This Privacy Policy sets out the basis on which Peoplewave Pte. Ltd. of 410 North Bridge Road Singapore 188726 (Unique Entity Number 201627404W) (together with our subsidiaries, our holding company, subsidiaries of our holding company from time to time, collectively called “Peoplewave Pte. Ltd.” or “we”) collects personal data from you and how we process such data.

By visiting our website www.peoplewave.co (our “Site”) or using  First 100 Days, Performance Wave  or any other applications or software we provide from time to time (collectively our “App”), you accept and consent to the practices set out below.

1. Collection of information

1.1 For the purposes outlined in Clause 2, we may collect and process the following information about you:

(a) Information you give us – information that you provide us (which may include your name, address, email address, telephone number, credit card information and other personal description) by filling in forms on our Site or our App, or by corresponding with us (by phone, email or otherwise), for example:

(i) when you register for an account with us on our Site and in our App;

(ii) when you report any problem to us;

(iii) when you use certain features on our Site or our App;

(iv) when you request any support from us; or

(v) when you complete any survey or questionnaire we send you.

(b) Information we collect about you – information automatically collected when you visit our Site or use our App, for example:

(i) technical information, including the Internet protocol (IP) address used to connect your computer to the Internet and your log-in information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;

(ii) information about your visit, including the full Uniform Resource Locators (URLs), clickstream to, through and from our site (including date and time), products you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number; and

(c) Information we receive from third parties – We work with third parties and we may receive information about you from them, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, or credit reference agencies. We will notify you when we receive information about you from them and the purposes for which we intend to use that information.

1.2 We only retain personal data for so long as it is necessary. Data may be archived as long as the purpose for which the data was used still exists.

2. Uses made of the information

We use information held about you for the following purposes:

(a) providing, improving and developing our services;

(b) researching, designing and launching new features or products;

(c) presenting content and information in our Site and our App in the most effective manner for you and for the device you use;

(d) providing you with alerts, updates, materials or information about our services or other types of information that you requested or signed up to;

(e) collecting overdue amounts;

(f) in any part of the world;

(g) responding or taking part in legal proceedings, including seeking professional advice;

(h) communicating with you and responding to your questions or requests; and

(i) purposes directly related or incidental to the above.

3. Disclosure of your information

We will keep your personal data we hold confidential but you agree we may provide information to:

(a) any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, as defined in Section 5 of the Companies Act (Chapter 50);

(b) personnel, agents, advisers, auditors, contractors, financial institutions, and service providers in connection with our operations or services (for example staff engaged in the fulfilment of your order, the processing of your payment and the provision of support services);

(c) our overseas offices, affiliates, business partners and counterparts (on a need-to-know basis only);

(d) persons under a duty of confidentiality to us;

(e) persons to whom we are required to make disclosure under applicable laws and regulations in any part of the world; or

(f) actual or proposed transferees of our operations (or a substantial part thereof) in any part of the world.

4. Cookies

4.1 Our Site uses cookies to distinguish you from other users of the Site. This helps us to provide you with a good experience when you browse our Site and also allows us to improve our Site.

4.2 A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer if you agree to the use of cookies. Cookies contain information that is transferred to your computer’s hard drive.

4.3 We use persistent cookies and session cookies. A persistent cookie stays in your browser and will be read by us when you return to our Site or a partner site that uses our services. Session cookies only last for as long as the session (usually the current visit to a website or a browser session).

4.4 We use the following cookies:

(a) Strictly necessary cookies – These are cookies that are required for the operation of our Site. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.

(b) Analytical/performance cookies – They allow us to recognise and count the number of visitors and to see how visitors move around our Site when they are using it. This helps us to improve the way our Site works, for example, by ensuring that users are finding what they are looking for easily.

(c) Functionality cookies – These are used to recognise you when you return to our Site. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

(d) Targeting cookies – These cookies record your visit to our Site, the pages you have visited and the links you have followed. We will use this information to make our Site and the information displayed on it more relevant to your interests.

4.5 You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you do so, you may not be able to access all or parts of our Site.

4.6 We may use third-party web services on our Site. The service providers that administer these services use technologies such as cookies (which are likely to be analytical/performance cookies or targeting cookies), web server logs and web beacons to help us analyse how visitors use our Site and make the information displayed on it more relevant to your interests. The information collected through these means (including IP addresses) is disclosed to these service providers. These analytics services may use the data collected to contextualise and personalise the marketing materials of their own advertising network.

