PRIVACY AND DATA PROTECTION POLICY
Hong Ye Group of Companies and our subsidiaries ((hereinafter collectively referred as“we”, “our”, “us”, “We”, “Our”, “Us”, "Hong Ye Group Pte. Ltd, "YY Life Pte. Ltd.” ) value the information you have provided us or permitted us to collect. We strive to protect your privacy while providing you with the best service and experience we can provide. All such personal information in our possession is collected, valued, used, disclosed and protected in accordance with the Singapore Personal Data Protection Act 2012 ("PDPA").
This Privacy and Data Protection Policy applies to all is intended to apply to all personal data submitted by you, third parties authorised by you via www.hongyegroup.com.sg, via its sub-domains, and any other websites, media platforms, applications including the YYCircle Mobile Application operated by us (hereinafter collectively referred to as the "Platforms") and any personal data that we receive from other third parties.
By visiting or using any of the Platforms, you are deemed to agree to the terms of this Privacy and Data Protection Policy. Please review this Privacy and Data Protection Policy carefully prior to visiting or using any such Platforms or otherwise providing any personal data.
INTRODUCTION TO THE PDPA
In Singapore, Personal data is protected under the Personal Data Protection Act 2012 (PDPA).
The PDPA establishes a data protection law that constitute various rules governing the collection, use, disclosure and handling of personal data. It acknowledges both the rights of individuals to protect their personal data, including rights of access and correction; and the requirements of organisations to collect, use or disclose personal data for legitimate and reasonable purposes.
In accordance to Advisory Guidelines on the Personal Data Protection Act (“PDPA”) for NRIC and Other National Identification Numbers (“NRIC Guidelines”), organisations are typically not allowed to collect, use or disclose an individual’s NRIC number (or copy of NRIC) from 1st of September 2019 unless:
a. required under the laws in Singapore (or an exception under the PDPA applies); or
b. necessary to accurately establish or verify the identity of the individual to a high degree of fidelity, where the failure to do so would pose a significant safety or security risk or significant impact or harm to an individual and/or organisation.
1. PERSONAL INFORMATION AND OTHER RELEVANT DATA COLLECTED
Personal data as defined in the PDPA refers to data whether genuine or not, about an individual who can be identified from either that particular data, or from that data and other information which we have or likely have access to. Personal data is collected where reasonably necessary for our functions and activities. Personal data that we may hold include the following:
- (a) name, address and contact details;
- (b) date of birth;
- (c) NRIC number, FIN number *;
- (d) bank account details;
- (e) details of services provided to an individual by us;
- (f) details of an individual's dealings with us, including telephone records, email and online interactions;
- (g) photos and video recordings;
- (h) your image;
- (i) voice recordings;
- (j) location data; and
- (k) other personal data as may be provided by an individual from time to time.
* Some of the information that we collect is sensitive in nature. This includes information such as your NRIC or FIN number. We only collect this information when permitted by applicable laws and when this is necessary to verify your identity to a high degree of fidelity.
Collection of Personal Data
Wherever possible, we will collect personal data directly from you. Notwithstanding the above, we may also receive personal data about you from various third parties such as analytics providers, data aggregators, or other providers of technical and delivery services, and public sources.
In addition to the personal data you provide to us, certain information related to you that is not considered personal data under the PDPA may also be collected. We collect this information to improve our Platforms. Such non-personal data may include information such as the internet browser you use or the duration of use of our Platforms. Lastly, any other purposes that we notify you at the point of obtaining your consent
Cookies are small files which require user permission in order to be installed on a computer’s hard drive. Cookies will only start to perform their functions after such permission is granted. By collecting and analysing data on the user’s browsing patterns, cookies allow web applications to respond to the user as an individual by tailoring a web application’s operations to the user’s specific needs and preferences.
Permission for cookies is granted by default in most web browsers. You can however choose to disable this function in your browser’s settings. This may prevent you from taking full advantage of our Platforms.
We may use traffic log cookies to identify which pages are being used. This use is designed to assist us in gathering data on webpage traffic. The gathered data is used only for statistical purposes and is removed from our database shortly after.
Overall, the data collected by the cookies is used for the purpose of improving your browsing experience on our Platforms, to help us better understand how the website is performing, and to enable the website to function properly.
Cookies do not grant us access to your computer or any information about you outside of your browsing activity on our Platforms.
Our services and Platforms are only intended for those of sufficient legal age. If a parent or guardian becomes aware that his or her child, who is below the sufficient legal age, has provided us with information without their consent, he or she should contact our data protection officer, whose contact details are listed in section 10 below. We will delete such information from our files within a reasonable timeframe.
By using our services and platforms, you consent to the collections and use of your personal information and data in the ways herein (subjected to change from time to time as supported by section 8); unless and until you inform us on the withdrawal of your consent.
Your consent will also include the exchange of your personal information between us and our internal stakeholders, external parties or individuals, to prove the authenticity of your declared status.
2. USE OF YOUR PERSONAL DATA
We collect personal data for various purposes. Without limitation, these purposes include:-
- (a) to register as a user on the Platforms;
- (b) to verify your identity;
- (c) to assess and/or verify your employability;
- (d) to deliver the services which you have requested, including but not limited to the services provided by the Platforms;
- (e) to enable us to manage and administer the services which you have requested, including but not limited to the services provided by the Platforms;
- (f) to deliver relevant content to you, including advertisements and promotions; and to measure and analyse the effectiveness of the content that we serve you;
- (g) to manage our relationship with you including notifying you of any changes to the Platforms or any service we provide;
- (h) supplying you with information that is relevant to your existing relationship with us;
- (i) providing customer and marketing support;
- (j) to investigate and resolve your complaints, discrepancies or enquiries.
