1. ABOUT THIS POLICY
1.2.1 access or use our websites includingtrustana.com and wholesale.trustana.com (collectively, our “Websites”) and services;
1.2.2 and/or provide us with your personal data.
Email : email@example.com
When you contact us, we may require that yousubmit certain forms or provide certain information, including verification ofyour identity, before we are able to respond.
3. WHAT PERSONAL DATA WE COLLECT
3.1 What is personal data. “Personal data” is data that can be used to identify a natural person. Furtherto paragraph 1.3 above, the types of personal data we may collect include:
3.1.1 Identity and Contact Data. Thisincludes the name, address, contact details, telephone numbers, email address,geographic location of business representatives and/or business owners; 3.1.2Profile Data. This includes: (a) uniqueidentifiers such as your account password, and (b) details of your use of ourproducts and services;
3.1.3 Feedback, messages and survey responses. This includes any messaging you send us in a servicerequest, question or concern including via email, telephone or via ourWebsites.
3.1.5 Other information. Any other information of a personal nature that youvoluntarily provide to us in the course of your use of our Websites and/or services.
3.2 Voluntary provision of personal data. Wemay collect personal data (1) that you voluntarily provide to us; or (2) fromthird parties; or (3) through your use of our (or our services provider’s)digital technologies and services (Please see Section 4 How WeCollect Personal Data for further details).What personal data we collect depends on the purposes for which the personaldata is collected and what you have chosen to provide.
When our collection is based on consent, you canchoose not to provide us with personal data. You also have the right towithdraw your consent for us to continue collecting, using, disclosing andprocessing your personal data, by contacting us in accordance with paragraph1.7. However, if you do so, it may not be possible for us to fulfil thepurposes for which we require the personal data, including processing yourtransactions or providing you with the products and services that you require.
3.4 Accuracy and completeness ofpersonal data. You are responsible forensuring that all personal data that you provide to us is true, accurate andcomplete. You are responsible for informing us of any changes to your personaldata.
3.5 Minors. Our Websites and/or services are not intended to beaccessed or used by children, minors or persons who are not of legal age (whichin Singapore is below the age of 13 years under the Personal Data ProtectionAct 2012). If you are a parent or guardian and you have reason to believe yourchild or ward has provided us with their personal data without your consent,please contact us.
4. HOW WE COLLECT PERSONAL DATA
4.1 Personal data you provide. Wecollect personal data that is relevant to our relationship with you. We maycollect your personal data directly or indirectly through various channels, suchas when:
4.1.1 you access, download or use our Websitesand services;
4.1.2 you authorise us to obtain your personaldata from a third party;
4.1.3 you enter into agreements with us;
4.1.4 you transact with us, contact us orrequest that we contact you through various communication channels, forexample, through social media platforms, messenger platforms, face-to-facemeetings, telephone calls, emails, fax and letters;
4.1.5 you request to be included in an e-mail orour mailing list;
4.1.6 we seek information about you and receiveyour personal data in connection with your relationship with us;
4.1.7 and when you submit your personal data tous for any other reason.
4.2 Personal data provided byothers. Depending on your relationshipwith us, we may also collect your personal data from third party sources, forexample, from:
4.2.1 any third parties whom you have authorisedus to obtain your personal data from;
4.2.2 and/or your family members or friends whoprovide your personal data to us on your behalf.
5 WHAT WE DO WITH YOUR PERSONAL DATA
5.1 What we do. We collect, use, disclose and process yourpersonal data where:
5.1.1. you have voluntarily provided us withyour personal data;
5.1.2 you have given us consent;
5.1.3 necessary to comply with our legal orregulatory obligations, e.g. responding to valid requests from publicauthorities;
5.1.4 necessary to support our legitimatebusiness interests, provided that this does not override your interests orrights;
5.1.5 and necessary to perform a transactionwhich you have entered into with us or which you have instructed us to perform,or provide a service that you have requested or require from us.
