Section I Introduction
- You have been directed to the Policy because you are or may be providing personal data or other information as described below about yourself, other individuals or organisations (collectively, Information) to AQLA.
- In the Policy, “we”, “us” or “our” refers to AQLA. The Policy applies to all Information that you may provide to us. By providing us with any Information, you shall be deemed to have agreed to the terms in the Policy.
- AQLA recognises its obligations under the Personal Data Protection Act 2012 (No. 26 of 2012) (PDPA) which includes the collection, use and disclosure of personal data.
Section II What personal data or information is collected
- In your interaction with us, you may be providing us with personal data, for example, your name, gender, occupation, address, birthdate, email address, telephone number and any other information which can identify you or some other person or other information through conflict and due diligence searches and checks or otherwise.
- There is also information about your computer hardware and software that could be automatically collected by us. This information may include: your IP address, browser type, domain names, access times and referring Web site addresses.
- AQLA is not responsible for the privacy statements or other content on websites outside of AQLA.
Section III How is the collected personal data or information used
- We use the Information provided to us for the purposes of providing services arising out of or in connection with our scope of engagement. This includes, where applicable:
- providing you with the services;
- performing legal, directorship, corporate secretarial and registered office address activities or transactions, preparing and filings of related documents;
- administrative or billing purposes;
- resolving any requests, queries, complaints or disputes.
- We may also use the Information for purposes arising out of or in connection with our business, for example:
- complying with legal, regulatory or professional obligations, requirements and guidelines (collectively, Rules), including but not limited to conducting conflict and due diligence searches and checks, maintenance and updates of records or documents, formulating policies, procedures and controls;
- performing the Rules, or enforcing payment or other obligations owed to us;
- administration, finance, accounting, risk management, compliance, audit, inspection and record keeping purposes;
- carrying out research, planning, surveys and statistical analysis;
- providing you with updates on the law and news, for example, through newsletters and bulletins;
- marketing our services to you;
- personnel training.
- AQLA has a network of trusted external business and professional associates in different countries (collectively, network associates). In relation to any request for network associates’ services or their delivery of services or service proposals to you, you agree that we may disclose or share Information you provide to us or that you may disclose or share Information to them, such that we/they may collect, use or disclose the Information for the purpose of our and/or their providing services to you and for the purposes set out in the Policy.
- If we need to use Information for any other purposes, we will notify you and obtain your written consent beforehand. You will be given the opportunity to withhold or withdraw your consent for the collection, use or disclosure of Information for these other purposes.
Section IV Disclosure of Information
- We may disclose or share Information with third parties (who provide services to us), such as:
- service providers, legal or corporate secretarial associates or staff and data processors working on our behalf and providing services such as commercial investigative work, hosting and maintenance services, analysis services, e-mail messaging services, delivery and courier services, handling of payment transactions, conflict and due diligence searches and checks, etc;
- our consultants and professional advisers (for example, accountants, auditors and IT).
- You agree that we may transfer Information to any location outside of Singapore for the purposes set out in the Policy. If we do so, we will ensure that Information is protected to a standard comparable to the protection accorded to personal data under the PDPA.
- AQLA will collect, use or disclose Information to third parties without notice:
- in the manner of the practices and situations described in the Policy;
- if or when required or permitted to do so by law; or
- in the good faith belief that such action is necessary or reasonable to:
- conform to the Rules; or
- comply with legal process served on AQLA; or
- protect or defend the reputation, rights, interest or property of AQLA or its partners, shareholders, personnel or users.
- Due to the Rules, we are required to collect, use and/or disclose Information to enable us to commence, provide or continue to provide our services and/or fulfil our scope of engagement. If you do not provide Information, or if you do not accept the Policy, or if you refuse or withdraw your consent from us to collect, use or disclose Information, please give us reasonable written notice of at least ten (10) business days before effecting such decisions and the reasons for those decisions. This may be done at any time and as long as there are no legal or operational restrictions or realities deterring you from doing so or deterring us from effecting the consequences of your decisions. It is important to note that in these events, we may be unable to collect, use, or disclose relevant or completed Information. As a result, it may not be possible for us to commence, serve or continue to serve you or fulfil our scope of engagement, and you may no longer be able to rely on AQLA or its initiatives for support or services.
Section V Access and correction rights
- If you have provided Information to us, you may request, by giving us reasonable written notice of at least ten (10) business days, for access to Information that you provided or for how such Information is being collected, used or disclosed for the last 12 months to the extent your right is allowed by law. You also have the right to request correction to your personal data. In order to facilitate your request, you may be charged an administrative fee.
- AQLA website may use “cookies” to help you personalise your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.
- One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you personalise AQLA pages, or register with AQLA site or services, a cookie helps AQLA to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to the same AQLA website, the information you previously provided can be retrieved, so you can easily use AQLA features that you customised.
- You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the AQLA services or websites you visit.
Section VII Security
- We endeavour to take precautions to ensure that the information you have provided is protected against unauthorised or unintended use, access or disclosure. However, we cannot be held responsible for unauthorised or unintended use, access or disclosure that is beyond our reasonable control.
Section VIII Disclaimer
- TO THE MAXIMUM EXTENT PERMITTED BY LAW, WE SHALL NOT BE LIABLE IN ANY EVENT FOR ANY SPECIAL, EXEMPLARY, PUNITIVE, INDIRECT, INCIDENTAL OR CONSEQUENTIAL DAMAGES OF ANY KIND OR FOR ANY LOSS OF REPUTATION OR GOODWILL, WHETHER BASED IN CONTRACT, TORT (INCLUDING NEGLIGENCE), EQUITY, STRICT LIABILITY, STATUTE OR OTHERWISE, SUFFERED AS A RESULT OF UNAUTHORISED OR UNINTENDED COLLECTION, USE, ACCESS OR DISCLOSURE OF INFORMATION.
Section IX Changes to the Policy
- We may amend the Policy from time to time and the amended Policy will be published on this website to reflect changing Rules or circumstances and other feedback. Your engagement of or continued interaction with us will also be an acknowledgement of your acceptance of the Policy or the amended Policy, which will apply to all Information previously or at any time provided to us.
Section X Contacting us
- If you wish to act in accordance with paragraph 15 above, or have access to or update Information, or comment on the Policy, please contact us as follows:
Attention to: Data Protection Officer
- In order to process your communication, please ensure that you provide the following information:
- Full Name
- AQLA File Reference Number
- Identify yourself
- Identify your relationship with AQLA
- Details of the nature of your request, query, complaint or dispute
- Reasons for:
- the communication; and
- any decision or action you take or going to take
- Contact Address
- Contact Phone Number
- Email Address
- We will endeavour to respond within thirty (30) days or earlier after the receipt of your communication, and if that is not possible, we will inform you of the time by which we will respond to you.
- We may be prevented by law or the Rules from complying with any request that you may make. We may also decline any request that you may make if the law or the Rules permit us to do so.
Section XI Governing Law
- The Policy or the amended Policy will be governed by and construed in accordance with the laws of Singapore. AQLA and you will submit to the exclusive jurisdiction of Singapore and its courts.