Effective Date: 1 June 2020
Bonsey Jaden and its affiliates (“Bonsey Jaden,” “BJ,” “us,” or “our”) provide this Privacy Notice, which applies to Singapore resident employees, employee applicants, owners, directors, officers, or contractors of Bonsey Jaden, including as applicable, those individuals’ emergency contacts and beneficiaries. This Privacy Notice sets forth our privacy practices that are compliant to both Singapore PDPA and GDPR. Please note, there may be additional or different privacy notices or disclosures that govern our use of your personal information beyond the PDPA. Where collection, use and disclosure of personal information is subject to the PDPA and GDPR, this Privacy Notice shall prevail.
This Privacy Policy describes the types of personal information we collect about individuals on http://bonseyjaden.com (the “Site”), how we may use the information, with whom we may share it, and the choices available regarding our use of the information. The Privacy Policy also describes the measures we take to safeguard the personal information, how long we retain it and how individuals can contact us about our privacy practices and to exercise their rights.
Click on one of the links below to jump to the listed section:
- What information we collect about you
- How we use information we collect
- How we share information we collect
- How we store and secure information we collect
- How we transfer information internationally
- Your Rights
- Changes to this policy
- Policy towards children
- Cookies Policy
- Legal Basis
- Contact us
Information We Obtain
In connection with your use of the Site, you may provide personal information to us in various ways. The types of personal information we may obtain include personal information contained in content you submit, such as when you email us by clicking on Bonsey Jaden email address hyperlinks on the Site. You are not required to provide this information but, if you choose not to do so, we may not be able to offer you certain of our services and features of the Site.
1 What information we collect about you
1.1 We collect the following types of information about you:
(a) account and profile information that you provide when you register for an account or sign up for our products or services, for example “your name, email addresses, resumes, briefs, telephone numbers, description of businesses, purpose of contact’ (collectively, “Account Data”);
(b) information you provide through support channels, for example when you report a problem to us or interact with our support team, including any contact information, documentation, or screenshots (collectively, “Support Data”);
(c) communication, marketing, and other preferences that you set when you set up your account or profile, or when you participate in a survey or a questionnaire that we send you (collectively, “Preference Data”);
(d) information about your device or connection, for example “your internet protocol (IP) address, email subscription data, browser type and version, time-zone setting, browser plug-in types and versions, operating system and Site, and other technology on the devices you use to access our websites” and information we collect through cookies and other data collection technologies (please read our Cookies Policy for details) (collectively, “Technical Data”); and
(e) Information about your use of or visit to our Site, for example “your clickstream to, through, and from our Site, products you viewed, used, or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), or methods to browse away from the page” (collectively, “Usage Data”).
1.2 We collect the above information when you provide it to us or when you use or visit our Site. We may also receive information about you from other sources, including:
(a) our group companies or overseas offices that provide “information technology services, system administrative services, and marketing services”; and
(b) our business partners and service providers based inSingapore, Australia, Indonesia, Malaysia, Thailand, Vietnam and the Philippines who provide “technical, payment, advertising networks, analytics, market research, and search information services”.
1.3 We do not collect sensitive data or special category data about you. This includes details about your race, ethnic origin, politics, religion, trade union membership, genetics, biometrics, health, or sexual orientation.
2 How we use information we collect
2.1 We only use your personal information where the law allows us to. We use your personal
information only where:
(a) we need to perform the contract we have entered into (or are about to enter into) with you, including to operate our products or services, to provide customer support and personalised features, and to protect the safety and security of our Site;
(b) it satisfies a legitimate interest which is not overridden by your fundamental rights or data protection interests, for example for research and development, and in order to protect our legal rights and interests
(c) you’ve given us consent to do so for a specific purpose, for example we may send you direct marketing materials or publish your information as part of our testimonials or customer stories to promote our products or services with your permission; or
(d) we need to comply with a legal or regulatory obligation.
2.2 If you have given us consent to use your personal information for a specific purpose, you have the right to withdraw your consent any time by contacting us (please refer to paragraph 9 for contact information), but please note this will not affect any use of your information that has already taken place.
2.3 We do not share your personal information with any company outside our group for marketing purpose, unless with your express specific consent to do so.
2.4 For visitors to or users of our Site who are located in the European Union, we have set out our legal bases for processing your information in the Legal Bases Table at the end of this policy.
4 How we store and secure information we collect
4.1 We use data hosting service providers based in United States to host the information we
collect.
4.2 We have adopted the following measures to protect the security and integrity of your personal information:
(a) information is encrypted using TLS/SSL technology;
(b) access to your personal information is restricted to personnel or service providers on a strictly need-to-know basis, who will only process your information on our instructions and who are subject to a duty of confidentiality; and
(c) our information collection, storage, and processing practices are reviewed regularly.
4.3 We have put in place procedures to deal with any suspected privacy breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
4.4 While we implement safeguards designed to protect your information, please note that no transmission of information on the Internet is completely secure. We cannot guarantee that your information, during transmission through the Internet or while stored on our systems or processed by us, is absolutely safe and secure.
