Data Protection Policy

INTRODUCTION

KGiSL (“we” or “us”) values our website visitors and service user’s privacy. We are committed to safeguarding and maintaining the accuracy, confidentiality, and security of your personally identifiable information (“Personal Information”). As part of this commitment, our privacy policy governs our actions and summarizes what information we collect from a website visitors and service users’ and how it’s used (“you”).

Our Privacy Policy will explain to you what we will and will not do with it (relate to the collection, use and disclosure of Personal Information and it).

HOW WE USE YOUR PERSONAL DATA

We collect and use personal data as required for us to provide you with products, services and business support. Your personal data shall include information such as

  • Name
  • Address
  • Phone Number
  • Email Address
  • Usage Data
  • Other data that shall identify you either directly or indirectly

We may collect and process information about your use of our website and our services. These information shall include your time of interaction, IP address, browser type and version, geographical location, page views and website navigation paths, operating system, referral source, length of visit, as well as information about the frequency and timing.

We may collect and process the information that were provided during registration. Such data may include name, address, phone number, email and company information. These data are processed for the purpose of monitoring your use of our website and services.

We may process data contained in any enquiry that you submit to us regarding our products and services (“enquiry data“). These enquiry data may be processed for the purposes of offering, marketing and selling relevant services and products to you.

We may process data that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data“). These data may be processed for the purposes of sending you the notifications and/or newsletters.

We may process any of your personally identifiable information in this policy wherever necessary as required for instituting or defending any legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

In addition to the above purposes, we may also process any of your personal information where such information processing is necessary for legal compliance to which we are subject, or in order to protect the interests of yours and any other natural person.

Please do not provide any other personal data to us, unless we asked you to do so.

THE LEGAL BASIS FOR WHICH WE PROCESS YOUR PERSONAL DATA

The legal basis conditions for processing your personal data are Consent, Legitimate Interests and Legal Obligation.

We always ensured to minimize the information/data we collect. We will only process your data when we have given permission to do so, as it’s required to deliver the products or services that you have purchased/availed, or for other legal and lawful purposes. We use this data to:

  • Improve and enhance the performance of our Products/Services
  • Collect data about the use of our website and Services
  • Analyze your use of our Website and Services and which of our Services are most relevant to you
  • Monitoring, improving and enhancing our website and services as well as management and administration of our website and business.

SHARING YOUR PERSONAL DATA

All personal data shall be treated confidentially.

We may disclose your personal data to any of our affiliates, subsidiaries, ultimate holding company or any other member of our group of companies as reasonably required for the lawful purposes, and on the legal basis, set out in this policy.

Communicating with you. We may connect with you either directly or through a third party service provider regarding the products/Services that you have purchased or availed from us. We may also connect with you to offers additional services if you give us consent, or when it is allowed based on legitimate interests. The methods of communication may include:

  • Email
  • Phone calls
  • Text messages

Website analytics. We use various third party web analytics tools such as Google Analytics to collect information on how you connect and interact with our website. This information may include the pages you visit, time spent on each page, the OS and the browser you use, and geographic location information.

Compliance with legal. We may disclose your personal data under an order or mandate by a court or a governmental authority or under any law as necessary to respond to any claims or any legal processes, to protect our property and rights or the property and rights of any third party, or to protect the safety of the public or an individual, or to prevent or stop illegal or unethical activity.

If we are legally allowed to do so, we will take reasonable steps to notify you in the event we are required to provide your information to third parties as part of a legal process.

RETENTION OF PERSONAL DATA

All personal data that you provide to us is stored on secure servers. We strictly adhere to generally accepted standards and procedure to collect, store and protect personal information, including the use of cryptography procedure. We retain any personal data that we process for as long as it is required to provide the intended lawful purposes and thereafter as necessary for legal and business purposes.

RIGHTS UNDER GDPR

Below are few of the rights of data subjects under the General Data Protection Regulation (GDPR). This does not list out all the rights and remedies available and you should aware of relevant changes in the relevant laws and regulations.

Your principal rights under data protection law are:

  • the right to access;
  • the right to rectification;
  • the right to erasure (the “right to be forgotten”);
  • the right to restrict processing;
  • the right to object to processing;
  • the right to data portability;
  • the right to complain to a supervisory authority; and
  • the right to withdraw consent.

