E-CONFIDENTIAL SECURITY MANAGEMENT LLP PRIVACY POLICY

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E-CONFIDENTIAL SECURITY MANAGEMENT LLP or as appropriate in the context, “we”, “us” or “our” respect the protection of the Personal Data of individuals and value the relationship we have with you.

This Personal Data Policy (“Policy”) describes the types of Personal Data we may collect from you, how we may use that information, and with whom we may share it. Our Policy also describes the measures we take to protect the security of the information you provide to us, including without limitation through this Website. We also tell you how you can reach us to update your Personal Data, ask questions you may have about our personal data protection practices and provide feedback on our personal data protection practices.

“Personal Data” in this Policy means data that can identify an individual.

1. Personal Data that we collect

-             The types of Personal Data that we collect about individuals may include:

Name, NRIC number / FIN number / passport number, Bank account details, Mobile number, Personal email address, Residential address and/or Residential telephone number.

-             You may have provided the Personal Data to us personally or authorised other individuals to provide the Personal Data to us and consent (on your behalf) to our collection of your Personal Data from these individuals. These individuals could be your superiors, employees, subordinates, colleagues and your family members.

-             Where you give us Personal Data about other individuals, you confirm that you are authorized to disclose and consent, on their behalf, to the processing of such Personal Data for the purposes described in the section “Purposes for which we collect and use Personal Data”, or other purposes for which your consent has been sought and obtained.

2. Purposes for which we collect and use Personal Data

-             We only collect and use Personal Data for purposes which you have consented to and for which we have been authorised. If we need to use your Personal Data for any purpose which you have not previously consented to, we would seek your consent prior to using your Personal Data for the new purpose.

-             We collect and use the Personal Data that you provide to us for the following purposes:

If you are a Customer

• To conduct due diligence / background checks that are mandated by legislation or Econsec internal policies and practices
• To provide products and services and to communicate with customers as part of providing products and services
• To evaluate Econsec products and services and how we can improve its products and services
• To respond to queries or comments on our products and services
• Security clearance / entry access into our premises and premises of foreign government agencies
• To communicate with customers on developments on our products and services.
• To facilitate attendance at events/functions organised by us.

Others

• To evaluate applications for employment / job positions with E-Confidential Security.
• To conduct due diligence/background checks on job applicants
• To evaluate suitability and eligibility for training courses
• Security clearance / entry access into our client’s premises
• To facilitate attendance at our client sites.
• For informing next of kin in the event of an emergency

3. Disclosure, sharing and transfer of Personal Data

E-Confidential Security does not sell or rent Personal Data that we collect from individuals, including our website visitors. In the course of or in connection with providing our products and services to our customers, we disclose, share and transfer Personal Data to the following parties for the following purposes:

• To our clients/employees/subcontractors/consultants for tender purposes.
• To our representatives and sub-contractors for the purposes of providing products and services to our customers on our behalf.
• To government and non-government authorities, agencies and/or regulators as required under law or under directions or orders from the government and non-government authorities, agencies and/or regulators for security, regulatory approvals or permits.
• To other E-Confidential Security entities for the purpose of responding to questions, concerns, comments or feedback on our products or services or our business, or to share knowledge on issues such as industry developments, E-Confidential Security’s business, market outlook, corporate events and other products and services of the E-Confidential Security that may be of interest to your company, organisation or business.
• To other E-Confidential Security entities to facilitate the provision of products and services to our customers where the project or engagement involves E-Confidential Security.

We also disclose and transfer Personal Data to the following parties for the purposes of managing, operating, administering and running our business and for our business and legal purposes:

• To other E-Confidential Security entities for security purposes
• To other E-Confidential Security entities for purposes of evaluating our products and services and our business
• Financial institutions for purposes of payments and transactions related to E-Confidential Security provision of products and services or related to products and services provided E-Confidential Security by our vendors / service providers / consultants
• Professional, financial and legal advisors, tax advisors, auditors, insurers and insurance brokers
• Vendors, service providers and consultants that have been engaged to help manage, operate, administer and run E-Confidential Security operations and business process or provide services to facilitate our provision of our products and services; and
• External contractors to provide consultancy and evaluative services to E-Confidential Security and for E-Confidential Security ‘s products and services, or organise events for E-Confidential Security  

-             For job applicants, your Personal Data may be shared with E-Confidential Security and if we take the view that you may be suitable or eligible for another job position within us, unless you inform us otherwise (please refer to Section 6). The Personal Data will be used in a confidential manner to help E-Confidential Security monitor their recruitment processes.

