Personal Data and Privacy Policy
DATA PROTECTION NOTICE
This Data Protection Notice (“Notice”) sets out the basis which Emerge Creatives Group LLP. (“we”, “us”, “our” or “Emerge”) may collect, use, disclose or otherwise process personal data of persons in accordance with the applicable personal data protection laws and regulations. This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or otherwise process personal data for our purposes.
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Personal Data
1.1 What personal data we collect. The personal data we collect depends on the purposes for which we require the personal data and what you have chosen to provide. This may include your name, address, contact information (e.g. telephone number and email address), identification number, photograph, video image and any other information that may identify you or is personal to you.
1.2 How we collect personal data. We collect personal data relevant to our relationship with you. We may collect your personal data directly or indirectly through various channels, including when :
a) you submit an application form or other forms (whether physically or electronically) to us;
b) you visit our website and applications including establishing any online accounts with us;
c) you transact with us or request that we contact you through various communication channels, for example, through social media platforms, messenger platforms, face-to-face meetings, telephone calls, emails, fax and letters;
d) you sign up for our events and training courses, or participate in our survey questionnaires;
e) your images are captured via photographs or videos taken by us or our representatives when you are within our premises or attend training courses or events organised by us;
f) we seek information about you and receive your personal data in connection with your relationship with us, for example, if you are a course or event participant; or
g) you submit your personal data to us for any other reason.
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Purposes
2.1 General purposes. Generally, we collect, use and disclose your personal data for purposes connected or relevant to our business, including:
a) managing your relationship with us;
b) facilitating your use of our platforms and services;
c) assisting you with your requests, enquiries and feedback;
d)administrative purposes, g. accounting, risk management and record keeping, business research, data and planning and statistical analysis;
e) compliance with laws and regulations
f) enforcing legal obligations owed to us, or responding to complaints, litigation or investigations concerning us;
g) managing and engaging third parties or data processors that provide services to us, e.g. IT services, data analytics, marketing, and other professional services;
h) engaging you as an associate trainer or matters relating to training;
i) any other reasonable purposes related to the aforesaid
2.2 Marketing Purposes. Where you give us consent, we collect, use and disclose your personal data for purposes of:
a) managing and/or administering your request to receive news (including events and product launches), promotions and marketing information from us (and/or our affiliates or related entities);
b) analyzing and/or profiling your purchases, transactions and/or likes or dislikes so as to be better able to send you relevant or targeted news (including events and product launches), promotion and marketing information from us (and/or our affiliates or related entities);
c) sending you news (including events and product launches) and promotions from us (and/or our affiliates or related entities) as well as marketing information from us (and/or our affiliates or related entities) and on products.
d) any other reasonable purposes related to the aforesaid
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Disclosure of Personal Data
3.1 We may disclose your personal data for the purposes described in paragraph 2, including to the following parties:
a) third parties who are appointed to provide services to us, e.g. associate trainers, IT vendors, marketing companies and event organisers
b) third parties that we conduct joint marketing and cross promotions with; and/or business partners; and/or
c) regulatory authorities and public agencies.
3.2 When disclosing personal data to third parties, we will (where appropriate and required by applicable law) enter into contracts with these third parties to protect your personal data in a manner that is consistent with applicable laws and/or ensure that they only process your personal data in accordance with our instructions.
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Cross Jurisdiction Transfers of Personal Data
4.1 We store our data in Singapore and within cloud services. Generally, we do not transfer your personal data to other jurisdictions unless it is necessary for business-related purposes. If a transfer is required, require recipients of the personal data to protect personal data at a standard comparable to that under the laws of Singapore. Should the data protection laws in the destination jurisdiction not be comparable to the PDPA of Singapore, we will seek your consent before proceeding with the transfer.
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Protection of Personal Data
5.1 Period of retention. We keep your personal data only for so long as we need the data to fulfil the purposes we collected it for, and to satisfy our business and legal purposes, including audit, accounting or reporting requirements. How long we keep your personal data depends on the nature of the data, e.g. we keep personal data for at least the duration of the limitation period for bringing claims if the personal data may be required to commence or defend legal proceedings. Certain information may also be retained for longer, e.g. where we are required to do so by law or to maintain a record of the certification you have obtained with us.
5.2 Unauthorised access and vulnerabilities. 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 up-to-date antivirus protection and encryption to secure all storage and transmission of personal data by us and disclosing personal data both internally and to authorised third parties and agents only on a need-to-know basis.
5.3 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 personal data and are constantly reviewing and enhancing our information security measures.
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Accuracy of Personal Data
6.1 We will make every reasonable effort to ensure that personal data collected by us or on our behalf is accurate and complete.
6.2We generally rely on personal data provided by you. In order to ensure that your personal data is current, complete, and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer at the contact details provided in paragraph 8.
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Your Rights
7.1 You enjoy certain rights at law in relation to your personal data that we hold or control. These rights include:
a) Withdrawal of consent. You may withdraw your consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing to our Data Protection Officer at the contact details provided in paragraph 8. Depending on the complexity of the request and its impact to our relationship with you, we will cease (and instruct any of our data intermediaries and agents to cease) collecting, using or disclosing the personal data within ten (10) calendar days of our receipt of your request, unless required or authorised under applicable laws.
b) Correction. you may request that any incomplete or inaccurate data that we hold or control be corrected by submitting your request in writing to our Data Protection Officer at the contact details provided in paragraph 8.
c) Access. you may ask if we hold or control your personal data and if we are, you can request access or a copy of such data by submitting your request in writing to our Data Protection Officer at the contact details provided in paragraph 8. We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within fourteen (14) calendar days after receiving your request in writing (including both electronic and non-electronic methods), we will inform you in writing within thirty (30) calendar days of the time by which we will be able to respond to your request. A reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request. We may also be permitted under applicable laws to refuse a request.
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Data Protection Officer
If you have any feedback or issues in relation to your personal data, or about this Notice, or wish to make a complaint to us, you may contact our Data Protection Officer whose contact details are set out below.
Data Protection Officer: Lynn Foo
Email address : training@emerge-creatives.com