Yamato Transport (S) Pte Ltd Personal Data Protection Policy
Our employees, servants, agents, representatives, and/or contractors shall abide by the Personal Data Protection Act 2012 (the “PDPA”) and shall make thorough, ongoing efforts to protect your Personal Data.
1.3 A third party means any person other than yourself. Examples of third parties include but are not limited to your family members or employees.
1.4 Generally, consent can be given in two forms, that is, express consent or deemed consent. You are deemed to have given your consent in the following situations:
(a) by conduct – You are deemed to have given your consent by conduct when you voluntarily provide your Personal Data to us. You may be regarded as voluntarily providing Personal Data where you take certain actions that allow the Personal Data to be collected, without providing the data yourself. Your consent is deemed to be given to the extent that you have intended to provide your Personal Data and have taken the action required for your Personal Data to be collected by us;
(b) by contractual necessity – You are deemed to have given your consent where you provide your Personal Data to us for the purpose of a transaction, and it is reasonably necessary for us to disclose such Personal Data to another organization for the necessary conclusion or performance of the transaction between you and us, or;
(c) by notification – You are deemed to have given your consent to the collection, use and/or disclosure of your Personal Data for a purpose that you have been notified of, and you have not taken any action to opt out of the collection, use and/or disclosure of such Personal Data.
For examples of deemed consent by conduct, contractual necessity or notification, please refer to Advisory Guidelines on Key Concepts in the Personal Data Protection Act (Revised 1 October 2021), at [12.21] – [12.23], which can be accessed at https://www.pdpc.gov.sg/guidelines-and-consultation/2020/03/advisory-guidelines-on-key-concepts-in-the-personal-data-protection-act.
- Personal Data
2.2 To illustrate, Personal Data includes but is not limited to the following:
(a) Contact information which may include your name, telephone number(s), mailing address, and/or email address;
(b) Financial information which may include your income levels, bank account number, credit card information, payment status, invoices and/or credit history;
(c) Information that is found on your National Registration Identification Card, passport and/or any other identification number that can be used to ensure verification of your identity;
(d) Background information, which may include employment history and/or education background;
(e) User and preference information which may include complaints, communication, and/or browsing preferences; and/or
(f) Cookies which may include IP address, unique device or user ID, system and browser type, date and time stamps referring to content and pages you access on our website, dates, times, locations and actions that take place, and/or websites you visit in connection to our services.
3.1 Cookies are small, often encrypted text files that are located in browser directories, on a user’s computer or device. Cookies are created when a user’s browser loads a particular website. The website sends information to the browser which then creates a text file. Amongst other things, cookies help the website user to navigate efficiently between pages and the website operator to track usage of the website.
3.2 Our website uses “Session cookies”, which are strictly necessary in order for our website to function. Session cookies are used to:
(a) store user authentication details such as the username and password of a user on login;
(b) indicate when a particular user is logged in; and/or
(c) customise the view of the admin interface of our website and the front-end of the website.
3.3 Further, our website uses “Comment cookies”, which are persistent cookies that are not strictly necessary for our website to function. Comment cookies are used to remember the users of our website so that the values (such as the name and email address of each user) are automatically filled in the corresponding fields and the users do not have to enter such details every time they want to fill in an enquiry form on our website. Such cookies are set for almost a year.
3.6 By using our services, including our website, you agree and accept that we will access your information stored on the cookies.
3.7 Further, please be informed that if you continue to browse our website without clicking on the “Accept cookies” button on the cookies banner of our website, our website will continue to send cookies to your device.
3.8 You may instruct your browser to refuse or disable cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our website and our service.
3.9 You may also choose to opt out of being tracked by Google Analytics across all websites. Please visit https://tools.google.com/dlpage/gaoptout for more information on how to opt out of being tracked by Google Analytics.
- Collection of Personal Data
4.1 We collect Personal Data in the following ways:
(a) when you submit any form or documentation relating to any of our services;
(b) when you submit your CV or resume and any other supporting documents for an employment opportunity with us;
(c) when you interact with our representatives via telephone calls, letters, face-to-face meetings and/or emails;
(d) when you are contacted by, and respond to, our marketing representatives and agents;
(e) when you respond to our request for Personal Data;
(f) when we receive references of you from business partners and/or third parties;
(g) when a third party submits your Personal Data to us as a recipient of our services; and/or
(h) when we seek information from third parties about you in connection with the services you want us to provide.
4.2 We do not collect Personal Data from you if you click on the “Leave website” button of the cookies banner. However, please be informed that if you click on the “Accept cookies” button of the cookies banner, or if you continue to browse our website without clicking on any of the buttons on the cookies banner, Personal Data will be collected from you. Personal Data will also be collected from you if you provide such information on our website.
- Purposes for the Collection, Use and Disclosure of Your Personal Data
5.1 We collect, use and disclose your Personal Data for the following purposes:
(a) carrying out and providing the services you requested including the preparation of documentation and/or application for permit and/or licences from relevant authorities;
(b) responding to your queries, complaints and/or feedback;
(c) conducting our administrative and business operations (including but not limited to conducting marketing research, and/or improvement of services provided to you), analysing and/or managing commercial risks;
(d) enforcing and/or protecting our contractual and/or legal rights;
(e) preventing and/or investigating crimes, complying with requirement(s) by law enforcement and/or by relevant authorities (including the use of CCTV surveillance and/or conducting security clearance);
(f) carrying out billing;
(g) for quality assurance, employee training and/or performance evaluation, and identity verification purposes;
(h) processing any insurance claims and/or payments arising under the respective policies; and/or
(i) any other purpose relating to any of the above or such that which in our opinion reasonably requires the use of your Personal Data subject to your rights at law.
