Introduction
JustCo (Singapore) Pte. Ltd (UEN: 201507302C) (“JustCo“) and the JustCo Group to the extent that it is covered by the PDPA, respect and uphold your rights to privacy protection under Singapore’s Personal Data Protection Act 2012, as amended from time to time (the “PDPA“).
This policy details the practices we have adopted to protect your privacy, so that you can feel confident about how we manage the Personal Data you entrust to us. This policy should be read in conjunction with the terms and conditions of our Membership Agreement. Keeping user identifiable information secure is a priority for the JustCo Group.
The purpose of this policy is to set out how we collect, use and disclose your Personal Data in connection with the use of our websites (“Website Services“), applications (“apps“), or other service that refers to or links to this policy, as well as any offline products, programs, courses and services (collectively our “Services“).
This policy also:
- sets out the best way our staff can clearly communicate the Personal Data handling practices of the JustCo Group;
- enhances the transparency of our business operations; and
- informs you about the sort of Personal Data that the JustCo Group holds, and the way we handle that Personal Data.
Definitions and Interpretation
JustCo Group means JustCo, its affiliates, associated and/or related parties (collectively, the “JustCo Group”),
Membership Agreement means the standard terms of conditions to be entered into between you and JustCo.
Personal Data means data, whether true or not, about an individual who can be identified (a) from that data; or (b) from that data and other information to which the organisation has or is likely to have access.
Services means the Services referenced in this policy and those services as set out in the Membership Agreement which for the avoidance of doubt includes all services provided by the JustCo group.
References to “you” means anyone who uses our Services, Website Services or Apps. If you are an Employee or Applicant that uses our Services, this policy explains how we use Personal Information in the context of your use of our Services.
Information we collect
The JustCo Group may collect information from you including your Personal Data (such as name, e-mail, phone number, date of birth and postal address) through our website, by e-mail correspondence, by postal mail or fax, over the telephone, or in person. The information collected will vary depending on your particular interaction with the JustCo Group but will be limited to that information necessary to record and manage our interaction with you. In accordance with the PDPA, we will only solicit Personal Data where it is reasonably necessary for our functions or activities.
Use of Personal Data
How we use your Personal Data depends on your relationship with us. In general, we will use your Personal Data to:
1 Provide you with our Services, in order to meet our contractual obligations to
you;
2 Contact you about our Services, promotions and sweepstakes. We generally rely on our legitimate interests in marketing our Services to you, whether on our own websites or on third party websites, and in providing these promotions or sweepstakes, where permitted by applicable law. We ensure that we do not use your Personal Data in ways you would not expect and by using our Services you consent to use of your Personal Data in this way;
3 Comply with our legal obligations including any reporting obligations required
under any applicable Singapore law and regulation;
4 Monitoring and reviewing the JustCo Group’s compliance with relevant
regulations and codes of conduct in its dealings with you;
5 Generating customer lists for the purposes of market research;
6 Managing recruitment for JustCo;
7 Automated data collection through interaction with our website, for example:
7.1 It is a necessary part of visiting any website, including the JustCo Group’s site, that the user’s web browser provides the machine’s identity (its IP address) to the web-server, so that the server can address the reply to the correct machine. In addition, the browser type and operating system are provided.
The JustCo Group will only use Personal Data for the primary purpose for which it was given to us; for purposes which are directly related to one of our business functions or activities; or, to the extent:
1 indicated to you at the time of supply of the information to us;
2 you consented to a secondary use or disclosure;
3 you would reasonably expect it to be used at the time of supplying the
information to a third party or publicly available source;
4 required to provide you with a service or goods which you have requested or
which relates to that good or services;
5 required for the ordinary operation of our Website or our business (e.g. to send
you information about our goods and services);
6 required by compulsion of law or regulatory practice;
7 expressly permitted under any agreement with you; or
8 to lessen a threat to a person’s health or safety.
