Data Protection Notice
DATA PROTECTION NOTICE / PRIVACY POLICY
Effective date: 25/07/2024
This Data Protection Notice aka Privacy Policy (“Notice”) sets out the basis which Possbly Pte. Ltd. (“we”, “us”, or “our”) which is founded and based in Singapore, may collect, use, disclose or otherwise process personal data of our prospective service users, service users, service users' (“you”, “your”, “user”) authorised representative in accordance with the Singapore’s Personal Data Protection Act (“PDPA”) when you use our website (https://possbly.app and https://possbly.com) (the “Service”).
This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.
Collection, use, disclosure or otherwise processing of personal data of our service users on behalf of government ministries or statutory boards will be in accordance with guidelines set out in the government’s data management policy. Possbly Pte. Ltd. will comply with the relevant requirements under the government’s data management policy.
PERSONAL DATA
1. As used in this Notice:
“personal data” means data, whether true or not, about an individual (whether a prospective service users, service users, service users' authorised representative or otherwise) 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.
2. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include name, identification numbers such as NRIC, fin, work permit local national ID, driving licence, and birth certificate, contact information such as residential address, employment address, email address, mobile phone number or telephone number, nationality, gender, date of birth, marital status, photographs and other audio-visual information, employment information, financial information such as credit card numbers, debit card numbers or bank account information, IP location and social media profile.
3. Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).
COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
4. We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
Generally, we collect/receive information about you in the following manner:
o When you fill up the registration form or otherwise submits personal information
o Interacts with the website
o From public sources such as but not limited to internet search engine and social media profiles
5. We may collect and use your personal data for any or all of the following purposes which includes establishing or managing your relationship with us. This includes:
Where you are a prospective service user:
o processing and evaluating your application for our services
Where you are a service user or service user’s authorised representative:
o providing the services requested by you;
o processing and evaluating the service user’s application for our services;
o monitoring, evaluating and/or auditing of services provided. This may include an assessment of the quality of the services provided and the effects of the services provided (both in the short and long term, and after you have stopped using the services);
o research related to your personal user experiences or services you used, in particular, for our research relating to improving our services. We will notify you and obtain your written consent before using your personal data for any specific research project, unless otherwise permitted under the PDPA or other legislation;
o providing you with information on our upcoming events or activities, where you have specifically requested to receive such information;
o verifying your identity;
o responding to, handling, and processing queries, requests, applications, complaints and feedback from you;
o complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
o any other purposes such as ad service, sponsors, marketing agencies, legal entities, analytics, payment recovery services, data collection and process, for which you have provided the information;
o transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
o any other incidental purposes related to or in connection with the above.
6. We may disclose/share your personal data:
o where such disclosure is required for, or in connection with, the provision of the services requested by you;
o to third party service providers, agents and other organisations we have engaged to perform any of the purposes listed in clause 5 above for us;
o to comply with any applicable laws, regulations, codes of practice, guidelines, rules or requests by public agencies, or to assist in law enforcement and investigations; and
o any other party to whom you authorised us to disclose your personal data to, or where necessary to undertake any action requested by you.
7. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under a contract with you).
When we disclose/share your personal data, we require such third party’s to use the personal information we transfer to them only for the purpose for which it was transferred and not to retain it for longer than is required for fulfilling the said purpose.
We may also disclose your personal information for the following: (1) to comply with applicable law, regulation, court order or other legal process; (2) to enforce your agreements with us, including this Notice; or (3) to respond to claims that your use of the Service violates any third-party rights.
If the Service or our company is merged or acquired with another company, your information will be one of the assets that is transferred to the new owner.
DEEMED CONSENT BY NOTIFICATION
8. We may collect or use your personal data, or disclose existing personal data for secondary purposes that differ from the primary purpose which it had originally collected for pursuant to clauses 5 and 6. If Possbly Pte. Ltd. intends to rely on deemed consent by notification for such secondary purposes, Possbly Pte. Ltd. will notify you of the proposed collection, use or disclosure of his personal data through appropriate mode(s) of communication.
9. We may rely on deemed consent by notification to collect, use or disclose your personal data for the following purposes:
o Marketing/Promotional
o Creating user account
o Testimonials
o Customer feedback collection
o Processing payment
o User Support
o Administration info
o Targeted advertising
o Manage customer order
o Site protection
o User to user comments
o Dispute resolution
o Manage user account
o Enforce Terms and Conditions including Terms of Service and incorporated policies
10. Before relying on deemed consent by notification, Possbly Pte. Ltd. will assess and determine that the collection, use and disclosure of the personal data will not likely have an adverse effect on you.
11. You will be given a reasonable period to inform us if you wish to opt-out of the collection, use and disclosure of your personal data for such purposes.