- Disclosure of Personal Data
6.1 We do not disclose Personal Data to third parties except when required by law, when we have your consent or deemed consent, or in cases where we have engaged a third party such as data intermediaries or subcontractors, specifically to assist with our company’s activities. Any such third parties whom we engage will be bound contractually to keep all information confidential.
6.2 We will take reasonable steps to protect your Personal Data against unauthorised disclosure.
(a) our related companies and/or employees to provide our services to you;
(b) agents, contractors and/or third party service providers who provide operational services to us to fulfil and/or perform the services, to be provided to you;
(c) collection and/or repossession agencies in relation to the enforcement of payment obligations for debts;
(d) our professional advisers e.g. lawyers and/or auditors;
(e) relevant government regulators, statutory boards or authorities, and/or law enforcement agencies to comply with any laws, rules, guidelines, regulations and/or schemes imposed by any governmental authority; and
(f) any other party to whom you have given your consent, or have deemed to have given your consent for us to disclose your Personal Data.
- Access to and Correction of Your Personal Data
7.1 Upon request, we will provide you with access to your Personal Data or other appropriate information on your Personal Data in accordance with the requirements of the PDPA.
7.2 Upon request, we will correct any error or omission in your Personal Data that is in our possession or control in accordance with the requirements of the PDPA.
7.3 We may charge for a request for access in accordance with the requirements of the PDPA.
7.4 In the event you wish to request access to and/or correct your Personal Data, please write to our Data Protection Officer (“DPO”) via email at [email protected] with your request to access and/or correct your Personal Data.
- Withdrawal of Consent
8.1 Upon reasonable notice being given by you of your withdrawal of any consent given or deemed to have been given in respect of our collection, use or disclosure of your Personal Data, we will cease (and cause any of our data intermediaries and agents to cease) collecting, using or disclosing your Personal Data unless it is required or authorised under applicable laws.
8.2 Upon withdrawal of your consent to any or all use of your Personal Data, we may not be in a position to continue to provide our services to you. In the event any such withdrawal may result in the termination of any contractual relationship and you being in breach of your contractual obligations or undertakings, our legal rights and remedies in such event are expressly reserved.
8.3 In the event you wish to withdraw any consent given or deemed to have been given in respect of our collection, use or disclosure of your Personal Data, please write to our DPO via email at [email protected] with your request to withdraw any such consent given or deemed to have been given.
- Security and Protection of Personal Data
9.1 We shall implement generally accepted standards of technology and operational security to prevent leakage, loss or damage, unauthorised access and/or copying of Personal Data in our possession.
9.2 We will cease to retain Personal Data, as soon as it is reasonable to assume that the purpose for collection of such Personal Data is no longer being served by such retention, and such retention is no longer necessary for legal or business purposes.
- Transfer of Personal Data out of Singapore
10.1 We will ensure that any transfers of Personal Data to a territory outside of Singapore will be in accordance with the PDPA so as to ensure a standard of protection to Personal Data so transferred that is comparable to the protection under the PDPA.
10.2 Notwithstanding the above, we are deemed to have satisfied our obligation(s) as set out at clause 10.1 in the following situations:
(a) if the individual whose Personal Data is to be transferred gives his consent to the transfer of such Personal Data, after he has been informed about how such Personal Data will be protected in the destination country;
(b) if the individual is deemed to have consented to the disclosure by us of his Personal Data where the transfer is reasonably necessary for the conclusion or performance of a contract between us and the individual, including the transfer to a third party organisation;
(c) if the transfer is necessary for a use or disclosure that is in the vital interests of individuals or in the national interest, and we have taken reasonable steps to ensure that such Personal Data will not be used or disclosed by the recipient for any other purpose;
(d) if the Personal Data is data in transit; or
(e) if the Personal Data is publicly available in Singapore.
- Notification in the event of a data breach
11.1 In the event of a data breach, we will take reasonable and expeditious steps to assess whether the data breach is notifiable under the PDPA. If the data breach is assessed to be notifiable under the PDPA, we will notify the affected individuals and/or the Personal Data Protection Commission (the “PDPC”). A data breach is notifiable if such breach is likely to result in significant harm to the affected individuals. Significant harm can include severe physical, psychological, economic and financial harm, and other forms of severe harms that a reasonable person will identify as a possible outcome of a data breach.
11.2 The Personal Data Protection (Notification of Data Breaches) Regulations 2021 sets out a list of personal data (or classes of personal data) that is deemed to result in significant harm to affected individuals if compromised in a data breach. Where a data breach involves any of the prescribed personal data, we will notify the affected individuals and the PDPC of the data breach. Please refer to the Personal Data Protection (Notification of Data Breaches) Regulations 2021 at https://sso.agc.gov.sg/SL-Supp/S64-2021/Published/20210129170000?DocDate=20210129170000&WholeDoc=1 for more information regarding such a list of personal data (or classes of personal data).
- Data Protection Officer
In order to handle your concerns or further queries about how your Personal Data is protected or managed, we have appointed a DPO. Please feel free to contact our DPO at:
Phone number: +65 6632 7410 / +65 6632 7409
Email: [email protected]