Personal Data Protection Notice

Viewqwest Pte. Ltd. (“VQ”) respects the privacy and confidentiality of all personal data in our possession or under our control. We have implemented policies and practices to better protect the collection, use, disclosure, storage, and other processing of personal data provided to us. Please read this Personal Data Protection Notice (“Notice”) to learn more about how VQ is committed to safeguarding the personal information provided to us. 

Effective Date of this Notice: 12th July 2019. It supersedes the previous Personal Data Protection Policy.

 1. Application of the Notice 

This Notice is based on the Singapore Personal Data Protection Act 2012 (“PDPA”) and all the associated regulations and guidelines as may from time to time be issued by the Personal Data Protection Commission (“PDPC”) of Singapore. In jurisdictions outside of Singapore, VQ’s practices may be subject to different or more restrictive local laws. Please review this Notice carefully before providing us with any of your personal data.

 2. How we collect your Personal Data about you

We collect personal data from the following sources:

a. Internal Collection Channels

· Admin Office

· Department – Finance / Account

· Department – Human Resource

· Roadshow

· Department – Sales

· Company Premises (Front Staff)

· Reception Area

· Seminar / Event / Exhibition

· Social Media – Individual

· Website – Corporate (via submission forms, emails)

· Website – Micro Sites

· Department – Marketing / Marcom

· Headquarters

· Department – Operations

· Service Counter

· Employees own devices

· LinkedIn profiles of job applicants, employees or former employees

· Showroom / Showflat

· Subsidiary / Branch offices

· Call Centre

· Customer Service / Support

· Retail Outlet

· Vesta Internet of Things system

b) External Collection Channels

· Job Applicant

· Front Line Staff

· Job Search Portals

· External Call Centre or Contact Centre

· External Sales Associates

3. Types of Personal Data about you that we process

The types of personal data we collect about you and process (or have a service provider process on our behalf) may include:

· Arming/Disarming of Vesta system

· Authentication

· Communication and Correspondence

· Computer Device

· Demographic

· Education Qualifications

· Emergency Contact Details

· Ethnicity

· Event Logs

· Family Background & Details

· Financial Information

· Location

· Ownership

· Personal Contact Information

· Personal Details

· Photos & Video Footage

· Premises Sensor

· Professional Profile

· Remote (which button is pressed)

· Storage Access

· Transactional

4. Our purpose(s) for processing Personal Data about you

We use and otherwise process the personal data we have collected about you for one or more of the following purposes:

Accounting/Finance

· Account payables/receivables

· Claims & disbursements

· Income tax returns

· Sales commissions

Banking & Financial services

· Conduct credit checks, screenings or due diligence checks as may be required under applicable laws/regulations

· Seek professional advice, including legal advice

General

· Billing, payment processing and other credit-related activities

· Carry out our obligations arising from any contracts entered into between you and us

· Comply with or fulfil legal obligations and regulatory requirements

· Create or develop new applications, products or services

· Customer care and account management

· Develop new products and services

· Enforce obligations owed to us

· Enforce terms and conditions of use

· Enhance or improve our applications, products or services

· Fulfil legal requirements

· Fulfil requests, orders and delivery of products and services

· Internal purposes for accounting, auditing and booking

· Internal purposes for auditing, data analysis and research

· Investigate complaints, claims and disputes

· Maintaining the safety and security of our premises with the use of security cameras

· Manage and improve our business and operations to serve you better

· Manage and improve our business and operations to serve you better or enhance customer experience

· Market and provide products or services

· Obtain opinions, comments or feedback about our products or services

· Pass information about you to our agents, associates, subsidiaries or partners to carry out services for us

· Process and administer employment records

· Process contract renewals and upgrades

· Process payment for purchases, transactions, products or services

· Respond to queries and feedback, and provide customer service and support

· Send information, updates and promotional materials on our products or services

· Shop and submit orders for products or services

· Update records in our database

General Data Processing

· Appraise and evaluate employee performance

· Build camaraderie among employees through team building activities

· Conduct Call Centre or Contact Centre activities

· Email/Web hosting for mailing and data backup for employees

· Enrol with and utilize insurance benefits from the Firm’s insurance provider

· Enrol with and utilize of the benefits from the Firm’s health maintenance organization (“HMO”) partner