GRIEVANCE OFFICER

In accordance with Information Technology Act 2000 and rules made there under, the name and contact details of the Grievance Officer are provided below:

Mr. Jaffer Sadique

KGiSL

365, GSS Towers, KGiSL Campus,

Thudiyalur Road, Saravanampatti,

Coimbatore – 641 035, India.

corpcomm@kgisl.com

If you have any questions about this Policy or other privacy concerns, you can also email us at sales@kgisl.com

CHANGES TO OUR PRIVACY POLICY

We reserve the right to update or change this Privacy Policy at any time and you should check this policy periodically. Please review this policy from time to time so that you are aware of what data we collect and how we use those data. Your continued visit of our website and services after modification to the policy will constitute your acceptance of the modifications and your consent to abide and be bound by the updated Privacy Policy.

If we make any material modifications/updates to this Privacy Policy, we will notify you by placing a prominent notice on our website.

Singapore

This Data Protection Policy (“Policy”) sets out the basis upon which KG Information System Pte Ltd (“we”, “us” or “our”) may collect, use, disclose or otherwise process personal data of Job Applicant in accordance with the Personal Data Protection Act (“PDPA”). This Policy applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.

This Policy is an addendum of our Job application form and should be retained as part of the whole document for the job application process.

APPLICATION OF THIS POLICY

1.This Policy applies to all individual who have applied for any job position with us (“Job Applicant”).

PERSONAL DATA

2.As used in this Policy, “personal data” means data, whether true or not, about a Job Applicant who can be identified:

(a) from that data; or (b) from that data and other information to which we have or are likely to have access.

3.As a Job Applicant, personal data which we may collect in the context of your employment with us If you are a Job Applicant, personal data which we may collect includes, without limitation, your:

(a)full name

(b)date of birth,

(c)mobile number,

(d) email address and

(e)any additional information provided to us by you

COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

4.We generally collect personal data that (a) you knowingly and voluntarily provide in the course of or in connection with your employment with us, or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”, which may include your job placement agent), after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).

5.As a Job Applicant, your personal data will be collected, used and may disclosed by us for the following purposes:

(a)assessing and evaluating your suitability for employment in any current or prospective position within the organisation;

(b)verifying your identity and the accuracy of your personal details and other information provided;

(c)complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;

(d)transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and

(e)any other incidental business purposes related to or in connection with the above.

6.As a Job Applicant if you provide any other individual personal data other than your own personal data to us, you should obtain the consent for collection, use and disclosure from the individual before disclosing the personal data to us.

WITHDRAWING CONSENT

7.The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing via email. You may withdraw consent and request us to stop collecting and/or using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing via email to our Data Protection Officer at the contact details provided.

8.Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process and to take effect your request within 10 business working days after receiving the request. However, if we are unable to complete your request within the timeline, we will inform you within the 10 business days.

9.Whilst we respect your decision to withdraw your consent, please note that depending on the nature and extent of your request, we may not be able to process your request. We shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing via email.

10.Please note that withdrawing 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 or required under applicable laws.

ACCESS TO OF PERSONAL DATA

11.If you wish to make an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, you may submit your request in writing via email to our Data Protection Officer at the contact details provided below.

12.Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.

13.We will respond to your access request as soon as reasonably possible. Should we not be able to respond to your access request within 30 business days after receiving your access request, we will inform you in writing via email to inform you the time by which we will be able to respond to your request. If we are unable to provide you with any personal data requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

14.Please note that depending on the request that is being made, we will only need to provide you with access to the personal data contained in the documents requested, and not to the entire documents themselves. 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.

15.We will not provide information under the access requirement for: -

(a)opinion data kept solely for an evaluative purpose.

(b)any examination, examination scripts and, prior to the release of examination results, examination results.

(c)the personal data of the beneficiaries of a private trust kept solely for the purpose of administering the trust.

(d)personal data kept by an arbitral institution or a mediation centre solely for the purposes of arbitration or mediation proceedings administered by the arbitral institution or mediation center;

(e)documents related to a prosecution if all proceedings related to the prosecution have not been completed.

