Garmco (S) Pte Ltd respects the privacy and confidentiality of our customers’ or business partners’ information. We have developed this Privacy Notice to assist you in understanding how we collect, use, disclose, process, protect and retain your data in accordance with the Singapore Personal Data Protection Act 2012 and all associated regulations and guidelines which may from time to time be issued by the Personal Data Protection Commission of Singapore.
- Application of This Privacy Notice
1.1. This Privacy Notice concerns our customers and business partners.
1.2. This Privacy Notice applies to all data in any form about an individual who can be identified from that data which are in our possession or under our control for the purposes of and in connection with our contractual duties and provisions of our services.
1.3. Under the Singapore Personal Data Protection Act, business contact information (e.g. name, business address, business telephone number) is not considered as Personal Data so long as it is used strictly for business-to-business (B2B) transactions.
- Collection of Personal Data
2.1. We collect Personal Data that you voluntarily provide to us, for example when you communicate with us via email, telephone or other channels. The data we collect includes contact information (name, address, phone no., email address), company name, relevant department and position/job title.
2.2 When contacting us through our website, you will be required to provide your full name, company name and email address. The information you provide will be handled according to this Privacy Notice.
2.3 We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
- Consequences of Not Providing Us with Personal Data
3.1. Providing us with your Personal Data is voluntary. However, if you choose not to provide us with the Personal Data described in this Notice, we may not be able to fulfil our contractual duties towards you or facilitate your request or provide the service to you, or the company you may be representing.
- Use of Personal Data
4.1. We use the Personal Data you provide us for one or more of the following purposes:
• Carry out obligations arising from any contracts entered into between you and us;
• Enter into a contract with you or manage our existing business relationship;
• Provide you with information that you request from us or which we think may interest you;
• Respond to your enquires and feedback; and
• Comply with or fulfil legal obligations and regulatory requirements.
We do not sell, distribute or otherwise make your Personal Data available to any third party other than described in this Privacy Notice.
- Disclosure of Personal Data
5.1. We may disclose your Personal Data to third party providers, agents and other organizations we have engaged to perform any of the functions listed in section 4 above for us; and
5.2. Where required to do so by law, we may disclose Personal Data about you to the relevant authorities or to law enforcement agencies.
- Accuracy of Personal Data
6.1. We will take reasonable steps to ensure that the Personal Data we collect about you is accurate, complete, not misleading and kept up-to-date. If we are in an ongoing business relationship with you, please update us of any changes to your Personal Data for the purposes listed in section 4 of this Privacy Notice.
- Protection of Personal Data
7.1. We employ appropriate administrative, physical, technical and organizational security measures to help protect your Personal Data against loss and to guard against access by unauthorized persons.
7.2. When we disclose your Personal Data to third parties, we will ensure that they provide sufficient guarantees to us to have implemented the necessary security measures to protect your Personal Data.
- Retention of Personal Data
8.1. We will not retain any of your Personal Data when it is no longer needed for any business or legal purposes.
8.2. We will dispose of or destroy such documents containing your Personal Data in a secure manner as soon as it is reasonable to assume that the permitted purpose is no longer being served by their retention.
- Access and Correction to Your Personal Data
9.1. You have the right to know what Personal Data we have and process about you. You may write in to us at the contact details provided in section 11 to find out how we have been using or disclosing your Personal Data over the past one year.
9.2. You are also entitled to have incorrect Personal Data about you corrected and you may in some cases ask us to delete your Personal Data. You can also object to certain Personal Data about you being processed and request that processing of your Personal Data be limited.
9.3. Before we accede to your access or correction request, we may need to verify your identity by checking identification document, and the legitimacy of your request.
9.4. We will respond to your access or correction request as soon as reasonably possible, or within 30 days from the date we receive your request. If we are unable to do so within 30 days, we will let you know and give you an estimate of how much longer we require.
9.5. 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.
- Withdrawing Your Consent
10.1 The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in Section 13.
10.2 Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request) 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 shall seek to process your request within ten (10) business days of receiving it.
10.3 Whilst 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 goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request
10.4 Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
- Transfer of Personal Data Outside of Singapore
11.1. Our subsidiaries and shareholders outside of Singapore from time to time may have access to your Personal Data.
11.2. We will ensure that the standard of data protection in the recipient country is comparable to that of the Singapore Personal Data Protection Act 2012. If this is not so, we will enter into an agreement with the receiving party to accord similar levels of data protection as those in Singapore.
- Data Breach Notification
12.1 In the event a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data, we shall promptly assess the impact and once assessed that it is a notifiable data breach, we shall report this breach within 3 calendar days to the Personal Data Protection Commission (PDPC). We will notify you when the data breach is likely to result in significant harm to you after our notification to PDPC. We may also notify other relevant regulatory agencies, where required.
- Contacting Us
13.1. If you have any questions or feedback regarding this Privacy Notice, or any complaint you have relating to how we manage your Personal Data, you may contact our Data Protection Officer (DPO) via this email address: email@example.com
Any query or complaint should include, at least the following details:
- Your Name and Contact Information
We treat such queries and feedback seriously and will deal with them confidentially and within reasonable time.
- Effect of Notice and Changes to Notice
14.1. This Notice applies in conjunction with any other sources, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your Personal Data by us.
14.2. We may revise this Notice from time to time. Please visit our website periodically to note any changes. Changes to this Notice take effect when they are posted on our website.
14.3. Your continued use of our services constitutes your acknowledgment and acceptance of this Notice and any such changes.
Effective Date: 1st Oct 2019
Last Updated: 03rd November 2022