Data Protection Notice for Customers

Personal Data

As used in this notice, "customer" means an individual who has contacted us through any means to find out more about any goods or services we provide, or who may enter, or has entered, into a contract with us for the supply of goods or services.

"Personal data" means data, whether true or not, about a customer who can be identified from that data, or 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, examples of personal data we may collect include your name, email address, telephone number, nationality, and photograph. Other terms used in this notice have the meanings given to them in the PDPA, where the context permits.

Collection, Use and Disclosure of Personal Data

We generally do not collect your personal data unless it is provided voluntarily by you, or by a third party who has been duly authorised by you to disclose your personal data to us, after you have been notified of the purposes for collection and have provided written consent for those purposes. We may also collect and use personal data without consent where permitted or required by the PDPA or other laws.

We will seek your consent before collecting additional personal data, and before using your personal data for a purpose that has not been notified to you, except where permitted or authorised by law.

We may collect and use your personal data for the following purposes:

• Performing obligations in the course of, or in connection with, the provision of goods and services requested by you.
• Verifying your identity.
• Responding to, handling, and processing queries, requests, applications, complaints, and feedback from you.
• Managing your relationship with us.
• Any other purpose for which you have provided the information.
• Any incidental business purpose related to, or connected with, the above purposes.
• Education qualification checks.

We may disclose your personal data where disclosure is required for performing obligations in the course of, or in connection with, the provision of goods and services requested by you.

Reliance on the Legitimate Interests Exception

In compliance with the PDPA, we may collect, use, or disclose your personal data without your consent for the legitimate interests of Gluetron E Business Pte Ltd or another person. When relying on this exception, we will assess the likely adverse effects on the individual and determine that the legitimate interests outweigh any adverse effect.

In line with the legitimate interests exception, we may collect, use, or disclose your personal data for fraud detection and prevention, detection and prevention of misuse of services, and collection and use of personal data on company-issued devices to prevent data loss.

These purposes may continue to apply even where your relationship with us, for example under a contract, has been terminated or altered in any way, for a reasonable period thereafter.

Withdrawing Your Consent

The consent you provide for the collection, use, and disclosure of your personal data remains valid until it is withdrawn by you in writing. You may withdraw consent and request that we stop collecting, using, or disclosing your personal data for any or all listed purposes by submitting your request in writing or by email to our Data Protection Officer.

Upon receiving your written withdrawal request, we may require reasonable time to process the request and notify you of the consequences, including any legal consequences that may affect your rights and liabilities to us. In general, we will seek to process your request within thirty (30) business days of receiving it.

Depending on the nature and scope of your request, we may not be able to continue providing goods or services to you. In such cases, we will notify you before completing the processing of your request. If you decide to cancel your withdrawal of consent, please inform us in writing.

Withdrawing consent does not affect our right to continue collecting, using, and disclosing personal data where such collection, use, or disclosure without consent is permitted or required under applicable laws.

Access to and Correction of Personal Data

If you wish to request access to a copy of the personal data we hold about you, information about how we use or disclose your personal data, or correction of personal data we hold about you, you may submit your request in writing or by email to our Data Protection Officer.

A reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.

We will respond to your request as soon as reasonably possible. In general, our response will be within fifteen (15) business days. If we are not able to respond within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond.

If we are unable to provide personal data or make a requested correction, we will generally inform you of the reasons, except where we are not required to do so under the PDPA.

Protection of Personal Data

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. These include minimised collection of personal data, authentication and access controls, good password practices, need-to-basis data disclosure, encryption, anonymisation, up-to-date antivirus protection, regular patching, web security measures, one time password, two-factor or multi-factor authentication, and regular security review and testing.

No method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect your information and regularly review and enhance our information security measures.

Accuracy, Retention and Transfer of Personal Data

We generally rely on personal data provided by you or your authorised representative. To ensure your personal data is current, complete, and accurate, please update us if there are changes by informing our Data Protection Officer in writing or by email.

We may retain your personal data for as long as necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.

We will cease retaining your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that retention no longer serves the purpose for which the data was collected and is no longer necessary for legal or business purposes.

We generally do not transfer your personal data to countries outside Singapore. If we do so, we will obtain your consent and take steps to ensure your personal data continues to receive a standard of protection at least comparable to that provided under the PDPA.

Data Protection Officer

You may contact our Data Protection Officer if you have enquiries or feedback on our personal data protection policies and procedures, or if you wish to make a request.

Effect of Notice and Changes to Notice

This notice applies together with any other notices, contractual clauses, and consent clauses that apply in relation to the collection, use, and disclosure of your personal data by us.

We may revise this notice from time to time without prior notice. You may determine whether a revision has taken place by referring to the date on which this notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.