Privacy Policy

This Personal Data Protection Policy ("Policy") is designed to assist you in understanding how Nuffield Holdings Private Limited., as well as its representatives and/or agents (collectively referred to herein as "NH", "us", "we" or "our") collects, uses, discloses and/or processes the Personal Data you may provide in the course of the use of our website and/or application, and such functionalities, services or features offered in connection thereof (collectively, the "Platform"), or in connection with your dealings with, through, or on the same.

1.1 In this Policy, "Personal Data" means (a) all data that falls within the definition of personal information, personal data, personally identifiable information or similar language under the PDPA and any applicable law related to the protection, privacy and security, collection, use or disclosure of sensitive or other personally identification information (collectively, "Data Protection Laws"); (b) all personally identifiable information including name, residential or business address, email address, telephone number, photograph, account number, driver's license, passport, social security or government issued identification number; and (c) all other information relating to or associated with such personally identifiable information.

1.2 Examples of such Personal Data which you may provide to us could include (depending on the nature of your interaction with us):

• your name, addresses, telephone numbers, email addresses, ID or passport number, photographs, video images, contact preferences, date of birth, medical records, and any other information relating to you which you have provided us in any form you may have submitted to us, or via other forms of interaction with you;
• your payment related information, such as your bank account or credit card information, and your credit history.

2.1 Generally, we may collect your Personal Data in the following ways, depending on the nature of your interaction with us:

• when you register your details with our company representatives;
• when you enter into any agreement or provide other documentation or information in respect of your interactions with us;
• when you submit your Personal Data to us when you enter our property and/or premises and/or when your images are captured by us via CCTV cameras while you are within our property and/or premises, or via photographs or videos taken by us or our representatives when you attend our events;
• when you complete our sales orders, requests or applications for our products and services (by phone, in person, mail, or electronically);
• when you interact with our staff in relation to our products and services, including customer service officers, for example via telephone calls (which may be recorded), direct mails, fax, face-to-face meetings, social media platforms, emails or any other means;
• when you use and/or subscribe to any of our products and services such as consultation services, training services and/or any of our maintenance and after sales service program;
• when you conduct certain types of transactions such as payments;
• when you interact with us during promotions, competitions, contests, special events, workshops or respond to any request for additional Personal Data;
• when we receive your Personal Data from business partners, public agencies, your ex-employer, referral intermediaries, and any third parties or the relevant authorities, for example where you have been referred by business partners or where we have sought information about you in connection with your relationship with us, including for our products and services or job applications; and/or
• when you submit your Personal Data to us for any other reason.

2.2 Without prejudice to the generality of Clause 2.1, we may collect information about the computer, mobile telephone, smartphone or other device you use to access our Platform.

2.3 When you browse our Platform, you generally do so anonymously but please see Clause 9 below for information on cookies, web beacons and other technologies which we have implemented on our Platform. We do not, at our Platform, automatically collect Personal Data unless you provide such information to us.

2.4 If you provide us with any Personal Data relating to a third party (e.g. referral information from existing customers), by submitting such information to us, you represent to us that you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes.

2.5 Where consent is not obtained, NH may collect, use and disclosed personal data pursuant to an exception under the PDPA or other written law when the use is necessary for the following scenario:

• To respond to an emergency that threatens your life, health and safety or of another individual
• Necessary in the national interest, for any investigations or proceedings

3.1 Subject to the provisions of any applicable law, generally, we may collect, use and disclose your Personal Data for the following purposes depending on the nature of your interaction with us:

• to communicate with you;
• to assess, process and provide products, services and/or facilities to you, including performing obligations in the course of or in connection with our provision of the goods and services requested by you;
• to administer and process any payments related to products, services and/or facilities requested by you or your commercial transactions with us;
• to establish your identity and background;
• to respond to your enquiries, feedback, requests or complaints and/or resolve any issues and disputes which may arise in connection with any dealings with us
• to facilitate your participation in, and our administration of, any events including workshops, promotions, contests or campaigns; to maintain and update internal record keeping
• for internal administrative purposes, or managing and planning the administrative and business operations of NH and complying with internal policies and procedures;
• to share any of your Personal Data pursuant to any agreement or document which you have duly entered with us for purposes of seeking legal and/or financial advice and/or for purposes of commencing legal action;
• for detecting, conducting any form of investigation and preventing fraudulent, prohibited or illegal activities and analysing and managing commercial risks, including those relating to disputes, billing, fraud, offences, prosecutions etc;
• for enabling us to perform our obligations and enforce our rights under any agreements or documents that we are a party to;
• to transfer or assign our rights, interests and obligations under any agreements entered into with us;
• for meeting any applicable legal or regulatory requirements and making disclosure under the requirements of any applicable law, regulation, direction, court order, by-law, guideline, circular or code applicable to us;
• to enforce or defend our rights and your rights under, and to comply with, our obligations under the applicable laws, legislation and regulations;
• for purposes required to operate, maintain and better manage our business and your relationship with us; which we notify you of at the time of obtaining your consent;
• facilitating business asset transactions (which may extend to any mergers, acquisitions or asset sales);
• matching any Personal Data held which relates to you for any of the purposes listed herein;
• managing the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances);
• monitoring or recording phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes; and/or
• in connection with any claims, actions or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution), and/or protecting and enforcing our contractual and legal rights and obligations.