· Escalate grievances or lodge complaints among employees

· Process employment permits of clients with the concerned government agencies

· Provide training and professional development of employees through briefings, trainings, seminars and workshops

· Source applicants for the staffing needs of the firm

· Submit and get approval for an employee’s sick leave or vacation leave

· Submit documents with government agencies for the formation of a new corporation or business entity

· To compute the compensation and monetary benefits received by an employee

Health

· Process and administer health records

Human Resource

· Benefits & compensation management

· Employee communication

· Payroll processing

· Personnel management

· Processing & administration of employment records

· Recruitment and selection

· Sharing salary information with tax authorities

· Staff Appraisals

· Tax calculation and salary administration

· Training & career development

Legal

· Manage board of director and committee meetings and ensure statutory and regulatory compliance

Marketing

· Analyze sales and marketing data

· Conduct direct marketing activities

· Conduct joint marketing with other companies and service providers

· Conduct lead generation activities

· Conduct needs analysis and requirements

· Contact winners of contests/competitions

· For purpose of marketing, promotions, and customer relationship management

· Notify you about enhancements to our services

· Notify you about products, services or special offers

· Process and administer surveys, sweepstakes, contests and promotions

· Provide advertisement, newsletters and promotional updates

· Provide information about products and services

· Provide information on events, conferences, seminars or workshops

· Provide newsletters and updates

· Send latest product announcements, software updates and upcoming events

Online

· Analyze website visits

· Communicate with customers, members and website visitors

· Customization of content and advertising

· Develop and provide advertising tailored to your interests

· Ensure content is presented in most effective manner

· Interact with external social networks and platforms

· Provide usage of online services

· Register, setup and manage accounts

· Remarketing and behavioral targeting – Adwords

Product Development

· Improve the Internet of Things experience

· Improve the Vesta product

· Notification of information to the customer on what is happening at home, as detected by the Vesta system

Retail

· Improve the shopping experience

· Process exchange or product returns

5. Who we disclose Personal Data about you to

We disclose some of the personal data we have collected about you to the following parties or organisations outside of VQ:

Credit Reference & Debt Collection Agencies

· Credit Reporting Agencies

· Debt Collection Agencies

· Payment Card Processing Vendors

Data Processing and Hosting Companies

· Cloud Service Providers

· IT/Technical Support

· Webhosting Companies

Emergency Contacts

· Notification of Vesta alerts

Providers of Professional Services

· Legal Services

· Other Outsourced Vendors

6. How we manage the Collection, Use, Disclosure and Storage of your Personal Data

a) Obtaining Consent

If we collect personal data directly from you, we will ordinarily first notify you of the purposes for which we are collecting it and obtain your express consent to us collecting, using and disclosing it for those purposes. However, when you voluntarily provide personal data to us for a purpose and it is reasonable that you do so we may rely on you being deemed to have consented to us collecting, using and disclosing your personal data for that purpose.

Under certain circumstances, we may collect, use and/or disclose personal data about you without your consent, for example, so that we can comply with our statutory obligations or where personal data is publicly available.

b) Third-Party Consent

If you have a one-on-one meeting with us or do a transaction with us on behalf of another individual, you must obtain consent from that individual in order for us to collect, use or disclose his/her personal data.

7. How you can limit processing of Personal Data about you

Withdrawal of Consent

If you have given us consent to collect, use, disclose and otherwise process personal data about you, you may withdraw that consent at any time. You should give us reasonable advance notice of your withdrawal of consent. We will notify you of the likely consequences of your withdrawal of consent, e.g. without your personal contact information we may not be able to inform you of future updates or that the quality of our service may be impacted.

Your request for withdrawal of consent can take the form of an email or letter to us, or through the UNSUB feature in an online service.

8. Accessing and making a correction to Personal Data about you

You may ask us in writing to tell you what personal data we hold about you and how we have, or may have, used or disclosed it within a year before the date of your request. We will respond to your request as soon as reasonably possible and, in any event, we will respond to you within 30 days after receiving your request. We may charge a fee for processing your request, but we will let you know the amount of the fee before you incur it.

You may also ask us to correct an error or omission in the personal data we hold about you. Unless we are satisfied on reasonable grounds that a correction should not be made, we will correct the personal data as soon as practicable.

