The purpose of this document (“Data Protection Policy”) is to inform you of how Edhub Pte Ltd. manages Personal Data which is subject to the Singapore Personal Data Protection Act (No. 26 of 2012) (“the Act”). Please take a moment to read this Data Protection Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data.
By interacting with us, submitting information to us, or signing up for any Products and Services offered by us, you agree and consent to Edhub Pte Ltd. (including its related corporations and business units) (collectively, the “Companies”), as well as their respective representatives and/or agents (collectively referred to herein as “Edhub”, “us”, “we” or “our”) collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to the Companies’ authorised service providers and relevant third parties in the manner set forth in this Data Protection Policy.
This Data Protection Policy supplements but does not supersede nor replace any other consents you may have previously provided to Edhub in respect of your Personal Data, and your consents herein are additional to any rights which to any of the Companies may have at law to collect, use or disclose your Personal Data.
Edhub may from time to time update this Data Protection Policy to ensure that this Data Protection Policy is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of the Data Protection Policy as updated from time to time on our website. Please check back regularly for updated information on the handling of your Personal Data.
A. Personal Data
- In this Data Protection Policy, “Personal Data” refers to any data, whether true or not, about an individual 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, including data in our records as may be updated from time to time.
- Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us) your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address, network data and any other information relating to any individuals which you have provided us in any forms you may have submitted to us, or via other forms of interaction with you.
B. Collection of Personal Data
Generally, we collect Personal Data in the following ways:
- when you submit an application form or other forms relating to any of our Products and Services (defined below);
- when you interact with our customer service officers, for example, via telephone calls, letters, face-to-face meetings and emails;
- when you use some of our services, for example, websites and apps including establishing any online accounts with us;
- when you purchase or obtain third party services through us;
- when you request that we contact you, be included in an email or other mailing list;
- when you respond to our promotions, initiatives or to any request for additional Personal Data;
- when we receive references from business partners and third parties, for example, where you have been referred by them;
- when we seek information from third parties about you in connection with the Products and Services you have applied for; and
- when you submit your Personal Data to us for any other reasons.
We do not at our website automatically collect Personal Data unless you provide such information or login with your account credentials.
If you provide us with any Personal Data relating to a third party (e.g. information of your volunteers, etc), by submitting such information to us, you represent to us that you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes.
You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with the Products and Services you have requested.
C. Purposes for the Collection, Use and Disclosure of Your Personal Data
Generally, Edhub collects, uses and discloses your Personal Data for the following purposes:
- responding to your queries and requests;
- managing the administrative and business operations of Edhub and complying with internal policies and procedures;
- facilitating business asset transactions any of the Companies;
- matching any Personal Data held which relates to you for any of the purposes listed herein;
- resolving complaints and handling requests and enquiries;
- preventing, detecting and investigating crime and analyzing and managing commercial risks;
- monitoring or recording phone calls and customer-facing interactions for identity verification purposes;
- legal purposes (including but not limited to obtaining legal advice and dispute resolution);
- conducting investigations relating to disputes, billing, suspected illegal activities or fraud;
- meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on Edhub (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies and conducting audit checks, due diligence and investigations); and
- purposes which are reasonably related to the aforesaid.
In addition, Edhub collects, uses and discloses your Personal Data for the following purposes:
- opening or continuation of accounts and establishing or providing you with the Products and Services you subscribe to (including but not limited to service activation, service operations, service delivery and order processing);
- facilitating the continuation or termination of your subscription to our Products and Services (including but not limited to administering subscription arrangements, account maintenance, account closure, processing renewal of contracts and customer relationship management);
- facilitating the daily operation of the Products and Services (including but not limited to billing, customer service, customer verification, technical support, network maintenance and troubleshooting);
- managing and executing our service-level agreements with you;
- processing of payment instructions, direct debit facilities and/or credit facilities requested by you;
- enforcement of repayment obligations (including but not limited to debt collection, filing of claims and retrieval of payments from losses made by service partners);
- credit and internal risk management (including but not limited to performing credit checks and disclosures to law enforcement agencies);
- administering fee adjustments, refunds and waivers;
- analysing your use of the Products and Services so as to help us improve, review, develop and efficiently manage the Products and Services offered to you; and
- purposes which are reasonably related to the aforesaid.
In relation to particular Products and Services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.
You have a choice to withdraw your consent for receiving marketing or promotional materials/communication. You may contact us using the contact details found below.
Please be aware that once we receive confirmation that you wish to withdraw your consent for marketing or promotional materials/communication, it may take up to 30 working days for your withdrawal to be reflected in our systems. Therefore, you may still receive marketing or promotional materials/communication during this period of time. Please note that even if you withdraw your consent for the receipt of marketing or promotional materials, we may still contact you for other purposes in relation to the Products and Services that you hold or have subscribed to with Edhub.
D. Disclosure of Personal Data
Edhub will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, your Personal Data may be disclosed, for the purposes listed above (where applicable), to the following:
- Edhub’s related corporations and employees to provide content, Products and Services to you, address your questions and requests in relation to your customer accounts, subscription and billing arrangements with us as well as our Products and Services, to activate, deactivate, install, maintain and operate our systems and/or services;
- any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving any of the Companies;
- collection and repossession agencies in relation to the enforcement of repayment obligations for debts;
- our professional advisers such as auditors and lawyers;
- relevant government regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and
- any other party to whom you authorise us to disclose your Personal Data to.
E. Governing Law
This Data Protection Policy and your use of this website shall be governed in all respects by the laws of Singapore.