Data Protection & Privacy Policy
Last updated: August 2024
immigrationcentralsg.com (the “Platform”) is a product of Immigration Central SG Pte. Ltd. This Data Protection and Privacy Policy (the “Policy”) informs you of how immigrationcentralsg.com and Immigration Central SG Pte. Ltd. manage personal data subject to the Singapore Personal Data Protection Act (No. 26 of 2012) (“the Act”).
Please take a moment to read this Policy so that you know and understand the purposes for which we collect, use and disclose your personal data.
By interacting with us, submitting information to us or signing up for any promotions or services offered by us, you agree and consent to Immigration Central SG Pte. Ltd. and its Affiliates (as defined below). Their related corporations (collectively, the “Companies”), as well as their respective representatives and/or agents (“Representatives”) (collectively referred to herein as “TR”, “us”, “we” or “our”) collecting, using, disclosing and sharing amongst themselves your Personal Data (as defined below), and disclosing such Personal Data to the Companies’ authorized service providers and relevant third parties in the manner set forth in this Policy. Please note that “Affiliates” as used in this Policy refers to the owners and key appointment holders of the Platform managed by Immigration Central SG Pte. Ltd. Such owners include but are not limited to directors, officers, employees, members, representatives, affiliates, agents, parent(s), subsidiaries, successors.
This Policy forms part of and is to be read together with our Terms of Use (the “Terms”) and any agreements which you may enter into with us. All capitalised terms and phrases used herein shall (unless otherwise defined) have the same meaning given to them in the Terms. This Policy supplements but does not supersede nor replace any other consents you may have previously provided to TR in respect of your Personal Data, and your consents herein are additional to any rights which any of the Companies may have at law to collect, use or disclose your personal data.
1. Personal Data
- In this Policy, “Personal Data” refers to any 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 are likely to have access, including data in our records as may be updated from time to time. Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us) your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address and any other information relating to any individuals which you have provided us in any forms you may have submitted to us, or via other forms of interaction with you.
2. Collection of Personal Data
- Generally, we collect Personal Data in the following ways:
- when you submit any form and or request;
- when you interact with our staff and other representatives, for example, via telephone calls (which may be recorded), letters, fax, face-to-face meetings, and email;
- when your images are captured by us via CCTV cameras while you are within our premises or photographs or videos were taken by us or our representatives when you attend events hosted by us;
- when you use our services provided through online and other technology platforms, such as websites and social media platforms;
- when you request that we contact you, be included in an email or other mailing list; or when you respond to our promotions and other initiatives, or our requests for additional Personal Data;
- when you are contacted by and respond to our marketing representatives and agents and other service providers;
- when you submit an employment application or when you provide documents or information in connection with any appointment as an officer, director or other representative;
- when we receive your personal data from business partners, public agencies, your employer or other third parties;
- when we seek information from third parties about you in connection with your relationship with us, for example, from your ex-employer and the relevant authorities in relation to employment applications and/or
- when you submit your Personal Data to us for any other reasons.
- When you browse our Platform, you generally do so anonymously, but please see the section below on cookies. We do not automatically collect personal data, including your email address, on our Platform unless you provide such information.
- If you provide us with any Personal Data relating to a third party (e.g. information of spouse, children, parents, and/or employees), by submitting such information to us, you represent to us that you have obtained the consent of the 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. Failure on your part to do so may result in our inability to provide you with the services you have requested.
3. Purposes for Collection, Use, and Disclosure of Your Personal Data
- TR collects, uses and discloses your Personal Data for any and all the following purposes (collectively, the “Permitted Purposes”) :
- responding to, processing and handling your complaints, queries, requests, feedback, and suggestions;
- managing the administrative and business operations of the Companies and complying with internal policies and procedures;
- facilitating business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving any of the Companies;
- matching any Personal Data held which relates to you for any of the purposes listed herein;
- verifying your identity;
- requesting feedback or conducting market research and/or analysis for statistical, profiling or other purposes for us to understand buyers’ behaviour, spending habits, preferences and market trends and to review, develop and improve the quality of our services;
- facilitating and carrying out due diligence checks;
- analyzing and managing commercial risks;
- providing media announcements and responses;
- legal purposes (including but not limited to obtaining legal advice and dispute resolution);
- meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on TR (including but not limited to disclosures to regulatory bodies, conducting audit checks, surveillance, and investigation, or customer due diligence); and/or
- any other purpose relating to any of the above.
- In addition, TR collects, uses and discloses your Personal Data for the following purposes depending on the nature of our relationship:
- If you are an existing or prospective customer or employee of TR,
- marketing and sales of properties (including but not limited to facilitating viewings, conducting negotiations, preparing quotations and entering into sale and purchase agreements);
- facilitating the merger and acquisition activities (including but not limited to liaising with lawyers and other administration);
- providing client servicing and benefits (including but not limited to sending you seasonal gifts and invites to events and other value-added services);
- archival management (including but not limited to warehouse storage and retrievals);
- enforcement of repayment obligations and arrears management (including but not limited to providing notification of outstanding arrears and preparation of legal documents); and/or
- any other purpose relating to any of the above.
- If you are an employee of an existing or prospective external service provider, vendor, supplier, consultant or contractor outsourced by TR:
- managing pre-qualification of vendor database;
- procuring, awarding and managing project tenders;
- managing the outsourcing relationship;
- managing the processing and payment of invoices and expense claims;
- managing project developments;
- managing premise security (including but not limited to conducting security screening and issuing contractor access passes);
- rendering premise maintenance and housekeeping; and/or
- any other purpose relating to any of the above.
