Last Updated: 14 November 2022
PLEASE CAREFULLY READ THIS PRIVACY POLICY, AS IT INCLUDES IMPORTANT INFORMATION REGARDING YOUR PRIVACY AND PERSONAL INFORMATION.
This privacy policy (“Privacy Policy”) applies to the Singapore Venture and Private Capital Association, its affiliated entities and their respective employees, members, directors and agents (collectively, “we”, “us” or “our”). We know you (“you”) care about your privacy and how your personal information is used and shared – and we take your privacy seriously.
This Privacy Policy applies to all of your activities on our websites, services, web and mobile applications (including www.svca.org.sg, any mobile applications and any future website or other digital service offered by us (collectively, the “Service”). This Privacy Policy describes and governs our practices regarding the collection, processing and usage of information we collect from you (“Personal Data”), which is used, disclosed and protected according to this Privacy Policy. This Privacy Policy applies to Organizers and users of our Services alike and contains provisions pertaining to each type.
This policy applies to information we collect:
· On this Service.
· In email, text, direct message, and other electronic messages between you and this Service.
· Through mobile and desktop applications you access or download from this Service, which provide dedicated non-browser-based interaction between you and this Service.
· When you interact with our advertising and applications on third-party Services and services, if those applications or advertising include links to this policy.
· When you use our Services.
· When you enter information into any of our applications.
It does not apply to information collected by us offline or through any other means.
By using or accessing the Service in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby agree that we may collect, use, and share your information as set forth below. For purposes of this Privacy Policy, the term “includes” or “including” mean including without limitation.
We reserve the right to periodically update and change this Privacy Policy and will post any changes to this Privacy Policy on this page. Thus, we encourage you to review this Privacy Policy periodically.
If you do not agree with any of the terms in this Privacy Policy, you should not use the Service.
If you have any questions about this Privacy Policy or our use of your Personal Data, please contact us by email at enquiries@svca.org.sg.
1. Use Of The Service By US and Organizers
The Service is used by us to manage our activities including servicing/managing our membership, recruiting new members, managing financial matters, disseminating information, e-mail campaigns, and planning and execution of events. The Service and your Personal Data may also be accessed and used by third-parties who are assisting us in any or all of the activities described in the preceding sentence (“Organizers”).
2. Personal Data We Collect
a) Information You Provide To Us
We collect Personal Data from you when you use the Service, including when you register for access to the Service, contact us with inquiries, use our mobile applications, respond to one of our surveys or browse any of our websites. The Personal Data we may collect includes:
· basic information: including name, date of birth, gender, address, phone number and email address;
· financial information: including credit/payment card numbers, expiration dates, credit card security codes;
· network identification information: including IP address;
· personal Internet access records: including website browsing records, software usage records and click records;
· information on computer equipment: including hardware model, device MAC address and operating system;
· employment and background information: including current employer, industry, current job title, and professional training background;
· information specific to you that may be assigned by our partners: including your advertising ID assigned by our partners;
· identification information: including ID card and passport information; and
· such other information that is available to us as a result of your use of the Service.
b) Your Location
Our Service may include location-based services, including on-site services at events. To provide such location-based services, we may collect, use and share precise location data, including the real-time geographic location of your devices (whether our Service is running in the foreground or background).
c) Other Information Collected From Your Use Of The Service
Whenever you interact with the Service, we may automatically receive and record information on our server logs from your browser or device, which may include your IP address, device identification information, Cookie information, the type of browser and/or device you are using, and the page or feature you requested (“Usage Data”). We may also transfer small files to your browser or device (“Cookies”) that allow us to collect certain information. We also use third-party services to collect usage information to better understand and improve the user experience.
3. Organizer’s Use Of Personal Data
In conjunction with an Organizer’s use of the Service, such Organizer may, through the Service or its own channels, collect the type of information noted in Section 2 above from you.
4. Email
We may use the Service (and information collected via the Service) to send emails to you. We may also allow Organizers to use our or their own email tools to contact you. So, you may receive emails from us or such Organizers. Please contact us if you wish to remove your contact information from any email lists utilized by us or one of our Organizers.
5. Our Use Of Personal Data
We may use your Personal Data for many purposes including the following:
· to operate and maintain the Service (including for the purposes of fixing malfunctions and testing our security systems);
· to provide you with the features, functions and benefits of the Service;
· to enhance, improve and further develop the Service (including creating new features or functions, refining the user experience, and increasing Service technical performance);
· to provide you with notices related to your use of the Service;
· to provide you with promotional and marketing information;
· to help personalize the Service experience for you (including remembering your information so you will not have to enter it each time you use the Service);
· to show you advertisements for products that we think may interest you; and
· for the other purposes referenced in this Privacy Policy.
We may also contract with third-parties that collect IP addresses and other information from our Service, from emails and from third-party digital services. Such third-parties may follow your online activities over time and across different websites or other online services by collecting device and usage data through automated means, including through the use of Cookies. These technologies may recognize you across the different devices you use, such as a desktop or laptop computer, smartphone or tablet. We and such third parties may use this information to provide advertisements about products and services tailored to you. You may see their advertisements on other websites or mobile applications on any of your devices. This process also helps us manage and track the effectiveness of our marketing efforts.
