POLICIES & PRACTICES

Introduction

1. This Personal Data Protection Notice (“Notice”) sets out the basis which Akribis Systems Pte. Ltd. and our subsidiaries (collectively “we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of our customers, suppliers and other persons with whom we have entered or may enter into a business relationship or transaction (collectively “business partners”).
2. This Notice 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.

Employee and Personal Data

1. As used in this Notice:
   1. “employee” means any person engaged in a contract of service with us (whether on a part-time, temporary or full-time basis) and interns and trainees working at or attached to us (collectively referred to as “employees”), and all references to “employment” shall apply equally to internships and traineeships; and
   2. “personal data” means data, whether true or not, about a employee who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.
2. Some examples of personal data which we may collect from you include your name, telephone number and email address, residential address, nationality, gender, NRIC / FIN or passport number, date of birth, educational qualifications, professional qualifications & certifications, memberships in professional associations, employment history, salary information and bank account details, performance assessments and disciplinary records, records on leave of absence from work, names and contact details of your next-of-kin, audio-visual images through recordings taken via security cameras at our business premises and/or taken during our company functions and events, and any additional information provided to us by you as a job applicant (that is, prior to you being engaged by us as an employee).

Collection, Use and Disclosure of Personal Data

1. We generally collect your personal data that:

   1. you knowingly and voluntarily provide in the course of or in connection with your employment with us, or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”, which may include your job placement agent), 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 applicable laws.

   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 law).

2. Your personal data will be collected and used by us for the following purposes and we may disclose your personal data to third parties where necessary for the following purposes:

   1. all administrative and human resources related matters within our organisation, including administering payroll, granting access to our premises and computer systems, processing leave applications, administering your insurance and other benefits, processing your claims and expenses, investigating any defaults and developing human resource policies;
   2. verifying your identity and the accuracy of your personal details and other information provided;
   3. managing and terminating our employment relationship with you, including monitoring your internet access and your use of our intranet to investigate potential contraventions of our internal or external compliance regulations, and resolving any employment related grievances;
   4. assessing and evaluating your suitability for employment / appointment or continued employment / appointment in any position within our organisation;
   5. ensuring business continuity for our organisation in the event that your employment with us is or will be terminated;
   6. performing obligations under or in connection with the provision of our goods or services to our customers or clients;
   7. facilitating any proposed or confirmed merger, acquisition or business asset transaction involving any part of our organisation, or corporate restructuring process;
   8. 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 and/or recognised stock exchange;
   9. any other purposes for which you have provided the information;
   10. transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, for the aforementioned purposes; and
   11. any other incidental business purposes related to or in connection with the above.
3. 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 the goods and services requested by you; or
   2. to third party service providers, agents and other organisations we have engaged to perform any of the functions with reference to the abovementioned purposes.
4. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to your employment contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under your employment contract).

Cookies

1. We may use “cookies” on our websites, where a small data file is sent to your browser to store and track information about you when you enter our websites. The cookie is used to track information such as the number of users and their frequency of use, profiles of users and their preferred sites. While this cookie can tell us when you enter our sites and which pages you visit, it cannot read data off your hard disk.
2. You can choose 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. This may prevent you from taking full advantage of the website.

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 collecting, 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 the processing of your job application with us) 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 ten (10) business days of receiving it.
3. Whilst we respect your decision to withdraw your consent, please note thatdepending on the nature and extent of your request, we may not be in a position to process your job application. We shall, in such circumstances, notify you before completing the processing of your request (as outlined above). Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in Paragraph 11 below.

Access, Correction, Removal or Portability of Personal Data

1. You can, by submitting a request in writing or via email to our Data Protection Officer at the contact details provided below, request that we:

   1. Access
      Provide you with copies of your personal data;
   2. Correction
      Correct any personal data about yourself that you believe is inaccurate;
   3. Removal
      Erase your personal data held by us;
   4. Portability
      Transfer the data that we have collected to another organization, or directly to you.

2. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.

3. We will respond to your request as soon as reasonably possible. In general, our response will be within thirty (30) business days. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under applicable laws).
4. Please note that depending on the request that is being made, we will only need to provide you with access to the personal data contained in the documents requested, and not to the entire documents themselves. In those cases, it may be appropriate for us to simply provide you with confirmation of the personal data that our organisation has on record, if the record of your personal data forms a negligible part of the document.

Protection of Personal Data

1. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as minimised collection of personal data and authentication and access controls.

Accuracy of Personal Data

1. We generally rely on the accuracy of the 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 changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.

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 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.

Transfers of Personal Data

1. As a global organisation, data we collect may be transferred throughout the Akribis worldwide organisation.  Your personal data may be transferred to the Akribis group and associated companies.  We transfer your data for administrative purposes and so that we can have a complete overview of your contacts and transactions with the Akribis group. We may also transfer your personal data in order to offer you a complete package of products and services.
2. We may also transfer your personal data to third parties (including banks, insurance companies, accountants and consultants) for their provision of products or services to us. When third parties are given access to your personal data, Akribis will take the required contractual, technical and organisational measures to ensure that your personal data are only processed to the extent that such processing is necessary and in accordance with applicable law.
3. If your personal data is transferred, we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under applicable law.

Data Protection Officer

1. You may contact our Data Protection Officer if you have any enquiries or feedback on this Notice, or if you wish to make any request relating to your personal data, in the following manner:

Effect of Notice and Changes to Notice

1. This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
2. We may revise this Notice 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 Notice was last updated. Your continued purchase of our goods, use of our services and/or entering into of business transactions or discussions with us constitutes your acknowledgement and acceptance of such changes.