12. After the lapse of the opt-out period, you may notify us that you no longer wish to consent to the purposes for which your consent was deemed by notification by withdrawing your consent for the collection, use or disclosure of your personal data in relation to those purposes.
RELIANCE ON LEGITIMATE INTERESTS EXCEPTION
13. In compliance with the PDPA, we may collect, use or disclose your personal data without your consent for the legitimate interests of Possbly Pte. Ltd. or another person. In relying on the legitimate interests exception of the PDPA, Possbly Pte. Ltd. will assess the likely adverse effects on the individual and determine that the legitimate interests outweigh any adverse effect.
14. In line with the legitimate interests’ exception, we will collect, use or disclose your personal data for the following purposes:
o A.I (Artificial Intelligence) analysis for prevention of crimes and service improvements.
o Fraud detection and prevention.
o Detection and prevention of misuse of services.
o Network analysis to prevent fraud and financial crime and perform credit analysis.
o Collection and use of personal data on company-issued devices to prevent data loss.
The purposes listed in the above clause may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter.
WITHDRAWING YOUR CONSENT
15. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you or your authorised representative in writing. You or your authorised representative may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request via email or otherwise in writing to our Data Protection Officer at the contact details provided below. If you are unable to submit your request in writing or if you require any assistance with the submission of your request, you can ask to speak with our user support team.
16. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.
17. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in the manner described in clause 15 above.
18. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
ACCESS TO AND CORRECTION OF PERSONAL DATA
19. If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request via email or otherwise in writing, to our Data Protection Officer at the contact details provided below. If you require assistance with the submission of your request, you can ask to speak to our user support team or email to our Data Protection Officer.
20. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
21. We will respond to your request as soon as reasonably possible. In general, our response will be within thirty (30) business days. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).
MORE RIGHTS
22. Depending on the law that applies, you may have a right to access and rectify or erase your personal data or receive a copy of your personal data, restrict or object to the active processing of your data, ask us to share (port) your personal information to another entity, withdraw any consent you provided to us to process your data, a right to lodge a complaint with a statutory authority and such other rights as may be relevant under applicable laws. To exercise these rights, you can write to us at privacy@possbly.com. We will respond to your request in accordance with applicable privacy laws such as GDPR and etc. based on your nationality.
You may opt-out of direct marketing communications or the profiling we carry out for marketing purposes by writing to us at privacy@possbly.com or select unsubscribe to our newsletter. Do note that if you do not allow us to collect or process the required personal information or withdraw the consent to process the same for the required purposes such as but not limited to user verification, you may not be able to access or use the services for which your information was sought.
PROTECTION OF PERSONAL DATA
23. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as minimised collection of personal data, authentication and access controls (such as good password practices, need-to-basis for data disclosure, etc.), encryption of data, data anonymisation, up-to-date antivirus protection, regular patching of operating system and other software, securely erase storage media in devices before disposal, web security measures against risks, usage of one time password(otp) / 2 factor authentication (2fa) / multi-factor authentication (mfa) to secure access, and security review and testing performed regularly.
24. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures. In other words, the security of your information is important to us, and we will use reasonable security measures to prevent the loss, misuse or unauthorized alteration of your information under our control. However, given the inherent risks, we cannot guarantee absolute security and consequently, we cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk.
ACCURACY OF PERSONAL DATA
25. We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer at the contact details provided below or update your user profile directly.
RETENTION OF PERSONAL DATA
26. We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws. Generally, we will retain your personal information with us for 90 days to 3 years after users terminate their accounts or for as long as we need it to fulfill the purposes for which it was collected as detailed in this Notice. We may need to retain certain information for longer periods such as record-keeping / reporting in accordance with applicable law or for other legitimate reasons like enforcement of legal rights, fraud prevention, etc. Residual anonymous information and aggregate information, neither of which identifies you (directly or indirectly), may be stored indefinitely.
27. We will cease to retain your personal data or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.
TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
28. We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made (if permitted by law), and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.
THIRD PARTY LINKS & USE OF YOUR INFORMATION
29. Our Service may contain links to other websites that are not operated by us. This Notice does not address the privacy policy and other practices of any third parties, including any third party operating any website or service that may be accessible via a link on the Service. We strongly advise you to review the privacy policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.
COOKIES ETC.
30. To learn more about how we use these and your choices in relation to these tracking technologies, please refer to our Cookie Policy.
DATA PROTECTION OFFICER
31. You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:
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Attention To
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: Data Protection Officer
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Email Address
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: privacy@possbly.com
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Address:
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60 Paya Lebar Road, #07-54 Paya Lebar Square, Singapore 409051
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EFFECT OF NOTICE AND CHANGES TO NOTICE
32. This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
33. We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.