Privacy and PDPA Statement

Update: 1 April 2020

Introduction and Application of This Statement

Mighty Glory Corporate Solutions (collectively “we”, “us” or “our”) is committed to respect your privacy and safeguard the personal information you provide or have provided us. The purpose of this Privacy and Personal Data Protection Statement (“Statement”) is to explain on how we collect, use, manage and protect your personal information, that we receive from you or through third parties and that is in our possession, in accordance with the Personal Data Protection Act (PDPA) 2012, Singapore.

This Statement supplements but does not supersede nor replace any consents which you may have previously provided us nor does it affect any rights which we may have at law in connection with the collection, use and disclosure of your Personal Data.

This Statement is also part of our website’s Terms and Conditions. In the event of conflict, contravention or inconsistency between this Statement and, Terms and Conditions, this Statement prevails. All the terms defined in the Terms and Conditions shall apply over this Statement unless otherwise stated.

We reserve the right to change this Statement, with or without notice, to ensure that it is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. Any changes to this Statement are effective upon posting to this website (“Site”). Subject to your rights at law, you agree to be bound by the prevailing terms of this Statement as updated from time to time on our Site. Please check this page regularly for updated information.

Collection of Personal Data

Under PDPA, personal data refers to any data about an individual, who can be identified either from that data or from that data and other information, to which an organisation has or is likely to have access. We collect information from you through your use of our Site, completion of forms or surveys, and/or other channels and throughout other interactions, communications and engagement of our services.

Personal data, collected by us, includes but are not limited to:

• Your personal information, such as name, passport or other identification numbers;
• Your contact information, such as mailing addresses, email addresses, telephone, mobile and fax numbers;
• Your corporate information, such as organisation name, company registration number (also known as Unique Entity Number, UEN), physical and registered office addresses, business telephone and fax numbers, business email addresses, corporate structure and shareholding details;
• Your billing and payment information, such as bank account details, fund transfer and cheque details.

Such information is collected, used and protected in accordance with the requirements under PDPA for the provision of or in relation to the services provided by us.

Providing us with your Personal Data is voluntary. However, if you choose not to provide us with the Personal Data described in this Policy, we may not be able to fulfil our contractual duties towards you or facilitate your request or provide the service to you, or the company you may be representing

You have choices regarding our collection, use or disclosure of your personal data. You have the right to object to the processing of your personal data and withdraw your consent in a manner described in this Privacy and PDPA Statement.

We may collect, use or disclose your personal data pursuant to an exception under the Personal Data Protection Act or other written law.

In view of the Advisory Guidelines under PDPA, this Site does not collect NRIC and/or other national identification numbers. Collection of such data would only be conducted by our Personal Data Protection Officer in person or any other modes (mutually agreed by both parties).

By interacting with us, submitting information to us or engaging our services, you agree and consent that Mighty Glory Corporate Solutions, affiliated parties and/or service providers collect, use, disclose and share among the relevant parties your Personal Data in the manner set forth in this Statement.

If you provide us any personal data relating to a third party, the submission of such information to us represents that you have obtained the consent of the third party for you to provide us with their personal data for the respective purposes. All personal data which you submitted to us is deemed to be complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with the services which you have requested.

Users should note that there are risks associated with the transmission of information over the internet. Users should therefore make their own assessment of risks in the provision of information on our Site. We will provide you with alternative means of providing information if you feel uncomfortable with the electronic transmission of information.

Certain information may be collected and stored automatically when you visit or use our Site. Such information includes the internet protocol (IP) address used to connect your computer or device to the Internet, connection information such as the browser type and version, operating system and platform, traffic patterns, cookie identifier and your activities, which include the pages you visited and the searches you have made.

Cookies

Cookies are small text files that our server store on your browser or the hard drive of your computer or device. Most web browsers automatically accept cookies but you may block or deactivate cookies in your browser settings. If cookies are declined, you may be restricted from some interactive features and/or services of our Site. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us. Unless you choose to disclose your identification to us, either by expressing interest on our events and/or promotional offers or filling forms, your identity remains anonymous. We use traffic log cookies to identify which pages are being used. Such information is only used for statistical analysis and then the data is removed from the system. By continuing to use our Site, you are agreeing to the use of cookies on the website, as outlined above.

Links to Other Websites

Our Site, other digital and telecommunication channels may contain links to other websites which are operated by third party companies with different privacy practices. Once you have used these links to leave our Site, please note that we have no control over the other websites. You should remain alert and understand the privacy statements of the other websites. We are not responsible for the protection and privacy of the information which you may have provided whilst browsing those websites.

