Privacy & Cookies Policy | SGInnovate
 

Last Updated: July 2021

Singapore Innovate Pte. Ltd. (“SGInnovate”, “we”, “us” or “our”) has been established to build, invest and support Deep Tech startups, including promoting these companies and connecting them through events and other mediums with investors, collaborators, partners, talents and customers. SGInnovate operates this website (“this Site”) in connection with its undertaking of the said services and activities (“Services”). Deep Tech is becoming an increasingly global marketplace where investors, sources of grants and consumers are located in all corners of the world. In recognition of SGInnovate’s widening footprint beyond Singapore, to places such as the European Union (“EU”), United States or the UK where some of our partners are located, we have been especially keen to ensure that this Privacy & Cookies Policy (“Policy”) takes account of the relevant data protection principles operating overseas. In particular we have measured and modelled this Policy against the high standards of data protection contained in the General Data Protection Regulation (EU) 2016/679 (“EU GDPR”) and since 1 January 2021 in the retained version of the EU GDPR which applies in the UK, as amended from time to time (the “UK GDPR”)1.

In providing our Services, we take your privacy seriously and are committed to providing a safe online experience. We believe in being transparent about our practices, which is why we have provided this Policy to explain how we collect, use and disclose your personal information. This updated Policy gives you more control over your personal information and more clearly explains how we use it. To be clear from the outset when we talk about “personal information” or “Personal Data” (as defined in section 4 herein) in this Policy, we are referring to information about you (or another person) as an identifiable living individual and may include some obvious identifiers such as a name, email address, telephone number, address and company, but also some less obvious personal identifiers such as social media posts, YouTube video clips, interactions on our blog, computer IP address, mobile device specification, GPS location data and cookie-logs relating to us or our partners with whom you interact (such as Facebook, LinkedIn, Twitter, Instagram and Youtube where SGInnovate is active).

  1. This Policy
    1.  This Policy describes how your information, including Personal Data (described below), will be collected, used and shared in connection with your use of our Services and this Site, our legal basis for doing so as well as your rights and choices regarding the information you provide to us. This Policy is intended to meet the requirements of the Personal Data Protection Act 2012 of Singapore and the Personal Data Protection (Amendment) Act 2020 of Singapore (collectively, the “PDPA”), the EU GDPR and the UK GDPR.
    2. We reserve the right to update this Policy from time to time. You should periodically visit this page to review the current terms of this Policy so that you are aware of any updated terms to which you are bound. If we do so, we will either notify you via e-mail or post the changes to this Policy on the Site and update the “Last Updated” date at the top of this Policy as the effective date of change. However, any changes will not apply retrospectively.
    3. By using our Services and/or this Site, you agree that you have read and understood this Policy, and you consent to our use of your information in accordance with this Policy.
    4. If you have any questions about this Policy or our practices, please contact our Data Protection Office ("DPO") at [email protected]. (“DPO Contact”)
  2. Your Rights
    1. You have the following rights under this Policy, and by law if you are within the EU or the UK, to:
      • Request access to your Personal Data. This enables you to request for access to your Personal Data in our possession or control or for information about the ways in which your Personal Data has been or may have been used or disclosed by us within a year before the date of your request. If you are within the EU or UK, this enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully processing it.
      • Request correction of the Personal Data that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected.
      • Request erasure of your Personal Data. This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to process it. You also have the right, if you are within the EU or UK, to ask us to delete or remove your Personal Data where you have exercised your right to object to processing (see below).
      • Object to processing of your Personal Data. This right exists where we are relying on legitimate interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to the processing of your Personal Data on this ground. You also have the right to object where we are processing your Personal Data for direct marketing purposes.
      • Request the restriction of processing of your Personal Data. This enables you to ask us to suspend the processing of Personal Data about you, for example if you want us to establish its accuracy or the reason for processing it.
      • Request the transfer of your Personal Data. If you are within the EU or UK, we will provide to you, or a third party you have chosen, your Personal Data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you. If you are in Singapore, such transfer request (or “data porting request”) will be processed, or may be refused, in accordance with the PDPA.
      • Withdraw consent. This right only exists where we are relying on consent to process your Personal Data ("Consent Withdrawal"). If you withdraw your consent, we may not be able to provide you with access to the certain specific functionalities of our Site. We will advise you if this is the case at the time you withdraw your consent.
      • Make a complaint and seek a remedy. Under EU GDPR and UK GDPR you have inalienable rights to (i) be informed about your right to complain through this Policy, (ii) make an actual complaint to your relevant supervisory authority depending on where you live (such as the European Data Protection Supervisor), and (iii) to receive an effective judicial remedy if your rights need to be upheld or enforced.
    2. Please note that certain rights provided in paragraph 2.1 above are available to you if you are within the EU or UK because of the EU GDPR and UK GDPR respectively. . Otherwise, your rights will be governed by this Policy to the extent of complying with the PDPA.
  3. How to exercise your rights
    1. If you wish to exercise the rights under paragraph 2 above, please:
      • put your request in writing via the DPO Contact;
      • provide us with sufficient information, or we may request for further information, for us to verify your identity as our security measures to ensure that Personal Data is not disclosed to any person who has no right to receive it; and
      • specify the right which you wish to exercise and identify the relevant Personal Data for this purpose.
    2. We will endeavor to respond to all legitimate requests within thirty (30) days unless your request is particularly complex or you have made multiple requests. In this regard, we will notify you and keep you posted. Typically, you will not have to pay a fee to access your Personal Data (or to exercise any of the other rights). However, if your request is clearly unfounded, repetitive or excessive, we may charge a reasonable fee or refuse to comply with your request in these circumstances.
    3. If you wish to stop receiving marketing communications from us or modify your preferences (such as email), you may follow the opt-out links on specific marketing communications sent to you, or contact us to do so via the DPO Contact. Where you opt-out of receiving these marketing communications, it does not mean that it will apply to Personal Data provided to us as a result of communications relating to previous, existing or pending Services from us or your prior consent to earlier direct communications. If you wish to remove your Personal Data from all communications from us, please contact us to do so via the DPO Contact.
    4. You may submit a complaint to us via the DPO Contact in relation to this Privacy or our practices in relation to your Personal Data. If you are in the EU or UK and feel that your complaint has not been adequately resolved, you have the right under the EU GDPR or the UK GDPR to contact your local data protection supervisory authority. (For example, in the UK the ICO can be contacted at Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. They can be contacted by telephone on UK Code + 0303 123 1113 or 01625 545 745)
  4. Types of Data that we collect
    1. Personal data that you provide directly to us. When you use our Services and/or this Site, your Personal Data may be collected by us through your voluntary submission (e.g. when you contact us or when you sign up for our activities such as events and newsletter via our homepage).