5. Third-party sites

Our Site, our App or our communication with you may from time to time contain links to third-party websites over which we have no control. If you follow a link to any of these websites, please note that they have their own practices and policies. We encourage you to read the privacy policies or statements of these websites understand your rights. We accept no responsibility or liability for any practices of third-party websites.

6. Security

6.1 All information you provide to us is stored on our secure servers.

6.2 Any payment transactions will be encrypted using TLS/SSL technology.

6.3 Where we have given you (or where you have chosen) a password that enables you to access certain parts of the Site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

6.4 We restrict access to personal information to our employees, service providers and contractors on a strictly need-to-know basis and ensure that those persons are subject to contractual confidentiality obligations.

6.5 We review our information collection, storage and processing practices from time to time to guard against unauthorised access, processing or use.

6.6 Please note, however, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our Site; any transmission is at your own risk.

7. Data transfer

7.1 The data that we collect from you may be transferred to, and stored at, a destination outside Singapore. It may also be processed by persons referred to in Clause 3 above who operate outside Singapore.

7.2 By submitting your personal data you agree to this transfer, storing or processing of data outside Singapore. We will take all steps reasonably necessary to ensure that your data is treated securely in accordance with this privacy policy.

Personal Data Protection Act (PDPA) of Singapore

Peoplewave complies with the Protection and Retention Limitation Obligations of the Personal Data Protection Act of Singapore (the “PDPA”).

Obligations imposed by the data protection provision include:

1. The obligation to obtain, on or before the collection, the individual’s consent to the collection, use and disclosure of the individual’s Personal Data (the “Consent Obligation”).

2. The obligation to ensure that Personal Data is collected, used and disclosed only for purposes which consent was given or which a reasonable person would consider appropriate in the circumstances (the “Purpose Limitation Obligation”).

3. The obligation to notify the individual, on or before collection, use or disclosure, the purposes for which it is collecting, using and/or disclosing the individual’s Personal Data (the “Notification Obligation”).

4. The obligation to provide, upon the request of the individual, information about the ways in which the individual’s Personal Data has been or may have been used or disclosed in the year before the request, and allow the individual to correct his/her Personal Data (the “Access and Correction Obligation”).

5. The obligation to use reasonable effort to ensure that the Personal Data collected by or on its behalf is accurate and complete (the “Accuracy Obligation”).

6. The obligation to make reasonable security arrangements to protect the Personal Data and prevent unauthorised access, collection, use disclosure or similar risks (the “Protection Obligation”).

7. The obligation to cease retaining Personal Data or remove the means by which the Personal Data can be associated with an individual when the personal data is no longer necessary for business or legal purpose (“Retention Limitation Obligation”).

8. The obligation not to transfer Personal Data to a country or territory outside of Singapore except in accordance with the requirements under PDPA (“Transfer Limitation Obligation”).

9. The obligation to make information about its data protection policies, practices and complaints process available on request, and designating one or more individuals as its data protection officer to ensure that the organisation complies with the PDPA (“Openness Obligation”).

The PDPA applies only to Personal Data of individuals given in a personal capacity, for personal purposes and does not apply to “business contact information” which is defined in the PDPA as “an individual’s name, position name or title, business telephone number, business address, business electronic mail address or business fax number and any other similar information about the individual, not provided by the individual solely for his personal purposes”. An organization is not required to obtain consent or otherwise comply with the PDPA in collecting, using or disclosing any business contact information disclosed in the course of a commercial transaction.

Licensee Personal data provided to us

When an Account is created by a licensee, Personal Data is collected. This information constitutes business contact information for purposes of the PDPA. In this regard, we are not required to obtain consent or comply with the Data Protection Provisions in relation to such Personal Data. We do, however as a matter of good business practices describe how we collect, use, disclose and Process this Personal Data in our Privacy Policy.

We have in place appropriate administrative, physical and technical measures to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks to the Personal Data in our possession or under our control, regardless whether the Personal Data is stored in a central server, or on local storage media, or at facilities operated by a third party vendor.