Aggregated Personal Data.
In an ongoing effort to understand and serve you better, we may conduct research on demographics, interests and behavior based on Personal Data that we have collected. This research may be conducted on an aggregate basis. Once Personal Data is aggregated, for purposes of this Privacy Policy, it is no longer Personal Data.
6. Sharing, Transfer And Disclosure Of Personal Data
a) Sharing Your Personal Data
We will not share your Personal Data with companies, organizations or individuals other than our affiliates, except in the following circumstances:
i) Sharing with explicit consent. We will share your Personal Data with other parties with your explicit consent.
ii) Sharing as required by laws or contractual obligations. We reserve the right to access, read, preserve, and disclose any information that we believe is necessary to comply with any law or court order; enforce or apply our terms of service and other agreements, or protect the rights, property, or safety of us, our employees, our users, or others.
iii) Sharing with our affiliates. Your Personal Data may be shared with our affiliates.
iv) Sharing with Organizers. Certain services of ours will be jointly provided together with our Organizers. We may share certain Personal Data of yours with our Organizers in an effort to provide you better customer service and user experience. We may also share your Personal Data with our Organizers so they can provide you with their services.
We may anonymize your Personal Data so that you are not individually identified, and provide that information to our Organizers. We may also provide aggregate usage information to our Organizers, who may use such information to understand how often and in what ways people use the Service, so that they, too, can provide you with an optimal online experience.
b) Transfer
Except for the purposes described above, we will not transfer the possession of your Personal Data to any company, organization or individual, except in the following circumstances:
i) we may transfer your Personal Data to other parties with your explicit consent; or
ii) in case of any acquisition, merger, insolvency or liquidation, if the transfer of Personal Data is involved, we will require the new company, organization or individual in possession of your Personal Data to continue to be bound by this Privacy Policy, or we will require such company, organization or individual to obtain your authorization and consent for any use of your Personal Data.
c) Public Disclosure
We will disclose your Personal Data to the public only under the following circumstances:
i) you have explicitly authorized us to disclose your Personal Data;
ii) disclosing your Personal Data is in the interest of national security; public health, or another major public interest;
iii) your Personal Data is relevant to any criminal investigation, prosecution, judgment, or enforcement;
iv) disclosing your Personal Data is necessary to protect yours or another individual’s life, property or other major lawful right;
v) Personal Data is disclosed voluntarily by you to the public; and
vi) Personal Data is collected from public channels, such as news reports or from public government documents.
Pursuant to applicable laws, sharing and transfer of aggregated data which cannot be recovered by the recipient to re-identify individual Personal Data does not constitute sharing, transfer and disclosure of Personal Data, and therefore it may be stored and processed without notice to you and without your consent.
7. User Rights To Personal Data
a) The Right To Access And Correct Personal Data
Please contact us if you wish to access or modify your Personal Data and other profile information.
b) The Right To Request That Your Personal Information Be Transferred
Subject to the limitations of applicable laws, where processing Personal Data is necessary for entering into or performing our obligations under a contract with you or is processed with your consent, you may request that your Personal Data be transferred to you or another designated party (where technically feasible).
c) The Right To Change Your Authorization Scope Or Withdraw Your Authorization
To the extent you have authorized us to collect and process your Personal Data, you may withdraw that authorization by deleting information, turning off device functions, or changing privacy settings on our website or in our software. You may also stop using the Service so that we cannot continue collecting your Personal Data. Please note that some parts of the Service may not function properly if you remove our authorization to collect your Personal Data. For any Personal Data that you have authorized the Organizers directly, you should contact the Organizers to withdraw such authorization.
8. Security
We take various precautions to protect your Personal Data from loss, misappropriation and misuse, and from being accessed, disclosed, modified or destroyed without permission.
In the event of any Personal Data security breach, we will, in accordance with the requirements of applicable laws, notify you of the basic information and possible consequences of such security breach, actions we have taken or will take in response to the breach, suggestions on how you may prevent and reduce risks on your own, and actions we will take on your behalf. We will notify you of the relevant information through email, letter, phone, or push notification, or by publishing an announcement to www.svca.org.sg. Any such notice will be issued in compliance with all applicable laws.
9. International Transfers Of Personal Data
a) The Location Of Your Data
Personal Data collected and generated from your use of the Service will be stored at hosting facilities located in Singapore or in cloud facilities provided by third parties in other locations. These facilities are either operated by us or our third-party providers. By using the Service, you are consenting to have this data stored, transferred and processed according to this Privacy Policy.
