DATA PROTECTION POLICY

Updated 3rd March 2025

1         Introduction

• We Accrete Technology (S) Pte Ltd (“ACCRETE”) respect the privacy and confidentiality of the personal data of the individuals whom we interact with while providing our services. We are committed to implementing policies, practices, and processes to safeguard the collection, use and disclosure of the personal data you provide us, in compliance with the Singapore Personal Data Protection Act (PDPA) 2012.

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• We have developed this Data Protection Privacy Policy to assist you in understanding how we collect, use, disclose, process, protect and retain your personal data that is in our possession.

2         Personal Data

1. Definition:

“personal data” means data, whether true or not, about an individual 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, some examples of personal data which we may collect from you include name, NRIC number, email address, telephone number, office address, photograph or images of an individual, employment information, and financial information.  

• Other terms used in this Policy / Notice shall have the meanings given to them in the PDPA (where the context so permits).

3         Collection, Use and Disclosure of Personal Data

1. We generally do not collect your personal data unless:

1. it is provided to us voluntarily by you directly or via a third party who has been duly authorized by you to disclose your personal data to us (your “authorized representative”) after

1. you (or your authorized representative) have been notified of the purposes for which the data is collected, and

1. you (or your authorized representative) have provided written consent to the collection and usage of your personal data for those purposes, or

• collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorized by law).

• We may collect and use your personal data for any or all the following purposes:

1. For safety and security purposes

2. processing of job application

3. performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;

4. verifying your identity;

5. responding to, handling and processing queries, requests, applications, complaints, and feedback from you;

6. complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and / or regulatory authority;

7. carry out our obligations arising from any contracts entered between you and us;

8. processing payment or credit transactions; and

9. transmitting to any unaffiliated third parties including our third-party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purpose

• We may disclose your personal data:

1. where such disclosure is required for performing obligations during or in connection with our provision of the goods and services requested by you; or

2. to third party service providers, agents, and other organizations we have engaged to perform any of the functions with reference to the above-mentioned purposes.

• We may collect, disclose or use your personal data pursuant to an exception under the Personal Data Protection Act or other written law such as during the following situations

1. To respond to an emergency that threatens your life, health and safety or of another individual; and

2. Necessary in the national interest, for any investigation or proceedings.

You have the right of choice regarding the collection, usage and disclosure of your personal data. If you choose not to provide us with any of your personal data requested in this form, you may do so by indicating in the relevant field. Whilst we respect your decision, please note that depending on the nature and extent of your request, we may not be in a position to process your job application or service. We shall, in such circumstances, notify you before continuing to process your job application or service. 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 carry out your request, 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).

4         Withdrawal of Your Consent

1. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all the purposes listed above by submitting your request in writing or via email to our Data Protection Officer (DPO) at the contact details provided below.

2. Upon receipt of your written request to withdraw your consent, 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. In general, we shall seek to process your request within thirty (30) calendar days after receiving it.

3. 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 able 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 writing in the manner described in clause 1 of this section. 

4. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

5         Access to Correction of Personal Data

1. If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.

2. 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.

3. We will respond to your request as soon as reasonably possible. In general, our response will be within thirty (30) days. 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).

6         Protection of Personal Data

1. 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 such as minimized collection of personal data, authentication and access controls (such as good password practices, need-to-know basis for data disclosure, etc.), encryption of data, up-to-date antivirus protection, regular patching of operating system and other software, disclosing personal data both internally and to our authorized third-party service providers and agents only on a need-to-know basis.

• 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.

7         Accuracy of Personal Data

We generally rely on personal data provided by you (or your authorized representative). To ensure that your personal data is current, complete, and accurate, please update us if there are changes to your personal data by informing our DPO in writing or via email at the contact details provided below.

8         Retention of Personal Data

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

• We will cease to retain your personal data or remove how the data 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 data was collected and is no longer necessary for legal or business purposes.

9         Transfer of Personal Data Outside of Singapore

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

10      Data Protection Officer

You may contact our DPO if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:

Email Address: dpo@accrete.com.sg

11      Data Breach Notification

In the event a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data, we shall promptly assess the impact and if appropriate, report this breach within 3 calendar days to the Personal Data Protection Commission (PDPC). We will notify you when the data breach is likely to result in significant harm to you after our notification to PDPC. We may also notify other relevant regulatory agencies, where required. If we are a Data Intermediary, we shall inform the Data Controller immediately of any data breach so they can promptly assess the impact and comply with their data breach notification obligation.

12      Effect on Policy and Changes to Policy

1. This Policy applies in conjunction with any other policies, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.

2. 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.