DATA PROTECTION POLICY

Data protection policy of SJP Sealing Technology (S) Pte. Ltd. and its related companies

Effective Date: 01 May 2022

This data protection policy applies to SJP Sealing Technology (Singapore) Pte Ltd and its related companies which are established in Singapore (“SJP” or “we”). This policy governs the collection, use and disclosure of personal data submitted to SJP including through the webpages of sjpsealtech.com, and explains how we collect and handle personal data of individuals and comply with the requirements of the Personal Data Protection Act 2020 of Singapore and its regulation(s) (“The Act” or “PDPA”). In this policy, “personal data” shall have the meaning ascribed to it in the PDPA.

SJP shall also comply with the requirements in a number of ways including through this policy. We also have other policies which deal with data protection, which may be in connection with specific functions or business activities. For more information about: please refer to our (i) Recruitment Data Protection Policy, and our (ii) Marketing Data Protection Policy.

This policy does not override data protection requirements in the other above-mentioned policies to the extent those requirements are in addition to the requirements of this policy or protect personal data to at least the same standard as this policy. This policy overrides the data protection requirements in the other above-mentioned policies to the extent this policy imposes additional requirements or requires a higher standard of protection of personal data. For the avoidance of doubt, nothing herein shall require SJP to act in breach of applicable Singapore laws.

MAIN DATA PROTECTION POLICY

Summary

We will collect, use or disclose personal data for reasonable business purposes only if there is consent or deemed consent from the individual and information on such purposes have been notified. We may also collect, use or disclose personal data if it is required or authorized under applicable laws.

Collection of Personal Data

We collect personal data from clients, customers, business contacts, partners, personnel, contractors and other individuals. Such personal data may be provided to us in forms filled out by individuals, face to face meetings, email messages, telephone conversations, through our websites or provided by third parties. If any individuals contact us, we may keep a record of that contact.

We collect these personal data when it is necessary for business purposes or to meet the purposes for which the individuals have submitted the information.

We will only collect, hold, process, use, communicate and/or disclose such personal data, in accordance with this policy. If any party is acting as an intermediary or otherwise on behalf of a third-party individual or supplying us with information regarding a third-party individual (such as a friend, a colleague, an employee etc), such intermediary party undertakes that you are an authorized representative or agent of such third-party individual and that you have obtained all necessary consents from such third-party individual to the collection, processing, use and disclosure by us of their personal data. Because we are collecting the third-party individual’s data from you, you undertake to make the third party individual aware of all matters listed in this policy preferably by distributing a copy of this policy to them or by referring them to our website.

Use of Personal Data

We use personal data for the following purposes:

  • to provide our services
  • to respond to the individual’s request or for the purposes for which it was provided to us as stated at the time of the collection (or as is obvious from the context of collection)
  • to maintain contact with clients and other contacts
  • to keep clients and other contacts informed of the products and services we offer, industry developments, seminars, exhibitions and other events we are holding, that may be of interest to them
  • for general management and reporting purposes, such as invoicing and account management
  • for recruitment purposes
  • for purposes related to the employment of our personnel and providing internal services to our personnel
  • all other purposes related to our business.

Any individual may choose to unsubscribe from mailing lists, registrations, or elect not to receive further marketing information from us by contacting our Data Protection Officer, or if we have contacted such individual by email, such individual may use the unsubscribe function in that email to notify us. Such requests will be processed within 30 days.

Disclosure of Personal Data to Third Parties

We do not disclose personal data to third parties except when required by law, when we have the individual’s consent or deemed consent or in cases where we have engaged third parties such as data intermediaries or subcontractors specifically to assist with our company’s activities.  Any such third parties whom we engage will be bound contractually to keep all information confidential.

We may disclose personal data to other SJP group of companies, where it is necessary (i) to meet the purpose for which such individual has submitted the information; or (ii) to enable such individual to be provided with information at a later date which may be of relevance and interest to such individual based on the nature and purpose of such individual’s voluntary requests.  We may also transfer all data in our possession to a successor-in-interest to our business or assets.

Access to and Correction of Personal Data

Upon request, we will provide the individual with access to their personal data or other appropriate information on their personal data in accordance with the requirements of the PDPA.

Upon request, we will correct an error or omission in the individual’s personal data that is in our possession or control in accordance with the requirements of the PDPA.

