1. INTRODUCTION
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SingapuraManagement Pte. Ltd. and all its subsidiaries and affiliates globally (“Singapura”, “Us, “We”, “Our”) is committed to collecting, using, storing, sharing and disposing your Personal Data in a fair, ethical, transparent, secure and legitimate way, in accordance with Singapore PDPA (Personal Data Protection Act) of Singapore and other applicable Data Protection and Privacy acts, standards or regulations.Our Privacy Statement is applicable to our use of your Personal Data when interacting with our websites, social media sites, applications and other platforms (“Sites”), and describes what Personal Data we use about you, how we use it, and your rights in relation to your Personal Data.The Privacy Statement forms part of our Terms of Use governing the use of
our Sites.

2. WHAT INFORMATION DO WE COLLECT
Personal Data is any information that is related to you and can be used to identify you. For specific definitions, please refer to the PDPA and other applicable standards.

​Personal Data that we collect directly from you:

​When you use our Sites, access or download any white papers or reports in print and other media formats, subscribe to our mailing lists or newsletters, we will collect any information that you submit through that Site, including but not limited to, your First and Last Name, Email, Contact Info, Industry, Job-title/Role, Country of Residence or Work, and your Company. When you post or respond to our social media pages, we may collect information about you from your post.

• When you register and attend our events, workshops, or seminars, we will collect any information that you submit for registration, including but not limited to your Name, Email, Industry, Role, Country of Residence or Work, Company, and any additional information in our forms, video and/or audio recordings.
• When you request information from us, we may collect, including but not limited to, your Name, Email, Industry, Role, Country of Residence or Work, Company, and any additional information and Inquiry Information.
• PersonalData that we automatically collect.
  

We, and our Service Providers, may automatically collect about your use of our Sites through website cookies, web beacons, and other technologies, , including but not limited to, your domain name, your browser/operating system, webpage views, links you have accessed, language preferences, marketing preferences, IP addresses, time and length of access to our Sites, referring links that led you to our Sites, approximate locations.

• PersonalData we collect from other sources.
  

We may collect Personal Data about you from our subsidiaries and affiliated entities, from our business partners (with whom we offer our services and solutions and joint marketing programs), from public sources and databases, from our 3rd party service providers (where you have provided your Personal Data and agreed to your data being shared and used).

• We will not ask for Special Categories of Personal Data covering information relating to your health, biometric or genetic information, religion, political beliefs, union membership, race or sexual orientation.
  

Youcan choose not to provide your Personal Data to us. However, if your Personal Data is required to provide our products, services and solutions to you as required by our contract, we may not be able to provide these to you without your Personal Data.

3. WHAT IS OUR LEGAL BASIS FOR USING YOUR PERSONAL DATA

​We may rely on the following legal bases to use your Personal Data in connection with the purposes in this Privacy Statement.

• Applicable laws and regulations
• Performance of contracts
• Your consent to the use of your Personal Data
• Legitimate business interest
  

4. WHAT WE USE YOUR PERSONAL DATA FOR

Products, services, and solutions improvements. For example:

• To carry out administrative and business tasks and internal reporting, we will send administrative information to you and manage our business relationship.

We will request feedback from you regarding our products, services, and solutions, using your Personal Data solely for assessing website performance and improving operations.

• Processing your orders and delivering our products, services, and solutions to you.
• Providing timely updates about our products, services, and solutions.
• Addressing your inquiries and fulfilling any requests you make.
• Maintaining updated records and ensuring the accuracy of your contact details.
• Provide you with marketing materials and to personalize your experience. For example to:
• Distribute marketing communications to you.
• Enhance your interaction with us by offering a tailored experience.
• Facilitate your subscription to our newsletters and mailing lists.
• Empower you to manage your marketing and cookie preferences.
• Enable you to register for events, workshops, and seminars organized by us.
• Achieving our business purposes and analyse information. For example, to:
• Establish, oversee, and sustain our business association with you.
• Furnish you with details about our products, services, and solutions that might interest you.
• Aggregate usage data for our Sites.
• Handle and address privacy inquiries, questions, worries, and grievances.
• Fulfill our contractual commitments
• Research and analytical purposes. For example to:
• Gain insights into your usage patterns on our Sites.
• Enhance the quality of our products, services, and solutions.
• Assess the demand for our products, services, and solutions.
• Conduct surveys and questionnaires, including those for market research or to meet client satisfaction needs.
• Fulfil our legal obligations, such as:
  - Investigating, preventing, or addressing illegal activities or suspected fraud.
  - Investigating violations of our Terms of Use or this Privacy Statement.
  

