We at SESTO ROBOTICS PTE. LTD. (the “SESTO”) take our responsibilities under Singapore’s Personal Data Protection Act 2012 (the “PDPA”) seriously. We also recognize the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data.
If you, at any time, have any queries on this policy or any other queries in relation to how we may manage, protect and/or process your personal data, please do not hesitate to contact our Data Protection Officer (the “DPO”) at:
Data Protection Officer
SESTO ROBOTICS PTE. LTD.
Singapore telephone number: +65 6266 1522
1 WHAT IS PERSONAL DATA
1.1 “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 include names, identification numbers, contact information, medical records, photographs and video images.
1.2 We will collect your personal data in accordance with the PDPA. We will also notify you of the purposes for which your personal data may be collected, used, disclosed and/or processed, as well as obtain your consent for the collection, use, disclosure and/or processing of your personal data for the intended purposes, unless an exception under the law permits us to do so without your consent.
2 PURPOSES FOR WHICH WE COLLECT, USE, DISCLOSE AND PROCESS PERSONAL DATA
2.1 The personal data which we collect from you may be collected, used, disclosed and/or processed for various purposes, depending on the circumstances for which we may/will need to process your personal data, including :
(a) facilitating and/or processing your transaction with us;
(b) facilitating, processing, dealing with, administering, managing and/or maintaining your relationship with us, including but not limited to sending you marketing, advertising and promotional information and materials relating to our products, or any services that we may be selling or marketing under our company;
(c) carrying out your instructions or responding to any enquiry given by (or purported to be given by) you or on your behalf;
(d) carrying out due diligence or other screening in accordance with any legal or regulatory obligations or our risk management procedures that may be required by law or that may have been put in place by us;
(e) conducting research, analysis and development activities (including but not limited to data analytics, surveys and/or profiling) to improve our services and facilities in order to enhance your relationship with us or for your benefit, or to improve any of our products or services for your benefit;
(f) complying with or as required by any applicable law, governmental or regulatory requirements of any relevant jurisdiction, including meeting the requirements to make disclosure under the requirements of any law binding on us and/or for the purposes of any guidelines issued by regulatory or other authorities, whether in Singapore or elsewhere, with which we are expected to comply;
(g) any other purposes which we notify you of at the time of obtaining your consent.
(collectively, the “Purposes”)
As the purposes for which we may/will collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of your personal data without your consent is permitted by the PDPA or by law.
2.2 In order to conduct our business operations more smoothly, we may also be disclosing the personal data you have provided to us to our third party service providers, agents and/or our affiliates or related corporations, and/or other third parties whether sited in Singapore or outside of Singapore, for one or more of the above-stated Purposes. Such third party service providers, agents and/or affiliates or related corporations and/or other third parties would be processing your personal data either on our behalf or otherwise, for one or more of the above-stated Purposes.
3 SPECIFIC ISSUES FOR THE DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES
3.1 We respect the confidentiality of the personal data you have provided to us.
3.2 In that regard, we will not disclose your personal data to third parties without first obtaining your consent permitting us to do so. However, please note that we may disclose your personal data to third parties without first obtaining your consent in certain situations, including, without limitation, the following :
(a) cases in which the disclosure is required or authorized based on the applicable laws and/or regulations;
(b) cases in which the purpose of such disclosure is clearly in your interests, and if consent cannot be obtained in a timely way;
(c) cases in which the disclosure is necessary to respond to an emergency that threatens the life, health or safety of yourself or another individual;
(d) cases in which the disclosure is necessary for any investigation or proceedings;
(e) cases in which the personal data is disclosed to any officer of a prescribed law enforcement agency, upon production of written authorisation signed by the head or director of that law enforcement agency or a person of a similar rank, certifying that the personal data is necessary for the purposes of the functions or duties of the officer;
(f) cases in which the disclosure is to a public agency and such disclosure is necessary in the public interest; and/or
(g) where such disclosure without your consent is permitted by the PDPA or by law.
3.3 The instances listed above at paragraph 3.2 are not intended to be exhaustive. For more information on the exceptions, you are encouraged to peruse the Second, Third and Fourth Schedules of the PDPA which is publicly available at http://statutes.agc.gov.sg.
3.4 Where we disclose your personal data to third parties with your consent, we will employ our best efforts to require such third parties to protect your personal data.
4 REQUEST FOR ACCESS AND/OR CORRECTION OF PERSONAL DATA
4.1 You may request to access and/or correct the personal data currently in our possession or control by submitting a written request to us. We will need enough information from you in order to ascertain your identity as well as the nature of your request, so as to be able to deal with your request. Hence, please submit your written request to firstname.lastname@example.org.