      “Personal Data” means data that may enable us to identify you personally, including data about a person who can be identified (i) from that data, or (ii) from that data and other information to which we have or are likely to have access.
      The type of Personal Data collected may vary based on how it was gathered, which may include:
      • “Identity Data” such as your name, marital status, title, date of birth and gender, picture, or partial identification numbers (e.g. partial NRIC or passport number);
      • “Registration & Event Data” such as your image, voice, likeness, photo, depiction, all of which can be taken in the context of registering for and attending an event (which we subsequently record, screenshot, extract images or promote or similar);
      • “Contact Data” such as your home/work/billing address, e-mail address and telephone number;
      • “Professional Background Data” such educational and professional history, accomplishment credentials, job and salary preferences, third party recommendations, professional resumes, information about co-workers, your interests in certain job openings, job applications, interviewing information, and hiring results;
      • “Financial Data” such as details of bank account, payment card and financial statements;
      • “Transaction Data” such as details about payments to and from you and other details of services you have subscribed from us;
      • “Marketing Data” such as your preferences in receiving marketing from us and our third parties and your communication preferences. If you correspond with us by email or messaging through the Services, we may retain the content of such messages and our responses;
      • “Online Presence Data” such as links to your public account pages at social media websites, other online materials related to you, and your social media handles (LinkedIn/ Facebook/ Twitter membership ID);
      • “Investment Data” such as information about your investment objectives, investment experience, prior investments (on or offline), syndicates or leads backed, backing amounts and preferences, investment amounts and information provided by completing subscription documents for deals closed via the Services. Also included is information about your personal investment entities and their co-owners and beneficiaries, and tax-related information in connection with your investments through the Services;
      • “Behavioral Data” such as inferred or assumed information relating to your behaviour and interests, based on your online activity. This is most often collated and grouped into "segments";
      • “Technical Data” such as Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this Site or use our Services;
      • “Usage Data” includes information about how you use our website when you click on certain articles or blog posts, or look into certain tools such as our Comet 1 to 1 meeting opportunities, or register for information about the Deep Tech Summit, or “get involved” via our contact page where you can ask about hosting an event, join our community or contribute an article;
      • “Content Data” such as content you post to the Services not already included in another category, including your profiles, questions, preference settings, answers, messages, comments, and other contributions on the Services, and metadata about them (such as when you posted them) (collectively, "Content").
    2. Personal data from third party sources. We may also collect certain of your Personal Data from third party sources, for example, from credit reporting agencies, processors such as official photographers hired for particular events, or social media sites where we are present and active such as Facebook where we have over 19,000 followers and Linkedin where we have over 30,000 connections, our affiliates, our fund administration partners, analytics providers, advertisers, data brokers, and identity verification and compliance service providers.
    3. Non-Identifiable or Aggregated Data. When you interact with us through this Site, we may receive and store certain personally non-identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. We may store such information itself or such information may be included in databases owned and maintained by our affiliates, agents or service providers. This Site may use such information and pool it with other information to track, for example, the total number of visitors to this Site, the number of visitors to each page of this Site, the domain names of our visitors' Internet service providers, and how our users use and interact with our Services. Also, in an ongoing effort to better understand and serve the users of our Services, we often conduct research on our customer demographics, interests and behaviour based on Personal Data and other information provided to us. This research may be compiled and analysed on an aggregate basis. We may share such non-identifiable and aggregate data with our affiliates, agents and business partners, but this type of non-identifiable and aggregate information does not identify you personally. We may also disclose aggregated user statistics in order to describe our Services to current and prospective business partners, and to other third parties for other lawful purposes. However, if we combine or connect such non-identifiable or aggregated data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy.
    4. No Special Categories of Personal Data. We do not collect any "Special Categories of Personal Data" about you. This includes details about your race or ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. Nor do we collect any information about criminal convictions and offences.
    5. NRIC / Passport number or NRIC / Passport copies. Generally, we do not collect, use or disclose NRIC or passport numbers (or copies of NRIC or passport) unless the collection, use or disclosure thereof (i) is required under the law, or (ii) is necessary to accurately establish or verify your identity to a high degree of fidelity in order to provide you with our Services. If we do collect, use or disclose your NRIC or passport number or NRIC or passport copy, we will notify you of the purpose(s) of such collection, use or disclosure unless your express consent is not required under the PDPA.
