Singapore Corporate Counsel
What Personal Data do we collect?
“Personal Data” refers to any data or information, whether true or not, about you from which you can be identified either (a) from that data; or (b) from that data and other information to which we have or are likely to have access.
Depending on the nature of your interaction with us, Personal Data which we may collect from you include:
- your name, passport or other identification number, telephone number(s), mailing address, email address and any other information relating to you;
- information about your use of our Website and services, including cookies, IP address and membership subscription details, but only to the extent that the SCCA Limited may identify you from such information;
- payment related information, such as your bank account or credit card information, and your credit history; and
- information about your usage of and interaction with our Website and/or services including computer and connection information, device capability, bandwidth, statistics on page views, and traffic to and from our Website.
When do we collect Personal Data?
We collect Personal Data from you when you access our Website and/or provide information in the following manner:
- submit forms and/or applications relating to any of our services or products;
- register for or use any of our services on our Website, or other websites owned or operated by us or when you register as a member of our Website or other websites owned and/or operated by us, or use services on such other websites;
- use our services, e.g. our membership subscription service;
- make a purchase;
- request to be included in an email or other mailing lists;
- when you respond to our promotions, contests and other communications and initiatives; and
- when you submit your Personal Data to us for any other reason.
When browsing our Website, you generally do so anonymously but please see Section 5 below on cookies.
If you provide us with any Personal Data relating to a third party (e.g. Personal Data of spouse, children, parents, employees and/or authorised representatives), by submitting such Personal Data to us, you warrant and represent to us that you have obtained the consent of such third party to you providing us with their Personal Data for the respective purposes.
You should ensure that all Personal Data submitted to us is complete, accurate, true and correct.
Where the GDPR is applicable, we clarify that the provision of Personal Data may be partly required by law (e.g. tax regulations), or may also result from contractual obligations (e.g. information on the contractual partner), or may be necessary to conclude certain contracts. Before providing your Personal Data, you may choose to contact our data protection officer for more information on (i) whether the provision of the Personal Data is required by law, by contract or is necessary for the conclusion of a contract, (ii) whether there is an obligation to provide the Personal Data and (iii) what the consequences of non-provision of the Personal Data are.
How and for what purposes do we handle your Personal Data?
We may handle the Personal Data we collect from you for the following purposes:
- processing membership application and renewals, event sign-ups, advertisement submissions etc;
- responding to your queries and requests and responding to feedback and complaints;
- matching any Personal Data held which relates to you for any of the purposes listed herein;
- verifying your identity;
- protecting and enforcing our contractual and legal rights and obligations;
- compliance with internal policies and any applicable rules, laws and regulations, codes of practice or guidelines or request from any governmental, supervisory, regulatory, judicial or equivalent body, or to assist in law enforcement and investigations by relevant authorities;
- as reasonably required for the provision and/or receipt of third-party services;
- managing our relationship with you, personalising your experience and to allow us to deliver the type of content and product offerings in which you are most interested;
- improving our website in order to better serve you and responding to your customer service requests; and
- to quickly process your transactions.
The SCCA Limited may also handle your Personal Data for the following purposes, depending on the nature of our relationship with you:
- If you have a membership subscription with us:
- to process your application for membership subscription;
- to maintain or renew your membership subscription with us;
- to verify and process your personal particulars and payments (if applicable) in relation to events and provision of our membership subscription service;
- to provide you with services which you have signed up for;
- communicating with you to inform you of changes and development to the SCCA Limited policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you;
- conducting market research for statistical, profiling and statistical analysis for the improvement of products and services provided to you; and
- resolving complaints and handling requests and enquiries;
- processing of your Personal Data in relation to any of the purposes stated above.
- If you submit advertisements to us:
- to verify and process your personal particulars and payments made for the posting of the advertisements;
- communicating with you to inform you of changes and development to the SCCA Limited policies, terms and conditions and other administrative information, including for the purposes of servicing you in relation to products and services offered to you; and
- resolving complaints and handling requests and enquiries.
Where permitted under the PDPA, we may also handle your Personal Data for the following purposes:
- providing services, products and benefits to you, including email alerts, promotions, event notifications;
- matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision or offering of products and services, whether by the SCCA Limited or other third parties;
- sending you details of products, services, special offers and rewards, either to our members generally, or of particular products and services which may be of interest to you; and
- conducting market research, understanding and determining location, preferences and demographics for us to review, develop and improve our products, services and also develop special offers and marketing programmes.
In relation to particular products or services or in your interactions with us, we may also have specifically notified you of other purposes for which we handle your Personal Data. If so, then we will handle your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.
Where the GDPR is applicable, we rely on the following legal basis for processing your Personal Data:
- where it is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract;
- where it is necessary for our legitimate interests or the legitimate interests of a third party;
- where necessary for us to comply with our legal and regulatory obligations; and
- where we have your consent (please note that you have a right to withdraw your consent at any time).
How do we protect your Personal Data?
