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PRIVACY POLICY

The purpose of this document ("Privacy Policy") is to inform you of how we handle or process Personal Data (as defined below) which is subject to the Personal Data Protection Act 2012 of Singapore ("PDPA"). Please take a moment to read this Privacy 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 or services offered by us, you agree and consent to Silicon Box Pte Ltd (UEN: 202117750K) and its related corporations (collectively, the "Companies"), as well as their respective representatives and/or agents ("Representatives") (the Companies and Representatives collectively referred to herein as "SB", "us", "we" or "our") collecting, using, disclosing and sharing amongst ourselves your Personal Data, and disclosing such Personal Data to our authorised service providers and relevant third parties in the manner and for any of the purposes set forth in this Privacy Policy. In addition, this Privacy Policy will also provide you with more information on the basis upon which we may lawfully collect, use and/or disclose your Personal Data without your consent, where permitted by applicable law.


This Privacy Policy supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your Personal Data, and any consents you may have provided in connection with this Privacy Policy are cumulative and additional to any rights which we may have under applicable law to handle or process your Personal Data.


We reserve the right to update or modify this Privacy Policy from time to time, and send you notification of updates to this Privacy Policy in any form as we may deem appropriate. While you should regularly check this Privacy Policy, we may also inform you of how we process your Personal Data by publishing (or amending) this Privacy Policy and, where required by applicable law, by posting a notice, or reaching you via other forms of communication (e.g. sending you an SMS message or email, or giving you a phone call) according to such contact particulars that we may have of you in our records from time to time. You may also contact us in the manner disclosed in this Privacy Policy to learn about our handling or processing of your Personal Data.


We may from time to time update this Privacy Policy to, for example, ensure that this Privacy Policy is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. To the maximum extent permissible under applicable law, you agree to be bound by the prevailing terms of this Privacy Policy as may be updated from time to time on our website (https://www.silicon-box.com), and/or as you may be notified. Hence, please check back regularly for updated information on our handling or processing of your Personal Data.


1. PERSONAL DATA


1.1.   In this Privacy 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.


1.2   Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us), your name, email address, phone number, and any other information relating to any individuals which you have provided us in any forms you may have submitted to us (including in the form of biometric data), or via other forms of interaction with you.



2. COLLECTION OF PERSONAL DATA


2.1.   Generally, we collect Personal Data in the following ways:


(a)    when you submit an employment application or when you provide documents or information including your resume and/or curriculum vitae in connection with any appointment or position;

(b)    when you interact with our staff or Representatives, for example, via telephone calls (which may be recorded), letters, fax, face-to-face meetings and email;

(c)    when we seek information about you and receive your Personal Data in connection with your relationship with us, including for our services and/or job applications, for example, from business partners, public agencies, your ex-employer and the relevant authorities; 

(d)    when you enter into any agreement or provide other documentation or information in respect of your interactions and transactions with us, or when you purchase our goods or use our services;

(e)    when you use our electronic services, or interact with us via our websites and platforms or use services and/or features on our websites and platforms;

(f)    when you share comments or feedback with us; and/or

(g)    when you submit any form to us or provide your Personal Data to us for any other reason.


2.2    If you provide us with any Personal Data relating to a third party (e.g. information on your customers, spouse, children, parents, and/or employees), by submitting such information to us, you represent to us that you have obtained the consent of such third party to you providing us with their Personal Data, and for the collection, use and disclosure of their Personal Data for all purposes set out in our herein and by or for the benefit of the persons referenced herein. 


2.3   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 any products and/or services you have requested.



3. PURPOSES FOR THE COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA


3.1    Generally, we collect, use and disclose your Personal Data for the following purposes:


(a)    managing the administrative and business operations of the Companies and complying with internal policies and procedures;

(b)  facilitating business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving any of the Companies;

(c)   providing you with goods and/or services which you have purchased or requested to receive, or otherwise as necessary to perform any contractual obligations owed to you or third parties;

(d)   responding to, processing and handling your queries, requests, feedback and suggestions, or otherwise providing customer support;

(e)  verifying your identity or matching any Personal Data held which relates to you for any of the purposes listed herein;


(f)   managing and preparing reports on incidents and accidents, preventing, detecting and investigating crime, including fraud and money-laundering or terrorist financing, and analysing and managing commercial risks;


(g)   providing media announcements and responses;


(h)   in connection with any claims, actions or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution), and/or protecting and enforcing our contractual and legal rights and obligations;


(i)   complying with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities; and/or


(j)   any other purpose relating to or reasonably necessary for any of the above.


3.2   In addition, we may collect, use and disclose your Personal Data for the following purposes depending on the nature of our relationship:


(a)   communicating with you and informing you of changes and development to our policies, terms and conditions and other administrative information;


(b)   if you submit any application to us as a candidate for employment: (i) conducting interviews; (ii) processing your application which includes pre-recruitment checks involving your qualifications and facilitating interviews; (iii) providing or obtaining employee references and for background screening; (iv) assessing your suitability for the position applied for; (v) processing staff referrals; and/or (vi) any other purposes relating to any of the foregoing; and/or


(c)   processing of your Personal Data in relation to any of the purposes stated above.