We may charge for a request for access in accordance with the requirements of the PDPA.

Withdrawal of Consent

Upon reasonable notice being given by an individual of his withdrawal of any consent given or deemed to have been given in respect of our collection, use or disclosure of his personal data, we will inform the individual of the likely consequences of withdrawing his consent. We will cease (and cause any of our data intermediaries and agents to cease) collecting, using or disclosing the personal data unless it is required or authorized under applicable laws.

Accuracy of Personal Data

We will make a reasonable effort to ensure that personal data collected by us or on our behalf is accurate and complete.

Security and Protection of Personal Data

We have implemented generally accepted standards of technology and operational security to protect the personal data in our possession or under our control and to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks. All SJP personnel follow a network-wide security policy. Only authorized SJP personnel are provided access to personally identifiable information and these personnel have agreed to ensure confidentiality of this information.

Retention of Personal Data

We will cease to retain personal data, as soon as it is reasonable to assume that the purpose for collection of such personal data is no longer being served by such retention, and such retention is no longer necessary for legal or business purposes.

Transfer of Personal Data outside of Singapore

We will ensure that any transfers of personal data to a territory outside of Singapore will be in accordance with the PDPA so as to ensure a standard of protection to personal data so transferred that is comparable to the protection under the PDPA.

Privacy on Our Websites

This Policy also applies to any personal data we collect via our websites. Cookies may be used on some pages of our websites. “Cookies” are small text files placed on your hard drive that assist us in providing a more customized website experience. Cookies are now used as a standard by many websites to improve users’ navigational experience. If individuals are concerned about cookies, most browsers permit individuals to decline cookies. In most cases, a visitor may refuse a cookie and still fully navigate our websites, however other functionality in the site may be impaired. After termination of the visit to our site, a visitor can always delete the cookie from his system if he wishes.

Because we want visitors’ website experience to be as informative and resourceful as possible, we may provide a number of links to third party websites. We assume no responsibility for the information practices of these third-party websites that visitors are able to access through ours. When a visitor to our website links to these third-party websites, our privacy practices no longer apply. We encourage visitors to review each website’s privacy policy before disclosing any data.

Report Data Breach / Raise Your Concern

If you have any concern about the way in which we have processed personal data about you or that refers to you – that is, if you feel we have not complied with this Policy and/or with the applicable PDPA please let us know. Please include the following:

  • sufficient contact details to enable us to identify you
  • clear and succinct details about the nature of the complaint – for example, what happened, when you became aware of it and who was involved
  • an outline of the impact the event that happened has had on you and
  • details of what you would like to see happen to resolve your complaint

We will acknowledge receipt of your concern as soon as practicable. Then we will investigate it. We may need to obtain further information from you, speak to relevant staff members, review relevant documents and/or obtain legal or technical advice to do our investigation. Once we have completed our investigation, we will write to you to let you know the outcome of the investigation.

Data Protection Officer

If an individual believes that information we hold about him is incorrect or out of date, or if an individual has concerns or further queries about how we are handling his personal data, or any problem or complaint about such matters, please contact our Data Protection Officer as follow:

  • By letter : 29 Tech Park Crescent Singapore 638103
  • By email : info@sjpsealtech.com
  • By phone : +65 6296 8333

Modifications

We reserve the right to modify or amend this Policy at any time. The amended Data Protection Policy will come into effect from the date that displayed at the beginning of this Policy.

RECRUITMENT DATA PROTECTION POLICY

SJP group of companies which are established in Singapore (“SJP” or “we”) believe that privacy is an important individual right and this policy provides information regarding our use and disclosure of personal data collected from individuals including via our websites for recruitment purposes. SJP’s information handling practices are in accordance with current privacy and data protection legislation in Singapore.

For more general information about the data protection practices of SJP, please refer to our Main Data Protection Policy.

Why do we collect personal data?

As part of our recruitment process, we collect necessary personal data about you to consider you for employment with our company. During the course of the recruitment and selection process, we may request further information about you to assess your suitability for positions with our company. In doing so, we only collect personal data that is necessary for recruitment decisions. The procedures used by the company to gather further information about you might include:

  • selection interviews;
  • assessment centres;
  • written skills tests;
  • referee reports;
  • security vetting; and,
  • necessary pre-employment activities.

