We (The Stakeholder Company Pte Ltd – “TSC”) are committed to protecting the data privacy and confidentiality of both our internal and external stakeholders including corporate customers, suppliers, employees and any member of the public which may have come into contact with us.
Our Privacy Statement is designed to inform you about the collection, use, process and disclosure of personal data as well as the physical, technical and administrative safeguards we have put in place to protect your information.
personal information in the possession of organisations which we have engaged to collect, use, disclose or process personal information for our purposes. It also outlines how you can access and change your personal information, ask a question or make a complaint.
1 Collecting personal information
1.1 What is personal information?
As used in this Notice:
“customer” means an individual who (a) has contacted us through any means to find out more about products we provide, or (b) may, or has, entered into a contract with us; and
“personal information” means data, whether true or not, about a customer 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.
“Sensitive information” means personal information that includes data or opinions about you such as your membership of political or professional associations or a trade union, your racial or ethnic origins, religious or philosophical beliefs or sexual orientation.
Depending on the nature of your interaction with us, some examples of personal information which we may collect from you include name, residential address, work address, email address, telephone/fax number, gender, employment information, date of birth and other biographical information, political and professional affiliations, languages, other skills and educational history.
the PDPA (where the context so permits).
1.2 What is the purpose for collecting personal information?
We only collect personal information for the purpose of developing, organising and integrating our information database on industry stakeholders, organisations, trends and issues for our clients. This database ultimately forms the basis of our business stakeholder product sales and support business.
We collect your personal information either:
(a) if you are a client or potential client, for the purpose of providing you with our high quality business stakeholder product and associated services. If we do not collect your personal information, we may not be able to provide this to you. For
example, we may not be able to communicate with you and deal with your enquiries or requests; or
(b) if you are a person with a significant role in culture, commerce, politics or any other prominent position, for the purpose of providing our clients with comprehensive analysis of issues important to them and their business. This may include using your personal information to give our clients a better understanding
of your background and how you are involved in the areas of interest to our clients.
(c) if you are an employee in the case of hiring, employment evaluation, issuing Salary & other compensation benefits, Medical Insurance and Managing or terminating employment. This may include using your personal information to fulfil the request of appropriate authority requests or other statutory obligations
1.3 How do we collect personal information?
There are several ways that we may collect your personal information, which are set out below. We continuously collect data and improve our data by matching and cross-checking sources. All of the information we collect is already disclosed by the individual, either publicly or to a third party.
(a) Directly from you
As a client or potential client you may give us personal information directly. We may collect this information when we meet you in person, such as if we visit you for sales or support purposes, when you receive a quote from us or complete an application form or contract. But we may also collect your personal information directly from you in other ways, including when we have a conversation with you over the telephone or you send an email or letter to us.
As an employee you provide us your Personal Identification information, Contact Information and other information for employee evaluation and administrative matters. As an employee you shall provide those information when we meet you in person at the hiring interview.
(b) From clients
Our clients may have existing personal information about you from their previous interactions with you, which we incorporate into our database.
(c) From publicly available sources
We may collect personal information about you from publicly available databases and other public sources, such as the websites of various organisations or from event websites. We may also collect personal information from publicly available government registers, professional association memberships, newspapers and journals. We collect such information both manually and by using automated software which we then compile into a database held at our own premises.
(d) From third party databases
From time to time we purchase access to third party databases containing information about significant figures that may contain personal information about you.
As a potential client, third parties may give us personal information about you so that we may contact you about our services.
When we obtain information about individuals from third parties, we use reputable sources, including public repositories. We employ appropriate measures to assure the quality of information which we collect.
(e) From other sources
We may collect information from ad hoc sources as it becomes available, such as business cards, email records and as revealed by processes undertaken by our data experts.
(f) From our website
We do not store or use personal information collected from you using our website, except as is reasonably necessary to operate the website. Such information is not used in our business functions and activities. If you are using our website, you will browse anonymously except as set out in this section.
Internet Explorer, Chrome or Firefox), the time of visit, pages visited and your IP
Information collected in this way is not capable of personally identifying you.
However, if you have completed an application form on our website or if you contact us by email and we have identified you, we may be able to link your Iidentity to your previous anonymous browsing history and collect information
about your possible future use of our website, irrespective of how you access our site (eg from a third party website). We do not do this as a matter of course, however it is technically feasible.
2 How we use and disclose your personal information?
2.1 Using and disclosing personal information
We only hold, use and disclose personal information about you for the purposes outlined in section 1.2, or for related purposes which might be reasonably expected.
For instance, we may collect, hold, use, process and disclose your personal information to provide our business stakeholder product and associated services to you, manage our relationship with you, verify your identity and other details, deal with your enquiries and concerns and to give our clients a better understanding of your background and experience if you are a person of interest in the area in which our clients operate.