We utilize robust precautions to protect the confidentiality and security of the Personal Data within the Service, by employing technological, physical and administrative security safeguards, such as firewalls and carefully developed security procedures. These technologies, procedures and other measures are used in an effort to ensure that Personal Data is safe, secure, and only available to Subscribers and to those authorized to access such Personal Data. However, no internet, e-mail or other electronic transmission is ever fully secure or error free, so licensees should take care in deciding what information is transmitted, stored or hosted through the Service.

As per the Retention Limitation Obligation, we are required to cease to retain Personal Data which is Processed or remove the means by which the Personal Data can be associated with particular individuals, as soon as it is reasonable to assume that the purpose for which the Personal Data was collected is no longer being served by retention of the Personal Data; and, the retention of the Personal Data is no longer necessary for legal or business purposes.

8. Your Rights

We will take all reasonable steps to ensure that the personal information we collect, use or disclose is accurate, complete and up-to-date, and we will try to confirm your details through our communications with you and promptly add updated or new personal information to existing records when we are advised.

However, we rely on the accuracy of personal information as provided to us both directly and indirectly. Regular review by Users is encouraged and if any of your details change, please log into your online profile to update it. If you believe we are holding information about you that is inaccurate, incomplete, irrelevant or misleading, you can ask us to correct it, or delete it.

If you would like to access personal information that we hold about you, or ask us to update, correct or delete it, you can do so by contacting us in writing via the contact details set out below and verifying your identity. We will do our best to respond to your request within 30 days. We will only refuse access in exceptional circumstances, and if this is the case, we will advise you of our reasons for doing so. We may charge a fee for searching for, and providing access to, your information on a per request basis.

8.1 You have the right to:

(a) check whether we hold personal data about you;

(b) access any personal data we hold about you; and

(c) require us to correct any inaccuracy or error in any personal data we hold about you.

8.2 Any request under Clause 8.1 may be subject to a small administrative fee to meet our cost in processing your request.

8.3 Rights Of Residents Of The European Economic Area And The UK

Under the applicable data protection law, residents of the European Economic Area and the UK have additional rights.

In accordance with applicable data protection law:

  • You are entitled to know what personal information we hold about you and you may ask us to make any necessary changes to ensure that it is accurate, up to date and complete;
  • You may request for us to restrict or object to the processing of personal information, including automated processing and profiling;
  • You may request that we delete personal information we hold about you, unless there is a lawful reason for us not to do so such as if retention is necessary for us to comply with our legal obligations; and
  • In some circumstances, you may request that we provide the personal information (that you have provided to us) to you in a structured, commonly used and machine-readable format and have it transferred to another provider of the same or similar services.

If you wish to exercise any of your rights, you can do so by contacting us in writing and verifying your identity. We will do our best to respond to your request within 30 days.

We will only refuse your request in exceptional circumstances and in accordance with the applicable law, and if this is the case, we will advise you of our reasons for doing so.

In some countries, we may charge a fee for searching for, and providing you with details of the information we hold about you.

9. Making A Complaint

We take any complaints seriously and we will attempt to resolve any issues quickly and fairly. If you consider that an act or practice of Peoplewave has interfered with your privacy in relation to your personal information, you can contact us using the details below. Please include your name, email address, telephone number and clearly describe your complaint.

If we cannot resolve your complaint to a satisfactory standard, you are entitled to lodge your complaint with the relevant supervisory authority. A list of EU national data protection authorities can be found on the European Commission website at: https://ec.europa.eu/info/strategy/justice-and-fundamental-rights/data-protection_en.

10. Changes to our privacy policy

We may amend this policy from time to time by posting the updated policy on our Site. By continuing to use our Site and our App after the changes come into effect means that you agree to be bound by the revised policy.

11. Additional Information

Testimonials

We may display Customer or User testimonials and other endorsements on our website. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial or any other endorsement, please contact us at info@peoplewave.co .

Social media widgets

Our websites may include social media features or widgets, such as the Facebook Like or Share buttons. Use of these features may collect your IP address, detect which page you are visiting on our website, and set a cookie to enable the feature to function properly. Your interactions with these features are governed by the privacy policy of the third party providing these features.

Links to external websites

Our website includes links to other websites. The privacy practices of those other websites may differ from our privacy practices. If you submit personal information to any of those websites, your information is governed by their privacy policy. We encourage you to carefully read the privacy policy of any website you visit.

12. Contact us

If you have any questions, comments or requests regarding personal data, please contact us at info@peoplewave.co.

Last updated:  1st September, 2018