- Where permitted under the Act, TR may also collect, use and disclose your Personal Data for the following purposes:
- providing products, services, and benefits to you, including promotions, loyalty and reward programs;
- 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 TR or other third parties;
- administering contests and competitions, and personalizing your experience at TR’s touchpoints;
- sending you details of products, services, special offers, and rewards, either to our customers generally or which we have identified may be of interest to you; and/or
- conducting market research, understanding and analyzing customer behaviour, location, preferences, and demographics for us to develop special offers and marketing programs.
- If you are an existing or prospective customer or employee of TR,
- If you have provided your Singapore telephone number(s) and have indicated that you consent to receive marketing or promotional information via your Singapore telephone number(s), then from time to time, TR may contact you using such Singapore telephone number(s) (including via voice calls, text, fax or other means) with information about our products and services (including discounts and special offers).
- In relation to particular services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.
4. Disclosure of Personal Data
- TR will take reasonable steps to protect your Personal Data against unauthorized disclosure. Subject to the provisions of any applicable law, your Personal Data may be provided, for the purposes listed above (where applicable), to the following entities or parties, whether they are located overseas or in Singapore:
- TR’s related corporations;
- companies or brokers providing services to TR;
- agents, contractors or third-party service providers who provide operational services to TR, such as courier services, telecommunications, information technology, payment, payroll, processing, training, market research, storage, archival, customer support investigation services or other services to TR;
- vendors, sales agents or other third-party service providers in connection with promotions, properties, goods or services offered by TR;
- any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or any debt or asset sale) involving any of the Companies;
- external banks, credit card companies and their respective service providers;
- third-party referrers;
- our co-brand and other business partners;
- our professional advisers, such as our auditors and lawyers;
- relevant government regulators, government ministries, statutory boards or authorities and/or law enforcement agencies, whether local or overseas, including the Inland Revenue Authority of Singapore, Ministry of Manpower and the Central Provident Fund Board, to comply with any directions, laws, rules, guidelines, regulations or schemes issued or administered by any of them;
- external business and charity partners in relation to corporate promotional events; and/or
- any other party to whom you authorize us to disclose your personal data.
5. Use of Cookies
- When you interact with us on our Platform, we may employ cookies in order for our server to recognize a visitor as a unique user, including, without limitation, monitoring information relating to how a visitor arrives at the Platform, what kind of browser a visitor is on, what operating system a visitor is using, a visitor’s IP address, and a visitor’s clickstream information and time stamp (for example, which pages they have viewed, the time the pages were accessed and the time spent per web page).
- Cookies are small text files stored in your computing or other electronic devices that allow us to remember you. The cookies placed by our server are readable only by us, and cookies cannot access, read or modify any other data on an electronic device. All web-browsers offer the option to refuse any cookie, and if you refuse our cookie then we do not gather any information on that visitor.
- Should you wish to disable the cookies associated with these technologies, you may do so by changing the settings on your browser. However, you may not be able to enter a certain part(s) of our Platform.
6. Data Protection
- We are committed to maintaining the security of your Personal Data. We have put in place appropriate security procedures and technical and organisational measures to safeguard your Personal Data.
- Having said the above, we do not warrant that the Platform or its contents are free of errors, infection by computer viruses and/or other harmful or corrupting code, program, macro and such other unauthorised software.
- You agree and acknowledge that you will not hold us liable for any disclosure of your Personal Data due to any circumstances beyond our control.
7. Data Retention
- We may retain your Personal Data for as long as it is necessary for the Permitted Purposes described in this Policy, or as required or permitted by applicable laws.
- We will cease to retain your Personal Data, or remove the means by which the Personal Data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the Permitted Purposes, and is no longer necessary for legal or business purposes.
8. Withdrawal of Consent, Access and Correction of Your Personal Data
- If you:
- have any questions or feedback relating to your Personal Data or our Policy;
- would like to withdraw your consent to any use of your Personal Data as set out in this Policy; or
- would like to obtain access and make corrections to your Personal Data records.
- Please contact as follows:
- Email: hello@immigrationcentralsg.com
- Write in: The Data Protection Officer (Immigration Central SG Pte. Ltd.)
- Address: 10 Anson Road #10-11, International Plaza Singapore 079903
- Please contact as follows:
- Please note that if your personal data has been provided to us by a third party (e.g. a recruitment agency), you should contact such parties directly to make any queries, feedback, and access and correction requests on your behalf.
- We charge a small fee for an access and change/ correction request, which we will inform you of the fee before processing your request.
- We will respond to your request as soon as reasonably possible. However, should we not be able to respond to your request 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 to your request.
- If we are unable to provide you with any Personal Data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).
- If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, may not be in a position to continue to provide our services to you, administer any contractual relationship in place, which may also result in the termination of any agreements with, and your being in breach of your contractual obligations or undertakings, and ’s legal rights and remedies in such event are expressly reserved.
9. Feedback
- We welcome your views on our personal data protection policies and procedures. You may contact our Data Protection Officer if you have any enquiries or feedback on our Policy, or if you wish to make any request, via email to hello@immigrationcentralsg.com .
10. Disclaimer
- We shall not be liable for any voluntary disclosure of Personal Data by you to other users in connection with the use of the Platform, as the case may be.
11. Policy Update and Change
- TR may from time to time update this Policy to ensure that this Policy is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements.
- Subject to your rights at law, you agree to be bound by the prevailing terms of the Policy as updated from time to time on our Platform https://immigrationcentralsg.com/privacy-policy.
- Please check back regularly for updated information on how to handle your personal data.
12. Governing Law
- This Policy and your use of this Platform shall be governed in all respects by the laws of Singapore