    6. Data Minimisation. We collect only relevant and minimal Personal Data limited to what is necessary in relation to the purposes for which they are collected and processed. In this regard, you agree to provide only true, accurate, current and complete information about yourself.
  5. Consent and Withdrawal
    1. By interacting with us using your Personal Data, registering for an event or voluntarily submitting your Personal Data to us when using this Site or our Services, you agree and consent to providing your Personal Data and to the other lawful bases and purposes for which your Personal Data will be handled as set forth in this Policy.
    2. If you are located in the EU or the UK, we will seek and rely on your consent as a legal basis for using your Personal Data where we have expressly sought it for specific purpose(s). You will be asked to provide clear and affirmative consent to the collection, processing and use of your Personal Data. If we do rely on your consent to a use of your Personal Data, you have the right to change your mind at any time (but this will not affect any processing that has already taken place).
    3. You may, by notice in writing to us, withdraw your consent to providing your Personal Data to us. We shall endeavour to cease processing your Personal Data, destroy or delete the information, or remove the means by which the data can be associated with you within thirty (30) days from the receipt of the said notice, unless its retention is required to satisfy legal, regulatory, accounting or other business requirements or to protect our interests.
    4. You may decline to provide us with your information. If you choose not to provide any Personal Data whenever required by us, this may limit your ability to use certain features of this Site or our Services, or we might not be able to adequately deliver our Services to you.
    5. To the extent where you attend our events which are open to the public, any photographs, videos or audio recordings taken, filmed or recorded during such events that may feature your image, likeness or voice are considered publicly available personal data which is exempted from consent requirement under the PDPA.
  6. How we use your Personal Data and the lawful basis
    1. Our primary objective in collecting and using your Personal Data is to provide, facilitate, personalise and/or improve our Services, including this Site, to you. Below are the more detailed examples of relevant purposes for which we may use your Personal Data:
      • Providing, updating, maintaining, enhancing and improving our Services, Site, business and client database, including to facilitate and fulfil our engagements or transactions with you, administering your participation in our events or activities and processing payment transactions, including transactions on behalf of our business partners such as in situations of joint events or joint marketing activities, or hosting of events through SGInnovate’s venues or services;
      • Conducting research and development, including to improve, enhance or develop new services or new methods or processes for business operations in relation to our Services, to perform market, demographic or trend analysis/survey for research and marketing purposes, for learning or understanding behaviour and preferences of individuals (including groups of individuals segmented by profile), and for data aggregation and analytics;
      • Communicating with users about our Services, including any testimonials or quotations from individuals (for example the testimonials relating to the Summation programme on the Talent section of our website), pen-pictures for our team, articles and blogs accessible on our site or via social media platforms, and to improve or personalise your online experience with us;
      • Providing customer support, including to contact you regarding any complaints, feedback, queries or requests;
      • Enhancing security, including to facilitate investigations into any suspicious or illegal activity on the Site or relating to the use of our Services;
      • Communicating with you for the purposes of marketing, promoting and driving engagement in respect of our Services, our present or future events or activities and third-party products and services which may be of interest to you based on your interactions with us;
      • Fulfilling any agreement we have with you, whether through our terms of use or terms which apply as agreed by you in connection with registration for a specific event e.g. you agree to receive marketing communications and out-reach in connection with future collaboration opportunities as part of your registration and participation or you agree to having your photograph, likeness, image or voice taken or recorded to be used in any broadcasts of our events and in subsequent productions drawn from photographs, videos or audio recordings of such events. This can extend to investment portfolios we have uploaded, collaboration opportunities, seminars/events whether hosted by SGInnovate, in partnership with SGInnovate or through SGInnovate’s services. Such communication may be in the form of postal mails, emails, text messages, social media channels, newsletters, brochures or other printed or digital communication;
      • Complying with applicable law, legal process and regulations and protecting legitimate business interests;
      • internal administrative and management purposes;
      • any purposes exempted under the applicable laws;
      • any other purposes reasonably related to the aforesaid which would include sharing a minimal amount of Personal Data in a responsible way to enhance our collaboration with partners at events. Our business partners would also have in place privacy policies or arrangements which would govern how they hold your Personal Data.
    2. We will only use your Personal Data when the law allows us to. We have set out below a visual depiction of all the ways we are allowed to process your Personal Data under the EU GDPR and UK GDPR, followed by a summary of the key “lawful bases” which are most appropriate for SGInnovate.

