PRIVACY POLICY

We, KBT Consulting Pte. Ltd., (hereinafter "us", "we" or "our") are committed to protecting your personal data in accordance with the Personal Data Protection Act 2012 (“PDPA”) of Singapore. This privacy policy (“Privacy Policy”) describes how we handle information we obtain when you access and use our website, our services or communicate with us (hereinafter collectively referred to as “Services”).

By submitting any personal data to us and by using our Services, you acknowledge that you have read this Privacy Policy and that you consent to us collecting, using and disclosing your personal data in accordance with the terms of this Privacy Policy.  If you do not consent to the terms of this Privacy Policy, please do not access or use our Services or provide your personal data to us.

We reserve the right to update this Privacy Policy from time to time. Any changes to this Privacy Policy will be posted to this page and will come into effect on the date of posting. Your continued use of our Services will be taken as acceptance of any such change. You are therefore encouraged to check this page regularly.


What is “Personal Data”?

“Personal Data” means data, whether true or not, about an individual who can be identified from that data or from that data and other information to which we have access to.

We do not knowingly solicit information from or market to children under the age of 13. If you become aware of any data we have collected from children under age 13, please contact us using the contact information provided below.


What isn’t Personal Data?

Please note that “business contact information” is not covered by the PDPA and this Privacy Policy. “Business contact information” refers to an individual’s name, position name or title, company name, business telephone number, business address, business electronic mail address or business fax number and any other similar information about the individual, not provided by the individual solely for his/her personal purposes.

Information we collect

We may obtain information about you in a variety of ways, such as when you voluntarily provide it to us, or when it is automatically sent to us by the device you use to access the Services.

When you use the Services or engage in certain activities, such as registering for an account, requesting for Services or information, contacting us directly, we may ask you to provide and/or collect some or all of the following types of information:

  1. Identification number or passport number;

  2. Mobile telephone number;

  3. Personal email address;

  4. Residential address;

  5. information about the Service you have requested;

  6. information from enquiries you have made;

  7. communications between us;

  8. Information from your use of our website


When do we collect your Personal Data?

We will only collect your Personal Data where it is reasonable and appropriate to do so in the circumstances.

Depending upon the Service you wish to use, some of the information we ask you to provide are identified as mandatory and others are optional. If you do not provide the mandatory information with respect to a particular Service, we will not be able to process your request. By submitting your Personal Data to us, you warrant that all Personal Data submitted to us is complete, accurate, true and correct. Failure to ensure that such data provided to us is complete, accurate, true and correct may result in inability on our part to provide you with the Services.

If you provide Personal Data to us on behalf of another person, you warrant that you have obtained consent from that person to provide such Personal Data on his/her behalf, and you agree to indemnify and hold us harmless from any breach of such warranty.


For what purposes do we collect, use or disclose your Personal Data?

We may collect, use or disclose your Personal Data when you use our Services for the following purposes:

  1. To provide you with access to our Services;

  2. To improve your experience while using our Services including providing customisations, features and advertising;

  3. To comply with legal and regulatory requirements;

  4. To monitor suspicious or fraudulent activities and to identify violations of policy;

  5. To respond to your queries, requests, feedback or complaints;

  6. To communicate with you for marketing, research, survey or promotional purposes;

  7. To inform or update you of other products or services available from us (such as event invitations, newsletters or publications and marketing materials) and/or our partners/affiliates, where you have consented to be contacted for such purposes;

  8. To update you on changes to our website and/or Services.

  9. To enforce our legal rights and obligations;

  10. To carry out market research and surveys;

  11. To conduct investigations or audits or carry our crime and fraud prevention and risk management activities; and

  12. Any other purposes necessary and/or incidental to any of the above purposes.

We will only collect and use your Personal Data with your consent or deemed consent or as otherwise permitted under the PDPA or other applicable laws and regulations, and for purposes which you have consented to, or where we believe it is necessary to protect or legal rights.  We may also use information about you in connection with legal claims, regulatory issues, audit function, merger or funding.


Who do we share your Personal Data with?

We do not use or share Personal Information for any purpose other than for the purpose for which it was disclosed. In the course of providing you with our Services, your Personal Data may be disclosed to the following third parties for the purposes listed above (which are non-exhaustive):

  1. our agents, contractors or service providers who have been engaged by us to provide services such as payment processing, data processing, marketing etc. and their respective service providers, business partners and agents;

  2. professional advisors engaged by us such as lawyers, auditors, advisors to help us perform statistical analysis;

  3. financial institutions, government authorities or law enforcement agencies or other entities as required under applicable law;

  4. any party to whom you authorise us to disclose your Personal Data.

  5. any of our partner/ affiliate/ subsidiary, which may contact you for the purpose of offering their services/ product that may be of interest to you.