When you make any such request, we may need to verify your identity – for example, by checking your identity card number or other legal identification document.

9. Accuracy of your Personal Data

We will take reasonable precautions and make reasonable verification checks to ensure that the personal data we hold is reasonably accurate, complete and up-to-date.

From time to time, we may do a verification exercise for you to update us on any changes to the personal data we hold about you. If we are in an ongoing relationship with you, it is important that you update us if there are any changes in the personal data we hold about you (such as a change in your home address).

10. Protection of Personal Data

We have implemented an Information Security Policy that governs how we protect personal data. We make reasonable security arrangements to protect personal data about you that is in our possession or under our control to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. All our employees will take reasonable and appropriate measures to maintain the confidentiality and integrity of your personal data, and will only share your data with authorised persons on a ‘need to know’ basis.

Entities that provide services to us to process personal data on our behalf will be bound by contracts with us that that require them to provide sufficient guarantees in respect of the technical and organisational security measures governing the processing to be carried out and to take reasonable steps ensure compliance with those measures.

11. Retention of Personal Data

We will not retain any documents containing personal data about you as soon as it is reasonable to assume that the purpose for which we collected that personal data is no longer being served by retention of it and retention is no longer necessary for legal or business purposes.

We have a Document Retention Policy that spells out when we must cease to retain personal data and that requires documents and personal data to be destroyed (paper documents) or deleted (electronic documents and data stored in databases) securely. Certain retention periods are based on statutory or regulatory requirements; IMDA requires us to retain customer information for twelve months after termination of a service.

12. Transfer of Personal Data

If there is a need for us to transfer personal data about you to a country or territory outside Singapore, we will ensure that the recipient organisation will be obliged to provide a standard of protection to such transferred data that is comparable to the protection it receives under Singapore law.

13. Location Information

Note that if you give us the permission to do so via your mobile device or Vesta system, we may use and store information about your location. We use this information to provide features of our Service in order to improve and customize our Service. You can enable or disable location services when you use our Service at anytime, through your mobile device settings.

14. Tracking of User Activity

Where we track user activity, we will document this in our Data Inventory, and disclose such activity in our Privacy Notice.

15. Behavioural Re-marketing

Where we use remarketing services to advertise on third party web sites to you after you have visited our website, we, and our third party vendors, use cookies to inform, optimize and serve ads based on your past visits to our website.

You can opt out of these re-marketing services by visiting the web site of the relevant third party vendor(s).

When you visit our website, we may assign your computer one or more “cookies.” By accessing our website, you agree that we can place cookies on your device. A cookie is a small text file that contains information that can later be read by us to facilitate your access to our website, gather statistical data, and personalize your online experience. We currently use cookies on our website for purposes including, but not limited to, detecting your web browser’s multimedia capabilities, tracking promotional advertisements that we have displayed to you, maintaining current login and purchase information on secure portions of the website and providing a unique identifier to your computer so that we can generate statistics regarding website usage.

Most browsers automatically accept cookies, but you can modify your browser setting to decline cookies. Generally, you can remove these cookies by following directions provided in

your Internet browser’s “help” file. If you choose not to allow us to place a cookie on your computer, you may be restricted from some services and some of the interactive features offered on our websites may be similarly restricted or rendered inoperable.

16. Compliance with Laws

Where required to do so by law, we will disclose personal data about you to the relevant authorities or to law enforcement agencies.

17. Links to other sites

Our website may contain links to other websites that are not operated by us. If you click on a third party link, you will be directed to that third party’s website. It is important that you review the Privacy Policy of every site you visit. We have no control over, and are unable to assume any responsibility for, the content, privacy policies or practices of any third party sites or services.

18. Changes to this Personal Data Protection Notice

We may update our Data Protection Policy from time to time. We will notify you of any changes by posting the policy on this page. Please revisit this page periodically for any changes. Changes to this Policy are effective when they are posted on this page.

19. Contacting us

If you have any questions about our collection, use, and/or disclosure of personal data about you; feedback regarding this Policy, or any complaint you have relating to how we collect, use, disclose and store personal data about you, you may contact our Data Protection Officer(s) at dpo@viewqwest.com .

Any query or complaint should include, at least, the following details:

· Your full name and contact information

· A brief description of your query or complaint