5.2 General purposes. We collect, use, disclose and process your personaldata for purposes connected or relevant to our business, to manage yourrelationship with us. Such purposes would include:
5.2.1. carrying out your transactions with us,taking steps as may be directed by you, or to provide our products and/or servicesto you;
5.2.2 facilitating your use of our Websites,including verifying and establishing your identity;
5.2.3 facilitating business assettransactions;
5.2.4 communicating with you, and assisting youwith your queries, requests, Websites, complaints, and feedback;
5.2.5 resolving any disputes, investigating anycomplaint, claim or dispute or any actual or suspected illegal or unlawfulconduct;
5.2.6 administrative purposes, includingfinance, IT and HR purposes, quality assurance and staff training, andcompliance with internal policies and procedures, including audit, accounting,risk management and record keeping;
5.2.7 carrying out research and statisticalanalysis, including development of new products and services or evaluation andimprovement of our existing products and services;
5.2.8 security purposes e.g. protecting ourWebsites from unauthorised access or usage and to monitor for securitythreats;
5.2.9 compliance with any legal or regulatoryobligations, applicable laws, regulations, codes of practices, guidelines, orrules, or to assist in law enforcement and investigations conducted by anygovernmental and/or regulatory authority;
5.2.10 performing data analytics and relatedtechnologies on data, to enable us to deliver relevant content and informationto you, and to improve our Websites and digital platforms;
5.2.11 managing and engaging third parties ordata processors that provide services to us, e.g. IT services, technologicalservices, delivery services, and other professional services;
5.2.12 carrying out our legitimate businessinterests;
5.2.13 such purposes that may be informed to youwhen your personal data is collected; and/or any other reasonable purposesrelated to the aforesaid.
Where personal data is used for a new purposeand where required under applicable law, we shall obtain your consent.
5.3 Legitimate businessinterests. In accordance with law, wemay also collect, use, disclose and process your personal data for thefollowing purposes to support our legitimate business interests, which include:
5.3.1 managing our business and relationshipwith you, and providing services to our customers;
5.3.2 assistance of carrying out corporaterestructuring plans;
5.3.3 complying with internal policies, and procedures;
5.3.4 protecting our rights and interests, andthose of our customers;
5.3.5 enforcing our terms and conditions, andobligations owed to us, or protecting ourselves from legal liability;
5.3.6 managing our investor and shareholderrelations;
5.3.7 and process or share your personal data tofacilitate acquisitions, mergers, or transfers of our business.
5.4 Marketing purposes. In order for usto market products, events and services which are of specific interest andrelevance to you, we may analyse and rely on your personal data provided to us,or data collected from your interactions with us However, no marketing, usingyour personal data in non-aggregated and/or identifiable form would be carriedout unless you have provided us with your consent to use your personal data forsuch marketing purposes. If you do not want us to use your personal data forthe purposes of marketing you can withdraw your consent at any time bycontacting us in accordance with paragraph 1.7 above.
5.5 Use permitted under applicable laws. We may also collect, use, disclose and process your personal data forother purposes, without your knowledge or consent, where this is required orpermitted by law. Your personal data may be processed if it is necessary onreasonable request by a law enforcement or regulatory authority, body or agencyor in the defence of a legal claim. We will not delete personal data ifrelevant to an investigation or a dispute. It will continue to be stored untilthose issues are fully resolved.
5.6 Contacting you. When we contactor send you information for the above purposes and purposes for which you haveconsented, we may do so by post, e-mail, SMS, telephone or such other meansprovided by you. If you do not wish to receive any communication or informationfrom us, or wish to restrict the manner by which we may contact or send youinformation, you may contact us in accordance with paragraph 1.7 above.
6. DISCLOSURE OF PERSONAL DATA
6.1 Disclosure to related parties. Wemay disclose or share your personal data with our related parties in order toprovide our services to you, for management and compliance purposes, and toutilise shared group IT functions.
6.2 Disclosure to thirdparties. We may also disclose yourpersonal data to third parties in connection with purposes described inparagraph 5, including without limitation the following circumstances:
6.2.1 disclosing your personal data to thirdparties who provide services to us (including, but not limited to, data providers,technology providers, insurance providers, and other professional services(including accountants, lawyers and auditors));
6.2.2 disclosing your personal data to otherusers or third parties for the purposes of any transaction;
6.2.3 disclosing your personal data to thirdparties in order to fulfil such third party products and/or services as may berequested or directed by you;
6.2.4 disclosing your personal data toauthorities, governments, law enforcement agencies or public agencies if requiredby applicable laws to do so;
6.2.5 If we are discussing, selling ortransferring part or all of our business – the information may be transferredto prospective purchasers under suitable terms as to confidentiality;
6.2.6 If we are reorganised or sold, informationmay be transferred to a buyer who can continue to provide continuedrelationship with you; and
6.2.7 If we are defending a legal claim yourinformation may be transferred as required in connection with defending suchclaim.
