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CapGrow Pte Ltd
Any information relating to an identified or identifiable natural person.
An ‘identifiable natural person’ is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.”
Special category Personal Information
Personal Information revealing racial or ethnic origin, political opinions, religious beliefs, philosophical beliefs or trade union membership
genetic and biometric data; and
data concerning health, sex life or sexual orientation
Collection of Personal Data We collect personal data from clients, customers, business contacts, partners, personnel, contractors and other individuals. Such personal data may be provided to us in forms filled out by individuals, face to face meetings, email messages, telephone conversations, through our websites or provided by third parties. If any individuals contact us, we may keep a record of that contact.
We collect these personal data when it is necessary for business purposes or to meet the purposes for which the individuals have submitted the information.
We will only collect, hold, process, use, communicate and/or disclose such personal data, in accordance with this policy. If any party is acting as an intermediary or otherwise on behalf of a third party individual or supplying us with information regarding a third party individual (such as a friend, a colleague, an employee etc), such intermediary party undertakes that you are an authorised representative or agent of such third party individual and that you have obtained all necessary consents from such third party individual to the collection, processing, use and disclosure by us of their personal data. Because we are collecting the third party individual’s data from you, you undertake to make the third party individual aware of all matters listed in this policy preferably by distributing a copy of this policy to them or by referring them to our website.
Use of Personal Data We use personal data for the following purposes:
to provide our services
to respond to the individual’s request or for the purposes for which it was provided to us as stated at the time of the collection (or as is obvious from the context of collection)
to maintain contact with clients and other contacts
to keep clients and other contacts informed of the services we offer, industry developments, service offerings, seminars and other events we are holding, that may be of interest to them
for general management and reporting purposes, such as invoicing and account management
for recruitment purposes
for purposes related to the employment of our personnel and providing internal services to our personnel
all other purposes related to our business.
Any individual may choose to unsubscribe from mailing lists, registrations, or elect not to receive further marketing information from us by contacting us through email@example.com, or if we have contacted such individual by email, such individual may use the unsubscribe function in that email to notify us. Such requests will be processed within 28 days.
Disclosure of Personal Data to Third Parties We do not disclose personal data to third parties except when required by law, when we have the individual’s consent or deemed consent or in cases where we have engaged third parties such as data intermediaries or subcontractors specifically to assist with our firm’s activities. Any such third parties whom we engage will be bound contractually to keep all information confidential.
We may disclose personal data to other member firms in the CapGrow network of firms, where it is necessary (i) to meet the purpose for which such individual has submitted the information; or (ii) to enable such individual to be provided with information at a later date which may be of relevance and interest to such individual based on the nature and purpose of such individual’s voluntary requests. We may also transfer all data in our possession to a successor-in-interest to our business or assets.
Access to and Correction of Personal Data Upon request, we will provide the individual with access to their personal data or other appropriate information on their personal data in accordance with the requirements of the PDPA.
Upon request, we will correct an error or omission in the individual’s personal data that is in our possession or control in accordance with the requirements of the PDPA.
We may charge for a request for access in accordance with the requirements of the PDPA.
Withdrawal of Consent Upon reasonable notice being given by an individual of his withdrawal of any consent given or deemed to have been given in respect of our collection, use or disclosure of his personal data, we will inform the individual of the likely consequences of withdrawing his consent. We will cease (and cause any of our data intermediaries and agents to cease) collecting, using or disclosing the personal data unless it is required or authorised under applicable laws.
Accuracy of Personal Data We will make a reasonable effort to ensure that personal data collected by us or on our behalf is accurate and complete.
Security and Protection of Personal Data We have implemented generally accepted standards of technology and operational security to protect the personal data in our possession or under our control and to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. All CapGrow personnel follow a network-wide security policy. Only authorised CapGrow personnel are provided access to personally identifiable information and these personnel have agreed to ensure confidentiality of this information. CapGrow’s policy is to use secure socket layer technology for the protection of credit card information submitted through web forms. This policy is also required for any fulfilment agents of CapGrow.
Retention of Personal Data We will cease to retain personal data, as soon as it is reasonable to assume that the purpose for collection of such personal data is no longer being served by such retention, and such retention is no longer necessary for legal or business purposes.
Transfer of Personal Data outside of Singapore We will ensure that any transfers of personal data to a territory outside of Singapore will be in accordance with the PDPA so as to ensure a standard of protection to personal data so transferred that is comparable to the protection under the PDPA.