Personal Data Protection Policy

1.0 Policy

This is the personal data protection policy of KBA Training Centre Pte Ltd. The terms “we”, “our” or “the company” in this policy refer to KBA Training Centre Pte Ltd (KBAT).

1.1 Compliance with this Policy. This policy applies to all personal data you provide to us, or that we may collect about you. Please do not provide any personal data to us if you do not accept this policy.
1.2 We may also require you to accept this policy when you contact, interact, transact or deal with us, or when you access and use our websites, applications or services. If you notify us that you do not accept this policy, we may not be able to establish a relationship with you or be able to service your requests.

2.0 Our Commitment toward this policy are to:

a) following the Personal Data Protection Act and its aims;
b) compliance with laws and regulations, internal policies and procedures;
c) limiting collection of personal data to its barest necessity;
d) protection of personal data by restricting those with access and handling such data as confidential;
e) requesting permission to use data beyond collected purpose;
f) ensuring accuracy by regular update; and
g) permanently remove personal data no longer considered relevant.

3.0 Personal Data

3.1 What personal data we collect. The personal data we collect depends on the purposes for which we require the personal data and what you have chosen to provide. This may include your name, address, contact information (e.g. telephone number and email address), identification number, photograph, video image and any other information that may identify you or is personal to you.

3.2 How we collect personal data. We collect personal data relevant to our relationship with you. We may collect your personal data directly or indirectly through various channels as PDPA requirements.
3.3 Accuracy and Completeness of personal data. You must ensure that all personal data that you provide is true, accurate and complete and promptly inform us of any changes to the personal data.

4.0 Purpose

4.1 We collect, use and disclose your personal data in an appropriate manner for the following purposes:

a) have given us the consent;
b) comply with our legal or regulatory obligations (e.g. Committee For Private Education, Skillsfuture Singapore, Ministry of Manpower etc.);
c) necessary for our legitimate business interests, provided that this does not override your interests or rights;
d) to perform a contract or transaction you have entered into with us.

e) to administer and process any payments (including refunds) related to products, services and facilities requested by you.

4.2 General purposes. Generally, we collect, use and disclose your personal data for purposes connected or relevant to our business, and marketing purposes to which your request to receive news, promotions and marketing information from us.

4.3 Use permitted under applicable laws. We may also collect, use, disclose and process your personal data for other purposes, without your knowledge or consent, where this is required or permitted by law.

5.0 Disclosure of Personal Data. We may disclose or share your personal data with the for the purposes described in paragraph 3.0

5.1 Other Disclosures. We may also disclose or share your personal data in connection with the purposes:-

a) third parties who are appointed to provide services to us, e.g. IT vendors, event organisers; conduct joint marketing and cross promotions with; and
b) regulatory authorities and public agencies.

6.0 Deemed consent by Notification. We may need to collect, use and disclose personal data for reasonable purposes as mentioned above and hat are articulated in the PDPA through deemed consent and exceptions to the consent obligation. Consent to the processing of personal data will be deemed to have been obtained in two circumstances, contractual necessity and notification and opt-out. In addition, the following three exception to consent are legitimate interest, business improvement and research.

7.0 Transfer Limitation Obligation. Some of our customers may be located overseas (if any) and, as a result, Personal Data collected and held by us, such as data storage in the cloud may be transferred overseas; thus KBAT will ensure that the country to which the data is being transferred offers a comparable level of data protection as is provided by the PDPA. Additionally, we are conforming to EU GDPR regulations for submission of personal data within the EU, thus that standard of protection is accorded to the data.

8.0 Protection of Personal Data

8.1 Period of retention. We keep your personal data only for so long as we need the data to fulfil the purposes we collected it for, and to satisfy our business and legal purposes, including audit, accounting or reporting requirements.

8.2 Anonymised data. In some circumstances we may anonymise your personal data so that it no longer identifies you, in which case we are entitled to retain and use such anonymised data without restriction, including for data analytics.

8.3 Unauthorised access and vulnerabilities. While we take reasonable precautions to safeguard your personal data in our possession or under our control, we cannot be held responsible for unauthorised or unintended access that is beyond our control, including hacking or cybercrimes. We also do not guarantee that our websites and applications are invulnerable to security breaches, or that your use of our websites and applications is safe and protected from viruses, worms, Trojan horses, and other vulnerabilities.

9.0 Your Rights. You enjoy certain rights at law in relation to your personal data that we hold or control. These rights include:

9.1 Withdrawal of consent: you may withdraw consent for our use of your personal data.

9.2 Correction: you may request that any incomplete or inaccurate data that we hold or control be corrected.

9.3 Access: you may ask if we hold or control your personal data and if we are, you can request access or a copy of such data.

10.0 Concerns and Contacting Us. If you have any feedback or issues in relation to your personal data, or about this policy, you may contact our Data Protection Officer – Email address: enquiries@kbassociates.org