To do this, we may disclose your personal information to third parties who:
(a) are our clients;
(b) provide services which are necessary for us to conduct our business, such as providers of archival, data storage, auditing, debt collection, banking, insurance, marketing, advertising, delivery, technology, data processing, research and professional advisory (legal, accounting, financial and business consulting) services;
(c) are regulatory bodies, government agencies, police, courts and dispute resolution schemes; or
(d) are your authorised agents, executors, administrators or legal representatives.
We may also hold, use and disclose your personal information in connection with suspected fraud, misconduct and unlawful activity, and as part of a restructure of TSC.
On some occasions, we may be obliged to disclose your personal information by law, e.g. court order or statutory notices pursuant to any legislation and to government authorities.
If your personal information is no longer needed for legal or business purposes, we will remove, destroy and anonymize your personal information.
2.2 Disclosure of personal information outside of Singapore
If you are a person with a significant role in culture, commerce, politics or any other prominent position, then we may have collected your information from publicly available sources. We do this for the purpose of developing and integrating our business stakeholder product and to comply with our contractual obligations with clients. As part of our business activities we may provide this
product to clients who are located outside of our headquarters in Singapore. It is not always practical to specify in which countries those clients may be located, but we have currently have clients in Australia, Europe, Papua New Guinea, the Middle East, the United Kingdom, the United States of America, and countries within Asia, Africa and South America.
Internet infrastructure is global, and therefore the personal information we collect about you may be transferred to countries outside of Singapore that do not have similar data protection legislation as set out in this policy (for example, we may host information on servers outside of Singapore). However, we have taken the steps outlined above to maintain the security of your information.
3 Keeping personal information secure
We are committed to implementing the highest standards of information security to protect the privacy and confidentiality of the individual’s personal information. Our data security policies are compatible with best practice and are ISO 27001 certified. We are constantly improving our security policies, and follow industry best practice, such as:
● We limit access to personal information of individuals to its authorized employees and also maintains physical, technical, administrative and procedural safeguards to protect the information against loss, misuse, damage or modification and unauthorized access or disclosure.
● The access to your personal information is limited to our employees and affiliates who need it to carry out their business transactions and responsibilities.
● Vendors and other external contractors we engage are subject to contractual requirements to ensure that personal information is safeguarded.
While we strives to protect your individual’s Personal Data, you should be aware of the risks associated with disclosing any Personal Data or information when performing transactions over the Internet, or when using public terminals or online portals. You are advised to take the necessary precautions
such as strong passwords, changing your password regularly and using a secure browser when disclosing Personal Information to us over the Internet.
4 Retention of personal information
We may retain your personal information for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
We will cease to retain your personal information, 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 information was collected, and is no longer necessary for legal or business purposes.
5 Access, deletion and correction of personal information
We take reasonable steps to ensure that all personal information we hold is as accurate as possible.
We may, upon your request, make available information about the ways in which your personal information has been or may have been used or disclosed within the past 1 year before the request. Also, if you feel that the personal information we hold for you is incorrect, you are able to contact us at any time to request that we correct or delete that information.
If you would like to do so please submit your request in writing to our Data Protection Officer at the contact details in section 6 below.
To help us to respond to your request for access, deletion or correction of any inaccuracies, it may be needed to ask you to verify your identity and provide other details. We shall respond to your request within a reasonable timeframe and might charge a reasonable fee for an access of request. If so, we will inform you of the fee before processing your request.
We reserve the right to refuse access and correction should your request be illegal, frivolous or vexatious or if it would have an unreasonable effect on the privacy of other individual. If access is refused, we will give you a notice explaining our decision to the extent practicable and your options to make a complaint.
We will normally try to resolve access, deletion and correction requests within 30 days of you making a request. If we need more time to resolve your request we will notify you in writing as to the delay and seek your agreement to a longer period.
6 Contact Information
You may contact our Data Protection Officer or our Local representative (for data protection matters in the EU and UK), if you have any enquiries, complaints, concerns or feedback on our personal information protection policies and procedures, in the following manners:
Data Protection Officer:
● Email: firstname.lastname@example.org,
● Telephone: Juliana Salto between 9.00am and 6.00pm Monday to Friday, +65 6815 0019
● Address: The Stakeholder Company, 23A Bussorah Street, Singapore 199441
EU and Uk Representative (Verasafe):
1) European Union:
● Website: https://verasafe.com/public-resources/contact-
● Telephone: +420 228 881 031.
● Address: VeraSafe Ireland Ltd. Unit 3D North Point House, North Point Business Park, New Mallow Road, Cork T23AT2P - Ireland
2) United Kingdom:
● Website: https://verasafe.com/public-resources/contact-data-protection-representative
● Telephone: +44 (20) 4532 2003.
● Address: VeraSafe United Kingdom Ltd., 37 Albert Embankment, London SE1 7TL, United Kingdom
7 Effect of Notice and changes to Notice
This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal information by us.
We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes. You can obtain a copy of the current version on request or at https://tsc.ai/privacy/
Last updated : 16/05/2023