References from your current or former employer(s) or other sources will only be obtained with your consent. In some cases, pre-employment checking may be necessary. Any checking is “tailor-made” and the extent and nature of information sought is no more than is justified by the particular position being filled. Failure to provide requested information may influence the processing and outcome of your application.

How do we use personal data?

We use the personal data for the following purposes:

  • managing your application(s) for employment, evaluating you for open positions, and managing your candidate profile;
  • evaluating your suitability for employment with SJP (including for example providing your personal information to third parties to conduct background checks);
  • sending you email notifications and other announcements, requesting additional information, or otherwise contacting you about your candidacy;
  • conducting statistical analyses and reports including for example, demographic analyses of candidates, reports on SJP recruitment activities, and analyses of candidate sourcing channels; and
  • relating to any other purposes for which you provided the information to SJP.

We will not collect or use personal data in ways other than as described in this policy unless we have obtained your consent. In some cases, we may specifically request a consent form to be signed. In other cases consent may be implied (for instance, you give us information after being fully advised of how it will be used).

Cookies and log files

This policy also applies to any personal data we collect via our websites. Cookies may be used on some areas of our website. “Cookies” are small text files placed on your hard drive that assist us in providing a more customized website experience. Cookies are now used as a standard by many websites to improve users’ navigational experience. If you are concerned about cookies, most browsers permit individuals to decline cookies. In most cases, a visitor may refuse a cookie and still fully navigate our websites, however other functionality in the site may be impaired. After termination of the visit to our site, you can always delete the cookie from your system if you wish.

In order to properly manage our website and related email services, we may anonymously log information on our operating systems about the number and duration of visits to our website and identify categories of visitors by items such as domains and browser types, and to track document identification number by way of email acknowledgement or return receipt. These statistics are reported in the aggregate to our webmaster and system administrators. In addition, site statistics are compiled by third parties, and therefore your IP address will be passed to third parties for statistical reporting only. This is to ensure that our website presents the best web experience for visitors and is an effective information resource.

Whenever a registered person visits our website, they may be required to identify themselves in order to gain entry. This data is logged by SJP primarily to measure website performance and in assisting to resolve any website technical difficulties.

Disclosure of personal data

Your personal data will be used only by management and staff directly involved in the recruitment process. Information will not be disclosed to third-parties except when required by law, when we have your consent or in cases where the third-party is a contractor or supplier whom we have engaged specifically to assist with our company’s activities. All such contractors will be bound contractually to keep all information confidential.

Transfer of Data to Other Countries

Personal data collected by SJP may be transferred internationally to our related companies, where it is necessary to meet the recruitment purposes. By submitting your personal data to SJP whether through our websites or otherwise, you are providing explicit consent to transborder transmission of such data collected by SJP whether through our websites or otherwise for the fulfilment of recruitment applications.

How is this information secured?

SJP has implemented generally accepted standards of technology and operational security in order to protect your personal information from loss, misuse or destruction. In particular, SJP has put in place appropriate confidentiality obligations and technical and organizational security measures to prevent any unauthorized or unlawful disclosure or processing of such information and the accidental loss or destruction of or damage to such information.

How long is information kept?

SJP must process your personal data in order to consider you for a position as part of the recruitment process, if you revoke your consent, SJP may need to terminate your application. SJP may retain certain information related to your application for a reasonable but limited period to meet applicable legal or records retention requirements. To request us to delete your personal data submitted to SJP whether through our websites or otherwise, please send your request to info@sjpsealtech.com.

Access to your personal data can be made by request to us unless granting access would infringe another person’s privacy. If you wish to gain access to your personal data, please send your request to info@sjpsealtech.com.

Correction and Concerns

If you believe that information we hold about you is incorrect, if you have concerns about how we are handling your personal data, or if you changed your mind about our usage of your data, please email us at info@sjpsealtech.com and we will try to resolve those concerns.

Changes to the SJP group of companies Recruitment Data Protection Policy

SJP reserves the right to modify or amend this policy at any time and for any reason. However, SJP commits to ensure that the privacy rights of individuals are maintained.

In order to keep visitors informed, SJP will ensure that we notify users of changes to our Recruitment Data Protection Policy by identifying the effective date at the beginning of this policy.

