NeuHR respects your privacy and is committed to protecting your personal information.
This Data Protection Policy (“Policy”) sets out the basis upon which NeuHR (“we”, “us” or “our”) may
collect, use, disclose or otherwise process personal data of individuals in accordance with the
Personal Data
Protection Act (“PDPA”).
1. PDPA INTRODUCTION
1.1 “Personal Data” is defined by the PDPA as data, whether true or not, about an individual who can
be
identified from that data, or from that data and other information to which an organization has or
is
likely
to have access. Common examples of personal data could include names, identification numbers,
contact
information, medical records and photographs.
1.2 We will only collect your personal data in accordance with the PDPA. We will obtain your consent
for
the
collection, use, disclosure and/or processing of your personal data for the intended purposes,
unless an
exception under the law permits us to collect and process your personal data without your consent.
2. PURPOSES FOR COLLECTION, USE, DISCLOSURE AND PROCESSING OF PERSONAL DATA
2.1 The personal data we collect may be used, disclosed and/or processed for various purposes,
depending
on
the circumstances, which include but are not limited to:
- Administrative matters on the service purchases and/or subscriptions, managing your accounts,
processing
your signups/registrations for mailing lists, etc. - Facilitating NeuHR’s ability to provide you with the products and services which you use
- Managing your enquiries and instructions, sending you marketing and/or promotional information
and
materials relating to products and/or services that we are selling or marketing. - Conducting market research and/or customer satisfaction surveys for NeuHR; and
- Any other purposes that we notify you of at the time of obtaining your consent. (collectively,
the
“Purposes”)
3. SPECIFIC ISSUES FOR THE DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES
3.1 We respect that the personal data you have provided us is confidential. With that in mind, we
will
not
disclose your personal data to other third parties without obtaining your permission first.
3.2 However, we may disclose your personal data to other third parties without obtaining your
permission
first in certain situations which include but are not limited to: situations in which the disclosure
is
required or authorized based on the law and/or regulations and/or permitted by the PDPA or law
situations in
which the disclosure is necessary to respond to an emergency that threatens the life, health or
safety
of
any individual; situations in which the disclosure is compulsory for any investigation or
proceedings
situations in which the disclosure is to a public agency and such disclosure is necessary in the
public
interest;
3.3 If we disclose your personal data to third parties with your consent, we will ensure the best
efforts
are
taken to provide adequate supervision over the handling of your personal data by such third parties
to
protect your personal data.
4. REQUEST FOR ACCESS AND/OR CORRECTION OF PERSONAL DATA
4.1 You may request to access and/or correct your personal data that is in our possession by
submitting a
written request to us. Please contact us for further information about how to access your personal
data.
4.2 When you make a request to access your personal data, we will request certain information from
you in
order to determine your identity with certainty. Once we have sufficient information, we will
respond to
your request within 30 days. Please note that the PDPA exempts certain types of personal data from
being
subject to your request to access it.
4.3 Please note that we may have to withhold access to your Personal Data in certain situations, for
example
when we are unable to confirm your identity.
4.4 There may be a small but reasonable charge for the handling and processing of your requests to
access
and/or correct your personal data. We will provide you a written estimate of the charges, and we are
not
required to respond to or deal with your request unless you have agreed to pay the charge.
5. REQUEST TO WITHDRAW CONSENT
5.1 If you do not agree with this Policy, please DO NOT continue to use or access the Services.
5.2 If you choose to withdraw your consent to any or all or the disclosure of your personal data,
please
note
that we may not be in a position to continue providing some of our services to you. We will process
your
request within a reasonable time from such a request for withdrawal of consent being made, and will
thereafter refrain from collecting, using and/or disclosing your personal data in the manner stated
in
your
request.
6. STORAGE AND SECURITY OF PERSONAL DATA
6.1 NeuHR takes breaches of privacy very seriously. Our employees are trained to handle the personal
data
securely and with utmost respect and confidentiality, failing which they may be subject to
disciplinary
action.
6.2 We will also ensure that your personal data is adequately protected and secured. We will place
reasonable
security arrangements to prevent any unauthorized access, collection, use, alteration, disclosure,
loss
and/or damage of your personal data. However, we do not take responsibility for unauthorized access
or
use
of your personal data by third parties that are wholly due to factors that are beyond our control.
7. COOKIES
7.1 We use cookies for the following purposes: to improve the your browsing experience; collect
analytics
data, or use third-party analytics tool to assist us in monitoring traffic and usage trends of the
website;
to assist the website in functioning properly.
7.2 You may control which cookies you want to enable or disable via your web browser’s settings. If
you
block
the cookies on our website, you should note that you might not be able to access the full range of
functions
that our website offers.
7.3 Personal Data that we collect from you through our cookies may be passed onto third party service
providers (whether within or outside Singapore), for managing or improving our website, for data
hosting
or
backup or for one or more of the purposes set out in 7.1 above.
8. CHANGES/UPDATES ON DATA PROTECTION POLICY
8.1 As part of our efforts to ensure that we properly manage, protect and process your personal data,
we
will
be reviewing our policies, procedures and processes from time to time. We encourage you to
periodically
review this privacy statement to stay informed about how we are helping to protect the personal
information
we collect.
8.2 We reserve the right to make changes to this policy at its sole discretion. Any changes made in
this
manner will be posted on this page.