E-Confidential Security requires that the parties to whom we transfer Personal Data and our service providers implement adequate levels of protection in order to protect Personal Data. We also require that these parties only process Personal Data strictly for purposes for which we engage them for and consistent with the purposes that we have described in the section “Purposes for which we collect and use Personal Data” or with other purposes for which consent has been sought and obtained.

In addition, we would disclose Personal Data in the following circumstances:

• We are required to do so by law;
• in response to a request from law enforcement authorities or other government officials;
• to comply with a court order or direction from a government agency or regulatory authority ordering the disclosure of the Personal Data; and
• Where the disclosure is necessary for investigations or legal proceedings.

4. Protection and Security of Personal Data

We employ a range of technological and physical security arrangements and maintain safeguards to protect against the accidental or unauthorised access, collection, use, disclosure, copying, modification, disposal, deletion and other similar risks to Personal Data.

5. Retention of your Personal Data

E-Confidential Security only retains Personal Data for as long as the retention is required for the purposes for which we collected the Personal Data, the purposes described in this Policy and for our business and legal purposes. Generally, we do not retain Personal Data for a period of longer than 7 years after the original purposes for which the Personal Data was collected have ceased to be applicable, unless otherwise required by law or other mandatory directions by court or government authorities or for purposes of legal proceedings or other similar proceedings or investigations. For unsuccessful job applicants, E-Confidential Security will retain your Personal Data for no longer than 2 years for the purposes of evaluating your suitability for future job openings within E-Confidential Security unless you inform us otherwise (please refer to Section 6).

6. How to Contact Us

If you have any questions or comments about this Policy and our policies and practices on our collection, use, disclosure or retention of Personal Data, you may contact our Data Protection Officers:

       Data Protection Officer:               Mr. Koh and Mr. Chua

       Email Address:                              enquiry@econsec.com

       Mailing Address:                           Blk 65 Ubi Road 1, Oxley Bizhub #03-87, Singapore 408729

      Office Number:                              6748 8628                       

If you are a job applicant and wish to inform us that: (i) you do not wish for E-Confidential Security to share your personal data with other entities for evaluating your suitability or eligibility for another job position within the us other than the one you are applying for; or (ii) you do not wish for E-Confidential Security to retain your personal data for the purposes of evaluating your suitability for future job openings within E-Confidential Security, please contact:

       Email Address:                              operation@econsec.com

       Mailing Address:                           Blk 65 Ubi Road 1, Oxley Bizhub #03-87, Singapore 408729

       Office Number:                                    6748 8628         

7. Updating or correcting your Personal Data

E-Confidential Security takes reasonable measures to ensure that the Personal Data we collect about individuals are accurate and complete. For this reason, if there is any change or update in Personal Data, we would like to know about these changes or updates. If there is a change or an update in your Personal Data or if there is a need to correct any Personal Data of yours that we have, please write to us and provide us with the following details:

• Your name and an email address or mailing address at which we can contact you.
• The nature of our relationship with you.
• The Personal Data for which there has been a change, update or correction.

You may send your requests to our Data Protection Officer at the contact details listed in Section 6 above.

We will endeavour to acknowledge the receipt of your request within 3 working days after the date of receipt of your request if it is sent by e-mail, or within 7 days after the date of receipt of your request if it is sent by post. As it is important to us that the Personal Data that we have about you is accurate and complete, it may be necessary for us to request for supporting documentation from you. We will contact you if we require supporting documentation from you.

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There may be circumstances where we will not update or correct Personal Data, including:

• The Personal Data is opinion data that is kept solely for an evaluative purpose; and
• The Personal Data is in documents related to a prosecution if all proceedings relating to the prosecution have not been completed.

8. Your Requests and Feedback on your Personal Data with us

-             You may request for information from E-Confidential Security on what Personal Data of yours we have and how we have used and shared your Personal Data during the last one year before the date of your request.

-             You may also choose to withdraw your consent to E-Confidential Security‘s use, collection, sharing or processing of your Personal Data at any time. Please understand that your withdrawal of your consent to our use of your Personal Data may affect our provision of products and services to you or our business dealings with you, depending on the nature of your relationship with us.

-             If you have any concerns, feedback or complaints about the use and/or sharing of your Personal Data, we are open to receiving your feedback or complaint. To learn more about how you may submit a complaint about our use and/or sharing of your Personal Data, please send us an email or call us.

9. Updates to this Personal Data Protection Notice

We may change or update portions of this Policy at any time and without prior notice to you. Please review this Policy from time to time so you are aware of any changes or updates to the notice. We will indicate the effective date of the notice. If you do not agree with any of the changes or updates to the Policy, you have the option of withdrawing your consent to our collection, use, disclosure and processing of your Personal Data (please refer to Section 8 above).