PROJECT ON PTE. LTD.
Last Updated: August 11, 2022
We at Project On Pte. Ltd. ("Project On”) take your personal data and privacy seriously. This policy explains how we manage your personal data in compliance with Singapore’s Personal Data Protection Act 2012 (“PDPA”).
Personal data refers to 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. Examples of personal data which you may provide to us include your name, billing address, email address, contact number, residential address, login data, profile data, username and password, and video, image or audio recordings of you. For the avoidance of doubt, data that has been anonymised by the removal of personally identifiable information shall not be regarded as personal data.
This policy applies to all personal data which we may collect from you or your authorised representative through our website(s) , web services, online services, mobile or other applications (collectively the “Services”), third-party online services with related accounts accessible or controlled by us, social media accounts (including Facebook, Instagram, etc.), instant messaging accounts, email, online advertisements and any other media utilised by Project On or from any other form of interaction with you or your authorised representative, or from third parties (the Services and these other modes of collection shall collectively be referred to as “media of collection”).
COLLECTION, USE AND DISCLOSURE OF YOUR PERSONAL DATA
5. We may collect your personal data in the following ways:
5.1. when you access or use any of the Services;
5.2. when you create an account on the Services;
5.3. when you subscribe to any of our mailing lists, newsletters and/or social media channels;
5.4. when you make a transaction regarding any of our products or services;
5.5. when you communicate with us whether through our website’s online form, email, social media accounts, instant messaging, phone calls, face-to-face interactions, any of the media of collection, or any other means;
5.6. when you participate in any promotion, activity, campaign, or survey initiated by us;
5.7. when you log in to your account on any Services or otherwise interact with us via an external service or application;
5.8. when you interact with any of our agents, officers, contractors (including our counsellors or the “writenow” website and/or mobile application) or employees;
5.9. when we receive personal data from third parties such as vendors, suppliers, business partners or customers;
5.10. when you interact with and/or provide your personal data to us via any of our online advertisements; and
5.11. when you provide your personal data to us for any other reason and by any means whatsoever.
6. The type of personal data we may collect from you includes the following:
6.1. When you make enquiries regarding our products or services via our email accounts, social media accounts, websites, or other media of collection, or when you interact with our website and/or mobile application or other media of collection, we may collect details from you such as your name, email address, contact numbers, residential addresses etc.
6.2. When you are engaging and/or transacting with us for the procurement of our products or services, we may collect details from you such as your name, email address and contact numbers. We may also collect your credit card details for payment of such products or services.
6.3. When you are accessing our mobile or other applications as a product user, we may, through such application, collect details from you such as your name, email address, contact number, usage data and usage diagnostics for the purposes of our product/service development and improvement, or any other personal data you may voluntarily provide in the course of using our website or mobile application.
6.4. When you visit our website, information is automatically collected by the technology platforms providing the experience. For example, your web browser or mobile device may share certain data with us as those devices interact with our website. This data includes device ID, network access, storage information and battery information, cookies, IP addresses, referrer headers, data identifying your web browser and version, web beacons and events.
6.5. When you apply to work with us or for us (e.g. as an independent counsellor or employee),we will collect your name, contact details, resume, and any other information you elect to provide us. We use these details to evaluate your application and to communicate with you regarding your application. Your information such as your name, image, user name, and email address will also be collected on our website and mobile application when registering your account with us for such purposes (should we proceed with engaging you for your services).
8. You should ensure that all personal data submitted to us is complete, accurate, true and correct. Any failure on your part to do so may affect our ability to provide you with the products and services you have requested. We shall have the right to request for documentation and carry out the necessary checks to verify the personal data provided by you as part of our user verification processes or as required under law.
9. We process your personal data for the following purposes:
9.1. to facilitate your use or our provision of the Services or any of our other products of services;
9.2. to administer your account with our website(s), mobile application(s), or other Services, including account and identity verification;
9.3. to process transactions for our products or services, This may include the disclosure of personal data such as name and credit card information to third party payment processors;
9.4. to personalise the provision of our services to you, and to better serve you by matching your preferences or needs with our products or services (e.g. to assign appropriate counsellors to you on our website and/or mobile application);
9.5. to understand reactions and feedback to products and/or services offered by us for product development and improvement;
9.6. to communicate with you regarding our website, products, services, campaigns, promotions, and surveys, including changes to our terms and conditions and policies;
9.7. to communicate with you for the provision of such products and/or services requested by you via the Services or other media of communication;
9.8. to provide you with information we think you may find useful or which you have requested from us;
9.9. to respond to your queries or requests or provide customer support;
9.10. to manage our business operations;
9.11. to develop or improve our business, website, mobile application, products, the Services, or other services or offerings;
9.12. to carry out research, data analysis, or surveys relating to the business, website, products, mobile application, the Services, or other services or offerings;
9.13. to investigate or process any wrongdoing, complaints, feedback, enforcement action or legal action in relation to our business, products or services;
9.14. for legal purposes, including obtaining legal advice, managing disputes and risks, complying with any laws, regulations, legal obligations or law enforcement requests;
9.15. to conduct audits, to verify that our internal processes function as intended and are compliant with legal, regulatory or contractual requirements.
