WHAT PERSONAL DATA WE COLLECT AND WHY WE COLLECT IT

DATA PROTECTION POLICY FOR CUSTOMERS

This Data Protection Policy (“Policy”) sets out the basis which MARGIN WHEELER PTE. LTD. and/or its related corporations (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of our customers under the Personal Data Protection Act (“PDPA”). This Policy applies to personal data in our possession or under our control, including personal data in the possession of organizations that we have engaged to collect, use, disclose or process personal data for our purposes.

PERSONAL DATA 

1. As used in this Policy:

“customer” means an individual who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us; and

“personal data” means data, whether true or not, about a customer 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. The personal data which we may collect from you include:
3. Your personal information such as your name, NRIC/FIN/Passport Number, date of birth, nationality, gender
4. Your contact information such as a residential address, email address, and contact number

3. Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context so permits).

COLLECTION, USE, AND DISCLOSURE OF PERSONAL DATA

4. We generally do not collect your data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorized by you to disclose your data to us (your “authorized representative”) after (i) you (or your authorized representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorized representative) have provided written consent to the collection and usage of your data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your data for a purpose that has not been notified to you (except where permitted or authorized by law).

5. If you provide us with any Personal Data relating to a third party (eg. information of your spouse, children, parents, and/or employees), by submitting such information to us, you represent and warrant to us that you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes.

6. We may collect and use your data for any or all of the following purposes:

• submit documents with government agencies for the formation of a new corporation or business entity;
• 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;
• respond to queries and feedback, and provide customer service and support;
• to provide you with services or assistance that you have requested;
• notify you about products, services, or special offers;
• for sending out the Annual filing reminder;
• process contract renewals and upgrades; and
• managing your relationship with us

We may for these purposes, contact you via mail, email, telephone, SMS, or other communication means.

7. We may disclose your data:

• the various departments within the organization;
• any of our collaborative partners, agents, contractors or third-party service providers that process or will be processing your data on our behalf including but not limited to those which provide administrative or other services to us such as courier services, telecommunication companies, information technology companies, and data centers;
• our professional advisors such as consultants, auditors, and lawyers;
• in the event of default or disputes, any debt collection agencies or dispute resolution centers (whether in Singapore or otherwise);

8. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, under your employment contract should you be hired) 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 a contract with you).

WITHDRAWING YOUR CONSENT

9. The consent that you provide for the collection, use, and disclosure of your 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 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.

10. Upon receipt of your written request to withdraw your consent, we may require a 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 thirty (30) days of receiving it.

11. 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 goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 8 above.

12. Please note that withdrawing consent does not affect our right to continue to collect, use, and disclose personal data where such collection, use, and disclosure without consent is permitted or required under applicable laws.

ACCESS TO AND CORRECTION OF PERSONAL DATA

13. If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about how we use or disclose your data, or (b) a correction request to correct or update any of your data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.

14. We will need enough information from you to ascertain your identity as well as the nature of your request, to be able to deal with your request. 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.

15. We will respond to your request as soon as reasonably possible. In general, our response will be within thirty (30) days. Should we not be able to respond to your request within the above time frame, we will inform you of the reasonably soonest time in which we will respond. 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 the PDPA).

PROTECTION OF PERSONAL DATA

16. To safeguard your data from unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, and disclosing personal data both internally and to our authorized third-party service providers and agents only on a need-to-know basis.

17. 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.

ACCURACY OF PERSONAL DATA

18. We generally rely on personal data provided by you (or your authorized representative). To ensure that your data is current, complete, and accurate, please update us if there are changes to your data by informing our Data Protection Officer in writing or via email at the contact details provided below.

RETENTION OF PERSONAL DATA

19. We may retain your data for as long as it is necessary to fulfill the purpose for which it was collected, or as required or permitted by applicable laws.

20. We will cease to retain your data or remove how 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.

TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE

21. We generally do not transfer your data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.

LINKS TO OTHER SITES

22. Our website may contain links to other websites that are not operated by us. If you click on a third party link, you will be directed to that third party's website. You must review the Privacy Policy of every site you visit. We have no control over and are unable to assume any responsibility for, the content, privacy policies, or practices of any third party sites or services.

DATA PROTECTION OFFICER

23. You may contact our Data Protection Officer if you have any enquiries or feedback on our data protection policies and procedures, or if you wish to make any request, in the following manner:

Contact No.      : 62720820

Email Address : [email protected]

EFFECT OF POLICY AND CHANGES TO POLICY

24. This Policy applies in conjunction with any other Policy’s, contractual clauses, and consent clauses that apply to the collection, use, and disclosure of your data by us.

25. We may revise this Policy from time to time without any prior Policy. 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 acknowledgment and acceptance of such changes.

Last updated:           07/02/2023