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This Privacy Notice outlines the Data Protection Policy (“Policy”) on how Sustainable Asset Management Solutions Pte. Ltd. (“SAMS,” “Company,” or “we”), a company registered in Singapore (UEN: 201711738K), collects, uses, discloses, or otherwise processes personal data in accordance with the Singapore Personal Data Protection Act (2012) (“PDPA”). Please note that this Policy may be updated periodically without further notice. At SAMS, we prioritize the privacy of individuals and are committed to protecting personal data in our possession or under our control from unauthorized disclosure or use. Below, you will find our Data Protection Policy.
1. Introduction
1.1 This Policy delineates our privacy practices regarding the collection, use, disclosure, and processing of personal data. This statement is provided in accordance with the PDPA.
2. Consent
2.1 You are acknowledged and deemed to have consented to the collection, use, and disclosure of your personal data in the circumstances outlined below:
(a) when you voluntarily provide your personal data to us at SAMS’s premises or onsite servicing or exhibition, in association with any activities involving our Company, or during your visits to our website, we collect and process that information accordingly.
(b) it is reasonable for you to have provided us with your personal data under the circumstances in which it was shared; and
(c) in all other circumstances where consent is deemed under the PDPA.
3. Definition of Personal Data
3.1 The terms used in this Policy are defined as follows:
3.1.1 The term “person” refers to an individual who has:
(a) reached out to us through any method to inquire about our goods or services,
(b) submitted an application for a job or internship with us, or
(c) contacted us for any other reasons or purposes; and
3.1.2 “personal data” means data, whether true or not, about an individual who can be identified:
(a) from that data, or
(b) from that data and other information to which we have or is likely to have access; but excludes,
(c) business contact information.
3.2 This may include, but is not limited to, the following items:
(a) Your name, NRIC, passport, employment pass numbers or any other identification numbers.
(b) Telephone number(s), physical mailing address, email address, payment information including the name of cardholder, card number, billing address and expiry data.
(c) Biometric data. (facial image)
(d) Video recording, photograph/video image and
(e) Any network data and additional information about individuals that you have provided to us in any format during your interactions and dealings with the Company.
3.3 Other terms referenced in this Policy shall have the meanings defined in the PDPA, as context allows.
4. Collection, Use and Disclosure of Personal Data
4.1 SAMS typically collects personal data from customers, visitors, employees, and other individuals, including job applicants. We collect personal data solely when it is provided voluntarily by the individual or through a third party whom the individual has expressly authorised to disclose such information (hereafter referred to as the “authorised representative”).
4.2. Personal data may be collected from you through forms you complete, in face-to-face meetings, through emails, or during telephone conversations. Additionally, we may maintain records of any interactions you have with us. The collection of this data will solely be conducted for business purposes or for the specific purposes articulated at the time of data collection.
4.3 You have options concerning how we collect, use, or disclose your personal data. If you decide not to provide the personal data outlined in this notice, we may be unable to process the services you need. You also have the right to object to the processing of your personal data and can withdraw your consent as described in section 7 below.
4.4. We may collect, disclose, or use your personal data in accordance with the exceptions outlined in the Personal Data Protection Act or other relevant written law or legislation, particularly in the following circumstances:
(a) to respond to an emergency that threatens your life, health and safety or that of another individual; and
(b) necessary in the national interest, for any investigation or proceedings.
4.5 The personal data that is collected may be used for one or more, but not limited to, the following purposes:
(a) to facilitate the provision of goods and services, process payments, execute deliveries, and engage in communication with you regarding our products and services.
(b) as a regular practice within our business operations.
(c) for the purposes of billing and reporting, including invoicing and account management.
(d) for the purposes of facilitating internship and employment applications, as well as recruitment activities.
(e) for follow-up actions on any complaints, feedback, inquiries, or requests that have been received.
(f) to enhance our services in various capacities, identify instances of fraud or abuse, and enable third parties to execute technical, logistical, or other functions on behalf of the Company; and
(g) to aid in law enforcement and investigations carried out by any governmental or regulatory authority.
4.6 SAMS does not sell, rent, or share your personal data with any third parties, except in cases that are necessary for your business interactions with us and in compliance with the PDPA.
4.7 SAMS is permitted to disclose your personal data under the following conditions:
(a) with your consent, the disclosure is required to execute the obligations under the provision for the requested goods or services.
(b) to ensure compliance with all applicable laws, regulations, codes of practice, guidelines, and rules; or
(c) we may disclose personal data to third-party service providers, agents, and other organizations that have been engaged to perform the functions detailed in Paragraph 4.5. It is imperative that any third party we engage enters into a contractual agreement to ensure the confidentiality of all personal data.
