Welcome to the MLS Company Secretary
MLS Company Secretary respects your
inform you as to how we look after your personal data when you visit our
website (regardless of where you visit it from) and tell you about your privacy
rights and how the law protects you.
1. IMPORTANT INFORMATION AND WHO WE ARE
PURPOSE OF THIS
This website is not intended for
children and we do not knowingly collect data relating to children.
It is important that you read this
we may provide on specific occasions when we are collecting or processing
personal data about you so that you are fully aware of how and why we are using
intended to override them.
MLS Company Secretary Pte. Ltd is the
controller and responsible for your personal data (collectively referred to as “we”,
We have appointed a data privacy
manager who is responsible for overseeing questions in relation to this privacy
requests to exercise your legal rights such as data access requests, please
contact the data privacy manager using the details set out below.
Our full details are:
Full name of legal entity: MLS Company
Secretary Pte. Ltd
Name of data privacy manager: Hélène Canard-Duchêne
Email address: [email protected]
Postal address: 28c Stanley Street Singapore 068737
You have the right to make a complaint at any time regarding how we are complying with the Personal Data Protection Commission (PDPA) or how we are handling your personal data, we welcome you to contact us with your complaints or grievance. Please contact us by e-mail to [email protected] or by letter to our postal address, attention to Data Protection Officer.
CHANGES TO THE
This version was last updated on 12
It is important that the personal data
we hold about you is accurate and current. Please keep us informed if your
personal data changes during your relationship with us.
This website may include links to third-party
websites, plug-ins and applications. Clicking on those links or enabling those
connections may allow third parties to collect or share data about you. We do
not control these third-party websites and are not responsible for their
privacy statements. When you leave our website, we encourage you to read the
2. THE DATA WE COLLECT ABOUT YOU
Personal data, or personal information,
means any information about an individual from which that person can be identified.
It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer
different kinds of personal data about you which we have grouped together as
- Identity Data
includes first name, last name, title, date of birth and gender.
- Contact Data
includes email address(es).
- Technical Data
includes internet protocol (IP) address, browser type and version, time zone
setting and location, browser plug-in types and versions, operating system and
platform and other technology on the devices you use to access this website.
- Usage Data
includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and
our third parties and your communication preferences.
We also collect, use and share Aggregated Data such
as statistical or demographic data for any purpose. Aggregated Data may be
derived from your personal data but is not considered personal data in law as
this data does not directly or indirectly reveal your identity. For
example, we may aggregate your Usage Data to calculate the percentage of users
accessing a specific website feature. However, if we combine or connect
Aggregated Data with your personal data so that it can directly or indirectly
identify you, we treat the combined data as personal data which will be used in
IF YOU FAIL TO
PROVIDE PERSONAL DATA
Where we need to collect personal data by law, or under the
terms of a contract we have with you and you fail to provide that data when
requested, we may not be able to perform the contract we have or are trying to
enter into with you (for example, to provide you with an estimate of fees). In
this case, we may have to cancel a product or service you have with us but we
will notify you if this is the case at the time.
3. HOW IS YOUR PERSONAL DATA COLLECTED?
We use different methods to collect
data from and about you including through:
- Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- use any one of our chatbots;
- complete a contact form; or
- request information to be sent to you.
- Automated technologies or interactions. For the moment, we don’t automatically collect Technical Data.
providers such as Google based outside the EU; and
- Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:
providers such as Google based outside the EU; and
(b) blogs such as Zegal based outside the EU.
4. HOW WE USE YOUR PERSONAL DATA
We will only use your personal data
when the law allows us to. Most commonly, we will use your personal data in the
- Where we need to perform a service that you have agreed to receive.
- Where it is necessary for our legitimate interests (or those
of a third party) and your interests and fundamental rights do not override
- Where we need to comply with a legal or regulatory
To find out more about the types of lawful basis that we will rely on to process your personal data, please Contact us.
PURPOSES FOR WHICH
WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table
format, a description of all the ways we plan to use your personal data, and
which of the legal bases we rely on to do so. We have also identified what our
legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please Contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
basis for processing including basis of legitimate interest
|To manage our relationship with you which will include:
(b) Asking you to leave a review or take a survey
(c) Marketing and
|(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests
(to keep our records updated and to study how customers use our
|To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To deliver relevant website content and newsletters to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity
(d) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve our website, products/services, marketing, customer relationships and experiences||(a) Technical
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. If you have any enquiries regarding how we use personal data in marketing and advertising, please do not hesitate to Contact us.
You can set your browser to refuse all
or some browser cookies, or to alert you when websites set or access cookies. For
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please Contact us.