4.5 We only retain personal information for so long as it is reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. “After such time, we will delete or anonymise your information, or if this is not possible, we will securely store your information and isolate it from further use”. We periodically review the basis and appropriateness of our data retention policy.
5 How we transfer information internationally
5.1 We collect information globally and primarily store that information in United States. We transfer, process, and store your information outside your country of residence where we or our service providers operate for the purpose of providing our products and services to you.
5.2 Some of the countries in which our companies or service providers are located may not have the privacy and data protection laws that are equivalent to those in your country of residence. When we share information with these companies or service providers, we make use of contractual clauses, corporate rules, and other appropriate mechanisms to safeguard the transfer of information.
6 Your rights
6.1 You have the right to:
(a) be informed of what we do with your personal information;
(b) request a copy of personal information we hold about you;
(c) require us to correct any inaccuracy or error in any personal information we hold
about you;
(d) request erasure of your personal information (note, however, that we may not always be able to comply with your request of erasure for record keeping purposes, to complete transactions, or to comply with our legal obligations);
(e) object to or restrict the processing by us of your personal information (including for marketing purposes);
(f) request to receive some of your personal information in a structured, commonly used, and machine readable format, and request that we transfer such information to another party; and
(g) withdraw your consent at any time where we are relying on consent to process your personal information (although this will not affect the lawfulness of any processing carried out before you withdraw your consent).
6.2 You may opt out of receiving marketing materials from us “by using the unsubscribe link in our communications or by contacting us”. Please note, however, that even if you opt out from receiving marketing materials from us, you will continue to receive notifications or information from us that are necessary for the use of our products or services.
6.3 As a security measure, we may need specific information from you to help us confirm your identity when processing your privacy requests or when you exercise your rights.
6.4 Any request under paragraph 6.1 will normally be addressed free of charge. However, we may charge a reasonable administration fee if your request is clearly unfounded, repetitive, or excessive.
6.5 We will respond to all legitimate requests within one (1) month. Occasionally, it may take us longer than a month if your request is particularly complex or if you have made a number of requests.
7 Changes to this policy
7.1 We may amend this policy from time to time by posting the updated policy on our Site. By continuing to use our Site after the changes come into effect, you agree to be bound by the revised policy.
8 Policy towards children
8.1 Our products and services are not directed to individuals under 18. We do not knowingly collect personal information from individuals under 18. If we become aware that an individual under 18 has provided us with personal information, we will take steps to delete such information. Contact us if you believe that we have mistakenly or unintentionally collected information from an individual under 18 years of age.
9 Cookies Policy
Cookies are small text files that are placed on your device by a web server when you access our Site. We use cookies to identify your access and monitor usage and web traffic on our Site to customise and improve our products and services.
We use both persistent cookies and session cookies. A persistent cookie stays in your browser and will be read by us when you return to our Site or a partner site that uses our services. Session cookies only last for as long as the session lasts (usually the current visit to a website or a browser session).
We use the following types of cookies:
(a) Strictly necessary cookies – these are cookies that are required for the operation of our site. They include, for example, cookies that enable you to log into secure areas of our website.
(b) Analytical/performance cookies – these allow us to recognise and count the number of visitors and to see how visitors move around our Site when they are using it. This helps us to improve the way our site works, for example, by ensuring that users are easily finding what they are looking for.
(c) Functionality cookies – these are used to recognise you when you return to our site.
(d) Targeting cookies – these cookies record your visit to our site, the pages you have visited, and the links you have followed.
You can block cookies by activating the setting on your browser that allows you to refuse the use of all or some cookies. However, if you do so, you may not be able to access all or parts of our site.
10 Legal Basis
| Processing purpose | Types of data processed | Legal basis |
|---|---|---|
|
To enable you to use our products and services |
anonymous browser, device and website behaviour data |
Legitimate interest to optimise the performance and content of our website for users and visitors |
|
To notify you about changes to our products, services, or terms |
Name and email contact details |
Legitimate interest to optimise the performance and content of our website for users and visitors |
|
To administer and maintain safety and security of our website |
Technical Data |
Legitimate interest to optimise the performance and security of our website for users and visitors |
|
To study usage of our website |
Browser, device and website behaviour data |
Legitimate interest to improve our website, products, and services |
|
To gather feedback on our website |
Browser, device and website behaviour data |
Legitimate interest to improve our Site, products, and services |
|
To provide information on products or services that may be of interest to you |
Browser, device and website behaviour data |
Consent, which you may withdraw any time |
11 Contact us
11.1 Please contact us at daniel@bonseyjaden.com or submit any written request to:
Bonsey Jaden Pte Ltd, 19 Carpenter Street, Singapore 059908 Attn: Daniel Posavac
11.2 Please contact us in the first instance if you have any questions or concerns. If you have unresolved concerns, you have the right to file a complaint with a data protection authority in the country where you live or work or where you feel your rights have been infringed.
Last updated: 1 June 2020