for which we use collected personal data

Purposes for which we share, disclose and transfer collected personal data

7. Advertent does not sell any personal data collected to any third parties.

8. Advertent may from time to time share, disclose and/or transfer personal data to the following parties for the following purposes, where applicable:

a. To Government and non-Government authorities and agencies as required under the law or required by lawful directions from the Government and non-Government authorities and agencies;

b. To our business partners for the purposes of providing our products and services to our customers, including:

i. Professional, financial, tax and legal advisors, insurers and insurance brokers and auditors;

ii. Service providers who provide outsourcing services such as e-mail services, deployment of manpower, equipment and other paraphernalia, and data storage;

c. To financial institutions for the purposes of payments and transactions related to our provision of products and services as well as any employment with us;

9. In addition, Advertent will disclose collected personal data in the following circumstances:

Where we are required to so under the law,

a. When we are responding to a request from law enforcement authorities or lawful orders from Government authorities or agencies.

10. Advertent will not share, disclose or transfer any collected personal data where we are prohibited to do so under any law in force in Singapore.

11. Where required under the law or for prudence in regard of the safety and security of personal data, Advertent will seek the consent of the individual whose personal data is being requested before sharing, disclosing or transferring the personal data to the requesting person.

C.
Purposes for which we share, disclose and transfer collected personal data

Data quality and security

12. We take reasonable steps to ensure that the personal data we collect, use or disclose is accurate, complete and up to date.

13. Reasonable measures are in place to protect the personal data we collect from misuse and lose, as well as from unauthorized access, modification and disclosure.

14. We do not keep personal data for longer than is necessary and take reasonable steps to destroy or permanently de-identify personal data once it is no longer necessary for us to keep the data.

15. Advertent also expects our valued clients, partners and vendors to comply with all relevant laws in force in Singapore as regards personal data by taking reasonable steps to protect personal data we share, disclose or transfer to them, for example, by getting our clients, partners and vendors to commit to a letter of undertaking for compliance.

D.
Data quality and security

Access and correction

16. Advertent will, upon the request of an individual, provide him, as soon as reasonably possible, with personal data about that individual that is in our possession, and information about the ways and purposes for which the personal data has been shared, disclosed or transferred within a year before the date of the request.

17. Where an individual requests that we correct an error or omission in the personal data we have collected about the individual, we will correct such data as soon as reasonably possibly, and ensure that any person or entity with which we have shared, disclosed of transferred the said data to, is informed of the corrected data, unless it is not necessary to do so for legal or business purposes.

18. Advertent reserves the right not to provide individuals with access to, or correct the information collected by us, in accordance with the Act, including, but not limited to the following circumstances:

a. We are satisfied on reasonable grounds that the request is frivolous or vexatious;

b. The information requested for is trivial;

c. The personal data is related to a investigation where all the proceedings related to the investigation have not concluded;

d. The personal data is related to a prosecution where all the proceedings related to the prosecution, including any appeals where applicable, have not concluded;

e. The personal data, if disclosed, would reveal commercial information that could, in the opinion of a reasonable person, harm the competitive position of Advertent;

f. We are satisfied on reasonable grounds that a correction should not be made.

19. Advertent reserves the right to impose a nominal fee upon an individual requesting personal data from Advertent to cover the cost for verifying the request, and locating, retrieving, reviewing and copying any material requested.

E.
Access and correction

Use of our website

20. Cookies may be used in our website. If you prefer not to receive cookies, you can configure your Internet browser to reject cookies. Please note that this may limit the functionality of our website.

21. Our website may contain links to third party websites whose personal data protection policies may differ from ours. We are not responsible for the content and personal data protection practices of these websites.

F.
Use of our website

Amendments

22. Advertent reserves the right to amend, revise or change this Data Protection Policy or any part thereof from time to time without prior or subsequent notice to you. By procuring our goods and services, entering into business transactions with us, accepting employment with us or accessing our website, you agree to be legally bound by any such amended and/or revised Data Protection Policy.

