1.2. This Policy applies to Personal Data in our possession or under our control, including Personal Data in the possession of organisations or persons that we have engaged to collect, use, disclose or process personal data for our purposes.
1.3. Please read this Policy carefully to understand how we will treat your Personal Data.
1.4. In this Policy, “Personal Data” means data, whether true or not, about you 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.
1.5. 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.
1.6. If you have any comments on, or questions about this Policy, please email them to Maxwell Chambers’s Data Protection Officer at [email protected].
2. What Personal Data We May Collect About You
2.1. Depending on the nature of your interaction with us, different kinds of Personal Data (that we have grouped together below) which we may collect from you include:
2.1.1. Identity Data (e.g. name, marital status, title, date of birth, gender, photograph, nationality, country of residence);
2.1.2. Contact Data (e.g. residential address, billing address, company address, postal codes, email address, telephone numbers);
2.1.3. Financial and Transaction Data (e.g. bank account and payment card details);
2.1.4. Technical Data (e.g. internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our website);
2.1.5. Usage Data (e.g. details of transactions that you carry out through our website, details of your visits to our website and the resources you use there, information that you put into forms or chatbots on our website at any time);
2.1.6. Profile Data (e.g. your username and password, subscriptions, purchases or orders made by you, your interests, preferences, feedback and survey responses);
2.1.7. Marketing and Communications Data (e.g. your preferences in receiving marketing from us and our third parties and your communication preferences); and
2.1.8. Other Data (e.g. employment information, or any record of any correspondence between you and Maxwell Chambers).
2.2. Where you do not provide us with Personal Data when requested, we may not be able to perform or conclude the contract we have or are trying to enter into with you or provide you with functions on our website or any service that requires such Personal Data.
3. How We Collect Your Personal Data
3.1. We use different methods to collect data from and about you including through:
3.1.1. Direct interactions. You may give us your Identity, Contact, Financial, and Other Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide when you:
188.8.131.52. Subscribe to our service (including, for example, our webinars or publications);
184.108.40.206. Use our website or our service (whether through this website or otherwise);
220.127.116.11. Request marketing to be sent to you; and
18.104.22.168. Give us feedback or contact us.
3.1.2. Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this Personal Data by using cookies, server logs and other similar technologies.
3.1.3. Third parties or publicly available sources. We will receive Personal Data about you from various third parties and public sources.
4. The Purposes of Collection, Use, and Disclosure of Your Personal Data
4.1. We will only collect, use, and disclose your Personal Data in the following circumstances to:
4.1.1. present website content effectively;
4.1.2. provide information about services that you request, or which we think may interest you;
4.1.3. perform obligations in the course of or in connection with our contract(s) with you or to take steps at your request prior to entering into a contract with us;
4.1.4. comply with a legal obligation to which we are subject;
4.1.5. allow you access to our interactive services on our website;
4.1.6. send you our publications and marketing materials in accordance with the subscription details and preferences that you have submitted to us;
4.1.7. tell you about our charges;
4.1.8. convey the necessary information to a potential buyer of our business; detect and prevent of misuse of services;
4.1.9. prevent, detect and deal with fraud or credit risks; and
4.1.10. convey to third party service providers, agents and other organisations we have engaged (e.g. payment processing providers, search engine facilities) to perform any of the functions with reference to the above mentioned purposes.
4.2. You can ask us to stop sending emails about services we think may interest you at any time by submitting your request via email to our Data Protection Officer at the contact details provided above at any time.
4.3. We may use your Personal Data without your knowledge or consent where this is required or permitted by law.
4.4. The purposes listed in the above clauses 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 (including, where applicable, a period to enable us to enforce our rights under a contract with you).
5. Reliance on the Legitimate Interests Exception
5.1. We may collect, use or disclose your Personal Data without your consent for the legitimate interests of Maxwell Chambers Pte. Ltd. or another person. In relying on the legitimate interests exception of the PDPA, Maxwell Chambers Pte. Ltd. will assess the likely adverse effects on the individual and determine that the legitimate interests outweigh any adverse effect.
5.2. In line with the legitimate interests’ exception, we will collect, use or disclose your Personal Data for the following purposes:
5.2.1. Fraud and credit risk detection and prevention; and
5.2.2. Detection and prevention of misuse of services.
5.3. The purposes listed in the above clauses 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 (including, where applicable, a period to enable us to enforce our rights under a contract with you).
6. Withdrawal of Consent
6.1. 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 in writing. You 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 to our Data Protection Officer at the contact details provided above.
6.2. 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 your request within ten (10) business days of receiving it.
6.3. 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 fulfil our contractual obligations to you or provide you with functions on our website or any service that requires such Personal Data. 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 via email to our Data Protection Officer at the contact details provided above.
6.4. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose Personal Data where such collection, use and disclose without consent is permitted or required under applicable laws.
7. Your Right to Access and Correct Your Personal Data
7.1. 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 to our Data Protection Officer at the contact details provided above.
7.2. 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.
7.3. 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).
8. How Your Personal Data is Protected
8.1. To safeguard your Personal Data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, and against the accidental loss of, or damage to, Personal Data, we have put in place appropriate administrative, physical, security and technical measures from the point of collection to the point of destruction. Some of the measures we have put in place are set out as follows:
8.1.1. We ensure that all our directors, employees, contractors, agents, and subcontractors comply with this Policy, and that they have access to your Personal Data on a need-to- know basis.
8.1.2. We ensure that only appropriately-trained, supervised and authorised personnel have access to the Personal Data we hold.
8.1.3. We regularly evaluate and review our collection and processing of Personal Data and the performance of employees and third parties working on our behalf, to ensure compliance with PDPA.
8.1.4. We keep internal records of the Personal Data that we collect, use and disclose, including our security measures, the purpose of our data collection, and the duration of retention of the data. We also retain details of all third parties that either collect your Personal Data for us or who we use to process your Personal Data.
8.1.5. We carry out privacy impact assessments as required by law.
8.1.6. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
8.1.7. Personal Data will only be transferred to a third-party data intermediary if there is agreement by them to comply with Maxwell Chambers’ practice and procedures.
8.2. 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.
8.3. If we give you a password in connection with any service we provide or any payment to be made, you must keep it confidential and not share it.
9. How We Keep Your Personal Data Accurate
9.1. 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 in writing or via email at the contact details provided below.
9.2. If we receive Personal Data relating to you from another source, we will check your Personal Data regularly and keep it accurate and up-to-date to the best of our knowledge. If we identify inaccurate or out-of-date Personal Data, we will take reasonable steps to amend or to erase that data.
10. How Your Personal Data is Retained
10.1. We may retain your Personal Data for as long as it is necessary to fulfil the purpose set out in this Policy, or as required or permitted by applicable laws.
10.2. 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.
10.3. It may sometimes be necessary to retain Personal Data if, for example, we are contractually bound to do so or if we have become involved in litigation or business disaster recovery in respect of which your Personal Data is relevant.
11. Transfers of Your Personal Data Outside of Singapore
11.1. We generally do not transfer your Personal Data to countries outside of Singapore. However, if we do so, 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.
12.1. We may revise this Policy 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 Policy was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.
13. Governing Law and Dispute Resolution
13.1. This Policy shall be governed by and interpreted in accordance with Singapore law.
13.2. In the event of a dispute arising out of or in connection with this Policy, the parties to the dispute (the Parties) shall use all reasonable efforts to resolve the dispute amicably.
13.3. If the dispute has not been amicably resolved within thirty (30) days of one Party giving written notice of a dispute to the other, the Courts of Singapore shall have jurisdiction over such dispute.