(f)personal Data subject to legal privilege;

(g)personal Data which, if disclosed, would reveal confidential commercial information that could, in the opinion of a reasonable person, harm the competitive position of the organization;

(h)personal Data collected, used or disclosed without consent pursuant to the exemptions in the PDPA, for the purposes of an investigation if the investigation and associated proceedings and appeals have not been completed.

(i)the personal data was collected or created by a mediator or arbitrator in the conduct of a mediation or arbitration for which he was appointed to act—

under a collective agreement under the Industrial Relations Act (Cap. 136) or by agreement between the parties to the mediation or arbitration;

under any written law; or

by a court, arbitral institution or mediation centre.

(j)any request: -

That would unreasonably interfere with the operations of the organisation because of the repetitious or systematic nature of the requests;

If the burden or expense of providing access would be unreasonable to the organisation or disproportionate to the individual’s interests;

For information that does not exist or cannot be found;

For information that is trivial; and

That is otherwise frivolous or vexatious.

(k)personal Data or other information shall not be provided to an individual if the provision of that Personal Data or information could reasonably be expected to:

Threaten the safety or physical or mental health of an individual other than the individual who made the request;

Cause immediate or grave harm to the safety or to the physical or mental health of the individual who made the request;

Reveal Personal Data about another individual;

Reveal the identity of an individual who has provided Personal Data about another individual and the individual providing the Personal Data does not consent to the disclosure of his/her identity; or be contrary to national interest.

(l)If Personal Data has been disclosed to a prescribed law enforcement agency without the consent of the individual or pursuant to the exemptions in the PDPA, we shall not be required to inform the individual of such disclosure.

CORRECTION OF PERSONAL DATA

16.If you wish to make a correction request to correct or update any of your personal data which we hold, you may submit your request via email to our Data Protection Officer at the contact details provided below.

17.We will respond to your correction request as soon as reasonably possible. Should we not be able to correct the correction request within 30 business days after receiving your request, we will inform you in writing via email on the time by which we will be able to correct your correction request. If we are unable to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

18.Correction request will not be approved in respect of:

(a)opinion data kept solely for an evaluative purpose;

(b)any examination conducted by an education institution, examination scripts and, prior to the release of examination results, examination results;

(c)the personal data of the beneficiaries of a private trust kept solely for the purpose of administering the trust;

(d)personal data kept by an arbitral institution or a mediation centre solely for the purposes of arbitration or mediation proceedings administered by the arbitral institution or mediation centre; or

(e)a document related to a prosecution if all proceedings related to the prosecution have not been completed.

PROTECTION OF PERSONAL DATA

19.To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus and firewall protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis.

20.You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

ACCURACY OF PERSONAL DATA

21.We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing via email at the contact details provided below.

RETENTION OF PERSONAL DATA

22.We may retain your personal data for as long as it is necessary to fulfil the purposes for which they were collected, or as required or permitted by applicable laws.

23.Upon confirmation or successful job application, your personal data provided in the job application will be kept as employment data.

24.We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purposes for which the personal data were collected, and are no longer necessary for legal or business purposes.

TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE

25.We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.

DATA PROTECTION OFFICER

26.You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures; or if you wish to make any request, in the following manner:

Attention to Data Protection Officer

Email: infosec-sg@kgisl.com

EFFECT OF POLICY AND CHANGES TO POLICY

27.This Policy applies in conjunction with any other policies, notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.

28.We may revise this Policy from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued employment and participation in our recruitment process constitute your acknowledgement and acceptance of such changes.

CONSENT CLAUSE FOR JOB APPLICANT

You acknowledge that you have read, understood and agree to the above Policy, and consent to the collection, use and/or disclosure of your personal data by us for the purposes set out in the Policy.

In the event that we have received your job application or personal data from any third party pursuant to the purposes set out in the Policy, you warrant that such third party has been duly authorised by you to disclose your personal data to us for the purposes set out in the Policy.

The collection of your personal data by us may be mandatory or voluntary in nature depending on the purposes for which your personal data is collected. Where it is mandatory for you to provide us with your personal data, and you fail or choose not to provide us with such data, or do not consent to the above or this Privacy Policy, we will not be able to provide our services to you.

You acknowledge that the personal data provided by you is accurate and complete.

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