GENERAL DATA PROTECTION POLICY (“this Policy”)
This Policy sets out the basis which Hyphens Pharma International Limited and its’ subsidiaries and affiliates (collectively, “Hyphens Group”) may collect, use, disclose and otherwise process personal data about shareholders, employees, partners, customers, suppliers and other individuals for a variety of reasonable purposes as described below. In this Policy, “personal data” has the same meaning given to that term in the Personal Data Protection Act 2012 and its regulations (“PDPA”).
Collection, Use and Disclosure of Personal Data
The Hyphens Group collects, uses and discloses personal data in accordance with the data protection principles under the PDPA:
- Consent and Notification – The individual whose personal data is required (“data subject”) will be informed of the purposes for which the Hyphens Group requires the use of personal data so that consent of the data subject for the collection, use and disclosure of such personal data can be obtained accordingly.
- Withdrawal of Consent – The data subject may withdraw his/her consent at any time, e.g. by opting out of the mailing list, or using the “unsubscribe” function. If the data subject wishes to withdraw his/her consent to his/her personal data, depending on the nature of the request, the Hyphens Group may not be in a position to continue to provide its products or services to the data subject or administer any contractual relationship in place, which may result in the termination of agreements with the Hyphens Group.
- Purpose – The Hyphens Group collects, uses, discloses and/or processes personal data for a variety of reasonable business purposes, including but not limited to the following:
- Provision of goods and services (including invoicing and account management, processing payment, and responding to customer requests, or for purposes for which the personal data was provided to the Hyphens Group at the time of collection (or as is obvious from the context of collection).
- Maintain contact with customers and other contacts (including where permitted at law, keeping such data subjects informed of market developments, service offerings, seminars and other events organised by the Hyphens Group that may be of interest to or based on the preference of the data subjects).
- Communicating with shareholders of the Hyphens Group in relation to its corporate affairs, including information on the performance, and the products and services, of the Hyphens Group.
- Purposes related to recruitment, and employment of personnel and providing internal services to personnel.
- Submission of data to relevant authorities as required by law.
- Safety, security and legal compliance.
- Transfer to third party service providers and agents and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes.
- Any other incidental business purposes related to or in connection with the above.
- Access and Correction – If any data subject wishes to withdraw consent to use of his/her personal data or obtain access to or correct his or her personal data records, please log in to the relevant account through which such personal data was first provided, if any, failing which, the data subject can contact the Hyphens Group’s Data Protection Officer (“DPO”) whose contact details are set out below. If there is any chargeable fee for any access, the DPO will notify the data subject first before processing any such request. The access request will be processed within 30 days or if not, the Hyphens Group will notify the data subject.
- Accuracy – The Hyphens Group will rely on personal data protected by the data subject. In order to ensure that such personal data is current, complete and accurate, the data subject will be required to update the Hyphens Group if there are changes to any personal data.
- Protection– The Hyphens Group does not disclose personal data to third parties except when required by law, or expressly or impliedly consented by the data subject. The Hyphens Group has implemented generally accepted standards of technology and operational security to protect the personal data under its control from unauthorised/unlawful processing, accidental loss, destruction and damage.
- Retention – The Hyphens Group will not keep personal data for any longer than necessary to fulfil the purpose(s) for which the data subject gave his consent, and its legal/business needs.
- Transfers – The Hyphens Group does not generally transfer personal data to territories outside of Singapore. Where it does, it will ensure that any transfer of personal data to a territory outside of Singapore will be conducted in accordance with the PDPA.
Photography and Filming
During the Hyphens Group’s events, photography, sound recording, videotaping and filming may be conducted for use in its publicity materials, e.g. website, brochures, email direct mailers and social media. Photos, sound recordings, videos and film recordings of certain individuals may be made during the Hyphens Group’s events. If any individual does not wish for any photos, sound recordings, videos and film recordings where he appears to be used by the Hyphens Group in its publicity materials, please notify the Hyphens Group at the time of registration for the event. Otherwise, every individual attending the Hyphens Group’s events will be deemed to have given his/her consent to the use of any photos, sound recordings, videos and film recordings where such individual appear to be used by the Hyphens Group.
This Policy is governed by the laws of Singapore.
Complaints can be provided via email or telephone call to the DPO who will investigate and resolve complaints within 5 working days where possible, or if not, the DPO will regularly update the complainant of the status of the investigation and estimated resolution time. Upon completion of the investigation, the DPO will provide written report to the complainant containing the investigation findings and steps to resolution, and confirm with user that complaint has been satisfactorily resolved.
Effect of, and Changes to, this Policy
This Policy is intended to supplement the Hyphens Group’s other policies relating to internet and email use. The Hyphens Group may amend this Policy at any time and from time to time without any specific notice to the data subjects.
Last updated on 10 September 2019