    3. The legal bases depend on the Services you use and how you use them. This means we collect and use your Personal Data only where:
      • we need it to provide you with the Services, including to operate the Services, fulfil our contractual obligations with you, provide customer support and personalised features and to protect the safety and security of the Services;
      • we need it to pursue our legitimate interests in a way that might reasonably be expected as part of running our business and that does not materially impact your rights, freedom or interests. We are a commercial enterprise which is bringing benefits, innovation, opportunities, partners and other support to startups and others in the Deep Tech ecosystem. We, therefore, believe the collation of core Personal Data is integral and necessary for our business to function and grow. We have considered alternate modes of operating -without our current use of Personal Data – and have weighed the balance of the impacts of our data processing on individuals. We take the view that there is minimal or no harm to the rights and freedoms of the persons, partners, startups, employees and others whose limited personal information we hold; or
      • we need to process your Personal Data to comply with a legal or regulatory obligation.
    4. If we intend to use, handle or process any Personal Data in any manner that is not consistent with this Policy or for new purposes, we will either send you a notification of change or publish a notification of change on this Site prior to the change becoming effective. You are deemed to have consented to such variation if we do not receive your notice of objection or opt-out within seven (7) days from the date of the said notice. If you are in the EU or the UK, we will notify you of such change through emails and you should respond accordingly to indicate whether or not you consent to such change.
  7. Use of Cookies and Similar Technologies
    1. Cookies