We will not disclose and/or transfer your Personal Data without your consent. We may disclose and/or transfer your Personal Data to a third party only if:

(a) the disclosure or transfer is necessary for the provision of the Services, in connection with legal proceedings, advice or rights, or required by any law or regulation to which we are subject;

(b) if a contract has been concluded between us and the relevant third party that provides for safeguards at a similar protection as provided by this Privacy Policy or by applicable law (including the PDPA);

(c) such third party has implemented binding corporate rules or a similar transfer control mechanism which provide adequate safeguards under applicable law.

All such third parties to whom Personal Data is disclosed and/or transferred are required to:

(a) maintain the confidentiality of your Personal Data in accordance with applicable laws (including the PDPA);

(b) use and process Personal Data only in accordance with our instructions and for purposes authorized by us; and

(c) take appropriate technical, physical and organizational security measures to protect the Personal Data.

Where we have your express or implied consent, or where we are otherwise permitted by law, we may use your Personal Data to send you information about the services we offer, as well as other information. We may send this information in a variety of ways, such as by mail, email, SMS, telephone, social media or by customising online content and displaying advertising on our website. If you do not wish to receive these communications, you can opt out at any time by contacting us.

We may also collaborate with other third parties to organise joint marketing and promotional campaigns, which may require us to disclose your information to such third parties. However, you may not be able to enjoy the promotion, offer or participate in the contest, unless you consent to disclosure of your information to our affiliate/ partner/ subsidiary.

We may also subcontract processing to, or share your Personal Data with third parties located in countries other than Singapore. You agree that we may transfer your Personal Data to our affiliates, subsidiaries and/or other third parties located outside of Singapore, as long as the Personal Data is handled in accordance with this Privacy Policy and all applicable laws. We will take all appropriate steps to ensure that any party in a country or territory outside Singapore to whom we transfer Personal Data is bound by legally enforceable obligations to provide to the transferred Personal Data a standard of protection which is comparable to the protection under the PDPA.

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction.


How do we manage, protect and store your Personal Data?

We have appointed a Data Protection Officer who will oversee and ensure management of Personal Data in accordance with the PDPA. The contact details of our Data Protection Officer are listed below.

  1. Protection

We take breaches of privacy very seriously and will take all reasonable steps and employ appropriate security measures like rendering data anonymous or using pseudonyms to ensure that your Personal Data is securely stored and protected against unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks.

Unauthorised entry or use, hardware or software failure, and other factors, may compromise the security of your Personal Data. We do not warrant or guarantee in any way that your Personal Data or communications will always remain private and/or safe. Although we will do our best to protect your Personal Dat, we cannot guarantee the security of your Personal Data transmitted to our website; any transmission is entirely at your own risk. We will advise you at the first reasonable opportunity upon discovering or being advised of a security breach where your Personal Information is lost, stolen, accessed, used, disclosed, copied, modified, or disposed of by any unauthorised persons or in any unauthorised manner.

  1. Accuracy and Correction

We endeavour to ensure that your Personal Data collected is accurate and complete if the Personal Data is likely to be used by us to make a decision that affects you or is likely to be disclosed by us to another organisation.

To help us maintain the accuracy of your Personal Data, if there is any change or update in your Personal Data, please update us accordingly. Alternatively, if you wish to correct any of your Personal Data which we have, please write to our Data Protection Officer at the contact details below, and we will correct or update your Personal Data as soon as reasonably practicable.

  1. Retention

We will only retain Personal Data for as long as the retention is required for (i) the purposes for which such Personal Data was collected and (ii) for legal and business purposes. Otherwise, we will exercise measures to ensure such Personal Data is disposed of or discarded in a secure manner that would prevent further processing, unauthorized access, or disclosure to any other party or public.


What are your rights?

  1. Right to withdraw consent

You may withdraw your consent for the collection, use and disclosure of your Personal Data at any time by giving us reasonable notice. You may withdraw your consent by sending a written request by email or by post to our Data Protection Officer at the address below. Upon receiving your written request, we will inform you of the likely consequences of the withdrawal of your consent, and will cease to collect, use and disclose your Personal Data therefrom, unless otherwise permitted or required by the PDPA or any other applicable laws and regulations.

Please note that if you withdraw your consent to any or all use or disclosure of your Personal Data, depending on the nature of your request, we may not be able to offer or to provide to you our products or services or administer any contractual relationship in place.

  1. Right of access and correction

You may request for information regarding your Personal Data that is in our possession or under our control, as well as information about the ways in which your Personal Data has been or may have been disclosed by us within a year before the date of your request.


Who should you approach?

If you have any feedback or enquiries relating to your Personal Data or if you wish to know more about our data protection policies and practices, please contact us at the following:

Email Address: info@kbt-consulting.com

Postal Address: KBT Consulting Pte. Ltd.

160 Robinson Road, #14-04

Singapore Business Federation Center

Singapore 068914

For more information about the PDPA, please visit http://www.pdpc.gov.sg.

This Privacy Policy shall be governed in all respects by the laws of Singapore.

This Privacy Policy was last updated on March 2024.