Privacy Policy

This Privacy Policy (“Policy”) sets out the basis which iSwans Consultancy Pte. Ltd. (“iSwans”, “we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of users in accordance with the Personal Data Protection Act (“PDPA”). This Policy applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.

This privacy policy supplements but does not replace any other consents you may have previously provided to iSwans.

1. THE TYPES OF PERSONAL DATA WE COLLECT

1.1. As used in this Policy: “member” means a member of iSwans, whether practising or otherwise;  “customer” means an individual who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us; "Personal Data" refers to any data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which iSwans has or is likely to have access. Depending on the nature and purpose of your interaction with us, examples of Personal Data which you may provide to us could include but are not limited to:

1.1.1. general personal information such as your name, nationality, identification number, passport number, date of birth, registered address, gender, marital status and personal interests;

1.1.2. contact information such as your phone number, mailing address and e-mail address;

1.1.3. current employment information, employment history and education background;

1.1.4. photographs, video recordings or recordings on other mediums in which your likeness may appear; and

1.1.5. technical data such as your IP address and information about your usage of iSwans's website and service.

2. HOW WE COLLECT PERSONAL DATA FROM YOU

2.1. We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) 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 and usage of your personal data for those purposes, or (b) collection and use 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).

2.2. Generally, we may collect Personal Data from you in the following ways:

2.2.1. when you subscribe to our email alerts or mailing lists on our website;

2.2.2. when you make general enquiries via email;

2.2.3. when you submit career enquiries to us;

2.2.4. when you submit a job application to us via our website or LinkedIn page, or through a third-party recruitment agency; and

2.2.5. when you attend events or webinars organised or conducted by us where photographs, video recordings or other recordings in other mediums in which your likeness may appear are taken.

2.3.  We may also collect Personal Data, including but not limited to your name, contact information and other identification information, from other sources where needed and in compliance with the applicable laws.

3. PURPOSES FOR COLLECTION, USE, DISCLOSURE AND PROCESSING OF PERSONAL DATA

3.1. We may collect and use your personal data for any or all of the following purposes:

3.1.1. operating our website and/or its subdomains (“Website”);

3.1.2. performing our statutory functions and administering our activities;

3.1.3. communicating with our members and customers; 

3.1.4. updating your personal and contact information; 

3.1.5. performing obligations in the course of or in connection with our provision of the goods and/or services requested by you; 

3.1.6. verifying your identity; 

3.1.7. responding to, handling, and processing queries, requests, applications, complaints, and feedback from you; 

3.1.8. managing your relationship with us; 

3.1.9. processing payment or credit transactions; 

3.1.10. complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority; 

3.1.11. statistical, analysis, planning and reporting; 

3.1.12. any other purposes for which you have provided the information; and 

3.1.13. any other incidental purposes related to or in connection with the above.

3.2. For any other purpose(s) not set out here, we will notify you of such other purpose(s) and seek your consent in accordance with the requirements of the Act, including but not limited to at the time of collecting your Personal Data, unless processing of your Personal Data without your express consent is permitted by the Act or by law.

4. DISCLOSURE OF PERSONAL DATA

4.1. Subject to the provisions of the Act and any other applicable law, and in order to carry out the purposes set out in Section 3 above, we may disclose your personal data:

4.1.1. where necessary to enforce the Terms of Use; 

4.1.2. where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods and services requested by you; 

4.1.3. to third party service providers, agents and other organisations we have engaged to perform any of the functions with reference to the above mentioned purposes; 

4.1.4. if required by law or in the good faith belief that such action is necessary to: 

4.1.5. conform to the edicts of the law or comply with legal processes served on us or the Website; 

4.1.6. protect and defend our rights or property; and 

4.1.7. act under exigent circumstances to protect the personal safety of users of the Website; or 

4.1.8. where your consent has been obtained for disclosure.

4.2. Where your use of the Website is concerned, you acknowledge and accept that certain functions, when activated or used by you, will operate to send or display information about yourself, including but not limited to, your personal data to certain third parties, and you agree to the sharing of such information with these third parties. You acknowledge and agree that we shall not be held responsible or accountable for any loss, injury or damage sustained by you for sharing the aforesaid information arising out of your activation or use of such features on the Website.

5. REQUEST FOR ACCESS OR CORRECTION OF PERSONAL DATA

5.1. You may request a copy of your Personal Data and ask us about the ways in which your Personal Data has been or may have been used or disclosed by us within the year preceding the date of your request ("Access Request").

