PERSONAL DATA PROTECTION NOTICE

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Keshet Agritech Ptd. Ltd. (hereinafter referred to as “KAPL”, “we”, “us”) is committed to
respecting and protecting your personal data. This Personal Data Protection Notice herein sets out how KAPL collects, uses, discloses and/or processes your personal data. By providing us with your personal data, you consent and agree to us processing your personal data in accordance with the Personal Data Protection Act 2012 as amended (“PDPA”).

Please note that this Personal Data Protection Notice is subject to amendments and updates from time to time. Please check back here for the latest version.

A. Definition of Personal Data

In this Personal Data Protection Notice, any reference to “personal data” shall refer to data, whether true or not, about an individual that is identifiable (a) from that data; or (b) from that data together with other information which we have or are likely to have access.

Some examples of personal data we may collect from you depending on the nature of your interface with us include the following:

(i) your full name and personal contact details

(e.g. phone numbers, date of birth, mailing and/or email addresses);
(ii) your NRIC or passport number (where so necessary and relevant);
(iii) your attendance at meetings and/or events for record purposes which may include
photographs or video recordings of any such meetings and/or events; and
(iv) any other relevant information including online technical data when you access our
platforms (including for e.g IP addresses - see section D below).

 

B. Collection of Your Personal Data

We may collect personal data in the following manner:

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• when you use, register or visit our platforms;

• in the ordinary course of business;

• managing various aspects of your relationship with us;

• when you provide us with the personal data to us (whether via email, or by any other means where so necessary);

• when you enter into any agreement with us or provide other documentation or information in respect of your interactions with us, or when you use our platforms/services;

• when you interact with us including via telephone calls, face-to-face meetings, social media platforms, letters and/or emails;

• when you register for any of our meetings, or use our platforms (including signing up our update meetings and any such similar events);

• when third parties provide it to us, where necessary with your consent or where
  otherwise permitted under law;

• meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which have jurisdiction over us (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies and conducting audit checks, due diligence and investigations); or 

• any other purposes which relate or are incidental to the aforesaid.

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C. Processing and Disclosure of Personal Data

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We may process your personal data for the following purposes:

• to provide services and/or updates to you in the ordinary course of business;

• to organise and/or send you notices, information on any events, meetings and/or updates, together with and any such related messages as necessary;

• to respond to your queries, requests and/or feedback;

• to ensure the smooth functioning of our platforms;

• for marketing or promotional purposes (if we have your consent or other deemed/legitimate interest permitted under current law);

• to comply with legal obligations, resolve disputes, analytics, security purposes, enforce our terms;

• any other purpose for which we notify you (or have notified you) and obtain your consent prior to processing (or have obtained consent); and/or

• any other purposes as required and/or permitted by law.

We may disclose your personal data for (i) the foregoing purposes or (ii) where such disclosure is otherwise required for or related the performance of our obligations to you and/or (iii) to our authorised consultants, third party service providers and/or agents and/or other professional advisors with whom we are dealing with, including any necessary governmental authorities and/or regulators. Where we are required to transfer your personal data out of Singapore for any of the above mentioned purposes, we will ensure that your personal data is protected to, at a minimum, the standard required in Singapore.

Please note that in the event that you provide us with any personal data of third parties (for example, your spouse, relative, children or a known person), you hereby confirm that you have obtained all necessary consents to do so, and that we may process such personal data for the purposes set out herein above and in accordance with the PDPA.
We will only retain your personal data for as long as is necessary for us to use your personal data for business or legal purposes as described above. However, please be advised that we may retain some of your personal data after our relationship comes to an end, for instance if the data is necessary to meet our business/legal obligations, such as retaining the information for tax and accounting purposes.

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D. IP addresses

By using our platforms please note that IP addresses may be recorded, together with the date, time and duration of your visit. An IP address is an assigned number, similar to a telephone number, which allows your computer to communicate over the Internet. We may use this information to compile aggregated statistical data on the use of our platforms to track how users navigate through our site. We may do this so we can evaluate and improve our platforms.

 

E. Cookies and links to third party sites

By accessing our platforms, you agree that we can place cookies on the device(s) that you use to access our platforms. We may use cookies to provide visitors with a personalised experience on our platforms. Cookies are pieces of information that platforms transfer to the memory or hard drive of a visitor’s device(s)/computer for record-keeping purposes. We use cookies to make improvements and to better tailor our platforms to our visitors’ needs. We also use this information to verify that visitors meet the criteria required to process their requests.

Most browsers used by visitors have options that allow the visitor to control whether the browser will accept cookies, reject cookies, or notify the visitor each time a cookie is sent. However, if you disable or refuse cookies, please note that some parts of our platforms may become inaccessible or not function properly. In addition, you can delete our cookies from your browser program at any time.

Please note that our platforms may contain certain links to external websites. Please note that this Personal Data Protection Notice does not apply to any such external websites and the operations you perform on those websites.

