At Blackpeach, we take our responsibilities under Singapore’s Personal Data Protection Act 2012 (the “PDPA”) seriously. We also recognise the importance of the personal data you have entrusted to us and are committed to properly manage, protect and process your personal data.
This Data Protection Policy is designed to help you understand how we collect, use, disclose and/or process your personal data as well as to assist you in making an informed decision before providing us with your personal data. If you give us personal data of someone else, please provide them a copy of our policy so that they may understand the manner in which their personal data may be collected, used, disclosed and/or processed by us in connection with dealings with Blackpeach.
If you have any queries on this policy or in relation to how we may manage, protect and/or process personal data provided to us, please contact our Data Protection Officer (the “DPO”) via firstname.lastname@example.org
1.1 “Personal Data” is defined under the PDPA to mean data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access. Common examples of personal data could include names, identification numbers, contact information, medical records, photographs and video images.
1.2 We will collect personal data provided to us in accordance with the PDPA. We will notify you of the purposes for which personal data may be collected, used, disclosed and/or processed, as well as obtain the necessary consent(s) for the collection, use, disclosure and/or processing of personal data provided to us for the intended purposes, unless an exception under the law permits us to collect, process and/or disclose personal data without consent.
2.1 The personal data which we collect from you may be collected, used, disclosed and/or processed for various purposes, depending on the circumstances for which we may/will need to process personal data.
2.2 Where you are a corporate entity, such personal data may include information about your directors, officers, employees, beneficial owners, partners, members, authorised signatories, representatives, agents, guarantors, other security providers and other natural persons related to you (collectively all of the foregoing who are natural persons, “Related Persons”).
2.3 The purposes for which we have been collecting, using, disclosing and processing your or your Related Person’s personal data include:
2.4 In order to conduct our business operations more smoothly, we may be disclosing the personal data you have provided to us to our third party service providers, agents and/or our affiliates or related corporations, and/or other third parties whether sited in Singapore or outside of Singapore, for one or more of the above stated Purposes. Such third party service providers, agents and/or affiliates or related corporations and/or other third parties would be processing your personal data either on our behalf or otherwise, for one or more of the above-stated Purposes.
3.1 We respect the confidentiality of the personal data you have provided to us.
3.2 In that regard, we will not disclose personal data provided to us to third parties without first obtaining the relevant consent(s) permitting us to do so. However, please note that we may disclose the personal data you provided to third parties without first obtaining your consent in certain situations, including, without limitation, the following :
4.1 You may request to access and/or correct the personal data currently in our possession or control by submitting a written request to us. 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 process your request.
4.2 For a request to correct personal data, once we have sufficient information from you to process the request, 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 practicable 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.
4.3 We will also be charging you a service fee for the handling and processing of your requests to access your personal data. We will provide you with a written estimate of the fee we will be charging. Please note that we are not required to respond to or process your access request unless you have agreed to pay the fee.
5.1 You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control.
5.2 We will process your request within 30 days from such a request for withdrawal of consent being made, and will thereafter not collect, use and/or disclose your personal data in the manner stated in your request.
5.3 However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal. In this regard, depending on the extent of your withdrawal of consent for us to process your personal data, it may mean that we will not be able to continue your existing relationship with us.
6.1 We will take reasonable efforts to ensure that the personal data you provided is reflected accurately and completely, if your personal data is likely to be used by Blackpeach to make a decision that affects you, or disclosed to another organisation. However, this means that you must also update us of any changes in relation to personal data that you had initially provided us with. We will not be responsible for relying on inaccurate or incomplete personal data arising from you not updating us of any changes in the personal data that you had initially provided us with.
6.2 We will also put in place reasonable security arrangements to ensure that the provided personal data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorised access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of the personal data provided. However, we cannot assume responsibility for any unauthorised use of such personal data by third parties which are wholly attributable to factors beyond our control.
6.3 We will also put in place measures such that personal data you provided in our possession or under our control is destroyed and/or anonymised as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes.
6.4 Where personal data you provided is to be transferred out of Singapore, we will comply with the PDPA in doing so. In this regard, this includes us obtaining the necessary consent(s) unless an exception under the PDPA or law applies, and taking appropriate steps to ascertain that the foreign recipient organisation of the personal data is bound by legally enforceable obligations to provide to the transferred personal data a standard of protection that is at least comparable to the protection under the Act. This may include us entering into an appropriate contract with the foreign recipient organisation dealing with the personal data transfer or permitting the personal data transfer without such a contract if the PDPA or law permits us to.
7.1 If you have any feedback or questions regarding how we are handling the personal data you have provided, please contact our Data Protection Officer through one of the following modes:
8.1 As part of our efforts to ensure that we properly manage, protect and process personal data provided to us, we will be reviewing our policies, procedures and processes from time to time.
8.2 We reserve the right to amend the terms of this Data Protection Policy at our absolute discretion. Any amended Data Protection Policy will be posted on our website and can be viewed at blackpeach.com.sg/legal/privacy-engagements/pdpa.
8.3 You are encouraged to visit the above website from time to time to ensure that you are well informed of our latest policies in relation to personal data protection.