3.3    In relation to particular products or services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use and/or disclose your Personal Data. If so, we will collect, use and/or disclose your Personal Data for these purposes as well.


4. DISCLOSURE OF PERSONAL DATA


4.1    Subject to applicable law, your Personal Data may be provided, for the purposes listed above (where applicable), to the following persons, whether they are located overseas or in Singapore:


(a)   our related corporations;


(b)   agents, contractors, vendors, and third party service providers (including software providers) who provide services to us;


(c)   any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or any debt or asset sale) involving any of the Companies;


(d)   our professional advisers such as our board of directors, auditors and lawyers;


(e)   relevant government regulators, government ministries, statutory boards or authorities and/or law enforcement agencies, to comply with any directions, laws, rules, guidelines, regulations or schemes issued or administered by any of them; and/or


(f)   any other party to whom you authorise us to disclose your Personal Data to.


5. DEEMED CONSENT


5.1    In addition to the matters set forth above, subject to and in accordance with applicable law, you shall be deemed to have consented to us collecting, using, disclosing and sharing amongst ourselves your Personal Data, and disclosing such Personal Data to our authorised service providers and relevant third parties:


(a)   where in response to a request for your Personal Data in connection with identified purposes, you voluntarily provide such Personal Data to us for such purpose(s) and it is reasonable that you would voluntarily provide such Personal Data; and


(b)   where the collection, use and/or disclosure of your Personal Data is reasonably necessary for the conclusion and/or performance of a contract, between you and us or any other organisation entered into at your request, which may include recipients of your Personal Data not indicated in this Privacy Policy.



6. OTHER BASES FOR HANDLING OR PROCESSING YOUR PERSONAL DATA

6.1    In addition to and without limiting the consents you have provided to our collection, use and/or disclosure of your Personal Data for the purposes set out elsewhere in this Privacy Policy, where permitted by applicable law, we may also in accordance the requirements thereof also collect, use and/or disclose your Personal Data as further detailed below including without consent, where we meet the requirements of applicable law:

(a)   for our legitimate interests or the legitimate interests of another person (but not for sending you direct marketing messages unless you have otherwise provided your consent), including without limitation for the following purposes:


(i)      any investigations or proceedings; 

(ii)     fraud detection and prevention;

(iii)    entering into, managing or terminating an employment relationship or appointment; and

(iv)     detection and prevention of misuse of services by users; and


(b)   we may collect your Personal Data from any of the Companies, we may use your Personal Data, and any of the Companies may disclose your Personal Data to us, for improving our products, services, processes or business, understanding customer preferences and personalising experiences and recommendations (regardless whether you have an existing or prospective relationship with any of the Companies).



7. USE OF COOKIES AND RELATED TECHNOLOGIES


7.1    You agree and acknowledge that our websites and platforms may include analytics code and other tools that may allow us to gather information on any use of any of our websites and platforms, and may include our use of cookies, running of verification and compliance analysis and/or use of data capture, syndication analysis, and/or other similar tools to track, extract, compile, aggregate, archive, disclose or otherwise analyse any data and/or information resulting from any person's access to and/or use of any of our websites and platforms, and further that: (a) we shall retain all rights, title and interest in and to all such gathered information and data; (b) you shall not disable or interfere with any such analytics code and tools; and (c) any intellectual property rights of or in the results of such analytics shall vest solely in us. For the avoidance of doubt, we may monitor, track and share with third parties your geo-location information obtained by any of our websites and platforms for safety, security, technical, marketing and commercial purposes, including to provide and improve our products and services.


7.2    For example, our websites and platforms may use cookies and other technologies. In this regard:


(a)   Cookies are small text files stored in your computing or other electronic devices when you visit our website and platforms for record keeping purposes. Cookies are stored in your browser's file directory, and the next time you visit the website or platform, your browser will read the cookie and relay the information back to the website, platform or element that originally set the cookie. Depending on the type of cookie it is, cookies may store user preferences and other information.


(b)   Web beacons (also known as pixel tags and clear GIFs) involve graphics that are not apparent to the user. Tracking links and/or similar technologies consist of a few lines of programming code and can be embedded in our websites or platforms. Web beacons are usually used in conjunction with cookies and primarily used for statistical analysis purposes. This technology can also be used for tracking traffic patterns on websites and platforms, as well as finding out if an e-mail has been received and opened and to see if there has been any response.