Use and Disclosure of Personal Data

We will/may collect, use, disclose and/or process your Personal Data for one or more of the following purposes (where relevant):

• For the supply of any goods and/or services which we may offer you or that you may request, obtain or purchase from us;
• To carry out your instructions, responding to any enquiry and feedback given by (or purported to be given by) you or on your behalf, including contacting you via voice call, text message, fax, email, postal mail and/or courier regarding your instructions, enquiries and/or feedbacks;
• To conduct analysis and development activities to improve our services and/or facilities for your benefit, or to improve any of our activities, events, services or projects;
• To conduct due diligence or other screening activities in accordance with legal or regulatory obligations or our risk management procedures that may be required by law or that may have been put in place by us;
• To comply with or as required by any request or direction of any governmental authority; or respond to requests for information from statutory boards or other similar authorities;
• To share your Personal Data with our agents, contractors, affiliates and/or service providers whom we hire for to perform services on our behalf. The sharing allows such third parties to contact you, on our behalf. These service providers do not have the right to use your data for their own purposes;
• For marketing purpose where we may occasionally send you news, information, materials and/or updates about activities, products and/or services that we and/or our business partners provide, or on our behalf. In this regard, we will be doing by way of postal mail and/or electronic transmission to your email address(es). You have the right to opt out from these marketing correspondences by sending a written notification to our Personal Data Protection Officer;
• To store, host, back up your Personal Data, whether within or outside Singapore.

(collectively, referred to as the “Purposes”)

Unless described in this Privacy Statement, we will not share, sell, rent or trade any of the information collected during the ordering and fulfillment process to any third party for any purpose whatsoever.

We may collect, use, disclose or process your Personal Data for other purposes that are not stated above. However, we will notify you of such purpose at the time of obtaining your consent, unless processing of your Personal Data without your consent is permitted by the PDPA or by law.

We may/will also be collecting from sources other than yourself, personal data about you, for one or more of the above Purposes, and thereafter using, disclosing and/or processing such personal data for one or more of the above Purposes. We may combine information we receive from other sources with information you give to us and information we collect about you. We may use this information and the combined information for the Purposes set out above.

Storage and Retention of Personal Data

We are committed to ensure that your Personal Data, whether stored electronically or in paper form, is secure. Appropriate measures, as what we are using for our own proprietary information, are in place to protect your Personal Data against risks of loss, destruction, duplication, misuse, modification, unauthorised access or disclosure. These include, but are not limited to:

• Restricting access to personal data to those who have a genuine business need to know (i.e. our authorised and designated officers). Those individuals, who are authorised to access or process the personal data, are obliged to maintain the confidentiality of such information;
• Where we have given you (or where you have chosen) a password which enables you to access certain data or system, you are responsible to keep this password confidential. We ask you not to share a password with anyone;
• Having regular personal data housekeeping in terms of retention periods for and classification of personal data for legal and business requirements; and
• Removing and destroying documents and/or purging databases containing your Personal Data, or removing the means by which your Personal Data can be associated with you as soon as it is reasonable to assume that the purpose for which the personal data was provided to us is no longer being served by the retention of such personal data, and retention is no longer necessary for any other legal or business purposes.

Any unsolicited personal data received by us will be returned to the sender immediately. If received by email or through our website, these unsolicited personal data will be deleted right away. If received by telephone, these will not be recorded.

Withdrawal of Consent

You may withdraw your consent for the collection, use and/or disclosure of your Personal Data in our possession or under our control by informing our Personal Data Protection Officer. However, your withdrawal of consent to any or all use of your Personal Data could result in certain legal consequences arising from such withdrawal, including us being unable to perform the transactions and/or services requested by you. We will review and inform you on the consequences of the withdrawal prior to processing your request. Please note that the withdraw of consent will not affect our authority to collect, use, disclose your Personal Data for a specific purpose without your consent, if the PDPA or a provision in applicable law permits us to.

Access and Correction of Personal Data

You have the right to access and/or correct any personal data that we hold about you, subject to the requirements of the PDPA. If you would like to have a copy of your Personal Data being held by us, or to update and/or correct the personal data which you have previously provided to us, please inform our Personal Data Protection Officer, whose contact details are available at the last paragraph of this Statement.

We will need enough information from you in order to ascertain your identity as well as the nature of your request, so as to be able to deal with your request. We reserve the right, or may, charge a reasonable fee for the processing of any data access request.

For a request to access personal data, once we have sufficient information from you to deal with the request, we will seek to provide you with the relevant personal data within 30 days. Where we are unable to respond to the request within the said 30 days, we will notify you of the earliest possible time within which we can provide you with the information requested.

For a request to correct personal data, once we have obtained sufficient information for verification and/or investigation, we will correct your Personal Data within 30 days. Where we are unable to do so within the said 30 days, we will notify you of the soonest practical time within which we can make the correction. Please note that the PDPA exempts certain types of personal data from being subject to your correction request as well as provides for situation(s) when correction needs not be made by us despite your request. We will send the corrected personal data to every other organisation to which the personal data was disclosed by us within a year before the date the correction was made, unless that other organisation does not need the corrected personal data for any legal or business purpose.

Complaint Process

If you have any complaint or resentment about how we are handling your Personal Data or how we are complying with the PDPA, please inform our Personal Data Protection Officer.

Where you are submitting a complaint via email, your indication at the subject header, that it is a PDPA complaint, would facilitate us in attending to your complaint efficiently. For example, you could use “PDPA Complaint” as the subject header. We will strive to resolve any complaint or resentment at the soonest in a fair manner.

Enquiries

If there is any question pertaining to this Statement, please write to:

Personal Data Protection Officer
Mighty Glory Corporate Solutions
60 Paya Lebar Road
#07-54 Paya Lebar Square
Singapore 409051
Email: dpo@mightyglory.sg

Governing Law

This Statement and your use of this Site shall be governed in all respects by the laws of Singapore.