 

F. Security

Your personal data/ information is as important to us as it is to you. In accordance with the PDPA, to enable the proper safeguarding of your personal data and also to ensure prevention of unauthorised access to our database platforms/systems and to ensure the appropriate use of personal information, KAPL exercises all reasonable efforts and have introduced appropriate administrative, physical and technical measures as necessary, and have put in place electronic processes and procedures to help safeguard your personal data and information from such unauthorised access, collection, use, disclosure, copying, modification, destruction or similar risks.

IMPORTANT: Please note however that no method of data or information transmission over the internet or method of electronic storage is completely secure. While security cannot be guaranteed, we have taken and continue to take reasonable efforts to protect the security of your information and are constantly reviewing and enhancing our information security measures.

 

G. How to access and update/correct your personal data

In the event that you wish to make (a) an access request for access to a copy of the personal data which we hold about you or (b) a correction request to correct or update any of your personal data which we hold, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.

We will respond to your request as soon as reasonably practicable. In general, our response is anticipated to be within thirty (30) business days. Should we not be able to respond to your access request within thirty (30) days after receiving your request, we will inform you in writing of the time by which we expect to be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (unless prevented by law or otherwise where we are not required to do so under the PDPA).

Please note that depending on the nature of the request that is being made, we reserve the right to only need to provide you with access to the personal data contained in the specific documents requested. In those cases, it may be appropriate for us to simply provide you with confirmation of the personal data that our organisation has on record, if the record of your personal data forms a negligible part of the document.

In accordance with the PDPA, please note that KAPL reserves the right to charge a reasonable admin fee for any access request. If so, we will inform you of the fee before processing your request. KAPL reserves the right not to process your request nor provide you the requested access should you elect not to pay any such relevant fees.

 

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H. Deemed Consent by Notification

We may collect or use your personal data, or disclose existing personal data for secondary purposes that differ from the primary purpose which it had originally collected for pursuant to clauses above. If KAPL intends to rely on deemed consent by notification for such secondary purposes, KAPL will notify you of the proposed collection, use or disclosure of personal data through appropriate mode(s) of communication.

In particular, we may rely on deemed consent by notification to collect, use or disclose your personal data for the following purposes of marketing and promotional purposes.

 

Before relying on deemed consent by notification, KAPL will assess and determine that the collection, use and disclosure of the personal data will not likely have an adverse effect on you.

You will be given a reasonable period to inform us if you wish to opt-out of the collection, use and disclosure of your personal data for such purposes.

 

After the lapse of the opt-out period, you may notify us that you no longer wish to consent to the purposes for which your consent was deemed by notification by withdrawing your consent for the collection, use or disclosure of your personal data in relation to those purposes.

I. Withdrawal of Consent
Please note that the consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time when you decide to withdraw such consent in writing. Do note however that any such withdrawal of consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted and/or required under applicable laws.

After our receipt of your written request for withdrawal of your consent, we may require
reasonable time for your request to be processed and for us to notify you of the consequences of this action, including any legal consequences which may affect your rights and liabilities to us. In general, depending on the complexity of the request and its impact on our relationship with you, we expect to process your request within thirty (30) business days of receiving it.

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 in a position to continue to provide any updates/services to you or administer any contractual relationship which may be in place. Accordingly, such withdrawal may also result in the termination of any agreement you may have with us. Our legal rights and remedies are expressly reserved in such event.

 

 

J. Reliance on Legitimate Interests and other Exceptions

In compliance with the PDPA, we may collect, use or disclose your personal data without your consent including for the business improvement and/or legitimate interests of Keshet Agritech Pte. Ltd.. In relying on the legitimate interests exception of the PDPA, Keshet Agritech Pte. Ltd. will assess the likely adverse effects on the individual and determine that the legitimate interests outweigh any adverse effect.

 

In line with the legitimate interests’ exception, we will collect, use or disclose your personal data for purposes including the following purposes:

a. Fraud detection and prevention.
b. Detection and prevention of misuse of services.
c. Network analysis to prevent fraud and financial crime, and perform credit analysis.

d. Collection and use of personal data on company-issued devices to prevent data loss.

The purposes listed in the above clause may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has come to an end, deemed to have ended or altered in any way, for a reasonable period thereafter.

 

 

K. Effect of Notice on Personal Data Protection

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This Personal Data Protection Notice is governed exclusively in all respects by the laws of the Republic of Singapore and shall apply in conjunction with any other policies, notices, agreements, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
We reserve the right to revise this Personal Data Protection Notice (or any part thereof) from time to time without any prior notice to you. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued relationship with us constitutes your acknowledgement and acceptance of such changes.

 

L. Contact Details

If you have any questions or feedback on our personal data protection policies and procedures; or if you wish to make any withdrawal, access and correction request please contact our Data Protection Officer at dpo@keshetagritech.com.