7.3    Without limiting the generality of the foregoing, we may employ cookies and other technologies as follows:


(a)   tracking information such as the number of visitors and their frequency of use, profiles of visitors and their preferred sites;


(b)   making our websites and platforms easier to use. For example, cookies may be used to help speed up your future interactions with our websites and platforms;


(c)   to better tailor our products and services to your interests and needs. For example, cookies information may be identified and disclosed to our vendors and business partners to generate consumer insights;


(d)   collating information on a user's search and browsing history;


(e)   when you interact with us on our websites and platforms, we may automatically receive and record information on our server logs from your browser. We may collect for the purposes of analysis, statistical and site-related information including, without limitation, information relating to how a visitor arrived at the website or platform, the browser used by a visitor, the operating system a visitor is using, a visitor's IP address, and a visitor's click stream information and time stamp (which may include for example, information about which pages they have viewed, the time the pages were accessed and the time spent per web page, your searches for hotels or experiences, bookings you have made, and other actions);


(f)   using such information to understand how people use our websites and platforms, and to help us improve their structure and contents;


(g)   using cookies that are necessary in order to enable our websites and platforms to operate, for example, cookies that enable you to log onto secure parts of our websites and platforms; and/or


(h)   personalising the website and platform for you, including delivering advertisements which may be of particular interest to you and using cookie related information to allow us to understand the effectiveness of our advertisements.


7.4    We may also collect information about your precise or approximate location as determined through data such as your IP address or mobile device's GPS to offer you an improved user experience. Most mobile devices allow you to control or disable the use of location services for applications in the device's settings menu. We may also collect this information even when you are not using the app if this connection is enabled through your settings or device permissions.


7.5    Some cookies we use are from third party companies to provide us with web analytics and intelligence about our websites and platforms. These companies collect information about your interaction with our websites and platforms. We use such information to compile statistics about visitors who interact with the websites, platforms and our other online content, to gauge the effectiveness of our communications, and to provide more pertinent information to our visitors.


7.6     If you do not agree to such use of cookies, you can adjust your browser settings. Unless you have adjusted your browser settings to block cookies, our system will issue cookies as soon as you visit our site or click on a link in a targeted email that we have sent you, even if you have previously deleted our cookies.


7.7    The way which cookies can be managed depends on your browser. Please check with your browser provider on how you may configure or disable cookies on your browser.


7.8    If you do not agree to our use of cookies and other technologies as set out in this Privacy Policy, you should delete or disable the cookies associated with our websites and platforms by changing the settings on your browser accordingly. However, you may not be able to enter certain part(s) of our websites or platforms. This may also impact your user experience while on our websites or platforms.



8. DATA SECURITY


8.1    We cannot completely guarantee the security of any Personal Data we may have collected from or about you, or that no harmful code will enter our website (for example viruses, bugs, trojan horses, spyware or adware). You should be aware of the risks associated with websites.


8.2    We cannot ensure the security of the information you transmit to us via the Internet, and we urge you to take every precaution to protect your Personal Data when you use our platforms. We recommend that you change your passwords often, use a combination of letters and numbers, and ensure that you use a secure browser.


9. THIRD-PARTY SITES


9.1    Our website may contain links to other websites operated by third parties. We are not responsible for the privacy practices of websites operated by third parties that are linked to our website. We encourage you to learn about the privacy policies of such third party websites. Some of these third party websites may be co-branded with our logo or trademark, even though they are not operated or maintained by us. Once you have left our website, you should check the applicable privacy policy of the third party website to determine how they will handle any information they collect from you.


10. CONTACTING US - QUESTIONS, FEEDBACK, WITHDRAWAL OF CONSENT, ACCESS AND CORRECTION OF YOUR PERSONAL DATA


10.1    If you:


(a)   have any questions or feedback relating to your Personal Data or our Privacy Policy, including without limitation our reliance on the legitimate interests and/or deemed consent bases of collecting, using and/or disclosing your Personal Data as described in this Privacy Policy;


(b)   would like to withdraw your consent to any use of your Personal Data as set out in this Privacy Policy; or


(c)    would like to obtain access and make corrections to your Personal Data records, please write to our Data Protection Officer (DPO) via the contact details set out below. 


10.2    You may also write to our DPO as follows:


Data Protection Officer

Silicon Box Pte Ltd

dpo@silicon-box.com


Please note that if your Personal Data has been provided to us by a third party, you should contact such party directly to make any queries, feedback, and access and correction requests to us on your behalf.


10.3    You may withdraw your consent as provided under PDPA. However, if you withdraw your consent to any or all collection, use, and/or disclosure of your Personal Data, depending on the nature of your request, we may not be in a position to continue to provide our products or services to you, administer any contractual relationship already in place, or perform or conclude an existing or prospective agreement. This may also result in the termination of any agreements you have with us, and your being in breach of your contractual obligations or undertakings. Our legal rights and remedies in such event are expressly reserved.


11. GOVERNING LAW


11.1    This Privacy Policy and your use of this website shall be governed by the laws of Singapore.


Last updated: 25/09/2024

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