The purpose of this document (“Data Protection Policy”) is to inform you of how we, of Vallen Asia , manage Personal Data which is subject to the Singapore Personal Data Protection Act (No. 26 of 2012) (“the Act”). Please take a moment to read this Data Protection Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data.

By interacting with us, submitting information to us, or applying for any employment opportunities through us, you agree and consent to us (including our related partners and business units) (collectively, the “Organisations”), as well as their respective representatives and/or agents (collectively referred to herein as “Vallen Asia”, “us”, “we” or “our”) collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to the Companies’ authorised service providers and relevant third parties in the manner set forth in this Data Protection Policy.

This Data Protection Policy supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your Personal Data, and your consents herein are additional to any rights which to any of the Companies may have at law to collect, use or disclose your Personal Data.

We may from time to time update this Data Protection Policy to ensure that this Data Protection Policy is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of the Data Protection Policy as updated from time to time on our website (http://www.vallen.asia/privacy-policy).

Please check back regularly for updated information on the handling of your Personal Data.

1. Personal Data
   1. In this Data Protection Policy, “Personal Data” refers to any 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 we have or are likely to have access, including data in our records as may be updated from time to time.
   2. Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us) your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address, network data and any other information relating to any individuals which you have provided us in any forms you may have submitted to us, or via other forms of interaction with you.
2. Collection of Personal Data
   1. Generally, we collect Personal Data in the following ways:
      1. when you submit any forms, including but not limited to resumes, application or declaration forms;
      2. when you interact with our officers, for example, via telephone calls, letters, face-to-face meetings and emails;
      3. when you use some of our services, for example, websites and online stores;
      4. when you request that we contact you, be included in an email or other mailing list;
      5. when you respond to our initiatives or to any request for additional Personal Data;
      6. when you are contacted by, and respond to, our officers;
      7. when we receive references from business partners and third parties, for example, where you have been referred by them;
      8. when you submit your Personal Data to us for any other reasons.
   2. When you browse our website, you generally do so anonymously but please see the section below on cookies. We do not at our website automatically collect Personal Data unless you provide such information or login with your account credentials.
   3. If you provide us with any Personal Data relating to a third party (e.g. information of your employees), by submitting such information to us, you represent to us that you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes.
   4. You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with the Products and Services you have requested.
3. Purposes for the Collection, Use and Disclosure of Your Personal Data
   1. Generally, we collect, use and disclose your Personal Data for the following purposes
      1. responding to your queries and requests;
      2. managing the administrative and business operations and complying with internal policies and procedures;
      3. facilitating business transactions involving any of the Organisations;
      4. matching any Personal Data held which relates to you for any of the purposes listed herein;
      5. resolving complaints and handling requests and enquiries;
      6. preventing, detecting and investigating crime and analyzing and managing commercial risks;
      7. providing announcements and responses;
      8. organising promotional events;
      9. legal purposes (including but not limited to obtaining legal advice and dispute resolution);
      10. conducting investigations relating to disputes, billing or fraud;
      11. meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on us (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies and conducting audit checks, due diligence and investigations); and
      12. purposes which are reasonably related to the aforesaid.
   2. In addition, we collect, use and disclose your Personal Data for the following purposes:
      1. If you are a customer or an employee of an organisation which is a customer of our Products and Services:
         1. opening or continuation of accounts and establishing or providing you with Products and Services (including but not limited to activation, operations, delivery and processing);
         2. facilitating the continuation or termination of your subscription to our Products and Services (including but not limited to account maintenance, account closure, processing renewal of contracts and customer relationship management);
         3. facilitating the daily operation of the Products and Services (including but not limited to billing, customer service, customer verification, technical support, network maintenance and troubleshooting);
         4. managing and executing our service-level agreements with you;
         5. processing of payment instructions requested by you;
         6. enforcement of repayment obligations (including but not limited to debt collection and filing of claims);
         7. generating internal reports (including but not limited to annual, operational and management reports);
            and efficiently manage the Products and Services offered to you; and
         8. purposes which are reasonably related to the aforesaid.
      2. Furthermore, where permitted under the Act:
         1. We may also collect, use and disclose your Personal Data for the following “Additional Purposes”:
            1. analytics and tracking, including facilitating the sale of analytical data;
            2. conducting market research and surveys to enable us to understand and determine customer preferences and demographics to develop marketing programmes in relation to our Products and Services, and to improve our service delivery and your customer experience;
            3. providing additional Products and Services and benefits to you;
            4. matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision, marketing or offering of Products and Services by us;
            5. lead generation and management for marketing our Products and Services;
            6. organising promotional events and corporate social responsibility projects; and
            7. purposes which are reasonably related to the aforesaid.
         2. In addition, where permitted under the Act and subject to the provisions of any applicable law, your Personal Data may be disclosed, for our Additional Purposes, to the vendors or other third party service providers in connection with promotions and services offered by us.