4.8 The purposes outlined in Paragraph 4.5 may continue to be relevant even if the relationship between you and us (for instance, as defined in a contract) has been terminated or modified in any manner. This relevance shall persist for a reasonable duration, thereafter, including any periods necessary to fulfil our business or legal obligations.
5. Transfer of Personal Data Outside Singapore
5.1 SAMS typically refrains from transferring your personal data outside of Singapore, except when such transfers are necessary for business-related purposes. In instances where we transfer your personal data, we will ensure that the recipients adhere to a standard of protection comparable to the safeguards established by the PDPA.
6. Security of Personal Data
6.1 SAMS implements appropriate administrative, physical, and technical measures to protect your personal data from loss, unauthorized access, misuse, disclosure, alteration, and other similar risks.
6.2 It is essential to recognize that while no protection method can offer absolute security, SAMS are dedicated to taking all reasonable measures to safeguard the personal data in our custody and control.
7. Withdrawal of Consent
7.1 The consent you provide for the collection, use, and disclosure of your personal data shall remain valid until it is withdrawn by you in writing. You may withdraw your consent at any moment and request that we cease the use and/or disclosure of your personal data for any or all the purposes specified above. To initiate this request, please submit your written communication to our Data Protection Officer (DPO) using the contact details provided below.
7.2 Depending on the complexity of the request and its implications for our relationship with you, SAMS will cease (and will instruct any of our data intermediaries and agents to cease) the collection, use, or disclosure of personal data within a reasonable timeframe upon receiving your written request, unless such action is mandated or permitted by applicable laws.
7.3 In the event that you choose to withdraw your consent, you acknowledge and agree that the Company may, at its discretion, be unable to continue providing you with our goods or services. Additionally, you will remain bound by any contracts related to the goods or services with the Company that were established before the withdrawal of your consent.
8. Access to and Correction of Personal Data
8.1 In accordance with the stipulations outlined in Paragraph 8.3 below, we will respond to your written request within a reasonable timeframe by providing access to the personal data in our possession or control. Additionally, we will provide information on how your personal data was used or disclosed by us within a year before the date of the request.
8.2 Subject to the provisions of Paragraph 8.3 below, upon receiving your written request, we will promptly correct any inaccuracies or omissions in your personal data that are in our possession or control. We will complete the corrections within a reasonable timeframe and ensure that the amended personal data is communicated to any organizations to which your data was disclosed within the year before your request.
8.3 Should your request relate to personal data that we manage on behalf of another organization, we will transfer your request to the relevant organization for their prompt attention and necessary action.
8.4. You are invited to submit your request for access to or correction of your personal data to our Data Protection Officer (DPO) using the contact details provided below. Please be informed that a reasonable fee may apply to the processing of access requests. If applicable, we will notify you of the fee before proceeding with your request.
9. Accuracy of Personal Data
9.1. We rely on the personal data you provide, as well as that submitted by your authorized representative. To maintain the accuracy, completeness, and currency of your personal data, please notify us of any updates or changes by contacting our DPO using the contact details provided below.
9.2 It is essential that all personal data submitted to us is complete and accurate. Inaccuracies or incomplete information may hinder our ability to provide you with the requested goods and services.
10. Retention of Personal Data
10.1 Your personal data will be retained only for the period necessary to fulfil the purpose(s) for which it was collected, or as required or permitted by relevant laws. The Company will cease to retain personal data when it is no longer needed for any legal or business purposes.
11. Law, Jurisdiction and Language
11.1 This Policy, in conjunction with your utilization of this website, shall be governed by and construed in accordance with the laws of the Republic of Singapore. By accessing this website, you hereby consent to submit any disputes, controversies, or claims arising from or related to this Policy, including any inquiries regarding its existence, validity, or termination, to the exclusive jurisdiction of the courts of Singapore.
11.2 The Policy shall be executed in the English language. All notices, documents, and other communications shall also be in English.
12. Contacting SAMS’s Data Protection Officer (DPO)
12.1 For any inquiries, feedback, or complaints regarding our personal data protection policies and practices, please do not hesitate to contact us via the details listed below. We invite you to submit any requests or notify us if you believe that any information, we hold about you is incorrect or outdated. Your communication is valuable and will be addressed promptly.
The Data Protection Officer
Phone: (65) 6911 8180
Email: sams.dpo@samsolu.com
Address: 31, Penjuru Lane, Block A, #04-01/02, #06-02 & #08-02, Singapore 609198.
The Company is committed to addressing your inquiry within a reasonable timeframe. Should additional time be required for a comprehensive investigation and response, we will inform you in writing. Please note that the Company does not respond to anonymous inquiries.
13. Changes
13.1. We reserve the right to amend this Notice at any time without prior notification. Your continued engagement with our services and/or products constitutes your acknowledgement and acceptance of any changes made.