DATA PROTECTION POLICY

This is the data protection policy (“Policy”) of SHARPA PTE. LTD. (“Sharpa” or “we” or “our” or “us”). 

We take your privacy very seriously and have in place policies and practices dealing with data protection. We ask that you read this Policy carefully as it contains important information about our collection, use, processing and disclosure of personal data in our possession or under our control, including information on:

i) our policies and practices for meeting our obligations under laws, regulations and guidelines which concern data protection;

ii) how you may access, correct or make other requests in relation to your personal data in our possession or control as permitted by applicable laws; and

iii) details of our data protection complaints procedure.

1.COLLECTION OF PERSONAL DATA

1.1 Personal data that Sharpa collects include [names, email address, telephone number, organisation and job designation] and other relevant information in order for us to provide products and/or services and to share information that may be of interest.

1.2 Personal data may be collected by us, directly or indirectly, for instance:

1.2.1 when you respond to our promotions, or subscribe to our mailing lists;

1.2.2 when you attend events organised by us; 

1.2.3 when you visit our websites;

1.2.4 when you use our services or enter into transactions with us, or express any interest in doing so;

1.2.5 when you communicate with us by telephone, email, via our website or through other communication channels including social media platforms;

1.2.6 when we seek information about you and receive your personal data in connection with your relationship with us;

1.2.7 when you submit your personal data to us for any reason.

1.3 We also collect personal data from third party sources, for example:

1.3.1 from our business partners and third party service providers who provide advertising, marketing or promotional services to Sharpa;

1.3.2 from analytics and social media partners (such as Google Analytics, LinkedIn, or Meta) through cookies, tags, or similar technologies;

1.3.3 from public sources.

We only receive such data in aggregated or anonymised form where possible, and in compliance with the terms and privacy settings that you have agreed to with those third-party providers.

1.4 In certain circumstances, you may also provide us with personal data of persons other than yourself. If you do so, you warrant that you have informed him/her of the purposes for which we are collecting his/her personal data and that he/she has consented to your disclosure of his/her personal data to us for those purposes, including all purposes as set out in this Policy. 

2.PURPOSES OF COLLECTION, USE OR DISCLOSURE 

2.1 We may collect, use, process, store and/or disclose your personal data for one or more of the following purposes:

2.1.1 to provide you with our products and services that you have requested;

2.1.2 to conduct and complete transactions (e.g. processing orders and payments), performing our obligations or exercising our rights as set out in binding contractual terms, and otherwise to manage your relationship with us;

2.1.3 to provide customer service (e.g. providing information on status and updates), and to respond to any enquiries, queries or requests submitted by you or on your behalf;

2.1.4 conduct feedback, analysis and development activities to improve your experience and to improve our products and/or services;

2.1.5 to investigate and rectify technical issues;

2.1.6 to verify your identity;

2.1.7 to conduct research and analysis to improve our products and/or services;

2.1.8 to communicate with you about our products and services; 

2.1.9 to display and/or sending personalised content, offers, products, services, advertisements, and communications from us that might be of interest to you;

2.1.10 to respond to legal processes or to comply generally with any applicable laws, governmental or regulatory requirements of any relevant jurisdiction (and any applicable rules, codes of practice or guidelines), and requests of any governmental or other regulatory authority with jurisdiction over us, including, without limitation, meeting requirements to disclose under the requirements of any applicable law, assisting in law enforcement and investigations by relevant authorities, conducting audit checks or surveillance and investigation, whether in Singapore or elsewhere;

2.1.11 managing and preparing internal and external reporting and audits;

2.1.12 managing the administrative and business operations and comply with internal processes and policies;

2.1.13 facilitating corporate restructuring processes and/or business asset transactions, including any merger, acquisition, consolidation, restructuring, sale of assets, financing or any other similar scenarios involving the transfer of some or all of our business assets;  

2.1.14 such purposes that may be informed to you when your personal data is collected; 

2.1.15 any other reasonable purposes related to the aforesaid or for which you have provided any information to us; and/or

2.1.16 any other incidental business purposes related to or in connection with the above.

2.2 We may also collect, use, process, store and/or disclose personal data for purposes related to for which you have provided the personal data, in circumstances other than set out in this Policy where required, or permitted, by laws applicable to us or in any relevant jurisdiction, or where we have obtained your consent through other means (for example, pursuant to notices at our premises).

2.3 The purposes listed in the above clauses may continue to apply even in situations where your relationship with us has been terminated or altered in any way (for example, where we use personal data to enforce our rights under a contract with you).