5.2. To the extent permitted by law, we reserve the right to charge a reasonable administrative fee for processing your Access Request. We will inform you of any such fee prior to processing the Access Request.

5.3. You may request us to correct an error or omission in your Personal Data ("Correction Request").

5.4. You may submit your Access Request or Correction Request in writing via email at the contact details provided in paragraph 13 below.

5.5. There may be exceptional circumstances where we may refuse your Access Request or Correction Request. We will generally inform you of the reasons for the refusal, except where we are not required to do so under the Act.

5.6. We will respond to your Access Request or Correction Request as soon as possible. If we are not able to respond to your Access Request or Correction Request within 30 days after receiving it, we will inform you of the time by which we will respond to your Access Request.

6. REQUEST TO WITHDRAW CONSENT

6.1. You may withdraw your consent for the collection, use and/or disclosure of your Personal Data in our possession or under our control by submitting your request ("Withdrawal Request") in writing via email at the contact details provided in paragraph 13 below.

6.2. We will process your Withdrawal Request, and inform you of the likely consequences of your Withdrawal Request, within a reasonable time.

6.3. If you withdraw your consent to the collection, use or disclosure of your Personal Data for any purpose, we will cease (and cause our data intermediaries and agents to cease) such collection, use or disclosure of your Personal Data, as the case may be. However, your withdrawal of consent could result in us being unable to continue providing certain services or products to you, and may also result in you being in breach of your contractual obligations, in which event our rights are reserved.

6.4. In certain situations, we may continue with the collection, use or disclosure of your Personal Data notwithstanding a Withdrawal Request, where so required or authorised under the Act or other written law.

7. ACCURACY OF PERSONAL DATA

7.1. We need your assistance to ensure that your Personal Data is accurate and complete, particularly where your Personal Data is likely to be used by us to make a decision that affects you or to be disclosed by us to another organisation.

7.2. In order to ensure that your Personal Data is accurate and complete, please update us of any changes in your Personal Data by informing us in writing via email at the contact details provided in paragraph 13 below.

7.3. We will not be responsible for relying on inaccurate or incomplete personal data arising from your not updating us of any changes in your personal data that you had initially provided us with.

8. PROTECTION OF PERSONAL DATA

8.1. We will put in place reasonable security arrangements to ensure that your Personal Data is adequately protected and secured. However, we cannot guarantee the security of your Personal Data, particularly where information is transmitted via the internet, and any such transmission is at your own risk.

9. RETENTION OF PERSONAL DATA

9.1. We may retain your Personal Data for such period as is necessary to fulfil the purpose for which it was collected or for the purposes set out here, or as required or permitted by applicable laws.

9.2. We will cease to retain, or will anonymise, your Personal Data as soon as the retention of your Personal Data no longer serves the purpose for which it was collected or is no longer necessary for any other legal or business purposes.

10. COOKIES

10.1. Our website uses cookies, which are pixel that load when our website is loaded in your browser. The use of cookies enables us to improve our website and provide you with a better online experience.

10.2. The cookies will record user actions such clicks, gestures, screen time, and scrolling behaviour, and may collect data such as IP addresses, the type and model of your browser and the model of your device. Where any data collected qualifies as Personal Data, the terms of this privacy policy will apply.

10.3. Should you wish to disable the cookies on our website, you may use a cookie blocker or change your browser settings. However, you may not be able to access certain parts of our website if you do so.

11. THIRD PARTY WEBSITES

11.1. We may from time to time provide you with links to other websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please ensure you carefully read and review the privacy policies of these websites before you submit any Personal Data to these websites.

12. UPDATES TO PRIVACY POLICY

12.1. We reserve the right to amend the terms of this privacy policy from time to time, without prior notice except by publication on our website, to ensure that it is consistent with our future developments and/or any changes in the law. You agree to be bound by the prevailing terms of the privacy policy as updated from time to time.

12.2. We encourage you to check back regularly for any updates to the privacy policy.

13. HOW TO CONTACT US

13.1. If you have any queries or comments regarding this privacy policy or your Personal Data, or if you would like to make any requests under this privacy policy, please contact our Data Protection Officer in writing at:

iSwans Consultancy Pte. Ltd.
Data Protection Officer
60 Paya Lebar Road

#07-54 Paya Lebar Square
Singapore 409051
Email: dpo@i-swans.com

13.2. When writing to us, please reference "iSwans Privacy Policy" in the subject header.

14. GOVERNING LAW

14.1. This privacy policy shall be governed in all respects by the laws of Singapore.