GENERIC PRIVACY POLICIES
This Standard Operating Procedures (SOP) are to highlight our standard practices of protecting data and privacy of our stakeholders (clients, partners, vendors, collaborators, shareholders, directors, and so on). These standard practices and policies are practice by our personnel, publicized on our website, and through all our business conducts. As part of following the requirement set by the government of Singapore on PDPA. We will cover information such as the data protection lead officer, how do we keep and dispose of data, how we manage our risks and mitigations, and contingency planning when it comes to data breaches or malpractices.
The purpose of this SOP is to ensure and communicate clearly on all of our practices and policies to our staff and our clients. Giving all our stakeholders’ assurance on our highest regards and priorities in assuring protection of data and its privacy.
1.3 Functionality
These policies should be consistently and frequently updated, refreshed, and communicated by the data officer of the company, which in this case will be for Walker Technology. These generic practices should be accompanied with training slides as well as another internal SOP on data handling and client privacy that should be honored by all staff of Walker Technology.
2.1 Terms and Conditions
For any information provided by Walker Technology on our public domain, including our website is copyrights of Walker Technology or approved contents provided by either relevant agencies or stakeholders. Pertaining to this information, you agree and comply to:
Our rights include the following (our rights refer to the right of Walker Technology in relation to the website or public domain such as our social media assets):
In terms of the use of our social media (Instagram, Linkedin, Facebook, Tiktok, and so forth), we would like to emphasis the following code of conducts:
Finally, we own the intellectual property rights to all published information otherwise stated so and have full discretion on how to organise, disseminate, edit, and utilize the information with exception to our clients’ personal contact details and information. In addition, Permission is granted to download and print the Materials on this website for personal, non-commercial use only, provided you do not modify the Materials and that you retain all copyright notices and other proprietary notices contained in the Materials. You may not, without our permission, “deep link” to any part of this website, “frame” or "mirror" any Material contained on this website on any other server.
3. General Policies and Data Protection Policies.
3.1. Ethical, Lawful, and Transparency:
We adopt minimal data collection policies and only collecting based on what is required nor our website our public domain was equipped with unnecessary cookies other than for safety and privacy. For any events or any campaigns that may require customer registration or data collections, these data are collected only through secure and trustworthy platforms in which is only accessible to our personnel that has clearance. The purpose of these data collections is to confirm the identity of the registrants as well as the accompanying information. For any marketing purposes or engagements, there should be clear choices given during any registration whether to opt-in or opt-out to receive any email or mobile notifications of our newsletter or campaigns. Should there be approval to receive any marketing collaterals in the past and if the recipient decides to no longer want to receive them, they can simply unsubscribe to write to our generic email as follows: ask@walker-technology.com
Please note that all the external links provided on our website are genuine and official links that have been given permission for us to provide the information on our website or social media.
3.2 Data Security
Data protection is always considered, from the moment we collect your personal data in business activities. We encrypt, pseudonymize or anonymize the data wherever possible. This is something that our staff are always aware of. We have internal data protection policies and IT security policies for our staff and build awareness about data protection. Our business leaders know when to conduct a data protection impact assessment and we have a process in place to carry it out. For data breach matter, we have a process to notify authorities and other stakeholders that is guided by an internal data breach reporting policy and business continuity management programme. All staff, new and old will have to attend occasional training on PDPA be it conducted internally by the data protection lead officer or by external approved institution. Our entity is ISO certified and requires going for routine audits and checks.
3.3 Accountability and Governance
Governance is our primary priority and good administration is what we practice at Walker Technology. We have a data protection officer that overlooks at the overall implementation as well as control over data protection and governing policies. Under the regulation of IMDA or Infocom Media Development Agency of Singapore, we are intimately aware of our PDPA obligations which include appointing a data protection officer, providing clarity as well as communications on how our data is being handled, and identify potential risks as well as breaches to ensure countermeasures and contingency planning.
In the event of more information or clarity required, you can send an email or contact our data protection officer or lead as follows:
Officer Name: Andre W. Darmono
Designation: Business Development Director
Email: ask@walker-technology.com
General Line: +65 6685 9034
We will reply to you within 3 working days should there be any relevant case or inquiry lodged.