5. HOW WE SHARE YOUR PERSONAL DATA

We may share your Personal Data with the following parties for the purposes set out in this Privacy Statement (as applicable):

Our subsidiary companies and affiliated entities:

We might disclose your information to our subsidiary companies and affiliated entities to support the operation of our business, facilitate the delivery, analysis, enhancement, security, and customization of our products, services, and solutions, send marketing and other relevant communications regarding our business, and for other lawful purposes as allowed by applicable laws or with your consent.

Authorized personnel and advisors:

We may disclose information about you to authorized Singapura staff, agents, and professional advisors, including legal advisors, auditors, and consultants working with Singapura, as necessary.

Our Service Providers:

We might disclose information about you to our service providers in instances where we have subcontracted parts of our products, services, and solutions, engaged third-party applications, services, or products, or tasked third parties with administering internal business processes at Singapura. Examples include order processing and credit card transactions, website hosting, seminar registration hosting, assistance with sales-related activities or post-sales support, and provision of customer support.

Our business partners:

Information about you may be shared with our business partners, with whom we collaborate to offer our products, services, and solutions jointly. This collaboration includes providing additional technical assistance in resolving any issues reported.

We also may share Personal Data in the following circumstances:

• As part of the contractual terms agreed upon for the Service provided.
• In connection with any joint venture, merger, sale of company assets, consolidation or restructuring, financing, or acquisition involving all or a portion of our business, to our advisors and the advisors of the other company participating in such transactions.
• To safeguard the rights, property, or safety of Singapura, its business partners, you, or others, or as otherwise mandated by applicable law.
• To comply with a request for information from a competent authority in accordance with, or mandated by, any applicable law, regulation, or legal process; or as necessary to adhere to judicial proceedings, court orders, or government directives.
• In aggregated, anonymized, and/or de-identified form that cannot reasonably identify you.
• Any Service Providers or other parties with whom we share Personal Data are contractually obligated to institute suitable physical, administrative, and technical measures to safeguard Personal Data. They are expressly prohibited from utilizing Personal Data for any purpose other than the specific purpose for which they are provided with or granted access to Personal Data by us.
  

6. HOW WE SAFEGUARD YOUR PERSONAL DATA

We are deeply committed to protecting your Personal Data from accidental or
unlawful destruction, loss, alteration, unauthorized access, or disclosure.
This dedication is maintained through a comprehensive approach encompassing
physical, administrative, and technical safeguards. Furthermore, we require our
service providers, to whom we disclose your Personal Data, to uphold similar
levels of protection.

However,it's important to acknowledge that despite our stringent security measures, we
cannot guarantee 100% security of your Personal Data. Therefore, we encourage
you to take reasonable precautions to safeguard your Personal Data, such as
refraining from sharing your passwords, selecting strong passwords, and
implementing other appropriate measures to enhance security.

​

7.HOW WE KEEP YOUR PERSONAL DATA

​

Weretain information about you for the duration necessary to fulfill the purpose
for which it was collected, unless extended retention is mandated by legal
obligations, dispute resolution, asset protection, or enforcement of rights. We
retain your Personal Data under the following circumstances:

When obligated by law, contract, or other legal obligations, or as part of an investigation for
litigation purposes.

• When your Personal Data is necessary to maintain accurate business and financial records.
• If automated means are available, allowing you to access and delete your Personal Data at any
  time
• When you have provided consent for us to retain your Personal Data for an extended period,
  aligning with your consent.
• If Personal Data is present in backups or archived copies and its removal, deletion, or destruction is
  infeasible for any reason, Singapura will retain such Personal Data in
  accordance with applicable Data Protection Laws.
• We may anonymize your information following our policies and retain these anonymized records for
  longer durations in some cases.
  
• 8.CROSS-BORDER TRANSFERS
  
• ​
  
• Wemay transfer your Personal Data to countries where we, our Service Providers or
  Business Partners do business or to international organizations in connection
  with the purposes identified above and in accordance with this Privacy
  Statement.
  When we transfer your Personal Data outside of the country from where it was
  originally collected to a third country or international organization we ensure
  that appropriate safeguards are in place, in line with applicable law, to
  ensure that your Personal Data is protected. You may obtain a copy of these
  safeguards by contacting us in accordance with the ‘How to contact us’ section
  below.
  

​

9.YOUR PERSONAL DATA RIGHTS

​

Youpossess rights under diverse data protection laws across different countries
concerning your Personal Data, and we extend these rights regardless of your
location.