- (k) to contact you in respect to our services;
- (l) to administer and protect our business and the Platforms including troubleshooting, data analysis and system testing;
- (m) to improve placement opportunities for you which includes the use of data analytics and artificial intelligence in relation to your personal data to enable us in finding appropriate opportunities and to assist employers to assess the suitability of candidates for job vacancy for a spectrum of jobs and industries;
- (n) to manage staff training and quality assurance;
- (o) to conduct research and statistical analysis for the maintenance and development of our Platforms;
- (p) to monitor our performances and that of our Platforms;
- (q) for fraud prevention and detection; or
- (r) in our sole discretion, in exceptional circumstances such as national emergency, security concerns, or other situations in which we deem that such disclosure is prudent.
3. SHARING YOUR PERSONAL DATA
In the course of providing our services and products to you, we may need to disclose your personal data with classes of internal stakeholders, external parties or individuals. The reasons for which we may disclose your personal data are set out under section 2 above. The possible classes of internal stakeholders, external parties or individuals we may share your personal data with include without limitations, to the following:-
- a) other users of the Platforms
- b) our group of companies
- c) our affiliates
- d) our partners
- e) our clients
- f) the employers
- g) principals
- h) governmental or regulatory authorities
- i) educational institutes to verify on student status authenticity
j) third party service providers (for the purpose of providing us administrative or marketing support),
- i. the advertisers (including online advertisers)
- ii. payment gateway services
- iii. mapping services
- iv. data storage and analytics services
- v. market research and website usage analysis services
- vi. educational institutes for verifying of student status authenticity
- vii. approved training organisations
- viii. professional advisors
- ix. individuals or party involved in and for the purpose legal proceedings
If any of our businesses are sold or transferred to another entity, your personal data may be transferred along with the business.
We do not sell any personal data or information collected to any external parties or individuals
In the event that any of the above external parties or individuals receiving your personal data are located or are operating outside of Singapore, we will take reasonable steps to ensure that the overseas recipient provides a standard of protection to your personal data so transferred that is comparable to the protection under the PDPA.
4. THIRD PARTY LINKS
Our Platforms may, from time to time, contain links to and from the websites of our partner networks, advertisers, affiliates and third party service providers.
You may sign up with our Platforms through sign-in services such as Facebook connect or Google. This service will authenticate your identity and provide you the option to share personal information with us (such as your name and contact details) to pre-set our sign-up form.
Please note that these websites and any services that may be accessible through them have their own privacy policies and we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services. Please check these policies before you submit any personal data to these websites or use these services.
We will protect your personal data using industry standard precautions from theft, loss, misuse, disclosure, alteration and unauthorised access. While the transference of electronic data over the internet has inherent risks, we use reasonable precautions to ensure your personal data is not subject to unnecessary risks.
We although endeavor to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches over the internet, or any electronic storage methods. You have a personal responsibility to safeguard your passwords to the Platforms.
We will retain your personaldata for as long as necessary in order to fulfil the purpose for which it was collected, or as required for any legal or business purposes under relevant laws.
In some circumstances we will 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 notice to you.
7. ACCESS, UPDATE, WITHDRAWAL OF CONSENT
Understand that you may have different privacy concerns, you are entitled to be provided, upon request;
(a) access to some or all your personal data that is in our possession or control; or
(b) information about the ways in which that personal data has been or may have been used or disclosed by us within a year before the date of your request
You must submit a request to our data protection officer, whose contact details are set out in section 10 below, if you subsequently decide to request access to your personal data, update your personal data or withdraw your consent for us to collect, use and/or disclose your personal data, whether partial or in full. Please note that it may take up to 30 business days after receipt of your request to process your request. We may require further information from you to accurately verify your identity before processing your request. Kindly also take note that:-
a) your updated personal data, will also be sent to all relevant parties which we had originally disclosed to them within a year before the date of the update, unless the relevant parties have no more legal or business purposes for the personal data.
b) the PDPA exempts certain types of personal data from being subject to your access request.
c) Should your withdrawal of consent result in any legal consequences arising from such withdrawal, and depending on the extent of your withdrawal of consent, it may result in the discontinuation on your existing relationship with us.
We reserve the right to amend this Privacy and Data Protection Policy at any time. If material changes are made to this Privacy and Data Protection Policy, they will be posted on this page and date stamped. We encourage you to review this page periodically in order for you to stay notified of any changes.
Your continued use of the Platforms and acceptance of our services after any changes to this Privacy and Data Protection Policy constitutes your consent to any such changes, to the extent such consent is not otherwise provided.
9. COMPLAINT PROCESS
If you have any complaint or feedback regarding about how we handled your personal data or about how we are complying with the PDPA, feel free to contact us for clarifications at section 10 below via the company’s DPO.
We will certainly strive to deal with any complaint or feedback that you may have fairly and promptly.
10. CONTACT US
If you have comments or questions about this Privacy and Data Protection Policy statement, or wish to submit a request mentioned in paragraph 7 above, please contact our data protection officer at:
|Telephone number:||(+65) 66046896|
|Address:||60 Paya Lebar Road #05-43 Paya Lebar Square Singapore 409051|
11. GOVERNING LAW AND JURISDICTION