The SCCA Limited will take reasonable steps to protect your Personal Data against unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. We have implemented appropriate measures to ensure that, by default, only Personal Data that is necessary for the specific purpose is processed.
We have taken the following protective measures on our Website by engaging a vendor that complies with the following:
- no use vulnerability scanning and/or scanning to PCI standards;
- no requests for or storage of credit card details on the Website;
- regular Malware Scanning conducted;
- storage of Personal Data in secured networks that is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential; and
- encryption via Secure Socket Layer (SSL) technology for sensitive/credit information you supply.
We implement a variety of security measures when a user enters, submits, or accesses their information to maintain the safety of your Personal Data. We ensure that all transactions are processed through a gateway provider and are not stored or processed on our servers.
Where necessary, the SCCA Limited will also assess the impact of processing on the protection of personal data in certain circumstances, including where the processing (particularly the use of new technologies) is likely to result in high risk to the rights and freedoms of yourself.
In the event of a personal data breach, the SCCA Limited undertakes to comply with the notification requirements in accordance with the applicable laws, including notifying both the appropriate supervisory authorities, and notifying yourself.
Do we use 'cookies'?
When accessing our Website, we may collect or analyse anonymised information from which individuals cannot be identified, such as frequency of use, the number of page views (or page impressions) that occur on the Website and common entry and exit points into our Website.
You may choose to have your computer warn you each time a cookie is being sent, or you may alternatively choose to turn off all cookies. This can be done through your browser settings; please refer to your browser's help menu to effect such changes.
However, we, along with third-party vendors such as Google, use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our Website. Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising Initiative Opt Out page or by using the Google Analytics Opt Out Browser add on.
Disclosure and/or transfer to third parties
We do not sell, trade, or otherwise transfer to outside parties your Personal Data without your consent.
Subject to the provisions of any applicable law, this Personal Data may be disclosed and/or transferred for the purposes listed in Section 3 above (where applicable) to the following third parties, whether they are located in Singapore or overseas:
- SCCA Limited affiliates;
- vendors or any third-party business partners who offer goods and services or other promotional programmes on the SCCA’s sites, whether in conjunction with us or not;
- our professional advisors such as our auditors and lawyers;
- relevant governmental, regulatory, supervisory or judicial or other equivalent bodies or authorities or law enforcement agencies;
- any third parties to whom we are required by or requested to or under any obligation to disclose and/or transfer Personal Data pursuant to law or regulation or any legal process; and
- any other party to whom you authorise us to disclose and/or transfer your Personal Data.
Non-personally identifiable visitor information may be provided to other parties for marketing, advertising, or other uses.
Any transfer of Personal Data shall be in accordance with the PDPA and SCCA Limited will take reasonable steps to ensure that any recipient of such Personal Data will provide a standard of protection to Personal Data that is at least comparable to the protection under the PDPA.
Where applicable, SCCA Limited will also take reasonable steps to ensure that any transfer of Personal Data is in compliance with the conditions set out in the GDPR and that any Personal Data transferred to countries outside the European Union is protected by appropriate safeguards mentioned by the GDPR (such as the use of standard data protection clauses adopted or approved by the European Commission).
Retention of Personal Data
Where the GDPR does not apply to you, you have the following rights under the PDPA, subject to certain exemptions in the PDPA:
- Right to access and obtain copies of Personal Data that we hold about you; and
- Right to correct Personal Data that we hold about you that is incorrect.
Where the GDPR is applicable, you have the following rights under the GDPR:
- Right to access and obtain copies of Personal Data that we hold about you;
- Right to correct Personal Data that we hold about you that is incorrect;
- Right to require us to erase Personal Data that we hold about you;
- Right to object to our processing of Personal Data that we hold about you on legitimate grounds, including for the purposes of direct marketing;
- Right to require us to restrict processing of Personal Data that we hold about you, in circumstances provided for in the GDPR, including circumstances where the accuracy of the Personal Data is contested, or the processing is unlawful;
- Right to receive from us Personal Data that we hold about you in a structured, commonly used and machine-readable format, including for your transmission of that Personal Data to another organisation, in circumstances provided for in the GDPR; and
- Right not to be subject to automated decision-making (including profiling) where this has legal effect or significantly affects you.
Please note that you may be required to pay a reasonable administration fee (to the extent permitted under the relevant laws) for us to process such requests.
If you are concerned about the processing of your Personal Data, you can make a complaint to the Singapore Personal Data Protection Commission (https://www.pdpc.gov.sg).
Occasionally, at our discretion, the SCCA Limited may provide links to other/external sites ("Third Party Sites") that may be of relevance and interest to users, or that may be operated by third parties, such as our business partners. We are not responsible for the privacy practices of websites operated by third parties that are linked to our Website. Once you have left our Website, and are on a Third Party Site, please learn about the privacy policies of such third party websites to determine how they will handle any Personal Data they collect from you. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.
Via post : Singapore Corporate Counsel Association Limited
30 Merchant Road,
Riverside Unit 02-01
Attn: Data Protection Officer
Via email: email@example.com