Privacy Policy

We are committed to protecting the privacy and security of personal data. This policy tells you how we will collect and use your personal data, and what you should expect in respect of the personal data about you that we have collected. We are Sanden International Singapore Pte Ltd (registered in Singapore with Company No: 197702864G). Our Registered Office is at Sanden House, 25 Ang Mo Kio Street 65 Singapore 569062. We have appointed a person with responsibility for our data protection compliance (Personal Data Protection Manager, “PDM”) who can be contacted via email at dataprotection@sanden.com.sg. We are responsible for the personal data that we keep and use, and for making sure that our systems, processes and people comply with the relevant data protection laws in respect of that personal data. You can request for access to your personal data, that inaccurate data is rectified or withdraw consent to our processing of your personal data. We reserve the right to refuse any request and continue to process your personal data to the extent permitted or required by law. If you have a complaint or other concern about our handling of your personal data, please raise it by contacting the PDM as set out above. Please provide sufficient details explaining your concern and how we may contact you. We will investigate the issues raised and endeavor to respond to you as quickly as possible.

COLLECTION AND USE OF PERSONAL DATA
We collect and process data for the following reasons:
1. personal data collected and created in relation to our providing our products and services or information about them; and
2. personal data relating to people who have asked to attend events run by us, receive our newsletters and other information services or marketing materials; and
3. personal data relating to our people (which means those people working for our company, or providing services to us, or potentially working or providing services to us, including employees, consultants, temporary or casual workers and contractors).

1. Providing products and services
COLLECTION:
We will collect information which may include names, phone number, email address and any message. This will be done for the management of the commercial relationship with our customers. We may collect this information from you directly, and also from third parties, including publicly available third party sources. Additional personal data will be collected as it is created by or supplied to us. We will also collect information, including name and contact information, for individuals with whom we have a business relationship related to our supply of products or services.
USE:
We will use this information to provide information relating to and the supply of our products and services, including for the necessary administration of the relationship with our customer, and to comply with requirements that we are required or recommended to undertake, whether by statute or otherwise, such as credit checks. We will only use your personal data with your consent or when the law otherwise allows or requires us to.

2. Our events, newsletters, other information services & marketing materials (“our Communications”)
COLLECTION:
We will collect information such as name, email address, IP address (or similar unique identifiers) job title and the business that you work for together with the additional information that you provide to us, for example when you let us know those products or services that you are interested in receiving information about. In respect of events that we offer, this information may include details of any access or dietary requirements that you have, which may reveal information about the health or religious beliefs of an individual. We may collect this information from you (whether directly or via automated means such as our website) or from third parties. We will collect personal data in our CRM system when you tell us that you wish to receive all or part of our Communications, or otherwise give us your personal details. You may at any time tell us that you wish to stop receiving our Communications.
USE:
Personal data will be used to provide you with our Communications that you ask for, or that we think are relevant to the preferences that you may have given to us. We may analyse what areas of information are of interest to you so that we can better target our Communications that we provide. We will only use your personal data when the law allows or requires us to or with your consent.