6.3 When disclosing personal data to thirdparties, we will (where appropriate and permissible) enter into contracts withthese third parties to protect your personal data in a manner that isconsistent with all applicable laws and/or ensure that they only process yourpersonal data in accordance with our instructions.
7. TRANSFER OF PERSONAL DATA TO OTHER COUNTRIES
7.1 Transfers. We may transfer yourpersonal data to different jurisdictions in connection with the purposesdescribed in paragraph 5:
7.1.1 from the jurisdiction where it iscollected (or where you are located) to any other jurisdictions that we operatein;
7.1.2 and to third parties in otherjurisdictions.
7.2 Safeguards. Where we transfer your personal data acrossjurisdictions, we will ensure that your personal data is protected inaccordance with this policy and applicable laws regardless of the jurisdictionsthey are transferred to, but in any event to a level that is no less stringentthan the jurisdiction from which the personal data is transferred. When wetransfer your personal data internationally and where required by applicablelaw we put in place appropriate safeguards including jurisdiction-specificmodel clauses. You may obtain details of these safeguards by contacting us.
8. SECURITY AND RETENTION OF PERSONALDATA
8.1 Unauthorised access. While we take reasonable precautions tosafeguard your personal data in our possession or under our control, you agreenot to hold us liable or responsible for any loss or damage resulting fromunauthorised or unintended access that is beyond our control, such as hackingor cybercrimes.
8.2 Vulnerabilities. We do not make any warranty, guarantee, orrepresentation that your use of our systems or Websites is safe and protectedfrom malware, and other vulnerabilities. We also do not guarantee the securityof data that you choose to send us electronically. Sending such data isentirely at your own risk.
8.3 Period of retention. We retain your personal data only for as long as isnecessary to fulfil the purposes we collected it for, and to satisfy ourbusiness and/or legal purposes, including data analytics, audit, accounting orreporting purposes. How long we keep your personal data depends on the natureof the data, e.g. we keep personal data for at least the duration of thelimitation period for bringing claims if the personal data may be required tocommence or defend legal proceedings. Some information may also be retained forlonger, e.g. where we are required to do so by law.
8.4 Anonymised data. In some circumstances we may anonymise yourpersonal data so that it can no longer be associated with you, in which case weare entitled to retain and use such data without restriction.
9. YOUR RIGHTS
9.1 Rights you may enjoy. Depending on the jurisdiction that you are in or wherewe operate, you may enjoy certain rights under applicable law in relation toour collection, use, disclosure and processing of your personal data. Suchrights may include:
9.1.1. Access: you may ask us if we hold your personal data and, ifwe are, you can request access to your personal data. This enables you toreceive a copy of and information on the personal data we hold about you.
9.2.2 Correction: you may request that any incomplete or inaccuratepersonal data we hold about you is corrected.
9.2.3 Erasure: you may ask us to delete or remove personal datathat we hold about you in certain circumstances.
9.2.4 Restriction: you may withdraw consent for our use of yourpersonal data, or ask us to suspend the processing of certain of your personaldata about you, for example if you want us to establish its accuracy.
9.2.5 Portability: you may requestthe transfer of certain of your personal data to another party under certainconditions.
9.2.6 Objection: where we are processingyour personal data based on a legitimate interest (or those of a third party)you may object to processing on this ground.
If you wish to exercise any of your rights, youmay contact us in accordance with paragraph 1.7. We may require that you submitcertain forms or provide certain information to process your request. Wherepermitted by law, we may also charge you a fee to process your request.
9.2 Limitations. We may be permitted under applicable lawsto refuse a request, for example, we may refuse (a) a request for erasure wherethe personal data is required for in connection with claims; or (b) anobjection request and continue processing your personal data based oncompelling legitimate grounds for the processing.