Effective 12 August 2020
Dear valued WV customers and guests,This Personal Data Protection Policy notice for personal data (“Notice”) is issued to all our valued customers and guests of Wolin Ventures Pte Ltd (Wolin Ventures).
At Wolin Ventures, we take data protection very seriously.We understand the importance of your privacy and personal data. Therefore, we process all of your personal data in compliance with the Personal Data Protection Act 2012 (‘PDPA’). Additional measures in the form of our internal data protection policies and security safeguards are also in place when we handle personal data on behalf of our existing clients in our role as a service provider. While we know that privacy is important to you, it may be inevitable in the course of business that some of your personal data is shared and collected in communications between us, whether these communications are for the purpose of understanding your needs or providing any of our service offerings to you. This Data Protection Policy provides clarification on how Wolin Ventures in general collects, uses and shares your personal data. This policy covers all services and products provided by Wolin Ventures Pte Ltd, such as our mobile application Building Performance Alliance (BPA), etc.
Generally, the term “personal data” refers to any information that identifies or can be used to personally identify an individual. This includes information such as your name, address, telephone number, identification or passport number as well as your email address.
Personal data may be collected when you/we:-
In addition to the above, we may also obtain your personal data through third parties from time to time. Where we do so, we will seek confirmation from such third parties that they have obtained your personal data legally and that we have the right to acquire it from them and to use it.For those seeking a career with us, we may also collect your personal data as part of your application. Where you have voluntarily provided personal data of a third party in the course of submitting your application, kindly ensure that you have obtained the consent of such third party prior to providing such personal data to us.For work purposes and any form of work arrangements with us, we will collect your personal data for consistent purposes related to our business and legal matters.Kindly note that in all cases where personal data has been voluntarily provided, you will have been deemed to have consented to the collection and use of such personal data unless you inform us otherwise.
The type and extent of personal data we generally collect depend on the method and purpose of communication between us.Typically, we collect the following types of personal data:-
Information that includes but not limited to the following:
Information that provides the necessary support to the primary activities or operations etc., includes but not limited to the following:
Information we collected is meant to increase the performance and personalisation of our product, and provide you with better and more relevant services.Wolin Ventures does not collect sensitive personal data relating to your health, religion, race or political beliefs.For our existing clients, we may also have collected additional personal data about you as part of our business requirements (e.g. for point of contact for billing, invoicing and payment purposes). This is necessary for our continuing pursuit of providing you, our valued client, with consistent solutions and services of a world-class standard.
In general, we collect, hold and use your personal data for the purposes of:-
Wolin Ventures only keeps personal data for such a period as there is a business or legal need.Wolin Ventures does not use any of your personal data other than as described in this policy, or other than as permitted under local laws and regulations.
From time to time, Wolin Ventures will disclose or share your personal data with other parties subject to the purposes set out in paragraph 2.4. above. Where recipients of personal data shared by us reside overseas, we will take steps to ensure that such recipients have in place adequate measures and safeguards relating to confidentiality and data protection.In certain cases, we will also encrypt, aggregate and anonymise personal data before sharing it. This means that the information will only be presented over a range (e.g. by age) and cannot be used to personally identify you.This section sets out the parties to which your personal data is disclosed or shared and the purposes for doing so (where applicable).
Primarily, Wolin Ventures may disclose your personal data to our employees and affiliates for business and administrative reasons mentioned in paragraph 2.4. from time to time.
Where necessary and to the extent required, Wolin Ventures may from time to time disclose your personal data to:-
In some cases, our website may contain links that allow you to post your enquiries or comments that are accessible by the general public over the internet. When doing so, kindly be reminded that caution should be exercised whenever you are posting personal data online.Save as aforementioned, Wolin Ventures does not provide any personal data to unaffiliated third parties for direct marketing purposes; and, Wolin Ventures will only disclose personal data where required by law, an order of court/tribunal or otherwise permitted under the PDPA.
Where necessary, we may collect and hold personal data communicated to us, whether the medium of communication is verbal, electronic or written. However, we generally do not store personal data that is sensitive in nature.If your personal data is held by us, we will take reasonable precautions to protect them from misuse, loss, unauthorised access, modification or disclosure by using a combination of physical, administrative and technical safeguards. Some of the measures put in place to secure and protect your information include:-
While we take great care in ensuring the security of personal data held by us, we nonetheless wish to highlight that any information transmitted online remains susceptible to access by unauthorised third parties. This is because of the inherently insecure nature of the internet as a medium of data transmission. As such, we are unable to guarantee with any certainty regarding the security of communications containing personal data transmitted over the internet.Wolin Ventures also makes use of services offered by other companies and/or organisations and these services may include making use of their cloud space to store information or to help with managing the administration and operation of Wolin Ventures.These companies and/or organisation that Wolin Ventures may use including but not limited to the following:
As any communications over the internet are transmitted at your own risk, we once again hope to remind you to exercise caution when using the internet as a medium for data transmission for personal data.Security Features: From time to time we may introduce additional features to enhance the security measures. Depending on your location and types of services that you are using, we may require you to adopt one of the security features. These security features are made optional, therefore you will be responsible for any consequences of not using those features. We strongly encourage you to use all security features at all times.