Weare committed to upholding and respecting your rights, which include:

Right to be informed: You have the right to know what Personal Data we have about you, how we use
it, its source, whom we share it with, how long we retain it, and the
reasons for its necessity.

• Right of access: You have the right to access your Personal Data and obtain a copy from us.
• Right to rectification: You have the right to correct inaccurate or incomplete Personal Data about
  you.
• Right to be forgotten: You have the right to request the erasure, deletion, or destruction of your
  Personal Data.
• Right to data portability: You have the right to securely move, copy, or transfer your Personal Data
  for your own purposes.
• Right to withdraw consent: You have the right to withdraw consent regarding the use of your Personal
  Data or in relation to direct marketing activities at any time.
• Right to restrict use: You have the right to limit how we use your Personal Data.
• Right to object: You have the right to stop or prevent us from using your Personal Data, including
  objecting to its use for direct marketing or sale.
• Right to challenge automated decisions: You have the right to question and review decisions
  made about you using purely automated means.
• Right to complain: You have the right to lodge a complaint or raise concerns about how we use your
  Personal Data. Complaints can be directed to us or a relevant Data
  Protection Authority.
• When you contact us, we may request specific information from you to verify your identity, enabling us
  to search for and provide access to or a copy of your Personal Data, as
  permitted by applicable law. If allowed by law, we may charge a reasonable
  fee for access to your Personal Data; however, we will inform you of any
  fees in advance.
• Individuals may hold additional rights in certain countries, which must be recognized and
  upheld.
  
• Insome situations, we may not be required to enforce these rights, where
  permitted under applicable law. We may also have a legitimate business interest
  to decline a request to action your rights.
  

10. COOKIES AND SIMILAR TECHNOLOGIES

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When you access our Sites, we and our service providers mayuse cookies (small text files containing a unique identification number which
are placed on your PC, laptop, tablet or mobile phone) and similar technologies
including scripts, embedded web links, web beacons, Local Shared Objects and Local
Storage.

​

11. LINKS TO THIRD PARTY WEBSITES AND APPLICATIONS

​

Our websites may contain links to third-party websites andapplications. You can also engage with us through various third-party
applications, including those owned by our company or other entities like
LinkedIn, WhatsApp, Slack, Microsoft Teams, Facebook, Twitter, Google+, and
other social media platforms.
We want to emphasize that we do not assume responsibility for the security,
privacy practices, or content of these third-party websites and applications.
It's important that you review their privacy and cookie policies before sharing
any personal data. Your decision to use such websites and applications is
entirely at your own discretion and risk.

​

12. CHANGING YOUR CONSENT PREFERENCES

​

Incertain instances, you may grant Singapura consent to process your Personal
Data, such as when you opt in to receive direct marketing communications from
us. You have the flexibility to change your consent preferences at any time and
manage your communication settings where available by unsubscribing from our
communications or updating your preferences via email at admin@singapura-management.com.
Once we receive and confirm your request, we will promptly adhere to your
preferences to the best of our ability.

Even if you choose to opt out of receiving marketing-related communications
from us, you may still receive administrative messages or other essential
communications necessary for your continued use of our products, services, and
solutions, which cannot be opted out of.

We do not share your Personal Data with unrelated parties for their own direct
marketing purposes, nor do we sell, rent, distribute, or otherwise make
Personal Data commercially available to any third party.

13. CHILDREN'S PRIVACY

​

Weurge parents and guardians to actively monitor their children's online
activities. Our websites are not intended for children. If you suspect that we
have inadvertently collected Personal Data about an individual who is under the
applicable age of consent in your country without the proper consent of the
child's parent or guardian, please reach out to us.

​

14. UPDATES TO OUR PRIVACY STATEMENT

​We reserve the right to update our Privacy Statement at any time. In the event of updates, we will revise the "Version" and "Updated" details
on the Privacy Statement. We encourage you to check our Privacy Statement
periodically to stay informed about how we utilize your Personal Data and our
privacy practices.

15. OTHER PRIVACY STATEMENTS​

Further details regarding our Privacy Statement pertaining to Products, Services, Solutions, Human Resources, Finance, and other relevant aspects, as well as local territorial jurisdiction requirements, might be incorporated into distinct Privacy Terms and Conditions or other statements and notifications delivered to you. In cases of conflict, these separate statements and notifications will hold precedence for the specified situations.

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16. HOW TO CONTACT US

If you have any inquiries regarding our Privacy Statement, how we utilize your Personal Data, concerns about privacy, or if you wish to make a request or file a complaint regarding your Personal Data, please don't hesitate to contact us at admin@singapura-management.com. We are here to assist you.