      In order to improve our products or services, we collect data by way of “cookies”. A cookie is a small text file containing small amounts of information which are automatically downloaded into your computer (or other electronic devices) when you access this Site. Cookies help us to measure the number of visits, average time spent, page views and other statistics relating to your access to this Site. This information allows us to better administer this Site, and provide a more tailored and user-friendly service to our users. Cookies also enable you to use or access certain features or services of this Site. Each time you visit this Site from the same computer or device, the cookie will be retrieved from your computer or device, enabling this Site to recognise your computer or device as having previously visited the Site and thereby increase the functionality of the Site on your computer or device. Therefore, generally, we use cookies on to:

      The information we obtain from our use of cookies will not usually contain your Personal Data. Although we may obtain information about your computer or other electronic devices such as your IP address, your browser and/or other internet log information, this will not usually identify you personally. In certain circumstances, we may collect personal information about you but only where you voluntarily provide it (e.g. by completing an online form) or where you subscribe to our Service through the Site. The information we obtain through the use of cookies may be combined with other Personal Data relating to you.

      In most cases, we will obtain your consent in order to use cookies on this Site. The exception is where the cookies are strictly necessary in order for us to operate this Site and/or to provide you with a service you have requested. Most web browsers and devices can be set to notify you when you receive a cookie or to prevent cookies from being sent. If you use these features, you may limit the functionality we can provide you when you visit this Site. You are free to block, delete, or disable the cookies if your device permits so. You can manage your cookies and your cookie preferences in your browser or device settings. If you have recently disabled one or more cookies, we will stop using the disabled cookies to collect any further information. However, we may still use information collected from such cookies prior to your selecting the ‘disable’ preference setting.

      Further information about cookies, including how to see what cookies have been set on your computer or device and how to manage and delete them, visit www.allaboutcookies.org and www.allaboutcookies.org.

      • recognise your browser as a previous visitor and save any preferences that may have been set during your last visit to this Site;
      • obtain information about your preferences, online movements and use of the Internet;
      • track website analytics and carry out research and statistical analysis to help improve our content, products and services and to help us better understand our visitors’ or customers’ requirements and interests;
      • customise and target our marketing and advertising campaigns and those of our partners more effectively by providing personalised interest-based advertisements;
      • measure and research the effectiveness of our interactive online content, features, advertisements, and other communications;
      • make your online experience more efficient and enjoyable.
    • Third-Party Cookies

      Third-party cookies are set by a third-party site separate from this Site. We work with third-party service providers who are authorised to place third-party cookies and may also set cookies on this Site. These third-party service providers are responsible for the cookies they set on this Site. If you want further information, please go to the website of the relevant third party. If you would like to opt-out of all other types of technologies we employ on this Site, you may do so by changing your browser settings to block, delete or disable these technologies as your browser or device permits.

      In light of recent changes to cookies practices in 2021 (with respect to the disablement of third party cookies on some browsers) we include below an updated list of the more popular browser types with hyperlinks showing how to adapt their cookie settings accordingly:

      • Google Chrome • Microsoft Edge • Mozilla Firefox • Microsoft Internet Explorer • Opera • Apple Safari
    1. Log Files

      Logfile information is automatically reported by your browser each time you access a web page. When you use this Site, our servers automatically record certain information your web browser sends whenever you visit any website. These server logs may include information such as your web request, Internet Protocol address, browser type, referring / exit pages and URLs, the number of clicks, domain names, landing pages, pages viewed, and other such information.

    2. Clear GIFs Information (Web Beacons)

      When you use this Site, we may employ clear GIFs (also known as web beacons or tracking pixels) to anonymously track online usage patterns. No personally identifiable information about you is collected using these clear GIFs. In addition, we may also use clear GIFs in HTML-based emails sent to our users to track which emails are opened by recipients. The information collected is used to enable more accurate reporting and make SGInnovate better for our users.

    3. Use of Social Media Plug-Ins

      Our website may include at least one plug-in from YouTube, which is owned by Google, Inc. and domiciled in San Bruno, California, USA. The moment you visit pages of our website that are equipped with a YouTube plug-in, a connection to the servers of YouTube is established. The YouTube server is thereby notified about which specific page of our website you visited. If, in addition, you are logged into your YouTube account, you would enable YouTube to associate your surfing behaviour directly with your personal profile. You can prevent this possibility of the association if you log out of your account in advance. You can obtain further information on the collection and use of your data by YouTube in the discussion of data privacy at www.youtube.com.