3.THIRD PARTY’S WHO MAY BE PROVIDED WITH PERSONAL DATA

3.1Sharpa may disclose your personal data to the following, whether located within or outside Singapore, for the purposes set out or otherwise referred to in this Policy:

3.1.1 third parties to whom you authorise Sharpa’s disclosure of your personal data (through this Policy or otherwise);

3.1.2 Sharpa’s auditors, professional consultants, lawyers and other advisors;

3.1.3 Sharpa’s business partners;

3.1.4 Sharpa’s service providers or agents;

3.1.5 insurers, credit providers, courts, tribunals, law enforcement agencies, regulatory authorities and other governmental agencies as agreed or authorised by law; and

3.2 Where your personal data is transferred outside Singapore (for example, to our affiliated companies or service providers located overseas), we will ensure that such transfers comply with the requirements of the PDPA, including by ensuring that the receiving organisation provides a standard of protection comparable to that under the PDPA.

4.ACCURACY

4.1 We generally rely on the accuracy of personal data provided by you or your authorised representatives. In order to ensure that our records of your personal data is current, complete and accurate, please update us if there are changes to your personal data by writing to our Data Protection Officer at the contact details at the end of this Policy. 

5.COOKIES AND WEBSITE TRACKING

5.1 When you visit our websites or forums, please note that we may use cookies and similar tracking mechanisms and devices, for purposes such as monitoring the number of times you visit the websites, which pages you go to, and how long you spend browsing each page. This information helps us build a profile of users and improve our websites and other products and services. We may also use third-party analytics tools (e.g. Google Analytics) which collect data in an aggregated manner. You can manage or disable cookies through your browser settings at any time. [Where data is only used on an aggregated basis, we will be unable to identify any particular individual, and we generally track on per-device basis.]

6.OTHER WEBSITES

6.1 Our websites may contain links to other websites. However, this Policy only applies to Sharpa, and if you visit other websites, including through such links, different privacy policies will apply.

7.SECURITY AND RETENTION

7.1 To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, and loss of any storage medium or device on which your personal data is stored, we have introduced appropriate administrative, physical and technical measures, including to protect personal data from unintended access. 

7.2 You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure, and Sharpa cannot and does not guarantee that our systems or applications are invulnerable to security breaches. Sharpa makes no warranty, guarantee, or representation that your use of our systems or applications is safe and protected from viruses, worms, Trojan horses, and other vulnerabilities. 

7.3 We keep your personal data only for so long as we need the personal data to fulfil the purposes we collected it for, and to satisfy our business and/or legal purposes, including audit, accounting or reporting requirements. In some circumstances, we may anonymise your personal data so that it can no longer be associated with you, in which case we are entitled to retain and use such data without restriction.

8.YOUR RIGHTS

8.1 If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, (b) a correction request to correct or update any of your personal data which we hold about you, or (c) other request in relation to your personal data, as permitted by applicable data protection laws, you may submit your request by contacting the Data Protection Officer.

8.2 If you wish to exercise your rights, please contact the Data Protection Officer. You may be required to submit certain forms or provide certain information in order for your request to be processed. Where permitted by law, Sharpa may charge you a reasonable fee to process your request, and will inform you of the fee before processing your request.

8.3 We will respond to your request as soon as reasonably possible, and in accordance with applicable law. 

9.CONSENT WITHDRAWALS

9.1 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. You may withdraw consent and request us to stop using and/or disclosing your personal data by submitting a request in writing to our Data Protection Officer at the contact details provided below. 

9.2 Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) 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 fifteen (15) business days of receiving it.

9.3 If you withdraw your consent to any or all use of your personal data or do not consent to the collection of your personal data by us, we may not be able to provide or continue providing you with products and/or services which you have requested and such withdrawal may also constitute a termination event which results in legal consequences such as forfeiture of deposits. You understand and agree that in such instances where Sharpa requires your personal data to fulfil a contractual obligation to you and you withdraw your consent to collect, use or disclose the relevant personal data for those purposes, Sharpa cannot be held liable for breach of that agreement. Sharpa’s legal rights and remedies in such event are expressly reserved.

9.4 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 in any jurisdiction. 

10.CHANGES TO THIS POLICY

10.1 We keep this Policy under regular review. If we change this Policy we will post the changes on [Privacy Policy], so that you may be aware of the information we collect and how we use it at all times. 

10.2 Where you continue to provide personal data to us as described in this Policy, or continue to use our products or services, this will constitute your acknowledgement and acceptance of a revised Policy.

11.HOW TO CONTACT US / DATA PROTECTION OFFICER DETAILS

11.1 If you have any queries or comments on this Policy or the use of your personal data, or if you wish to lodge a privacy-related complaint, please contact Sharpa’s Data Protection Officer at:

Data Protection Officer

Email address: legal@sharpa.com

Sharpa will investigate your queries, comments or complaint, and will use reasonable endeavours to respond, in accordance with applicable laws.  

12.CROSS-BORDER TRANSFERS

12.1 We may transfer your personal data to locations outside Singapore for the purposes described in this Policy. Where we do so, we will ensure that such transfers comply with the PDPA requirements, including by ensuring that the recipient provides a standard of protection comparable to that provided under Singapore law.