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Copyright © 2022 Thesis Pte. Ltd. All Rights Reserved

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34 Boon Leat Terrace #04-09A Singapore 119866

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Copyright © 2022 Thesis Pte. Ltd. All Rights Reserved

DATA PROTECTION POLICY

This Data Protection Policy (“Policy”) sets out the basis which Thesis Pte Ltd (“Thesis” or “we”) may collect, use, disclose or otherwise processes personal data of, without limitation, our customers, and/or contractors and comply with the requirements of the Personal Data Protection Act 2012 of Singapore and its regulations (“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.

PERSONAL DATA

  1. In this Policy, “personal data” shall mean data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access.
  2. Other terms used in this Policy shall have the meanings ascribed to them in the PDPA where to context so permits.

COLLECTION AND USE OF PERSONAL DATA

  1. Under the PDPA, personal data is defined as data, whether true or not, about an individual who can be identified from that data; or from that data and other information to which the organisation has or is likely to have access.
  2. We collect personal data from clients, customers, business contacts, partners, personnel, contractors and other individuals. Such personal data may be provided to us in forms filled out by individuals, personally or on behalf of an entity, face to face meetings, email messages, telephone conversations, through our website or by third parties.
  3. The kind of personal data collected will depend on the circumstances. Typically, it may include but not be limited to the following:
    • Name, address, title
    • Telephone number
    • Email address
    • Records of communication with Thesis
    • Responses to market surveys
    • Website usage information
    • Video/camera footage that identifies individuals (including CCTV footage);
    • NRIC number/Passport details
    • Bank account information
    • Employment information
  4. We generally do not collect your personal data unless:
    1. 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 (“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
    2. collection and use of personal data without consent is permitted or required by the PDPA or other applicable laws and regulations.
    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 the law).
  5. We collect and use your personal data for any or all of the following purposes:
    1. performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
    2. verifying your identity;
    3. responding to, handling, and processing queries, requests, applications, complaints, and feedback from you for purposes for which it was provided to us as stated at the time of collection (or as is obvious from the context of collection);
    4. managing your relationship with us;
    5. for general management and reporting purposes, including processing payment or credit transactions;
    6. to keep you informed of the services we offer, industry developments, service offerings, and other events we will hold or are holding that may be of interest to you;
    7. 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;
    8. any other purposes for which you have provided the information;
    9. transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes;
    10. recruitment;
    11. for purposes related to the employment of our personnel and providing internal services to our personnel;
    12. any other purposes for which you have provided the information; and
    13. any other purposes related to our business.
  6. Any individual may choose to unsubscribe from mailing lists, registrations or elect not to receive further marketing information from us by contacting us, or if we have contacted such individual by email, such individual may use the unsubscribe function in that email to notify us.

DISCLOSURE OF PERSONAL DATA

    1. We do not disclose personal data to third parties unless:
      1. such disclosure is required by law; or
      2. we have the individual’s consent or deemed consent.

Effective date: 21 Oct 2019
Last updated: 21 Oct 2019

  1. We may disclose your personal data:
    1. where such disclosure is required for performing obligations in the course of or in connection with our provision of our services as requested by you; or
    2. to third party service providers, agents and other organisations we have engaged to assist with Thesis’ business activities. Any such third parties whom we engage will be bound contractually to keep all information confidential; or
    3. where the individual has consented; or
    4. purposes that a reasonable person will consider appropriate in view of the circumstances of
      the matter.

WITHDRAWING YOUR CONSENT

  1. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.
  2. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within fourteen (14) business days of receiving it.
  3. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our services to you and we shall, in such circumstances, notify you before completing the processing of your request.
  4. Please do note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

ACCESS TO AND CORRECTION OF PERSONAL DATA

    1. You may wish to:
      1. make an access request to access your personal data which we hold about you or information about the ways in which we use or disclose your personal data in accordance with the requirements of the PDPA; or
      2. make a correction request to correct or update any of your personal data that is in our possession or control in accordance with the requirements of the PDPA.

      In such an event, you may submit your request in writing or via e-mail to our Data Protection Officer at the contact details provided below.


Effective date: 21 Oct 2019
Last updated: 21 Oct 2019

  1. Please note that a reasonable fee may be charged for an access request in accordance with the requirements of the PDPA. In such an event, we will inform you of the fee before processing your request.

SECURITY AND PROTECTION OF PERSONAL DATA

  1. We have introduced generally accepted standards of administrative, physical and technical measures to secure all storage and transmission of personal data by us to safeguard your personal data from unauthorised access.
  2. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
  3. Any data that is destroyed will be disposed in manner that protects the privacy of the personal data.

ACCURACY OF PERSONAL DATA

  1. We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are any changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.
  2. Thesis will comply with the request to correct your personal data as soon as practicable.
  3. If we disagree with your request to correct their personal data on reasonable grounds, we shall annotate on our records the correction that was requested but not made.

RETENTION OF PERSONAL DATA

  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.
  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.

TRANSFER OF PERSONAL DATA OUTSIDE OF SINGAPORE

  1. We generally do not transfer your personal data to countries outside of Singapore. However, in an event where we do so, we will obtain your consent for the transfer to be made and we will ensure that any transfers of personal data will be in accordance with the PDPA so as to ensure a standard of protection that is comparable to the protection under the PDPA.

PRIVACY ON OUR WEBSITE

    1. This Policy also applies to any personal data we collect via our website. Cookies may be used on our website to improve your navigational experience whilst using our website. A visitor to our website may refuse a cookie and still navigate our website, however functionality may be slightly impaired. After termination of the visit to our site, the cookie can be deleted from your system if you wish.


Effective date: 21 Oct 2019
Last updated: 21 Oct 2019

  1. Thesis’ website may contain links to other websites. Thesis is not responsible for the data protection/privacy practices of the said other websites. We encourage you to read and understand the privacy policies of the other websites you link to from These Pte Ltd’s website.

DATA PROTECTION OFFICER

  1. If you believe that information we hold about you is incorrect or out of date, or if you have concerns or further queries about how we are handling your personal data, or if you have any problem or complaint about such matters, please contact our Data Protection Officer:

    Email: contact@onethesis.com
    Attn: Data Protection Officer
    Address: 34 Boon Leat Terrace #04-09A Singapore 119866

EFFECT OF POLICY

  1. This Policy 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.

CHANGES TO POLICY

  1. We reserve the right to modify or amend this Policy 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 Policy was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.