  8. How we share your information
    1. We are not in the business of selling your information. There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, such as with:
      • Our Affiliates and Third-Party Partners. Certain authorised affiliates (including related corporation within our group of companies) may access your Personal Data to help us develop, maintain, provide, enhance or improve our Services or new services, or develop, enhance or improve new methods or processes for business operations in relation to our Services, or help manage our customer relationships (including providing customer support, customer liaison, investment advisory services, etc). We may also share your Personal Data with our business partners whom we collaborate with in the organisation, management, hosting or promotion of events or activities in order to facilitate such events or activities, in which case these third parties are prohibited from using your Personal Data for any other purposes. But in instances where events or activities are jointly organised by SGInnovate and other business partners, such business partners will collect or receive your Personal Data whom will process and handle your Personal Data in accordance with their own privacy policies, including to use it for similar purposes mentioned in Clause 6.1 above, in which case you shall have the right to withdraw your consent by contacting the relevant business partners possessing your Personal Data.
      • Our Service Providers. Our service providers provide us support for our Services, including, for example, website and application development, hosting, data processing service, cloud service, maintenance, security, backup, storage, virtual infrastructure, payment processing, analysis, identity verification, background and compliance reviews, fund administration, banking services, and other services for us, which may require them to access or use Personal Data about you. These third parties are prohibited from using your Personal Data for any other purposes.
      • Our Professional Advisors. Our lawyers, accountants, bankers, auditors and insurers may need to review your Personal Data to provide consultancy, compliance, banking, legal, insurance, accounting and similar services. These third parties are prohibited from using your Personal Data for any other purposes.
      • Governmental Authorities or Agencies. We may disclose your Personal Data to governmental authorities or agencies if we believe it is reasonably necessary to comply with a law, regulation, order, subpoena, rule of a self-regulatory organisation or audit or to protect the safety of any person, to address fraud, security or technical issues, or to protect our legal rights, interests and the interests of others, such as, for example, in connection with the acquisition, merger or sale of securities or businesses (e.g. due diligence). We will not share your Personal Data with non-governmental entities, except where such entities have been duly authorised to carry out specific governmental activities.
      • Advertisers. Certain users of our Services may have access to your Personal Data for the purpose of enabling them to interact with you and more effectively offer opportunities through the Site that are targeted towards your background and preferences. We may also allow third-parties, including ad servers or ad networks, to serve advertisements on the Site, and such third parties may be provided with access to your Personal Data to provide advertising tailored to your interests.
      • Other Platforms. There are a number of other platforms and tools where we have accounts and profile. We use these to promote SGInnovate, reach out to our target audience, partners and community. We share and link posts on those sites, and certain personal profiles can be accessed and viewed on these. Among the more active platforms we share with are Linkedin.com, Facebook.com and Twitter.com.
      • Researchers. To enhance the public understanding of patterns and trends in the markets served by our Services, we may provide Personal Data to third parties under confidentiality obligations such as, for example, academics or contractors for research purposes. These third parties are prohibited from using your Personal Data for any other purposes.
    2. As we develop our business, and subject to the longer term intentions of our government shareholders, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganisation, dissolution or similar event, Personal Data may be part of the transferred assets.
    3. We may also share non-Personal Data (such as anonymous usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with interested third parties to help them understand the usage patterns for certain Services or conduct independent research based on such anonymous usage data.
    4. If you request that we remove your Personal Data in exercise of your rights, we will convey that request to any third-party with whom we have shared your data. We are not, however, responsible for revising or removing your Personal Data obtained by any third party who has previously been provided with your information by us in accordance with this Policy or any third party to whom you have provided such information (whether by sharing your login and password, or otherwise). For any articles, videos, blogs or similar which we have shared or promoted on linkedin.com or twitter.com, we recommend you contact those platform hosts directly in the event we are for whatever reason unable to delete or remove content which contains Personal Data.
    5. Recipients of your Personal Data may be located outside Singapore. You agree that we may transfer your Personal Data to our affiliates, subsidiaries and/or other authorised third parties (such as service providers e.g. cloud service providers, data processor, etc) located outside of Singapore, as long as the Personal Data is handled in accordance with this Policy and all applicable laws. We will ensure recipients of your Personal Data are legally bound to provide a standard of protection for your personal data comparable to the protection afforded under the PDPA and/or the data protection laws of the relevant jurisdiction.
    6. Where you are based in the EU or UK, it is likely that your Personal Data will be held and processed only in Singapore (rather than in any location or server in those overseas territories). We shall continue to be vigilant and monitor the development of EU and UK “standard contractual clauses” as a means of transferring data outside of the EU and UK (from the EU or UK) if and when this becomes relevant to us.
  9. Period of retention

    Personal Data provided by you will be retained and stored as long as the purpose for which the data was required continues, unless you request that we remove your Personal Data in exercise of your rights. Thereafter, we will destroy or delete the information, or remove the means by which the data can be associated with you, unless its retention is required to satisfy legal, regulatory, accounting or other business requirements or to protect our interests. We will however periodically review the data we hold, and erase or anonymise it when we no longer need it.

