1. As used in this Notice:
   
   “client” means an individual who (a) has contacted us through any means to find out more about services we provide, or (b) may, or has, entered into a contract with us for the services provided by us; and

   “personal data” means data, whether true or not, about a client 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.

   “third party” means legal persons, public authorities, agencies, and external entities.

   “process”  means any operation that is performed on personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
   
   

2. Depending on the nature of your interaction with us, categories of personal data that we may collect from you include name, email, address, telephone number, nationality, professional or employment-related information, specific business information related to you, personal preferences, and information you provide about you, etc.
   
   

3. Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).

1. Personal data collected during RDA business activities may be transferred and made available to RDA entities, service providers, and third parties as necessary to accomplish the specific business purposes for which the personal data were collected and to support our interactions with you, and otherwise as required to comply with applicable law.
   
   
2. We generally do not collect your personal data unless
   
   
   • it is provided to us voluntarily by you directly or via a third party that you have duly authorised to disclose your personal data to us (your “authorised representative”) after you (or your authorised representative) have been notified of the purposes for which the data is collected, and you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or
     
     
   • 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 that has not been notified to you (except where permitted or authorised by law).

    

3. We may collect and use your personal data for any or all of the following purposes:
   
   
   • performing obligations in the course of or connection with our provision of the services requested by you;
     
     
   • verifying your identity;
     
     
   • responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
     
     
   • managing your relationship with us;
     
     
   • to enforce our terms of use;
     
     
   • to prevent fraud against RDA, our affiliates, and/or business partners;
     
     
   • to support auditing, compliance, and corporate governance functions;
     
     
   • 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;
     
     
   • any other purposes for which you have provided the information;
     
     
   • 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
     
     
   • any other incidental business purposes related to or in connection with the above.
     
     
4. We may disclose your personal data;
   
   
   • where such disclosure is required for performing obligations in the course of or in connection with our provision of the services requested by you.
     
     
   • to third-party service providers, agents, and other organisations we have engaged to perform any of the functions concerning the above-mentioned purposes.
     
     
   • in the event of a re-organisation, merger, sale, joint venture, assignment, or other transfer or disposition of all or any portion of our business.
     
     
5. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, under a contract) has been terminated or altered in any way, for a reasonable period after that (including, where applicable, a period to enable us to enforce our rights under a contract with you).

1. We may collect or use your personal data or disclose existing personal data for secondary purposes that differ from the primary purpose, which it was originally collected for, according to clause 2. Suppose RDA intends to rely on deemed consent by notification for secondary purposes. In that case, RDA will notify you of the proposed collection, use, or disclosure of your personal data through the appropriate mode(s) of communication.
   
   
2. In particular, we may rely on deemed consent by notification to collect, use, or disclose your personal data to prevent the risk of harm to an individual; and respond to requests from law enforcement agencies, regulators, or courts.
   
   
3. Before relying on deemed consent by notification, RDA will assess and determine that the collection, use, and disclosure of personal data will not likely have an adverse effect on you.
   
   
4. 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.
   
   
5. 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 to those purposes.

1. Your consent for collecting, using, and disclosing your personal data will remain valid until you withdraw it in writing.  As a job applicant, you may withdraw consent and request us to stop collecting, using, and disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details below.
   
   
2. 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 and effect your request within ten (10) days of receiving it.
   
   
3. While we respect your decision to withdraw your consent, please note that depending on the nature and extent of your request, we may not be able to process your job application (as the case may be). In such circumstances, we shall notify you before completing the processing of your request (as outlined above). Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 10.
   
   
4. Please note that withdrawing consent does not affect our right to continue to collect, use, and disclose personal data where such collection, use, and disclosure without consent is permitted or required under applicable laws.

1. If you wish to make an access request for access to a copy of the personal data that we hold about you or information about how we use or disclose your personal data, or a correction request to correct or update any of your personal data which we hold, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
   
   
2. A reasonable fee for an access request may be charged. If so, we will inform you of the cost before processing your request.
   
   
3. We will respond to your request as soon as reasonably possible. Our response will generally be within thirty (30) business days. Should we not be able to respond to your access request within thirty (30) days of receiving your access 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 cannot provide you with any personal data or make a correction you requested, we shall generally inform you why we cannot do so (except where we are not required to do so under the PDPA).
   
   
4. Please note that depending on the request being made, we will only need to provide you with access to the personal data contained in the documents requested, not the entire documents themselves. In those cases, it may be appropriate for us to provide you with confirmation of the personal data that our organisation has on record if the record of your personal data forms a negligible part of the document.

1. 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 a minimised collection of personal data, authentication, and access controls (such as good password practices, need-to-basis for data disclosure, etc.), and up-to-date antivirus protection.
   
   
2. 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.

We generally rely on personal data provided by you (or your authorised representative). 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 in writing or via email using the contact details provided below.

1. We may retain your personal data for as long as it is necessary to fulfill the purpose for which it was collected, or as required or permitted by applicable laws.
   
   
2. We will cease to retain your personal data or remove how 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.

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 and, 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.

If you have any enquiries or feedback on our personal data protection policies, or if you would like to exercise your protection rights regarding your personal data, you can do so by emailing your request to us at touchbase@reddotassociates.com.

1. This Notice applies in conjunction with any other notices, contractual clauses, and consent clauses that apply to the collection, use, and disclosure of your personal data by us.
   
   
2. We may revise this Notice from time to time without any prior notice. You may determine if any such revision has occurred by referring to the date this Notice was last updated. Your continued use of our services constitutes your acknowledgment and acceptance of such changes.