Collection of Personal Data
It is our usual practice to collect Personal Data directly from the individual or their authorised representative. In event of collection of such Personal Data from an authorised representative, it shall be deemed that the authorised representative has obtained the consent of the data subject for the disclosure of their Personal Data to us.
Sometimes we collect Personal Data from a third party or a publicly available source, but only if an individual has consented to such collection or would reasonably expect us to collect their Personal Data in this way.
Your Personal Data is never shared, sold, rented or otherwise disclosed outside the JustCo Group (except as required for any statutory, legal or ethical requirements) in ways different from what is described in this policy.
Disclosure of Personal Data to third parties
To the extent possible, we aim to minimise disclosure of your Personal Data to third parties. However, in order to effectively carry out our business, we may disclose Personal Data to other associated companies of the JustCo Group, our community, our service providers and advertisers, and other end users, in order to provide our Services and to improve ways of working in our community.
1 JustCo Group of companies – our Services are provided by JustCo and its group companies depending on where you are located and that Services that you use. The JustCo Group uses your information in accordance with this policy.
2 Community – our Services include online and offline communities, forums and networks that allow you to share information and connect with others. We make this possible by creating profiles for members or permitting members to create their own profiles. Such a profile contains your name and the name of your company or other organisation and other information you provide. Depending on the Services you use, this profile might be created automatically and is accessible to other members of the forum or network, some of which include all JustCo members. You can supplement your profile by adding additional information about yourself and your company or organisation, and by posting content and comments. You can share your profile with a broader audience (e.g. via social media). Please note that we cannot control the actions of other users of the Services with whom you share information.
3 Service providers – we rely on third-party service providers to perform a variety of services on our behalf and we take steps to ensure that they act only in line with our instructions and on our behalf, or otherwise to use Personal Data as described in this policy.
4 Other parties in connection with a corporate transaction – we disclose or share your information in the event that we purchase, sell finance, transfer, acquire, dispose of all or a portion of a business or assets, such as in connection with a merger, or in the event of a bankruptcy reorganisation or liquidation.
5 Third-party advertising partners – we share limited personal information with third parties that serve our advertising online, so that they can display our adverts to individuals who may find them most relevant. We share this information in order to meet our legitimate interests in advertising our products effectively. We make sure that we only share limited Personal Data for this purpose, and only to trusted partners that are restricted in how they can use your Personal Data.
6 Other third party partners with your consent – we may request your consent to share Personal Data about you with certain third parties so that they can provide you with special offers, promotional materials, and other materials that may be of interest to you. With your consent, we also use and publicise your name, likeness and other personal characteristics and private information for advertising, promotion and other commercial and business purposes.
7 Research or surveys – from time to time, we will provide your Personal Data to our service providers to perform research (online and offline) via surveys on our behalf. Participation is voluntary, and we will use the information that we collect for research and reporting purposes, and to help us to improve the quality of our Services. We use the survey responses to determine the effectiveness of our Services, including the quality of our communications and our advertising and/or promotional activities. If you participate in a survey, your responses will be used along with other participants’ responses.
We may also disclose Personal Data to other third parties, who may be located overseas, including:
- third parties engaged by us to perform functions or provide products and
services on our behalf, such as:
– distributors of our products;
– event organisers and travel agents;
– hosting, data storage or archiving service providers, payment processing
and debt collection services;
– marketing, research and advertising agencies;
– fulfilment houses;
- third parties authorised by you to receive information held by us;
- third parties as part of a sale (or proposed sale) of all or part of our business.
We may impose obligations on any external organisations with which we share your Personal Data to maintain the integrity and security of that Personal Data.
Personal Data Transfer Abroad
JustCo is headquartered in Singapore but also provides Services outside of Singapore. Therefore your information will likely be collected in your country and subsequently transferred or stored in another country, including countries that may have privacy protections less stringent than your jurisdiction. In accordance with applicable law, we implement measures, such as standard data protections clauses, to ensure that any transferred Personal Data remains protected and secure.