3.4 Data Privacy and Rights
We have proper security procedure to handle our customers who make request about their personal data that is with us. It is easy for our customers to correct or update inaccurate or incomplete information. We do not use automated processes to make decision about our customers. If there is use of Artificial Intelligence/Machine Learning or use of website cookies to make decision, this is notified to our customers on the relevant company websites where such activities are taking place.
Our personnel in the company would have to attend the PDPA workshop especially for the data protection officer in which also has the responsibility to train and share information pertaining PDPA and cyber security through all the staff in the Walker Technology. In addition, we also follow strictly the code of conducts provided by the IMDA regarding PDPA. For personal contact information with exception to working email and working contact number, we do not publish, share, nor engage with personal information directly or indirectly without the consent of the data owner unless the consent was given to third party collaborators or partners.
4. Personal Data Protection Policies
Protection of your Personal Data is important to us. ThisWalker Technology Data Protection Policy (“Policy”) outlines how we manage the data within our organisation. Policy applies to:
a) Walker Technology
that holds all of the advisory clients’ details and upgrading projects.
b) Related corporations and affiliates;
We respect the confidentiality of Personal Data and privacy of individuals and are committed to complying with the Singapore Personal Data Protection Act (Act 26 of 2012) (“PDPA”) and other applicable data protection laws, including the European Union (“EU”) General Data Protection Regulation (“GDPR”), where applicable. Please read this Policy so that you know and understand the purposes for which we collect, use, and disclose your Personal Data.
We adopt a pragmatic “Data-light, Data-tight” approach in our business conduct.
“Data-light” means that we collect Personal Data only for what is required in business or in activities conducted by our organisation and will properly destroy the Personal Data once there is no business or legal purpose. We do not collect Personal Data randomly or indiscriminately without purpose.
“Data-tight” means that we do not disclose your Personal Data unless prior consent has been obtained and we have administrative, physical and Information Technology (IT) security measures to protect your Personal Data.
Generally, we process your Personal Data for one or more of the specific purposes identified in this Policy based on your consent obtained. Where GDPR applies, the legal basis for our processing of your Personal Data could also be that it is necessary for the legitimate interests pursued by us, or a third party which is described in paragraph 3.8 of this Policy. These legitimate interests include providing services to you where you are our client, managing the relationship between Walker Technology and you and facilitating internal business purposes and administrative purposes. In some cases, the provision and processing of your Personal Data may be a statutory and/or contractual requirement or may be necessary to perform any contract you have agreed with us or perform services that you have requested.
In addition, if your Personal Data has been collected, used or disclosed by us in a particular jurisdiction which has specific requirements or exceptions to the definition of Personal Data, including sensitive Personal Data, we will comply with those requirements under the applicable data protection regulations in that jurisdiction
.
4.1 Your Personal Data
“Personal Data” refers to any data or information about you from which you can be identified either (a) from that data alone; or (b) from that data combined with other information. Examples of such Personal Data which you may provide us include (depending on the nature of your interaction with us):
a) Your name, national registration identification number, passport number or other identification number, telephone number(s), mailing address, email address, facial image in a photograph or video recording, fingerprint and any other information relating to you which you have provided us in any form you may have submitted to us, or in other forms of interaction with you.
b) Information about your business, your products, your business planning, stakeholders, and so on derived either form advisory sessions or grant application.
c) Your employment history, education background, and income levels; and
d) Your company or personal financial information that may have been provided to use for the purpose of applying grant.
e) Any other generic information obtained either direct or indirect such as from contact us from our website or from our social media that may contain your contact number, name, email, and so forth.
4.2 Collection of Personal Data
Generally, we collect your Personal Data in the following ways:
a) When you made contact either directly through our channels or affiliated channels. Direct channels include walk-ins, submitting inquiries from our website or social media, emailing, or calling our direct email or line, and so on.
f) When you engage our Advisors either through the phone, virtual meeting, or face to face.
g) When you request that we contact you.
h) When you respond to our request for additional Personal Data.
i) When you ask to be included in an email or other mailing list.
j) When you respond to our promotions or other initiatives.
k) When you respond to our market surveys.
l) When you submit a grant application or other interest application such as attending our events and workshops.
m) When we receive references from business partners and third parties, for example, where you have been referred by them.
n) When you submit your Personal Data to us for any other reason; and
o) When you browse our website. As mentioned, our cookies do not drop trackers other than security or urgent related matters.
