Privacy Statement
1. PRIVACY STATEMENT
1.1 We value your privacy and understand the importance of your personal data. This Privacy Statement explains how Helmsman LLC collects, uses, discloses and/or otherwise processes Personal Data (as defined below).
1.2 If you, at any time, wish to:
a. send us any enquiries or comments about this policy;
b. send us any complaint about how we handle your Personal Data;
c. withdraw any consent you have provided to us previously in relation to your Personal Data; or
d. access or correct your Personal Data in our control or possession in accordance with your statutory rights under the Personal Data Protection Act 2012 of Singapore (“PDPA”),
you may contact our Data Protection Officer (the “DPO”) at email hidden; JavaScript is required.
2. THE PDPA
2.1 “Personal Data” is defined under the PDPA to mean data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access. Common examples of Personal Data would include an individual’s name, residential address, email address, telephone number, nationality, gender, date of birth, marital status, photograph, employment information and financial information.
2.2 In this Privacy Statement, “process” means the carrying out of any operation or set of operations in relation to Personal Data including any or all of the following: (a) collection; (b) recording; (c) holding, (c) organisation, adaptation or alteration; (d) use; (e) retrieval; (f) combination; (g) transmission; (h) disclosure; (i) erasure or destruction.
2.3 Subject to any specific data protection notice we may give to you and the terms and conditions of any contract which may be agreed between us, by interacting with us, using our website, submitting information (including Personal Data) to us whether directly or indirectly through another party and/or engaging our services, you agree and consent to us collecting, using, disclosing and/or otherwise processing your Personal Data in accordance with this Privacy Statement. If you provide us with any Personal Data relating to an employee, customer or other individuals and third parties, by submitting such Personal Data to us, you represent to us, and must ensure, that you have obtained his/her consent thereto and notified him/her of the terms of this Privacy Statement.
3. HOW WE COLLECT PERSONAL DATA
3.1 We may collect or otherwise obtain your Personal Data directly from you, a third party or from publicly available sources (such as LinkedIn) in the following circumstances:
a. if you or your organisation engage us or any of our affiliates, associated or related corporations (such as Tang & Co.) for the provision or services to you or (as the case may be) your organisation;
b. if you send or provide your Personal Data directly to us;
c. if your Personal Data is provided to us in order for us to provide legal services to you or any other person or organisation;
d. if you visit our website or attend at our office premises; and
e. in such other circumstances as we may notify you from time to time.
3.2 Where we receive unsolicited Personal Data (including in situations where Personal Data sent to us includes items of data that we did not request for), we reserve the right to process any and all such unsolicited Personal Data in such manner and for such purposes as we consider appropriate.
4. PURPOSES
4.1 We collect, use, disclose and/or otherwise process Personal Data for the following purposes:
a. providing legal services;
b. verification of identity;
c. managing our business operations and relationships (including with customers, vendors, and employees);
d. complying with any applicable law, regulation, code of practice, guideline or rule, including complying with any request or direction made by any governmental authority, public agency, ministry, statutory board or other similar authority;
e. processing applications for employment (including internship or a training contract) and handling tenders, vendor opportunities and vendor on-boarding;
f. conducting research, analysis and development activities (such as web analytics, surveys and/or profiling) to improve our services and facilities;
g. protecting the security and effective functioning of our information and communications technology systems including storing, hosting, backing up (whether for disaster recovery or otherwise) of Personal Data, whether within or outside Singapore;
h. ensuring effective functioning of our website;
i. responding to, handling, and processing queries, requests, applications, complaints, and feedback;
j. sending information on any administrative changes, updates, modifications and/or amendments to our policies, terms and conditions;
k. organising, recording (including taking photographs and videos) and publicising (including pre-event and post-event publicity and publicity by or in collaboration with third parties) seminars, events or other marketing / promotional activities;
l. providing complimentary electronic publications and updates;
m. any other incidental business purposes related to or in connection with the above;
n. (in the case of CCTV data) routine security monitoring;
o. any other purposes which we have notified at the time of obtaining consent (unless the processing of Personal Data without express consent is permitted by the PDPA or by law); and/or
p. any other purpose required or permitted by written law,
(collectively, the “Purposes”).
4.2 We may disclose Personal Data to our third-party service providers, agents, affiliates, associated or related corporations, and/or other third parties whether sited in Singapore or outside of Singapore, for one or more of the Purposes. Such third parties may process Personal Data either on our behalf or otherwise, for one or more of the Purposes. Where we disclose Personal Data to third parties, we will employ our best efforts to require that such third parties ensure such Personal Data is safely protected.
5. WITHDRAWAL OF CONSENT
5.1 You may withdraw your consent for the collection, use disclosure and/or other processing of your Personal Data in our possession or under our control at any time by submitting your request in writing to the DPO via the email address set out above.
5.2 We will process your request within a reasonable time from such a request for withdrawal of consent being made.
5.3 While we respect your decision to withdraw your consent, please note that, depending on the nature and scope of your request, we may not be in a position to continue providing our services to you/your organisation and, in such circumstances, we shall notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing to the DPO via the email address set out above.
5.4 Withdrawal of consent does not affect (a) our collection, use, disclosure and/or other processing of your Personal Data without your consent as permitted or required by law or (b) the terms and conditions of any agreement between us (save as and to the extent that they relate to our collection, use, disclosure and/or other processing of your Personal Data with your consent).
6. MANAGEMENT OF PERSONAL DATA
6.1 We will employ our best efforts to ensure that your Personal Data is protected and kept confidential. To safeguard your Personal Data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as minimised collection of Personal Data, authentication and access controls (such as good password practices), up-to-date antivirus protection, regular patching of operating system and other software, and web security measures against risks. However, please be aware that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
6.2 We will also put in place measures such that Personal Data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that (i) the purpose for which that Personal Data was collected is no longer being served by the retention thereof; and (ii) retention is no longer necessary for any other legal or business purposes.
6.3 We will take reasonable efforts to ensure that your Personal Data is accurate and complete, if your Personal Data is likely to be (i) used by us to make a decision that affects you, or (ii) disclosed to another organisation. However, it is your responsibility to update us of any changes in your Personal Data. We are not liable for relying on inaccurate and/or incomplete Personal Data resulting from your failure to update us of any changes in your Personal Data.
6.4 If you wish to make (a) an access request for access to a copy of the Personal Data which we hold about you or information about the ways in which we use or disclose your Personal Data, or (b) a correction request to correct or update any of your Personal Data which we hold about you, please inform us in writing to the DPO via the email address set out above. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request. We will process your request within a reasonable time.
6.5 Where Personal Data is to be transferred out of Singapore, we will comply with the provisions of the PDPA in doing so. We will take appropriate steps to ascertain that the foreign recipient organisation of such Personal Data is bound by legally enforceable obligations to provide to such Personal Data, a standard of protection that is at least comparable to the protection under the Act.
7. UPDATES ON PRIVACY STATEMENT
7.1 To ensure that we properly manage, protect and process Personal Data, we will, at our absolute discretion, periodically review, amend and update our policies, procedures and processes.
7.2 Our most up-to-date Privacy Statement may be accessed on our website at https://www.helmsmanlaw.com/.
7.3 You are advised to visit the above website on a regular basis to ensure that you are informed of our latest Privacy Statement.