Some organisations to which we disclose Personal Data may be located outside Singapore. We will not disclose your Personal Data to an overseas recipient without taking appropriate steps to ensure that the overseas recipient will provide a standard of protection to Personal Data so transferred that is comparable to protection under the PDPA. Such a disclosure could include use of an overseas data processing facility like an email server overseas.
Third Parties that provide content or functionality on our services
We partner with certain third parties to collect, analyse and use some of the Personal Data described in this policy, for example:
1 Third-parties – that provide features and functionality on the Services by means of plug-ins. Even if you do not click on or interact with social networking services or other plug-ins, they collect information about you, such as your IP address and the pages that you view.
2 Advertising providers – who help us and our advertisers provide advertisements on our Services or elsewhere, including advertisements that are targets based on your online behaviour, and analytics companies help us measure and evaluate the usage of our services.
3 Other content providers – who offer products and services on our Services and
operate contests, sweepstakes, or surveys on our Services.
4 Cookies and other internet technologies – who collect or receive certain information about your use of our Services, including through the use of cookies, web beacons and Internet technologies.
4.1 Some of these companies participate in industry-developed programs designed to provide consumers choices about whether to receive targeted advertising.
5 Public forums – our Sites may make member networks, chat rooms, forums, and/or other groups available to the users. Remember that anyone can read, collect or use your postings on a network or forum or in a chat room or group and, we cannot be responsible for unauthorised third party’s use of information that you disclose online.
6 Social media – we are active on social media and share information, images, and video with the public through unaffiliated external social media sites. We encourage you to read their policies. Remember that the social media sites are public, which means that anyone can see your posts, and your posts may even show up in search engine results.
6.1 Whilst we will not edit comments, we may delete a comment from our page on a social media site if it, for example does not relate to the post, promotes a commercial product or service, uses obscene, threatening, or harassing language or violates copyright laws.
Cookies
We may also use Cookies through our website to maximise your user experience. Unless you have adjusted your browser setting so that it will refuse Cookies, our system will set Cookies when you load and navigate around our website. By using our website, you consent to our use of Cookies under the terms of this policy.
Cookies are text files created on your computer when your web browser loads a website or web application. The Cookies we set help us to improve our website and to deliver a better and more personalised service, remembering your preferences, and generally improving the user experience
You may refuse to accept Cookies by activating the setting on your browser which allows you to refuse the setting of Cookie. Please be aware that if you elect to refuse or restrict Cookies you may be unable to access certain parts of our website.
Anonymity and Pseudonymity
Unless we are required by any applicable Singapore law and regulation, or it is otherwise impractical to deal with individuals who have not identified themselves, all individuals have the option of not identifying themselves, or using a pseudonym, when dealing with us in relation to a particular matter.
Notification of the Collection of Personal Data
If we collect Personal Data about you, we will take reasonable steps to notify you of:
1 our identity and contact details;
2 the fact and circumstances of collection;
3 whether the collection is required or authorised by law;
4 the purposes of the collection;
5 the consequences if Personal Data is not collected;
6 our usual disclosures of Personal Data of that kind;
7 information about our privacy policy; and,
8 whether we are likely to disclose the information to overseas recipients.
Direct Marketing
We will only use or disclose Personal Data to communicate directly with you to promote a good or service:
1 if we collected the information directly from you, and you have consented that
the information is to be used in this way; or
2 if it is permitted under the applicable Singapore laws and regulations to do so.
You will generally be given the opportunity to “opt out” of receiving marketing or promotional communications from us. Instructions for opting out will typically be included somewhere on the communication.
Data Quality and Security
We take steps to ensure that the Personal Data we collect is accurate, up to date and complete. These steps include maintaining and updating Personal Data when we are advised by individuals that their Personal Data has changed, and at other times when necessary.