We retain the data we collect for different periods of time depending on what it is, how we use it, and how you configure your settings:
When you delete data, we follow a deletion process to make sure that your data is safely and completely removed from our servers or retained only in anonymized form. We try to ensure that our services protect information from accidental or malicious deletion. Because of this, there may be delays between when you delete something and when copies are deleted from our active and backup systems.Safe deletion is important to protect our users and customers from accidental data loss. Complete deletion of data from our servers is equally important for users’ peace of mind. This process generally takes around 2 months from the time of deletion. This often includes up to a month-long recovery period in case the data was removed unintentionally.As with any deletion process, things like routine maintenance, unexpected outages, bugs, or failures in our protocols may cause delays in the processes and timeframes defined in this article. We maintain systems designed to detect and remediate such issues.
While we endeavour to ensure that personal data about you held by us remains accurate, up to date and complete, we may not be able to immediately react to changes to your personal data that may occur from time to time. We will update within 30 days from the date of your request.To that extent, you may wish to request access to personal data about you that is held by us at any time, including to correct such personal data that is inaccurate, incomplete or out of date.Kindly note that access to your personal data in the manner requested is given subject to exceptions allowed by law or the PDPA and where it is reasonable and practical to do so.Should you wish to access, correct your personal data or withdraw your consent, please submit your request via WV PDPA Application Form set out at the end of this policy. Our Data Protection Officer will respond to you within 30 days after you have made the request. Note that in some instances, a nominal fee may be charged to you to cover the cost of retrieving the requested personal data.In certain circumstances, we may nonetheless deny your request for access to or correction of your personal information. For example, where granting such access will interfere with the privacy of others, is unlawful or would result in a breach of confidentiality. In such cases, we will provide you with written reasons for refusing your request and the mechanisms available to you to appeal against our refusal.
If you have any concerns regarding how your personal data is being handled by Wolin Ventures or wish to make a complaint about a breach of the PDPA by Wolin Ventures, you may submit your complaint via our WV PDPA Application Form set out at the end of this policy.Our Data Protection Officer will respond to you in writing within thirty (30) days, setting out what action Wolin Ventures will take in response to your complaint, or alternatively, where there has been no breach, an appropriate explanation.Wolin Ventures will also inform you when there has been unauthorized access to personal data. Depending on the nature of unauthorized access, and the location of your affected contacts, you may be required to assess whether the unauthorized access must be reported to the contact and/ or a relevant authority.
As with most other websites on the internet accessible by the general public, Wolin Ventures’s website utilizes ‘cookies’ – a small file stored on a user’s computer designed to hold a modest amount of data specific to an incoming user and the website assessed. Using cookies allows Wolin Ventures to engage you in a more meaningful way by allowing us to recall information you have previously entered via our website without having you re-enter them and to tailor our website’s content to be more relevant to you.While Wolin Ventures’s website does not utilize tracking cookies – cookies which have the potential to track a user’s browsing habits, we nonetheless recognize that you may not wish to receive cookies on your computer. If that is the case, you may wish to visit the options menu for your browser to prevent cookies from being accepted.Kindly take note that from time to time, we may monitor user activity or log IP addresses on our website in order to administer the website, analyse demographic access trends and improve accessibility.
In using Wolin Ventures’s website, you may come across links to other websites of third parties. Please note that the contents of this policy do not extend to such third party websites. Should you visit any third-party websites through links made available on our website, kindly be reminded that Wolin Ventures make no representations or warranties in relation to the privacy practices of any third party website and are not responsible for the privacy policies or content of any third party website.
From time to time, we may send you communications and information about our services and solutions that we consider may be of interest to you. These communications may come in various forms e.g. mail, SMS, fax or email.If you do not wish to receive such direct marketing communications from us, you can opt-out of receiving them by submitting your request using the contact details set out at the end of this policy or using the opt-out mechanisms provided in the communications. Do note that if you do opt-out of receiving marketing-related communications from us, we may still send you important administrative messages, and you cannot opt-out from receiving administrative messages.
If you have any enquiries regarding Wolin Ventures’s Personal Data Protection Policy or would like to contact us regarding how your personal information is being handled by Wolin Ventures, please submit your request via WV PDPA Application Form @ bit.ly/WVPDPAApplicationForm
Wolin Ventures may revise this Data Protection Policy from time to time. Any such revisions will be announced via Wolin Venture’s website. Kindly take note to review this policy as well as any updates on a regular basis.
Wolin Ventures assumes no responsibility whatsoever for any and all claims, damages, losses, expenses, costs or liabilities (including without limitation, any direct, indirect, punitive, special, incidental or consequential damages or loss of profits) arising from the use of information taken from Wolin Venture’s website or from that of other companies that have placed links to their site on this website.
All contents contained in or accessed through Wolin Ventures’s website are provided on an “as is” and “as available” basis and the user agrees to use them at their sole risk. Wolin Ventures expressly disclaim all warranties of any kind, whether express or implied, including implied warranties of merchantability, satisfactory quality, fitness for a particular purpose and non-infringement, to the fullest extent allowed by law. Without prejudice to the foregoing, Wolin Ventures make no warranty as to the accuracy, reliability or quality of any content or service obtained through this website or any defects therein will be corrected and that such content and access to them are error-free and uninterrupted or available at all times.
By accessing Wolin Ventures’s website and online services, the user agrees that such access and/or use, as well as this policy, are construed in accordance with, and governed by the laws of the Republic of Singapore and hereby submits to the exclusive jurisdiction of the Singapore courts.
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