Privacy Policy

By accessing and using this Website that is linked to this Privacy Policy, you agree to be bound by this Privacy Policy that is in accordance with the Singapore Personal Data Protection Act 2012 (“PDPA”) and which forms an integral part of the Terms of Use governing your access and use of this Website. If you do not agree with this Privacy Policy, please discontinue your access and use to this Website immediately.

ACFA is responsible for collecting, processing, storing and safekeeping personal and other information as part of providing our services to you and the carrying out of our regular business activities. We manage personal data in accordance with applicable data protection legislation, namely the PDPA and its subsidiary regulations. Any questions regarding our processing of personal data should be directed to us via info@acfa.org.sg.

Data processing principles

We take protecting online privacy and data security seriously. Please read this entire Privacy Policy as it sets out our approach to processing personal data including what information we may collect from you, how we may use it, store it and protect it, and your rights as a data subject. This Privacy Policy outlines our approach to any kind of data processing where we are acting as a data controller or co-controller (including collection, use, transfer, storage and deletion) of personally identifiable information (any information that may be used to identify a physical person, and any other information associated therewith) about natural persons. This Privacy Policy applies to our processing of personal data collected through any means, actively as well as passively, from persons located anywhere in the world.

We are guided by the following principles when processing data:

• We will only collect personal data for specific and specified purposes;
• We will not collect personal data beyond what is necessary to accomplish those purposes; we will minimise the amount of information we collect from you to what we need to deliver the services required;
• We will collect and use your personal data only if we have business reasons for doing so, such as making available to you, our services;
• We will not use your personal data for purposes other than those for which it was collected, accepted as stated within our Privacy Policy, or with your prior consent;
• We will seek to verify and/or update your personal data periodically and we will accept requests from you for amendment of the personal data held;
• We will apply reasonable security arrangements to safeguard personal data in our possession or under our control against unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks;
• Except otherwise stated, we will not store personal data in identifiable form longer than is necessary to accomplish its purpose or as required by law.

Information that we collect

In accordance with the PDPA, we only collect and process information which we require to meet the specific purposes as stated above. The information we may collect about you could include, but is not limited to (i) full name, company name; (ii) contact details namely, email address and phone number; (iii) billing address and other shipping information; (iv) credit card or payment information; (v) personal details and identifiers; (vi) details about your occupation and business; and (vii) details about how you use this Website including technical data such as IP address.

We will only ask for information that is necessary to deliver our services, therefore, please do not to provide us with personal data or special category data, whether these relate to health data, minors or criminal convictions and investigations. Other information for instance, the name of your internet service provider, the website that you used to link to this Website, the web sites that you visit from this Website and your IP Address may be collected as well and all information so collected may be stored for various security purposes and could possibly lead to your identification. You will be informed at each collection point as to what information is required and what information is optional.

How personal data is collected, used and shared

Most of your personal data is provided directly and voluntarily by you when you engage with us to enquire about our services. We will collect personal data from you when you: (i) subscribe to our newsletter; (ii) contact us for information via our website or social media channels, by phone or email; (iii) post on our social media channels, website; or (iv) work with us in a commercial capacity.

We may also collect personal data about you from third party sources, such as when you choose to connect your social media accounts with this Website or log in through a social media platform. However, we will only use such personal data where these third parties either have your consent or are otherwise legally permitted or required to share your personal data with us.

We collect your personal data in order to make available to you, our services and to communicate with you in relation thereof. We may use the information collected to: (i) create a profile for you on our member database; (ii) send you our newsletters and/or provide you with information or services that you request from us or which we feel may interest you, where you have consented to be contacted for such purposes; (iii) respond to your enquiries about our services; (iv) ensure that content from this Website presented to you in the most effective manner for you and your computer or device; (v) notify you about changes to our services; and (vi) provide personalised content targeted to your interests.

We will not sell, lend your personal data to third parties or share your personal data for marketing purposes without your express consent. We will only share your personal data with third party service providers where necessary for rendering of our services, providing technical support or conducting of customer research or satisfaction surveys to enable us to serve you better and only where these service providers have appropriate PDPA compliant data protection systems and measures in place.