If we need to use your personal data
for an unrelated purpose, we will notify you and we will explain the legal
basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
5. DATA SECURITY
We have put in place appropriate
security measures to prevent your personal data from being accidentally lost,
used or accessed in an unauthorised way, altered or disclosed. In addition, we
limit access to your personal data to those employees, agents, contractors and
other third parties who have a business need to know. They will only process
your personal data on our instructions and they are subject to a duty of
We have put in place procedures to deal
with any suspected personal data breach and will notify you and any applicable
regulator of a breach where we are legally required to do so.
6. DATA RETENTION
HOW LONG WILL YOU
USE MY PERSONAL DATA FOR?
Subject to the applicable laws, we will
only retain your personal data for as long as necessary to fulfil the purposes
we collected it for, including for the purposes of satisfying any legal, accounting,
or reporting requirements.
To determine the appropriate retention
period for personal data, we consider the amount, nature, and sensitivity of
the personal data, the potential risk of harm from unauthorised use or
disclosure of your personal data, the purposes for which we process your
personal data and whether we can achieve those purposes through other means,
and the applicable legal requirements.
If you have any questions about the period of data retention, please do not hesitate to Contact us.
In some circumstances you can ask us to
delete your data: see [Request
erasure] below for further information.
In some circumstances we may anonymise
your personal data (so that it can no longer be associated with you) for
research or statistical purposes in which case we may use this information
indefinitely without further policy to you.
7. YOUR LEGAL RIGHTS
Under certain circumstances, you have
rights under data protection laws in relation to your personal data. Please
click on the links below to find out more about these rights:
- Request access to your personal data
- Request correction of your personal data
- Request erasure of your personal data
- Object to processing of your personal data
- Request restriction of processing of your personal data
- Request transfer of your personal data
- Right to withdraw consent
If you wish to exercise any of the rights set out above, please Contact us.
NO FEE USUALLY
You will not have to pay a fee to
access your personal data (or to exercise any of the other rights). However, we
may charge a reasonable fee if your request is clearly unfounded, repetitive or
excessive. Alternatively, we may refuse to comply with your request in these
WHAT WE MAY NEED
We may need to request specific
information from you to help us confirm your identity and ensure your right to
access your personal data (or to exercise any of your other rights). This is a
security measure to ensure that personal data is not disclosed to any person
who has no right to receive it. We may also contact you to ask you for further
information in relation to your request to speed up our response.
TIME LIMIT TO
We try to respond to all legitimate
requests within 5 working days. Occasionally it may take us longer than 5
working days if your request is particularly complex or you have made a number
of requests. In this case, we will notify you and keep you updated.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by Contacting us.
Contract means processing your data where it is
necessary for the performance of a contract to which you are a party or to take
steps at your request before entering into such a contract.
Comply with a
legal or regulatory obligation
means processing your personal data where it is necessary for compliance with a
legal or regulatory obligation that we are subject to.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data
access to your personal data (commonly known as a “data subject access request”).
This enables you to receive a copy of the personal data we hold about you and
to check that we are lawfully processing it.
Request correction of your personal data
correction of the personal data that we hold about you. This enables you to
have any incomplete or inaccurate data we hold about you corrected, though we
may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data
erasure of your personal data. This enables you to ask us to delete or
remove personal data where there is no good reason for us continuing to process
it. You also have the right to ask us to delete or remove your personal data
where you have successfully exercised your right to object to processing (see
below), where we may have processed your information unlawfully or where we are
required to erase your personal data to comply with local law. Note, however,
that we may not always be able to comply with your request of erasure for
specific legal reasons which will be notified to you, if applicable, at the
time of your request.
Object to processing of your personal data
processing of your personal data where we are relying on a legitimate
interest (or those of a third party) and there is something about your
particular situation which makes you want to object to processing on this
ground as you feel it impacts on your fundamental rights and freedoms. You also
have the right to object where we are processing your personal data for direct
marketing purposes. In some cases, we may demonstrate that we have compelling
legitimate grounds to process your information which override your rights and
Request restriction of processing of your personal data
restriction of processing of your personal data. This enables you to ask us
to suspend the processing of your personal data in the following scenarios: (a)
if you want us to establish the data’s accuracy; (b) where our use of the data
is unlawful but you do not want us to erase it; (c) where you need us to hold
the data even if we no longer require it as you need it to establish, exercise
or defend legal claims; or (d) you have objected to our use of your data but we
need to verify whether we have overriding legitimate grounds to use it.
Request transfer of your personal data
transfer of your personal data to you or to a third party. We will provide
to you, or a third party you have chosen, your personal data in a structured, commonly
used, machine-readable format. Note that this right only applies to automated
information which you initially provided consent for us to use or where we used
the information to perform a contract with you.
Right to withdraw consent
consent at any time where we are relying on consent to process your
personal data. However, this will not affect the lawfulness of any processing
carried out before you withdraw your consent. If you withdraw your consent, we
may not be able to provide certain products or services to you. We will advise
you if this is the case at the time you withdraw your consent.