G.
Amendments

Enquiry and complaints

23. We have designated Data Protection Officer, who is responsible for ensuring Advertent’s compliance with the applicable data protection laws. Should you have any queries or requests or wish to make any applications concerning your personal information or data, please contact our Data Protection Officer at hello @ advertentsecurity.com

H.
ENQUIRY AND COMPLAINTS

DEFINITION OF DATA

1. “Personal Data” is defined as data that can identify an individual.

2. The types of personal data we collect include, but is not limited to:

a. Name;

b. NRIC Number/ Foreign Identification Number/ Passport Number;

c. Residential Address;

d. Mobile Number/ Home Number;

e. Bank Details;

f. Vehicle Number;

g. Personal Email Address;

h. Thumbprint / fingerprint;

i. Photographs / Video and CCTV footage;

j. Specimen Signature; and/ or

k. Employment Details.

PURPOSES FOR WHICH WE USE COLLECTED PERSONAL DATA

3. Clients – The purposes for which we use collected personal data from our clients include, but are not limited to:

a. Providing services pursuant to and related to our business contracts with you;

b. Acting as a data intermediary for you in accordance with the Personal Data Protection Act when we collect personal data on your behalf, for example when we take down particulars of visitors to your premises;

c. Enabling the use of our products and services, including where necessary, contacting you by SMS, email or otherwise;

d. Dealing with enquiries made;

e. Maintaining and updating collected data;

f. Providing administrative and/or operational services;

g. Corresponding with you on our business and related services;

h. Providing statistical analysis;

i. Collecting fees, charges and expenses for services and products provided by us;

j. Processing credit notes and refunds;

k. Providing warranty and maintenance services pursuant to and in relation to your business transactions with us.

4. Vendors – The purposes for which we use collected personal data from vendors include, but are not limited to:

a. Providing services pursuant to and related to our business contracts with you;

b. Evaluating your products and services for the purpose of our business needs;

c. Collecting fees, charges and expenses for services and products provided by us; and/ or

d. Facilitating the making and paying of claims, including payments by cheque, bank transfers or other means.

5. Employees/ Job applicants – The purposes for which we use collected personal data from our employees/ job applicants include, but are not limited to:

a. Administering and maintaining personal records;

b. Paying and reviewing salary and other remuneration;

c. Providing, administering and reviewing benefits;

d. Undertaking performance appraisals and reviews;

e. Maintaining records for annual, medical and other leave;

f. Making decisions about your fitness for work;

g. Providing references and information to future employers;

h. Providing information, where necessary, to government and quasi government bodies, including the Inland Revenue and Central Provident Fund;

i. Providing information to current and/or future partners and/or purchasers of the Company and/or its business and/or any company within the Group or any of their respective businesses;

j. Maintaining medical and dental records, including information about your physical and mental health or condition;

k. Disciplinary and grievance matters;

l. Recruitment activities;

m. Opening, maintaining and operating bank accounts;

n. Where necessary, for the purposes of obtaining access to facilities, buildings or installations;

o. Where necessary, for the arrangement of flights, accommodation and visas;

p. Carrying out billing, accounting, auditing and the maintenance of proper book-keeping to explain the Company’s operations and business;

q. Tax filing purposes;

r. Preparing of financial reports and disclosure of books, documents, records and information (in hard and/or soft copy) to the auditors, where necessary; and/ or

s. Assigning you to work in associate or affiliate companies, in Singapore or in other countries.

6. Persons accessing our website – The purposes for which we use collected personal data from persons accessing our website include, but are not limited to:

a. Reviewing online job applicants submitted by you;

b. Reviewing, responding or processing any queries submitted by you;

c. Enabling you to access or use a service on our Website;

d. Administering or carrying out our obligations in relation to any agreement we have with you; and/ or

e. Complying with a court order or legal obligation, in response to a law enforcement agency’s request where validly made under law, or when it is necessary to disclose your personal data to identify, contact or bring legal action against someone who may be infringing on our rights or causing damage to our property.