Your personal data will also not be passed on by us or by our agents for use by third parties unless we have obtained your consent or are permitted by applicable law or legally required to do so or except where it is necessary (i) for disclosure to our business partners and relevant third parties for purposes of proper operation of this Website, provision of our services; (ii) for purposes of preventing or stopping security breaches of this Website; (iii) for preventing or stopping any illegal activities from being conducted; (iv) for rendering assistance to law enforcement, government, statutory or regulatory body or authority or for complying with applicable laws pursuant to an order of court or directive of any governmental, statutory or regulatory body or authority; or (v) for our protection, purposes of national security, law enforcement or other issues of public safety and importance.

We will not give consent to third party service providers or platforms to use your information, including audio and video recordings, for purposes other than those for which the information was collected and necessary for the delivery of our services. We will not give consent for your information to be used by third party service providers for training and development of AI modelling software, or similar purposes.

Your Consent

By providing your personal data to us in the manner described above, you agree that we may store, process, disclose and use the personal data collected from you for the purposes of enabling us to provide our services and support to you.

Further, by providing information to us via the above channels and/or conducting transactions or making applications with us online through this Website, you have consented or are deemed to have consented to all the terms and conditions of this Privacy Policy, including without limitation, terms relating to the collection, use, disclosure and transfer of such information in accordance with this Privacy Policy.

How personal data is stored and transferred

We recognise the importance of keeping your personal data registered with this Website secure. We have therefore in place, appropriate and reasonable administrative, technical, physical and organisational measures to ensure the security, confidentiality, integrity and availability of your personal data with us against loss, theft, misuse, unauthorised access, disclosure, alteration and destruction.

Your information is securely stored on our cloud storage database which is not publicly accessible or stored in any public domain – it is accessible to authorised personnel only, and is password protected. Any personal data provided by you to us will be encrypted in transit to prevent its possible misuse by third parties. You however acknowledge and agree that communications through the Internet is not entirely secure and hence any information transferred to us is done at your own risk. Our security procedures shall nevertheless continuously be revised based on new technological developments.

Your personal data may also be stored on our third party email marketing platform and other authorised third party consultants who support our business. Our third-party providers have their own privacy policies which you can view on their websites.

We will retain control of and responsibility for the use of any personal data you disclose to us. We may store or process your personal data on cloud based platforms or service providers whose servers are based outside of Singapore such as the United States which may hence constitute a transfer of data. We will use our best endeavours to ensure that appropriate safeguards are in place to require the data processor in that country to maintain protection on the personal data that is comparable to the level of security and protection as required under the PDPA.

We also have in place appropriate procedures to handle any potential personal data breaches, in accordance with the PDPA. Any such breaches will be reported to the relevant regulatory authority, including the Personal Data Protection Commission (PDPC) and notified to the affected data subjects where we are legally required to do so.

We will only keep your personal data for as long as you continue to use this Website or our services or is necessary to meet the requirements for which it was collected and in the case of termination of account, for as long as required for our legitimate interests or legal purposes or as needed to provide you with information you may request, subject to our discretion to request for a nominal administrative fee (and if there are any inaccuracies, we will, upon your notification of the inaccuracies, amend the information accordingly) unless a longer retention period is required or permitted by law. The expression, “legitimate interests”, shall include without limitation to evaluative purposes, investigations, proceedings, recovery of debt, to detect or prevent illegal activities like fraud, money laundering or threats to physical safety and security, IT and network security; preventing misuse of services; and carrying out other necessary corporate due diligence.

The database and its contents remain with us and stay with data processors or servers acting on our behalf and responsible to us. The retention period will vary depending on the nature of the requirements and the processing.

How personal data is managed

Whilst we have security measures in place to protect your personal data, please do not send any other confidential or proprietary information through this Website. Please exercise caution when disclosing such confidential or proprietary information in this way. We will not be responsible for any loss or damage arising from disclosure of such confidential or proprietary information that is sent through this Website. By sending non-personal data via this Website or through any other electronic means, you grant to us an unrestricted, irrevocable license to use, reproduce, display, modify, perform and distribute such non-personal data in any manner and for any purpose as we shall deem fit. Please keep your user name and password confidential and prevent unauthorised access. We shall not in any way, be held liable for any loss or damage resulting from such unauthorised use.