We are a Singapore-based organisation, but we operate global. Subject to applicable laws, we may transfer your Personal Data to any location worldwide when processing that data for the purposes described in this Privacy Policy. We may also transfer your Personal Data to our third party service providers, who may be located anywhere globally.
b) Singapore
For the purposes of the Personal Data Protection Act 2012 of Singapore (the “PDPA”), each User will be deemed to have consented to and acknowledged, under the terms of the Privacy Policy, that all Personal Data (as defined in the PDPA) provided to us or our Organizers by the User or to any of their respective agents and affiliates, may be collected, used, disclosed or otherwise processed to enable each of the aforesaid entities to carry out their respective duties and obligations in relation to the Services or as may otherwise be permitted under the PDPA.
c) California Residents
Under California Civil Code Sections 1798.83-1798.84, California residents may request a notice identifying the categories of Personal Data that we share with our affiliates and/or third parties for marketing purposes, and be provided with contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to: enquiries@svca.org.sg.
d) European Economic Area, SWITZERLAND AND UK ONLY
The EU General Data Protection Regulation (“GDPR”): In May 2018, a new data privacy law known as the EU General Data Protection Regulation became effective. The GDPR requires us to tell you about the legal grounds we are relying on to process any Personal Data about you. The legal grounds for us processing your Personal Data in conjunction with the Service will be that: (i) you provided your consent; (ii) the processing is necessary for our contractual relationship; (iii) the processing is necessary for us to comply with our legal or regulatory obligations; or (iv) the processing is in our legitimate interest in providing you with the Service.
Transfers of Personal Data: We are a Singapore based organisation, but we may need to transfer your Personal Data outside of the country from which it was originally collected. This may be intra-group or to third parties that we work with who may be in jurisdictions outside the European Economic Area (“EEA”), Switzerland and the UK, that have no data protection laws or laws that are less strict than those in the EEA, Switzerland and the UK.
Personal Data Retention/Rights: We retain your Personal Data for as long as necessary to provide you with the Service, comply with applicable laws, resolve disputes and enforce our agreements. If you have an account with us, we will typically retain your Personal Data for a period of up to seven years after your account becomes inactive or closed.
Data protection laws provide you with rights in respect to Personal Data that we hold about you, including the right to request a copy of the Personal Data, the right to request that we rectify, restrict or delete your Personal Data, and the right to unsubscribe from marketing communications.
You can exercise these rights by contacting us using the contact information set out in Section 1.
If you have a complaint about how we handle your Personal Data, please contact us as set forth in Section 1. If you are not happy with how we have attempted to resolve your complaint, you may contact the relevant data protection authority.
We act as a Data Controller and a Data Processor:
EU data protection law distinguishes between organizations that process Personal Data for their own purposes (known as "data controllers") and organizations that process personal data on behalf of other organizations or individuals (known as "data processors"). If you have any questions or complaints about how your Personal Data is handled, these should always be directed to the relevant data controller since they are the ones with primary responsibility for your Personal Data.
We may act as either a data controller or a data processor with respect to your Personal Data, depending on the circumstances. We will be a data controller of any information you submit to us in order to create an account. However, once a User submits Personal Data to an Organizer in conjunction with use of the Services, we become a data processor with respect to the Organizer Collected Personal Data.
10. Changes To This Privacy Policy
This Privacy Policy was last updated on the date set forth at the top of this Privacy Policy. We will alert you to any future updates to this Privacy Policy by placing a notice on www.svca.org.sg, by sending you an email, by notifying you when you logon to the Service, and/or by some other means. We will also edit the date at the top of this policy to reflect the date of the changes. Please note that if you have opted not to receive legal notice emails from us (or you haven’t provided us with your email address), our legal notices (including this Privacy Policy) will still govern your use of the Service, and you are still responsible for reading and understanding them. Use of Personal Data we collect is subject to the Privacy Policy in effect at the time such Personal Data is collected. If you use the Service after any updated Privacy Policy has been posted, that means that you agree to all the changes made with respect to all Personal Data, whether collected previously or in the future.
11. Minors
We do not knowingly collect or solicit personal information from anyone under the age of 14. If you are under 14, please do not attempt to register for the Service or send any personal information about yourself to us. If we learn that we have collected personal information from a person under 14, we will delete that information as quickly as possible. If you believe that a person under 14 may have provided us with personal information, please contact us at enquiries@svca.org.sg.
12. Requests To Delete Personal Data And Other Issues
a) The Right To Delete Your Personal Data
You can delete your account by contacting us at enquiries@svca.org.sg. If a User initiates a data deletion request, to the extent permitted under applicable law, we are authorized to delete or anonymize Personal Data of the requesting User from the Service. However, if you are a User, you understand that even if we delete or anonymizes your Personal Data upon your request or pursuant to this Privacy Policy, your Personal Data may still be available in the Organizer's own databases if transmitted to the Organizer prior to our taking action to delete or anonymize your Personal Data.
b) Retention Of Personal Data
Even after you remove information from your profile or delete your account, Personal Data may be retained by us on back-up servers, subject to and in compliance with applicable laws. For Organizer’s data retention policy, please contact the Organizer directly. We may retain your Personal Data for a period of time consistent with the original purpose of collection. We determine the appropriate retention period for Personal Data on the basis of the amount, nature and sensitivity of your Personal Data processed, the potential risk of harm from unauthorized use or disclosure of your Personal Data and whether we can achieve the purposes of the processing through other means, as well as on the basis of applicable legal requirements (such as applicable statutes of limitation).
We may also indefinitely retain and use any aggregated data derived from or incorporating your Personal Data.