1.1. This privacy policy sets out how we comply with the provisions of the Personal Data Protection Act 2012 of Singapore (“PDPA”) as follows:

 

(a)our policies on how we manage your Personal Data;

(b)the types of Personal Data we collect, use, disclose and/ or retain;

(c)how we collect, use, disclose and/ or retain your Personal Data; and

(d)the purpose(s) for which we collect, use, disclose and/ or retain your Personal Data.

 

1.2. We will collect, use or disclose Personal Data for reasonable business purposes only if there is expressed consent from the individual and information on such purposes have been notified. If you have decided to not give your consent, you may face consequences such as refused entry to our premises or denied for certain services provided by us. 

 

1.3. We may also collect, use or disclose Personal Data without your consent if it is required or authorised under applicable laws, or to respond to an emergency that threatens the life, health, and safety of individual.

 

1.4. You agree and consent to us, our authorised service providers and third parties to collect, use and disclose and/ or retain your Personal Data in accordance with this privacy policy.

 

1.5. This privacy policy supplements but does not supersede nor replace any other consent which you may have previously provided to us nor does it affect any right that we may have at law in connection with the collection, use, disclosure and/ or retention of your Personal Data.

 

1.6. From time to time, we may update this privacy policy to ensure that our policy is consistent with any regulatory changes, however, subject to your legal rights in Singapore, the prevailing terms of the privacy policy shall apply.

 

1.7 This policy applies to data subjects such as visitors, website users and if we received your personal data to perform our role as data intermediary.

 

 

2.1. In this privacy policy, “Personal Data” refers to any data and/or information about you from which you can be identified by, either from that data; or from that data and other information to which we may have legitimate access to.

 

2.2. Examples of such Personal Data include but are not limited to:

(a) your name, telephone number(s), mailing address, email address and any other information relating to you which you have provided in any forms you may have submitted to use, or in other forms of interaction with you;

(b) your photos;

(c) your employment history, education background, and income levels;

(d) Personal Data of your family members, such as next of kin, spouses, and children; and

(e) information about your usage of and interaction with our website and/or services.

 

2.3. For purposes such as employment, certain sensitive information may be collected include but are not limited to:

(a) NRIC number

(b) Passport number

(c) other Identification number

 

 

3.1. We generally collect personal data that 

(a) you knowingly and voluntarily provide in the course of or in connection with your employment or job application with us, or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”, which may include your job placement agent or your service provider), after 

(i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and 

(ii) you (or your authorised representative) have provided written consent to the collection, usage and disclosure of your personal data for those purposes, or 

(b) collection, usage and disclosure 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 authorised by law).

 

3.2. Such Personal Data may be provided to us in forms filled out by individuals, face to face meetings, email messages, telephone conversations, through our websites or provided by third parties.

 

3.3. If any individuals contact us, we may keep a record of that contact.

 

3.4. We collect these Personal Data when it is necessary for business purposes (such as when you register with us as a visitor to our premises or as a contractor) or to meet the purposes for which the individuals have submitted the information.

 

3.5. We will only collect, hold, process, use, communicate and/or disclose such Personal Data, in accordance with this privacy policy.

 

3.6. If any party is acting as an intermediary or otherwise on behalf of a third party individual or supplying us with information regarding a third party individual (such as a friend, a colleague, an employee etc), such intermediary party undertakes that you are an authorised representative or agent of such third party individual and that you have obtained all necessary consents from such third party individual to the collection, processing, use and disclosure by us of their Personal Data.

 

3.7 We may also collect your data from a third party to perform our role as data intermediary to fulfil our legitimate business purposes.

 

 

4.1 In general, we may use your Personal Data for the following purposes:

(a) to provide our services;

(b) to respond to the individual's request or for the purposes for which it was provided to us as stated at the time of the collection (or as is obvious from the context of collection);

(c) to maintain contact with clients, contractors and other contacts;

(d) for general management and reporting purposes;

(e) for recruitment purposes;

(f) for purposes related to the employment of our personnel and providing internal services to our personnel;

(g) for process your registration to our premises as a visitor or as a contractor 

(h) all other purposes related to our business; and

(i) to comply with applicable laws and regulations.

(j) Respond to an emergency that threatens the life, health and safety of individual

 

 

5.1 We do not disclose Personal Data to third parties except when required by law, when we have the individual's consent or in cases where we have engaged third parties such as data intermediaries or subcontractors specifically to assist with our company's activities.

 

5.2 We may also disclose your Personal Data to the following group of external organisations, subject to the requirements of applicable laws:

(a) our affiliated companies;

(b) agents, contractors, data intermediaries or third-party service providers who provide services, such as telecommunications, mailing, information technology, payment, payroll, data processing, storage and archival, to us;

(c) external banks, financial institutions and their respective service providers;

(d) our professional advisers;

(e) relevant government regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any government authority; and

(f) any other person in connection with the purposes set forth above.

(g) Respond to an emergency that threatens the life, health and safety of individual

 

5.3 We may also disclose your corrected personal data to other relevant organization, if you have consented.

 

5.4 In case we transfer your data outside Singapore, we shall ensure the data governance standard is at least equivalent to the latest PDPA requirement.

 

 

6.1 Our website may contain links to other websites operated by third parties independent of us, but we are not responsible for the privacy practices of such websites operated by third parties even though it is linked to our website(s).

6.2 We encourage you to learn about the privacy policies of such third-party website(s) by checking the policy of each site you visit and contact its owner or operator if you have any concerns or questions.

 

 

7.1 We maintain appropriate security safeguards and practices to protect your Personal Data unauthorised access, collection, use, disclosure, copying, modification disposal or similar risks, in accordance with applicable laws.

 

 

8.1. 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.

 

8.2. We will cease to retain your personal data, or remove the means by which 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.

 

 

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

 

9.2. You are required to read, agree, and accept the terms set out in this notice before sharing any personal data with us. We may revise this Notice from time to time without any prior notice. There will be no separate communications to you, you are required to check our website at www.toppannext.com for the latest version of this notice. Your continued use of the website constitute your acknowledgement and acceptance of such changes. 

 

 

Please contact dpo@toppannext.com if you:

 

(a) have any enquiries, complaints or feedback on our data protection policies and procedures; 

(b) need access or correction to the data which you have provided to us in the past 1 year, or dispute the outcome of your request, or;

(c) wish to withdraw your consent or make changes to your data, however, if the consent is withdrawn, you may face consequences such as refused entry to the premises.

 

Effective from 8 December 2023