      3. If you have provided your telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your telephone number(s), then from time to time, we may contact you using such telephone number(s) (including via voice calls, text, fax or other means) with information about our Products and Services.
      4. In relation to particular Products and Services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.
      5. You have a choice to withdraw your consent for receiving marketing or promotional materials/communication. You may contact us using the contact details found below.
      6. Please be aware that once we receive confirmation that you wish to withdraw your consent for marketing or promotional materials/communication, it may take up to 30 working days for your withdrawal to be reflected in our systems. Therefore, you may still receive marketing or promotional materials/communication during this period of time. Please note that even if you withdraw your consent for the receipt of marketing or promotional materials, we may still contact you for other purposes in relation to the Products and Services.
4. Disclosure of Personal Data
   1. We will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, your Personal Data may be disclosed, for the purposes listed above (where applicable), to the following:
      1. Our related corporations and employees to provide content, Products and Services to you, address your questions and requests in relation to your customer accounts and billing arrangements with us as well as our Products and Services, to activate, deactivate, install, maintain and operate our systems and/or services;
      2. agents, contractors or third party service providers who provide operational services to us, such as courier services, telecommunications, information technology, payment, printing, billing, payroll, processing, technical services, training, market research, call centre, security or other services to us;
      3. any business partner to facilitate business transactions involving any of the Companies;
      4. collection and repossession agencies in relation to the enforcement of repayment obligations for debts;
      5. external banks, credit card companies and their respective service providers;
      6. our professional advisers such as auditors and lawyers;
      7. relevant government regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and
      8. any other party to whom you authorise us to disclose your Personal Data to.
5. Use of Cookies
   1. A cookie is a small piece of information that is placed on your computer when you visit certain websites
   2. We may uses cookies on its websites for the following purposes:
      1. enabling certain features and functions on our websites, eg. remembering your user-id, favourite selections, browsing and other service preferences;
      2. building up a profile of how you and other users use the website;
      3. improving the efficiency of our website;
      4. administering services to you and to advertisers; and
      5. establishing usage statistics
   3. Most internet browsers provide you the option of turning off the processing of cookies (please see the “help” section of your browser), but this may result in the loss of functionality, restrict your use of the website and/or delay or affect the way in which it operates.
6. Data Security
   1. Vallen Asia will take reasonable efforts to protect Personal Data in our possession or our control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. However, we cannot completely guarantee the security of any Personal Data we may have collected from or about you, or that for example no harmful code will enter our website (for example viruses, bugs, trojan horses, spyware or adware). You should be aware of the risks associated with using websites.
   2. While we strive to protect your Personal Data, we cannot ensure the security of the information you transmit to us via the internet or when you use our electronic services, and we urge you to take every precaution to protect your Personal Data when you use such platforms. We recommend that you change your passwords often, use a combination of letters and numbers, and ensure that you use a secure browser.
   3. If applicable, you undertake to keep your username and password secure and confidential and shall not disclose or permit it to be disclosed to any unauthorised person, and to inform us as soon as reasonably practicable if you know or suspect that someone else knows your username and password or believe the confidentiality of your username and password has been lost, stolen or compromised in any way or that actual or possible unauthorised transactions have taken place. We are not liable for any damages resulting from any security breaches, on unauthorised and/or fraudulent use of your username and password.
7. Third-Party Sites
   1. Our website may contain links to other websites operated by third parties. We are not responsible for the privacy practices of websites operated by third parties that are linked to our website. We encourage you to learn about the privacy policies of such third party websites. Some of these third party websites may be co-branded with our logo or trademark, even though they are not operated or maintained by us. Once you have left our website, you should check the applicable privacy policy of the third party website to determine how they will handle any information they collect from you.
8. Contacting Us – Withdrawal of Consent, Access and Correction of your Personal Data
   1. If you:
      1. have any questions or feedback relating to your Personal Data or our Data Protection Policy;
      2. would like to withdraw your consent to any use of your Personal Data as set out in this Data Protection Policy; or
      3. would like to obtain access and make corrections to your Personal Data records, please contact Us as follows: Email: DPO.ASIA.@VALLEN.ASIA
         Write in:
         Data Protection Officer,
         Vallen Singapore Pte Ltd
         101, #07-01 Eunos Ave 3
         Singapore 409835
      4. Please note that if your Personal Data has been provided to us by a third party (e.g. a referrer), you should contact that organisation or individual to make such queries, complaints, and access and correction requests to us on your behalf.
      5. If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, We may not be in a position to continue to provide our Products and Services to you, administer any contractual relationship in place, which in turn may also result in the termination of any agreements with us, and your being in breach of your contractual obligations or undertakings. Our legal rights and remedies in such event are expressly reserved.
9. Governing Law
   1. This Data Protection Policy and your use of this website shall be governed in all respects by the laws of Singapore. The terms of this Employment Data Protection Policy are deemed to be understood and consented by you unless you send us a specific written letter to the contrary.