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Personal Data Protection Policy
The Experience Effect (or as appropriate in the context, “we”, “us” or “our”) respects the protection of the Personal Data of individuals and values the relationship we have with you. This Personal Data Protection Policy (“Policy”) describes the types of Personal Data we may collect from you, how we may use that information, and with whom we may share it. Our Policy also describes the measures we take to protect the security of the information you provide to us, including without limitation through this website. We also tell you how you can reach us to update your Personal Data, ask questions you may have about our personal data protection practices and provide feedback on our personal data protection practices.
“Personal Data” in this Policy means data that can identify an individual.
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1. Personal Data that we collect
The types of Personal Data that we collect about individuals include:
(i) Name
(ii) NRIC number / FIN number / passport number
(iii) Bank account details
(iv) Mobile number
(v) Email address
You may have provided the Personal Data to us personally or authorised other individuals to provide the Personal Data to us and consent (on your behalf) to our collection of your Personal Data from these individuals. These individuals could be your superiors, employees, subordinates, or colleagues.
Where you give us Personal Data about other individuals, you confirm that you are authorised to disclose and consent, on their behalf, to the processing of such Personal Data for the purposes described in the section “Purposes for which we collect and use Personal Data”, or other purposes for which your consent has been sought and obtained.
2. Purposes for which we collect and use Personal Data
We collect and use the Personal Data that you provide to us for the following purposes:
If you are a Vendor / Service Provider (excluding Trainers / Speakers)
(i) To conduct due diligence / background checks that are mandated by legislation or our internal policies and practices
(ii) For the purposes of the supply of products and services and support by vendors / service providers to us
(iii) To evaluate the products and services provided by vendors / service providers / business partners to us
(iv) Where applicable, security clearance / entry access into premises used for the conduct of courses, workshops, seminars and events
If you are a Trainer / Speaker / Vendor / Service Provider / Business Partner
(i) To conduct due diligence / background checks that are mandated by legislation or our internal policies and practices
(ii) For purposes related and ancillary to the organisation and conduct of courses, workshops, seminars and events
(iii) To evaluate and to improve our services and service offerings
(iv) Where applicable, security clearance / entry access into premises used for the conduct of courses, workshops, seminars and events
If you are a Customer or a Participant of our Courses, Workshops, Seminars and Events
(i) To communicate with customers as part of our organisation and conduct of courses, workshops, seminars and events for customers providing products and services
(ii) To facilitate attendance at courses, workshops, seminars and events
(iii) To evaluate our courses, workshops, seminars and events and we can improve our services and service offerings
(iv) To respond to queries or comments on our services and service offerings
(v) Where applicable, security clearance / entry access into premises used for the conduct of courses, workshops, seminars and events
(vi) To communicate with customers on updates on our services and service offerings
Others
(i) To evaluate applications for employment / job positions with us, including conducting due diligence/background checks on job applicants
(ii) To evaluate applications for internships and industrial attachments
We only collect and use Personal Data for purposes which you have consented to and for which we have been authorised. If we need to use your Personal Data for any purpose which you have not previously consented to, we would seek your consent prior to using your Personal Data for the new purpose.
3. Disclosure, sharing and transfer of Personal Data
We do not sell or rent Personal Data that we collect from individuals, including our website visitors. In the course of or in connection with providing our services and service offerings to our customers and participants, we may need to disclose, share and transfer Personal Data to the following parties for the following purposes:
(i) To trainers and speakers so that they are aware of the profile of participants who are attending our courses, workshops, seminars and events
We also disclose and transfer Personal Data to the following parties for the purposes of managing, operating, administering and running our business and for our business and legal purposes:
(i) Financial institutions for purposes of payments and transactions related to our services and service offerings or related to products and services provided to us our vendors / service providers / trainers / speakers.
(ii) To our service providers (who may be located outside Singapore) that have been retained to perform services on our behalf or on behalf of us, including:
a. Service providers who provide IT and outsourcing services such as data storage, electronic mail services, deployment of management operations for information technology and HR outsourcing services;
b. Professional, financial and legal advisors, tax advisors, auditors, insurers and insurance brokers;
c. Vendors, service providers and consultants that have been engaged to help manage, operate, administer and run our operations and business processes or provide products and services to facilitate our provision of our services and service offerings
We require that the parties to whom we transfer Personal Data and our service providers implement adequate levels of protection in order to protect Personal Data. We also require that these parties only process Personal Data strictly for purposes for which we engage them for and consistent with the purposes that we have described in the section “Purposes for which we collect and use Personal Data” or with other purposes for which consent has been sought and obtained.
In addition, we would disclose Personal Data in the following circumstances:
(i) we are required to do so by law;
(ii) in response to a request from law enforcement authorities or other government officials;
(iii) to comply with a court order or direction from a government agency or regulatory authority ordering the disclosure of the Personal Data; and
(iv) where the disclosure is necessary for investigations or legal proceedings.
4. Protection and Security of Personal Data
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We employ a range of reasonable security arrangements and maintain safeguards to protect against the accidental or unauthorized access, collection, use, disclosure, copying, modification, disposal, deletion and other similar risks to Personal Data.
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5. Retention of your Personal Data
We only retain Personal Data for as long as the retention is required for the purposes for which we collected the Personal Data, the purposes described in this Policy and for our business and legal purposes, unless otherwise required by law or other mandatory directions by court or government authorities or for purposes of legal proceedings or other similar proceedings or investigations.
For more information on our Personal Data Retention Policy, please contact our Data Protection Officer at the contact details set out in Section 6 below.
6. Contact Details
If you have any questions or feedback regarding this Policy and our policy and practices on our collection, use, disclosure or retention of Personal Data, you may contact our Data Protection Officer by email at hannah@experience.com.sg.
If you (i) wish to update or correct your Personal Data, (ii) wish to request for information from us on what Personal Data of yours we have and how we have used and shared your Personal Data during the last one year before the date of your request, (iii) wish to withdraw your consent to our use, collection, sharing or processing of your Personal Data or (iv) have any concerns, feedback or complaints about the use and/or sharing of your Personal Data, please contact our Data Protection Officer in writing.
If you are a job applicant and wish to inform us that you do not wish for us to retain your personal data for the purposes of evaluating your suitability for future job openings with us, please contact us by email at hannah@experience.com.sg.
7. Updates to this Personal Data Protection Policy
We may change or update portions of this Policy at any time and without prior notice to you. Please review this Policy from time to time so you are aware of any changes or updates to the notice. We will indicate the effective date of the notice. If you do not agree with any of the changes or updates to the Policy, you have the option of withdrawing your consent to our collection, use, disclosure and processing of your Personal Data (please refer to Section 8 above).
Effective date: 15 January 2020
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