3. Our people
COLLECTION:
For employees, as necessary for the employment role, we may collect names, addresses, contact details, education and employment history, identity and other background checks, marital status and information on next of kin and dependents, financial information (such as bank details and National Identification numbers), date of birth, gender, a copy of your passport and driving licence, performance information and compensation history, recruitment information (including references), salary, benefits, pension and annual leave information, disciplinary and grievance information, photographs, information about your use of our information and communications systems and CCTV footage or other information obtained through electronic means. We may collect and use categories of sensitive personal data including information relating to matters such as health, national origin, philosophical or moral beliefs and offences or alleged offences only for the purposes set forth below and subject to the relevant laws. Personal data may be collected from you during the selection process (for example via your application form and CV) and during your employment (including holiday forms, expense claims, performance reviews, any disciplinary or grievance processes), or from third parties, including referees, health service providers, background check providers. We will not collect all of the above-mentioned data from all job applicants. As a job applicant progresses through the selection process, we will collect additional personal data as needed to consider whether to make a job offer to the applicant and, if an offer is accepted, to then obtain all details needed to process a new employee.
USE:
Personal data of our people will be used for HR administration and management, both in respect of the selection of people to work for us (including suitability, eligibility and/or fitness to work), and those who do work for us, to include learning and development, disciplinary and security (of people, offices and data) requirements, providing and liaising with benefits providers, business management and planning (including accounting and auditing), paying you and dealing with tax, assessing and deciding on salary reviews and compensation, conducting performance reviews and managing performance, dealing with legal disputes involving you or others, preventing fraud, monitoring your use of our information and communications systems, ensuring compliance with our policies, and equal opportunities monitoring. We will only use your personal data with your consent or when the law allows or requires us to including to manage or terminate the employment relationship or where necessary for any investigation or proceedings. In respect of all disclosures of personal data, we will only share the personal information which is necessary for the particular purpose for which it is provided, or where it is otherwise required or permitted by law. The categories of sensitive personal data may be used in the following ways:
• in relation to leaves of absence, to comply with employment and other laws;
• in relation to your physical or mental health, or disability status, to ensure your health and safety in the workplace and to assess your fitness to work, to monitor, manage and administer benefits and absences;
• in relation to your national origin, philosophical or moral beliefs to ensure meaningful equal opportunity monitoring and reporting.

DISCLOSURE OF PERSONAL DATA
We may share personal data with third parties as is necessary to :
(a) supply of our products and services, including to third party providers who deliver services to support the operation of our business;
(b) provide Communications, including to third parties who provide goods or services to us, including IT, website hosting, email delivery and other services;
(c) service providers who support the operation of our business (such as payroll service providers); and
(d) other third parties reasonably necessary in the conduct of our business (including insurers, professional advisors, regulators).
In respect of all disclosures of personal data, we will only share the personal information which is necessary for the particular purpose for which it is provided, or as otherwise permitted or required by law. To the extent within our control, we will ensure that the personal data is appropriately protected.

RETENTION PERIOD
We will keep personal data only for as long as is necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting or reporting requirements, or until retention is no longer necessary for any legal or business purpose.

CHANGES TO YOUR PERSONAL DATA
It is very important that the personal information that we hold about you is accurate and current. Please tell us if your personal information changes during your relationship with us.

DATA SECURITY
We have put in place reasonable security measures to prevent your personal data from unauthorised loss, use or access, alteration or disclosure. In addition, we limit access to your personal data to those of our people and other third parties who have a business need to know. They will only process your personal data on our instructions and where they have agreed to treat the information confidentially and to keep it secure. We have put in place procedures to deal with any suspected data security breach and will notify you and the competent data protection regulator of a suspected breach where we are legally required to do so.

WHERE WE STORE YOUR PERSONAL DATA
We principally store data, both electronically and on file, at our offices, with archive storage for files locally. Personal data may be transferred outside of Singapore. We will ensure that your personal data continues to receive a standard of protection that is comparable to the protection provided under the PDPA.

YOUR RIGHTS
Under certain circumstances, you have the right by law to:
• request access to your personal data. This enables you to ask to receive a copy of or access to the personal data that we hold about you including information about the ways in which the personal data has been or may have been used or disclosed in the year before the request was made.
• request correction of any error or omission in the personal data that we hold about you, and, if necessary, to have the corrected personal data sent to every other organisation which the personal data was disclosed to by us in the past year.
• withdraw consent that was given to us for the processing of your personal data.
We may refuse an access or correction request or continue to collect, use and disclose personal data without your consent if required by law or if we are legally permitted do so.

LINKS FROM OUR WEBSITE
Our website may, from time to time, contain links to and from the websites of third parties that we permit to make such links. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. We recommend that you check these policies before you submit any personal data to these websites.

CHANGES TO THIS PRIVACY POLICY
Any changes we may make to our privacy policy in the future will be posted on our website, so please ensure that you are viewing the correct version. Please contact us if you have any questions, comments or requests regarding this Privacy Policy.