MARKETING DATA PROTECTION POLICY

SJP group of companies which are established in Singapore (“SJP” or “we”) believe that privacy is an important individual right and this policy provides information regarding our use and disclosure of personal data collected from individuals including via our websites for marketing purposes. SJP’s information handling practices are in accordance with current privacy and data protection legislation in Singapore.

For more general information about the privacy practices of SJP, please refer to our Main Data Protection Policy.

Why do we collect personal data and how do we use it?

The personal data submitted to SJP will be used by the SJP for the purposes of any relevant promotional activities organized by the SJP such as, but not limited to, seminars, exhibitions, company events and news alerts on publications. We may also send you communications from time to time, for example, to advise you of technical updates or ask you to participate in surveys which may be of interest to you. By submitting the information in this website, you acknowledge that you have consented to our processing data in accordance with the privacy statement for the purposes described.

Retention of Personal Data

Personal data which is kept by SJP will be destroyed after a reasonable period from the time when it becomes outdated or is no longer required for the purpose for which it was collected or when we receive your request to delete it.

How is this personal data secured?

The personal data submitted to SJP is stored in our contacts database or similar system and is available to only authorized SJP management, staff, and contractors.

Access to and Correction of Personal Data

If you wish to access, delete or correct your personal data provided to us or if you have any concerns about how we handle information about you, please send your request to our Data Protection Officer at info@sjpsealtech.com.

Upon request, we will provide the individual with access to their personal data or other appropriate information on their personal data in accordance with the requirements of the PDPA.

Upon request, we will correct an error or omission in the individual’s personal data that is in our possession or control in accordance with the requirements of the PDPA.

We may charge for a request for access in accordance with the requirements of the PDPA.

Withdrawal of Consent

Upon reasonable notice being given by an individual of his withdrawal of any consent given or deemed to have been given in respect of our collection, use or disclosure of his personal data, we will inform the individual of the likely consequences of withdrawing his consent. We will cease (and cause any of our data intermediaries and agents to cease) collecting, using or disclosing the personal data unless it is required or authorized under applicable laws.

Transfer of Personal Data outside of Singapore

Personal data collected may be transferred and shared internationally between the SJP group of companies, in order to meet the purpose for which you have submitted the information and activities directly related to it. By submitting personal data in this website, you are providing explicit consent to trans-border transmission of such data as described above. We will ensure that any transfers of personal data to a territory outside of Singapore will be in accordance with the PDPA so as to ensure a standard of protection to personal data so transferred is comparable to the protection under the PDPA.

Cookies, Log files and Social Plugins

This policy also applies to any personal data we collect via our websites. Cookies may be used on some areas of our website. “Cookies” are small text files placed on your hard drive that assist us in providing a more customized website experience. Cookies are now used as a standard by many websites to improve users’ navigational experience. If you are concerned about cookies, most browsers permit individuals to decline cookies. In most cases, a visitor may refuse a cookie and still fully navigate our websites, however other functionality in the site may be impaired. After termination of the visit to our site, you can always delete the cookie from your system if you wish.

We may use so-called social plugins from various social networks, such as ‘Like’, ‘Share’ and ‘Comment’ buttons made available by Facebook and LinkedIn. When you use a social plugin, internet browser creates a direct connection to the relevant social network’s server. The result is that the relevant social network provider receives the information that your internet browser accessed from the site on which we make our best offer to you. This happens even if you do not have a user account with the relevant social network provider or are currently not logged into your account. Log files (including the IP address) are, in this case, directly transmitted from your internet browser to a server of the relevant social network provider and might be stored there.

Social plugins are standalone extensions by social network providers. For this reason, we are unable to influence the scope of data collected and stored by them. The purpose and scope of the collection of data by a social network, the continued processing and usage of that data by the social network as well as your respective rights and setting options to protect your privacy can be found by consulting the relevant social network’s data protection notice.

In case you do not wish social network providers to receive and, if applicable, store or use data, you should not use the respective plugins.

Disclosure of Data to Third Parties

The personal data submitted will not be disclosed to third parties except when required by law, when we have your explicit consent or in cases where the third party is a contractor or supplier whom we have engaged specifically to assist with the company’s activities. All such contractors will be bound contractually to keep all information confidential.

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