TinkTank Privacy and Data Protection Policy
This policy applies to TinkTank and its associated/affiliated businesses, and outlines our obligations and practices in the handling of the Personal Data we collect and hold about our customers, prospects, vendors, suppliers, partners, and all others who come into contact with us and our related companies, across all touch points of our business operations, including those seeking employment with us.
In this Policy, when we use “we”, “us” or “our”, we refer to the company (within the TinkTank Group) which is collecting your personal data, or which is operating the website which you are accessing or using.
This Policy applies to all personal data that you may provide to us and the personal data we hold about you. By providing us with your personal data or by accessing, using or viewing the applicable website or any of its services, functions or contents (including transmitting, caching or storing of any such personal data), you shall be deemed to have agreed to each and all the terms, conditions, and notices in this Policy. If you do not agree, please cease use of the relevant website(s) and/or service(s) and DO NOT provide any personal data to us.
Purpose of Collection
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, face to face meetings, email messages, telephone conversations, through our websites or provided by third parties. If any individuals contact us, we may keep a record of that contact.
These purposes include, but are not limited to:
- Responding to your enquiries regarding training courses, and any other services we offer
- Receiving feedback
- Processing requests, orders and administering accounts
- Providing customer support including account servicing (class confirmation, reminders, postponements, cancellations etc.)
- Communication with you in relation to products and services we provide which are relevant to your existing relationship with us
- Offering you updated marketing and promotional packages you can benefit from, including products and services offered by our selected partners
- Course & product updates and upgrades
- Research and surveys
- Meeting regulatory and legal obligations
- Applications for employment
We may for these purposes, contact you via mail (including electronic mail), telephone, SMS or other communication (text or image) applications via mobile devices, and facsimile.
Collection of Personal Data
Where possible, we will collect your Personal Data directly from you and secure the relevant consent from you. This may take place in a number of ways, such as when you visit us at our Training Centres, Events etc., give us a written order or ask us to provide a product or service over the telephone or internet.
Disclosure of Personal Data
We do not disclose personal data to third parties except when required by law, when we have the individual’s consent or deemed consent or in cases where we have engaged third parties such as data intermediaries or subcontractors specifically to assist with our activities. Any such third parties whom we engage will be bound contractually to keep all information confidential.
From time to time, we may contact you via mail, electronic-mail, telephone (call or SMS-Text) or facsimile, to inform about our products and services, or about special offers and promotions that we think may be of interest to you. You can let us know at any time if you no longer wish to receive marketing material (by contacting us at the details below) and we will remove your details from our direct marketing database.
We will not disclose your Personal Data to external organisations outside TinkTank for the purposes of allowing them to directly market their products and services unless expressly authorised by you.
Withdrawal of Consent
Upon reasonable notice being given by an individual of his withdrawal of any consent given or deemed to have been given in respect of our collection, use or disclosure of his or her personal data, we will inform the individual of the likely consequences of withdrawing his consent. We will cease (and cause any of our data intermediaries and agents to cease) collecting, using or disclosing the personal data unless it is required or authorised under applicable laws.
Accuracy of Personal Data
We will make a reasonable effort to ensure that personal data collected by us or on our behalf is accurate and complete.
Access to Personal Data by Individuals
You can access most of the Personal Data we hold about you by contacting us formally through the contact details indicated below. We will require a formal written request from you to our Data Protection Officer (details below).
An administrative fee will be charged to you to cover the reasonable cost of retrieving the information and supplying it to you.
Access to Personal Data may be refused in a number of circumstances, such as where the Personal Data relates to anticipated legal proceedings or the request for access is frivolous or vexatious. If we deny or restrict your access, we will explain why as required by applicable laws.
We have implemented generally accepted standards of technology and operational security to protect the personal data in our possession or under our control and to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks.
Retention of Personal Data
We will cease to retain personal data, as soon as it is reasonable to assume that the purpose for collection of such personal data is no longer being served by such retention, and such retention is no longer necessary for legal or business purposes.
Transfer of Personal Data outside of Singapore
We will ensure that any transfers of personal data to a territory outside of Singapore will be in accordance with the PDPA so as to ensure a standard of protection to personal data so transferred that is comparable to the protection under the PDPA.
Privacy on Our Websites
This Policy also applies to any personal data we collect via our websites. Cookies may be used on some pages of our websites. “Cookies” are small text files placed on your hard drive that assist us in providing a more customised website experience. Cookies are now used as a standard by many websites to improve users’ navigational experience. If individuals are concerned about cookies, most browsers permit individuals to decline cookies. In most cases, a visitor may refuse a cookie and still fully navigate our websites, however other functionality in the site may be impaired. After termination of the visit to our site, a visitor can always delete the cookie from his system if he wishes.
If you send us an email:
If you send us an email containing your Personal Data, we will take reasonable steps to ensure the confidentiality of that information. The content of emails is sometimes monitored by our internet host for maintenance and fault detection purposes. We may also monitor email for legal compliance purposes.
Although we take steps to protect Personal data and information sent by e-mail, e-mail is not a secure method of communication and if you are concerned about sending your Personal Data to us in this manner you may prefer to contact us by any of the other means set out below.
If you believe that the privacy of your Personal Data has been compromised, please contact us and we will take the relevant steps to address your concerns.
Your Use of Other’s Information
You agree to respect to other users’ personal information that you obtain through the Site or through any of our Site-related communication or transaction.
In addition, under no circumstances will you disclose personal information about another user to any third party without our consent and the consent of such other user after adequate disclosure. Please note that law enforcement personnel and other rights holders are given different rights with respect to information they access.
We and our users do not tolerate spam.
TinkTank Talent Associates Pte. Ltd.
1 Scotts Road
#24-10 Shaw Centre