For the avoidance of doubt, we retain all rights over the online tools found on this Website. However all content posted, published and/or uploaded to the Website by you to our services remain your sole property and shall be made available to you as long as comply with our legal policies herein. Please refer to our legal policies to better understand your rights and responsibilities.

Legal basis for personal data processing

The PDPA provides that processing of your data shall only be lawful if and to the extent that at least one of the following applies: (i) you have consented; (ii) for the performance of your contract with us; (iii) for compliance with a legal obligation which we must perform; (iv) to protect the vital interests of you or another person; (v) it is in the public interest; (vi) it is in the legitimate interests (described above) pursued by us or a third party; (vii) business improvement purposes; and (viii) research.

We collect personal data for the purposes set out above. All personal data is managed to ensure that it is either erased from our system when it is no longer required for the purpose for which it was collected, retained for business or legal reasons or minimised and retained.

Your legal rights

You may exercise your rights by contacting us using the details at the end of this Privacy Policy. These rights include:

• the right to obtain information regarding processing of your personal data and access to the personal data which we hold about you. If you wish to access your personal data please email us at the address provided in this Privacy Policy;
• the right to withdraw your consent to our processing of your personal data at any time. Please however allow a reasonable time for your withdrawal of consent to be effective, which in any event shall not exceed 10 business days. Please note that we may still be entitled to process your personal data if we have other legitimate interests (other than consent) to do so. Please note that the withdrawal of your consent may result in our inability to provide our services to you or the early termination of your membership contract with us;
• in some circumstances, the right to receive some personal data in a structured, commonly used and machine-readable format and/or request that we transmit those data to a third party where this is technically feasible. Please note that this right only applies to personal data that you have provided to us;
• the right to request that we correct your personal data if it is inaccurate or incomplete;
• the right to request that we erase your personal data in certain circumstances. Please note that there may be circumstances where you ask us to erase your personal data but we must retain it for legal or business reasons;
• the right to request that we restrict our processing of your personal data in certain circumstances unless continued processing without consent is required by the PDPA or other written law;
• the right to lodge a complaint with the PDPC.

Links to and from this Website

This Website contains links to and from other websites operated by third parties over which we have no direct control. If you follow a link to any of these websites, please note that these websites have their own privacy and terms of use polices. We do not accept any responsibility or liability for these policies. We advise you to check the policies of these third party sites before you submit any personal data.

Marketing emails and Newsletters

We may send you marketing emails, newsletters and communications when you have opted in or otherwise given your consent. We will make it as easy for you to opt out of unwanted processing, provided it does not restrict our ability to provide the primary service requested. Please note if you wish to unsubscribe from any marketing emails or newsletters that you have signed up for, please click the unsubscribe link found in the marketing email or newsletter sent to you. It may take 24 hours for this to become effective.

Changes to this Privacy Policy

We will update this Privacy Policy to reflect changes in our services, customer feedback or upon changes to the PDPA whichever sooner. We do not intend to process your personal data except for reasons stated herein. When we make changes to this Privacy Policy, we will revise the date at the top of this Privacy Policy. If there are any material changes to it or how we will use your personal data, we will notify by prominently posting a notice of such changes prior to implementing the change or by directly sending you a notification and giving you the opportunity to opt-out of having your personal data used or shared in that new manner. Please refer to this Website periodically to access and view our updated Privacy Policy. This ensures that you understand how we are using your personal data and your legal rights regarding our usage of such personal data. Your continued use of this Website after such changes shall be deemed acceptance of the amended Privacy Policy.

In a merger or acquisition of ACFA, customer personal data will likely form part of the assets to be transferred, in accordance with applicable laws. Any and all changes to this Privacy Policy arising from such merger or acquisition will be posted on the Website and you will be notified of the changes directly.

If you have any questions or concerns regarding our data protection or privacy policies as set out in this Privacy Policy or would like to change your communication preferences, update or review personal data we have about you or withdraw your consent for the collection, use or disclosure of your personal data or to opt out of data collection or use by third party analytics companies, including without limitation to Google Analytics or to learn more about such settings, please contact our data privacy officer by sending an email to info@acfa.org.sg and we will be happy to respond to any concerns.