At Vantage Foundation Limited (“Vantage Foundation”), we respect the privacy and confidentiality of individuals’ personal information. We are committed to protecting the privacy and personal information in compliance with the Singapore Personal Data Protection Act 2012 (“PDPA”) and other applicable laws.
If you do not belong to any of these categories listed above and we collect, use, disclose or process your personal information in the course of our work, this Policy will apply to that personal information in the manner it applies to the individuals mentioned above.
1. As used in this Policy:
“personal information” means information, whether true or not, about an individual (whether a website visitor, donors, beneficiaries and volunteers or otherwise) 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.
2. Depending on the nature of your interaction with us, some examples of personal information which we may collect from you include name, identification numbers such as NRIC, FIN, work permit and birth certificate, contact information such as residential address, email address or telephone number, nationality, gender, date of birth, marital status, medical history, photographs and other audio-visual information, employment information and financial information such as credit card numbers, debit card numbers or bank account information.
3. Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context so permits).
COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION
4.We generally do not collect your personal information unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal information to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the information is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal information for those purposes, or (b) collection and use of personal information without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal information and before using your personal information for a purpose which has not been notified to you (except where permitted or authorised by law).
5. We may collect and use your personal information for any or all of the following purposes:
6. We may disclose your personal information:
7. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under a contract with you).
8. After the lapse of the opt-out period, you may notify us that you no longer wish to consent to the purposes for which your consent was deemed by notification by withdrawing your consent for the collection, use or disclosure of your personal information in relation to those purposes.
RELIANCE ON THE LEGITIMATE INTERESTS EXCEPTION
9. In compliance with the PDPA, we may collect, use or disclose your personal information without your consent for the legitimate interests of Vantage Foundation Limited or another person. In relying on the legitimate interests exception of the PDPA, Vantage Foundation Limited will assess the likely adverse effects on the individual and determine that the legitimate interests outweigh any adverse effect.
10. In line with the legitimate interests’ exception, we will collect, use or disclose your personal information for the following purposes:
The purposes listed in the above clause may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter.
WITHDRAWING YOUR CONSENT
11. The consent that you provide for the collection, use and disclosure of your personal information will remain valid until such time it is being withdrawn by you or your authorised representative in writing. You or your authorised representative may withdraw consent and request us to stop collecting, using and/or disclosing your personal information for any or all of the purposes listed above by submitting your request via email to [email protected].
12. Upon receipt of your written request to withdraw your consent, we may request you to provide a proof of identity. We may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us.
13. In line with the legitimate interests’ exception, we will collect, use or disclose your personal information for the following purposes:Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in the manner described in clause 11 above.
14. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal information where such collection, use and disclose without consent is permitted or required under applicable laws.
ACCESS TO AND CORRECTION OF PERSONAL INFORMATION
15. If you wish to (a) request access to a copy of your personal information held by us or seek information about how we collect, use, or disclose your personal information, or (b) request a correction or update of any of your personal information in our records, please submit your request via email to [email protected]. We are committed to addressing your requests promptly and ensuring the accuracy and completeness of your personal information.
16. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
17. We will respond to your request as soon as reasonably possible. 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 information 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).
PROTECTION OF PERSONAL INFORMATION
18. To safeguard your personal information from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures.
19. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
ACCURACY OF PERSONAL INFORMATION
20. We generally rely on personal information provided by you (or your authorised representative). In order to ensure that your personal information is current, complete and accurate, please update us if there are changes to your personal information via email to [email protected].
RETENTION OF PERSONAL INFORMATION
21. We may retain your personal information for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
22. We will cease to retain your personal information or remove the means by which the information can be associated with you as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal information was collected and is no longer necessary for legal or business purposes.
TRANSFERS OF PERSONAL INFORMATION
23. Where personal information is collected by Vantage Foundation outside of Singapore and subsequently transferred into Singapore, we are committed to ensuring the protection and privacy of your personal information in compliance with applicable data protection laws.
24. Vantage Foundation acknowledges that personal information collected overseas may be subject to the data protection laws of the country or territory in which it was collected (if any). As such, we will process your information in accordance with applicable data protection laws and regulations to the extent possible and ensure that your personal information continues to receive a standard of protection that is at least comparable to that provided under the PDPA.
25. Vantage Foundation remains committed to upholding the highest standards of data protection and privacy as we operate in diverse international jurisdictions. If you have any questions or concerns about your personal information or its processing, please email us at [email protected].
EFFECT OF POLICY AND CHANGES TO POLICY
26. This Policy applies in conjunction with any other policies, notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal information by us.
27. We may revise this Policy from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Policy was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.
Effective date : 22/09/2023
Last updated : 22/09/2023