We will take all reasonable steps to maintain the security and integrity of your Personal Data including the use of computer access passwords, lock-up cabinets, privacy policies & procedures and firewalls.
Links and Third Party Platforms
Websites operated by JustCo may contain links to other sites operated by third parties. JustCo makes no representations or warranties as to the privacy practices of any third- party site and is not responsible for the privacy policies of other sites.
Sometimes we use third party platforms to deliver information. These are sites hosted and managed by organisations other than ourselves. Before deciding if you want to contribute to any third party site, you should read their privacy policy.
Information collected through Employment Applications
In processing applications for employment, the JustCo Group collects resumes, references, certificates of graduation and qualification and other Personal Data about candidates. All applications for employment that we receive are stored in our Human Resources Division. A member of our Human Resources team will review your application. Alternatively, we may provide your application to a recruitment agency or contractor who assists in reviewing applications that we receive.
Resumes sent to the JustCo Group as part of an application for an advertised position, or sent generally to ascertain whether any positions are available, will be used to match applicants with available opportunities. If we consider that your application may be suitable to our current requirements, we, or a party acting on our behalf, will contact you to request that you attend an interview. We may also ask you to provide us with contact information for individuals who will act as professional and personal referees. We may contact these individuals and ask them questions we feel are relevant to your possible employment with us. We may contact you again to request that you attend
further interviews or to inform you of whether we are able to offer you a position with us.
If your application is not suitable to our current requirements, but we feel that there may be a position in the future for you with us, we will a keep a record of your application and may contact you again if a suitable position becomes available.
How you can access and/or correct your Personal Data
You can always, by written request, seek access to your Personal Data and/or ask us to correct or delete any inaccurate, incomplete or out of date information. Any request for access, correction or deletion of information, or complaint must be addressed to our Data Protection Officer using the following contact details:
By e-mail: Dataprotection@JustCoGlobal.com
Upon receipt of your request, we may request for additional information from you (including proof of identity) in order to process your request. We may also charge a reasonable fee to cover our administration costs when dealing with any requests for access, which we will inform you of in advance.
We will endeavour to disclose and/or correct such Personal Data in accordance with our legal obligations, and where we refuse to do so, we will, where possible, provide you with the reasons for our refusal.
Retention
The JustCo Group will retain your Personal Data for as long as you have a relationship with us, and for a period after your relationship with us has ended.
When determining how long this retention period will last, we take into account the length of time Personal Data is required to, among other things:
1 continue to develop, tailor, upgrade and improve our Services;
2 maintain business records for analysis and/or audit purposes;
3 comply with record retention requirements under the law;
4 defend or bring any existing or potential legal claims; or
5 address any complaints regarding the services.
Information Security
The security of all Personal Data provided to the JustCo Group is important to us. The JustCo Group takes reasonable steps endeavouring to use appropriate technical or organisational measures to protect your Personal Data, including against unauthorised or unlawful processing and accidental loss, destruction or damage. Unfortunately, no data transmission over the Internet or storage of information can be guaranteed to be 100% secure. As a result, while the JustCo Group strives to protect your Personal Data, we cannot ensure or warrant the security of any information that you transmit to the JustCo Group, and you do so at your own risk. As such, we ask that you help us be
safer together by implementing your own security controls, such as a strong password, not sharing your credentials with others, logging out when you leave your desk, and other security best practices.
Complaints and Queries
If you wish to make a complaint about our handling of your Personal Data, or if you have any queries in relation to this policy, please contact our Data Protection Officer using the contact details set out in the paragraph immediately above.
Upon receipt of any complaints, the JustCo Group will carry out an investigation and may contact you for further information.
What if our Privacy Policy changes?
We may review, amend or revise our privacy policy and the way we handle Personal Data from time to time. We will post the updated privacy policy on our website at https://www.JustCoGlobal.com and its terms will take effect from the date of posting. Please check this policy periodically to inform yourself of any changes.
Updated as at 7 January 2019