4.3 Use and Disclosure of Personal Data
b) In general, we will, subject to applicable law, use and disclose your Personal Data for the following purposes:
- Provide you with the products or services that you have requested.
- Help us review, develop, improve, manage the delivery of and – to the extent this requires the use of Personal Data – enhance our products and services, including analysing future customer needs, conducting market research and data analytics (which does not involve automated profiling or result in automated decision-making activity which is regulated under the GDPR).
- Communicate with you and respond to your queries, requests, and complaints.
- Provide ongoing information about our products and services which may be of interest to you.
- Handle disputes and conduct and facilitate investigations and proceedings.
- Protect and enforce our contractual and legal rights and obligations.
- Prevent, detect, and investigate crime, including fraud and money-laundering, and analyse and manage other commercial risks.
- Comply with any applicable rules, laws and regulations, codes of practice or guidelines or assist in law enforcement and investigations by relevant authorities.
c) If you are a vendor, a prospective vendor, or a contractor, we may use and access the following information:
- Evaluate your proposal.
- Conduct background checks on you.
- Communicate with your deployed staff, after award of contract, who are in our properties to carry out work or services, and for any emergency or/and security concerns; and
- Any other purpose related to any of the above.
d) If you apply to us as a candidate for employment:
- Process your application including pre-recruitment checks.
- Provide or to obtain references for background screening/vetting.
- Collect information about your suitability for the position applied for.
- Organise training and staff development programmes.
- Assess your performance.
- Administer benefits and payroll processing.
- Provide you with tools to facilitate or as required for you to do your job.
- Communicate with you to comply with our policies and processes, including for business continuity purposes; and
- Any other purposes related to the aforesaid.
k) If you are an existing employee of Walker Technology, Employee Personal Data Protection Policy would also apply to you.
l) Your Personal Data will be protected and kept confidential, but subject to the provisions of any applicable law, your Personal Data may, depending on the products or services concerned, be disclosed to third parties set out below. Such disclosure may be subject to additional legal requirements under applicable law, depending on the nature of such transfer to third parties. Your Personal Data will, in each case, only be disclosed to the extent necessary and proportionate.
6. Your Rights
a) You have the following rights, under applicable data protection laws (except where the exercise of these is restricted under applicable laws – for example, due to judicial proceedings or the carrying out of investigations), which can be exercised by contacting the relevant Data Protection Officer at the contact details provided in paragraph 3.1.
b) To obtain from us confirmation as to whether or not your Personal Data is being processed and request a copy of your information. Where legally required, we will provide your information in an easily accessible format and assist in transferring some of this information to third parties.
c) Rectification of your Personal Data. We endeavour to ensure that all Personal Data we have about you is accurate and up to date. We understand that this information changes frequently with changes of address and other personal circumstances. We encourage you to contact us as soon as possible to enable us to update any Personal Data we have about you. Incomplete or outdated Personal Data may result in our inability to provide you with products and services you have requested.
d) In certain circumstances, you can request to have your Personal Data deleted or restrict the processing of it.
e) If we process your information based on our legitimate interests explained above, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is necessary for legal reasons. Where we use your data for direct marketing purposes, you can always object using the unsubscribe link in such communications or by contacting us.
f) Prevent any processing of Personal Data that is causing or is likely to cause unwarranted and substantial damage or distress to you or another individual.
7. Management and Security
7.1 We have appointed Data Protection Officers to oversee our management of your Personal Data in accordance with this Policy and the applicable data protections law. We train our employees who handle your Personal Data to respect the confidentiality of your Personal Data, and we regard breaches of all applicable data protection laws very seriously.
8. Governing Law
8.1 This Policy and your use of this website shall be governed in all respects by the laws of Singapore. For the avoidance of doubt, the applicable data protection laws will apply to the processing of your Personal Data.
9. Review of this Policy
9.1 This Policy will be reviewed from time to time by us. We may also from time to time update this Policy to take account of new laws and technology, changes to our operations and practices and the changing business environment. If you are unsure whether you are reading the most current version, please contact us.
9.2 In the event of any inconsistencies between the English version and other translations of this Policy, the English version shall prevail.
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