3.2 In addition, we may collect, use and disclose your Personal Data for the following purposes, depending on the nature of our relationship with you:

• If you have an account with us:
  • to process your account and to maintain your account with us;
  • administering and processing your requests including creating and maintaining profiles of our users in our system database for administrative purposes (including but not limited to tracking your use of the Platform); and/or
  • administering debt recovery and debt management.
• If you are an employee, officer or owner of a vendor, contractor or other external service provider, or prospective vendor, prospective contractor, or other prospective external service provider of NH:
  • to conduct appropriate due diligence checks;
  • to evaluate your organisation's suitability as a vendor, contractor, and external service provider for NH and to conduct background checks on you;
  • to create and maintain profiles of our vendors, contractors, and external service providers in our system databases;
  • to process and facilitate necessary actions and processes for the purposes of the work or engagement of said vendor, contractor, and external service provider;
  • to respond to emergencies;
  • for facilities management purposes (including but not limited to issuing visitor access passes and facilitating security clearance); and/or
  • to communicate with your deployed staff, after award of contract, who are in our properties to carry out work or services, and for any emergency or/and security concerns.

3.3 Furthermore, where permitted under Data Protection Laws, NH may also collect, use and disclose your Personal Data for the following "Additional Purposes":

• taking or filming photographs and videos for corporate publicity or marketing purposes, and featuring your photographs and/or testimonials in our articles and publicity materials and/or on our website;
• providing or marketing services and benefits to you, including promotions, service upgrades, loyalty, reward and/or membership programmes (including event invitations, newsletters and marketing and promotional information to you pursuant to such membership programmes);
• organising roadshows, tours, campaigns and promotional or events and administering contests and competitions;
• matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision or offering of services;
• sending you details of services, services updates and rewards, either to our customers generally, or which we have identified may be of interest to you;
• aggregating and analysing customer profiles and data to determine patterns and trends, understanding and analysing customer behaviour, location, preferences and demographics for us to offer you other products and services as well as special offers and marketing programmes which may be relevant to your preferences and profile;
• to provide you with information and/or updates on our products, services, upcoming promotions offered by us and/or events and product launch events organised by us and selected third parties which may be of interest to you from time to time;
• for direct marketing purposes via phone call and/or any other appropriate communication channels to you on our services and products, in accordance with your consent; and/or
• to share any of your Personal Data with our business partners to jointly develop products and/or services or launch marketing campaigns.

3.4 You have the rights regarding NH, use or disclosure of your personal data. If you choose not to provide us the personal data as described in this notice, we may not be able to perform our obligations as stated in clause 3. You have the right to object to the processing of your personal data and withdraw your consent in the manner described in Clause 6 and 11.

3.5 If you have provided us with your Singapore telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your Singapore telephone number(s), then from time to time, NH may contact you using such Singapore telephone number(s) (including via voice calls, text, fax or other means) with information about our products and services.

3.6 In relation to particular products or services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.

3.7 NH shall undertake to protect personal data in its possession or under its control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks;

Subject to the provisions of any applicable law, your Personal Data may be disclosed, for the purposes listed above (where applicable), to the following entities or parties, whether they are located overseas or in Singapore:

• third party service providers, agents and other organisations we have engaged to perform any of the functions with reference to the above mentioned purposes;
• amongst NH staff in Singapore and overseas to carry out their job obligations with appropriate technical and organizational measures in place; to assist with the resolution of technical support issues relating to the Software, whether via ticketing system, telephone calls or otherwise.
• any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any mergers, acquisitions and debt or asset sale);
• relevant government regulators, government ministries, statutory boards, embassies or authorities and/or law enforcement agencies, whether local or overseas, to comply with any directions, laws, rules, guidelines, regulations or schemes issued or administered by any of them; and/or
• any other party to whom you authorise us to disclose your Personal Data.

5.1 You have the right, under the PDPA, to make:

• a 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; or
• a correction request to correct or update any of your Personal Data which we hold,

by submitting your request in writing or via email to our Data Protection Officer ("DPO") at the contact details provided below. Subject to the provisions of Data Protection Laws, we will endeavour to respond to your access and/or correction request within 30 days after receiving such request. If we are unable to respond to your access and/or correction within 30 days after receiving such a request, we will inform you in writing within 30 days of the time by which we will be able to respond to the request.

5.2 Depending on the scope and nature of the work required to process your access and/or correction request, we may be required to impose a fee to recover our administrative costs. This will be assessed on a case-by-case basis by our DPO. Where such a fee is to be imposed, we will inform you of the fee before processing your request. Please note that we will only process your request once you have agreed to the payment of the fee. In certain cases, we may also require a deposit from you before we process the access request. You will be notified if a deposit is required, if any.