  10. Information About Others

    If you give us information on behalf of someone else, you warrant that you have obtained the authorisation from that person to provide such Personal Data on his/her behalf and that other person has agreed that you can act on his or her behalf and (i) give consent on his or her behalf to the processing of his or her Personal Data in accordance with this Policy; (ii) receive on his or her behalf any data protection notices; and (iii) give consent to the use and transfer of his or her Personal Data abroad in accordance with this Policy. You agree to indemnify and hold harmless SGInnovate from any claim that such authority did not exist.

  11. Security
    1. We use industry-standard physical, managerial, and technical safeguards to preserve the integrity and security of your information from loss, misuse, and unauthorised access or collection, disclosure, alteration, or destruction. We limit access to your Personal Data to those employees and other staff who have a business need to have such access. All such people are subject to a contractual duty of confidentiality. We cannot, however, ensure or warrant the security of any information you transmit to us or guarantee that your information through our Services may not be accessed, disclosed, altered, or destroyed by a breach of any of our physical, managerial, or technical safeguards.
    2. In addition, we have in place the following additional measures with respect to Personal Data of individuals in the EU or UK:
      • we will conduct data protection impact assessments from time to time, when required by either EU GDPR or UK GDPR;
      • a documented type of information we receive, collect, its source, the lawful basis for having it (e.g. consent) and who we share it with;
      • a data breach response protocol which visually sets out a user-friendly and tailored escalation process which applies to SGInnovate. It works so that we are fully prepared with the right tools and skill sets so that all staff will know what to do in the unfortunate event of a data breach or cyber hack which affects our organisation; and
      • other appropriate technical and organisational measures (relating to IT and systems security at SGInnovate) to implement the data protection principles and safeguard individual rights.
    3. While we will use all reasonable efforts to safeguard Personal Data, you acknowledge that the use of the Internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any Personal Data that are transferred from you or to you via the Internet.
  12. Monitoring and Checking
    1. We may monitor and record communications with you (such as telephone conversations and emails) for the purpose of quality assurance, training, fraud prevention and compliance.
    2. For the prevention of fraud and money laundering, we may search the files of credit reference from fraud prevention agencies (who will record the search). If you provide false or inaccurate information and we suspect fraud, we may disclose information about how you conduct the Site to such agencies and if the situation warrants it, we may have to report to law enforcement authorities.
    3. We may preserve the content of any email or "Contact Us" or other electronic message that we receive. Any Personal Data contained in those messages will only be used or disclosed in ways set out in this Policy. The message content may be monitored by our service providers or employees for purposes including but not limited to compliance, auditing and maintenance or where email abuse is suspected.
  13. Exclusions

    This Policy applies to all users of our Services and this Site only. While you may encounter links on the Site to other websites, such as those relating to our third party partners, advertisers and other parties whom we collaborate with (“Third Party Platforms”). This Policy does not apply to the activities of such Third Party Platforms that may collect your Personal Data while accessing or using such third party’s services in connection with your use of this Site. The privacy practices of those third parties are not covered by this Policy. The links from this Site do not imply that we endorse or have reviewed the Third Party Platforms. We suggest you contact those platforms directly for information on their privacy policies.

  14. Privacy of Children

    If you are an individual in the EU who is less than 16 years old, please do not send us any information or your Personal Data. We do not knowingly collect nor do we wish to collect and personally identifiable information or other user information from children under the age of 16. In the event that we learn we have collected any personal information from a child under the age of 16, we will delete the information from our database and terminate the corresponding account, if any.

  15. Governing Law and Dispute Resolution

    Irrespective of the country from which you access or use this Site or our Services, to the extent permitted by law, this Policy shall be governed in accordance with the laws of Singapore without regard to choice or conflicts of law principles, and you hereby agree to submit to the exclusive jurisdiction of the courts of Singapore to resolve any claims or disputes which may arise in connection with this Policy. Any disputes or claims concerning breach or inadequacy of Personal Data protection raised by an individual located in the EU or UK will be dealt with in accordance with the EU GDPR or UK GDPR as appropriate.