9.16. to store, host, back up data, including personal data;
9.17. to prevent a threat to life, health or safety, if necessary;
9.18. any other purposes relating to the above purposes.
10. We may disclose or permit the disclosure of your personal data or transfer your personal data to third parties for the above-mentioned purposes. These third parties, which may be located in or outside your jurisdiction, include but are not limited to payment processors for transactions entered into by you with us.
12. We may share your personal data with a competent public authority, government, law enforcement or regulatory agency as permitted or required by applicable law or regulations.
13. We may share your personal data with any person to whom we propose to transfer any of our rights and/or duties relevant to you, including in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock.
14. If we disclose your personal data to these third parties, we endeavour to ensure that the third parties keep your personal data secure from unauthorised access, collection, use, disclosure or processing and retain your personal data only for as long as your personal data is needed to achieve the above-mentioned purposes or in compliance with applicable laws.
16. You should rest assured that we do not sell your personal data to any third party. Our employees and any third parties engaged by us are contractually obligated to protect the privacy and confidentiality of your information.
17. If you have provided to us any third party’s personal data, you shall be deemed to have obtained that party’s consent for the relevant purpose of providing the personal data to us.
18. Additionally, we may disclose your personal data to third parties if we believe that we are required by law to so disclose or that such disclosure is reasonably necessary to protect the rights, property or safety of our customers, the public or us.
REQUEST FOR WITHDRAWAL OF CONSENT, ACCESS OR CORRECTIONS
20. You may request:
20.1. access to your personal data held by us;
20.2. correction or deletion of your personal data (but only where it is no longer required for a legitimate business purpose);
20.3. that you no longer receive marketing communications directly from us;
20.4. that the processing of your personal data is restricted; and/or
20.5. that certain personal data that you have provided to us in a structured, digital form be transmitted to another party, if this is technically feasible.
21. If you would like to request access to, correction or deletion of your personal data, or request that the processing of your personal data be restricted, or opt out of marketing communications, you may (as applicable), (a) follow the instructions in the applicable communication from us, or (b) email us at firstname.lastname@example.org.
22. If you make a request as described above, the request must:
22.1. provide enough information for us to be able to verify you are the person whose personal data we hold or are an authorised representative of that person. We cannot respond to your request unless we can verify your identity or authority to make the request. If possible, this can be done by making the request via your password protected account. If not, we will aim to verify your identity based on personal data we already hold about you. If we need to request further information from you in order to verify your identity, we will only use that personal data for the purposes of identifying you or that you have authorized the request;
22.2. describe your request in enough detail so that we can properly locate the personal data the request relates to.
23. We will respond to your request consistent with applicable law.
24. If your personal data has been provided to us by a third party, you should contact that third party to make such queries, complaints or access and correction requests to us on your behalf.
25. You should note that if you withhold or withdraw your consent to the collection, use or disclosure of your personal data for any purpose, we may not be able to provide or continue providing any of our products and services to you or you may not be able to access certain parts or functions of our services, including the Services and our website and/or mobile application.
26. If you have any issues, queries, or complaints regarding the processing of your personal data, please contact us at email@example.com.
SECURITY OF YOUR PERSONAL DATA
27. We have implemented technology and policies with the objective of protecting your personal data from unauthorized access and improper use. In particular, we will use encryption and apply authentication and verification processes for access to the Services, our websites or other applications (as deemed necessary to protect personal data or other information), and we regularly test, assess and evaluate the effectiveness of our security measures. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Request” section above.
28. We will retain your personal data for as long as we are required or permitted to by law or as relevant for the purposes for which it was collected. We will cease to retain your personal data, or render anonymous or remove such data which can identify you, as soon as it is reasonable to assume that such retention no longer serves the purposes for which the personal data was collected, and is no longer necessary for any legal or business purpose.
COOKIES AND SIMILAR TECHNOLOGIES
31. To the maximum extent permitted by law, we shall not be liable in any event for any special, exemplary, punitive, indirect, incidental or consequential damages of any kind or for any loss of reputation or goodwill, whether based in contract, tort (including negligence), equity, strict liability, statute or otherwise, suffered as a result of unauthorised or unintended use, access or disclosure of your personal data.