4.2 For requests to access personal data, once we have sufficient information from you to deal with the request, we will seek to provide you with the relevant information within 30 days. Where we are unable to respond to you within the said 30 days, we will notify you of the soonest possible time within which we can provide you with the information requested. Note that the PDPA exempts certain types of personal data from being subject to your access request, and to that extent, we may not be able to comply with your request.
4.3 For a request to correct personal data, once we have sufficient information from you to deal with the request, we will :
(a) correct your personal data within 30 days. Where we are unable to do so within the said 30 days, we will notify you of the soonest practicable time within which we can make the correction. Note that the PDPA exempts certain types of personal data from being subject to your correction request as well as provides for situation(s) when correction need not be made by us despite your request; and
(b) subject to paragraph 4.4, we will send the corrected personal data to every other organisation to which the personal data was disclosed by SESTO within a year before the date the correction was made, unless that other organisation does not need the corrected personal data for any legal or business purpose.
4.4 Notwithstanding paragraph 4.3(b), we may, if you consent, send the corrected personal data only to specific organisations to which the personal data was disclosed by us within a year before the date the correction was made.
4.5 In certain cases, we may need to charge you a reasonable fee for the handling and processing of your requests to access your personal data. We will provide you with a written estimate of the fee we will be charging, if any. Please note that we are not required to respond to or deal with your access request unless you have agreed to pay the fee.
5 REQUEST TO WITHDRAW CONSENT
5.1 You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control by submitting your request to email@example.com or by opting out of our mailing lists via our electronic direct mailers.
5.2 We will process your request within a reasonable time from such a request for withdrawal of consent being made, and will thereafter not collect, use and/or disclose your personal data in the manner stated in your request.
5.3 However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal. In this regard, depending on the extent of your withdrawal of consent for us to process your personal data, it may mean that we will not be able to continue with your existing relationship with us.
6 ADMINISTRATION AND MANAGEMENT OF PERSONAL DATA
6.1 We will take reasonable efforts to ensure that your personal data is accurate and complete, if your personal data is likely to be used by SESTO to make a decision that affects you, or disclosed to another organisation. However, this means that you must also update us of any changes in your personal data that you had initially provided us with. We will not be responsible for relying on inaccurate or incomplete personal data arising from you not updating us of any changes in your personal data that you had initially provided us with.
6.2 We will also put in place reasonable security arrangements to ensure that your personal data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorized access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data. However, we cannot assume responsibility for any unauthorized use of your personal data by third parties which are wholly attributable to factors beyond our control.
6.3 We will also put in place measures such that your 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 of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes.
6.4 Where your personal data is to be transferred out of Singapore, we will comply with the PDPA in doing so. In this regard, this includes us obtaining your consent unless an exception under the PDPA or law applies, and taking appropriate steps to ascertain that the foreign recipient organisation of the personal data is bound by legally enforceable obligations to provide to the transferred personal data a standard of protection that is at least comparable to the protection under the Act. This may include us entering into an appropriate contract with the foreign recipient organisation dealing with the personal data transfer or permitting the personal data transfer without such a contract if the PDPA or law permits us to.
7 COMPLAINT PROCESS
7.1 If you have any complaint or grievance regarding about how we are handling your personal data or about how we are complying with the PDPA, we welcome you to contact us with your complaint or grievance.
7.2 Please contact us through one of the following methods with your complaint or grievance :
(a) Singapore telephone number: +65 6266 1522.
(b) E-mail: firstname.lastname@example.org. Attention it to the ‘Data Protection Officer’.
(c) Office address: SESTO ROBOTICS PTE. LTD. 6 Penjuru Close, Singapore 608614. Attention it to the “Data Protection Officer”
7.3 Where it is an email or a letter through which you are submitting a complaint, your indication at the subject header that it is a PDPA complaint would assist us in attending to your complaint speedily by passing it on to the relevant staff in our organisation to handle. For example, you could insert the subject header as “PDPA Complaint”.
7.4 We will certainly strive to deal with any complaint or grievance that you may have speedily and fairly.
8 UPDATES ON DATA PROTECTION POLICY
8.1 As part of our efforts to ensure that we properly manage, protect and process your personal data, we will be reviewing our policies, procedures and processes from time to time.
8.3 You are encouraged to visit the above website from time to time to ensure that you are well informed of our latest policies in relation to personal data protection.
Last Updated on 14 February 2017.