PURPOSES FOR WHICH WE SHARE, DISCLOSE AND TRANSFER COLLECTED PERSONAL DATA

7. Advertent does not sell any personal data collected to any third parties.

8. Advertent may from time to time share, disclose and/or transfer personal data to the following parties for the following purposes, where applicable:

a. To Government and non-Government authorities and agencies as required under the law or required by lawful directions from the Government and non-Government authorities and agencies;

b. To our business partners for the purposes of providing our products and services to our customers, including:

i. Professional, financial, tax and legal advisors, insurers and insurance brokers and auditors;

ii. Service providers who provide outsourcing services such as e-mail services, deployment of manpower, equipment and other paraphernalia, and data storage;

c. To financial institutions for the purposes of payments and transactions related to our provision of products and services as well as any employment with us;

9. In addition, Advertent will disclose collected personal data in the following circumstances:

Where we are required to so under the law,

a. When we are responding to a request from law enforcement authorities or lawful orders from Government authorities or agencies.

10. Advertent will not share, disclose or transfer any collected personal data where we are prohibited to do so under any law in force in Singapore.

11. Where required under the law or for prudence in regard of the safety and security of personal data, Advertent will seek the consent of the individual whose personal data is being requested before sharing, disclosing or transferring the personal data to the requesting person.

DATA QUALITY AND SECURITY

12. We take reasonable steps to ensure that the personal data we collect, use or disclose is accurate, complete and up to date.

13. Reasonable measures are in place to protect the personal data we collect from misuse and lose, as well as from unauthorized access, modification and disclosure.

14. We do not keep personal data for longer than is necessary and take reasonable steps to destroy or permanently de-identify personal data once it is no longer necessary for us to keep the data.

15. Advertent also expects our valued clients, partners and vendors to comply with all relevant laws in force in Singapore as regards personal data by taking reasonable steps to protect personal data we share, disclose or transfer to them, for example, by getting out clients, partners and vendors to commit to a letter of undertaking for compliance.

ACCESS AND CORRECTION

16. Advertent will, upon the request of an individual, provide him, as soon as reasonably possible, with personal data about that individual that is in our possession, and information about the ways and purposes for which the personal data has been shared, disclosed or transferred within a year before the date of the request.

17. Where an individual requests that we correct an error or omission in the personal data we have collected about the individual, we will correct such data as soon as reasonably possibly, and ensure that any person or entity with which we have shared, disclosed of transferred the said data to, is informed of the corrected data, unless it is not necessary to do so for legal or business purposes.

18. Advertent reserves the right not to provide individuals with access to, or correct the information collected by us, in accordance with the Act, including, but not limited to the following circumstances:

a. We are satisfied on reasonable grounds that the request is frivolous or vexatious;

b. The information requested for is trivial;

c. The personal data is related to a investigation where all the proceedings related to the investigation have not concluded;

d. The personal data is related to a prosecution where all the proceedings related to the prosecution, including any appeals where applicable, have not concluded;

e. The personal data, if disclosed, would reveal commercial information that could, in the opinion of a reasonable person, harm the competitive position of Advertent;

f. We are satisfied on reasonable grounds that a correction should not be made.

19. Advertent reserves the right to impose a nominal fee upon an individual requesting personal data from Advertent to cover the cost for verifying the request, and locating, retrieving, reviewing and copying any material requested.

USE OF OUR WEBSITE

20. Cookies may be used in our website. If you prefer not to receive cookies, you can configure your Internet browser to reject cookies. Please note that this may limit the functionality of our website.

21. Our website may contain links to third party websites whose personal data protection policies may differ from ours. We are not responsible for the content and personal data protection practices of these websites.

AMENDMENTS

22. Advertent reserves the right to amend, revise or change this Data Protection Policy or any part thereof from time to time without prior or subsequent notice to you. By procuring our goods and services, entering into business transactions with us, accepting employment with us or accessing our website, you agree to be legally bound by any such amended and/or revised Data Protection Policy.

ENQUIRY AND COMPLAINTS

23. We have designated Data Protection Officer, who is responsible for ensuring Advertent’s compliance with the applicable data protection laws. Should you have any queries or requests or wish to make any applications concerning your personal information or data, please contact our Data Protection Officer at hello @ advertentsecurity.com