Data Protection and Privacy Policy

Introduction

 
We at T2 Web Pte Ltd respect the privacy and confidentiality of personal data in our possession or under our control. We have implemented policies and practices to safeguard the collection, use, disclosure, storage and other processing of personal data provided to us.

 

How We Collect Your Personal Data About You

 
We collect personal data from the following sources:
 

Internal Collection Channels

  • Website – Microsites
  • Employees own devices, eg. Information sent via WhatsApp
  • Social Media – Corporate
  • Website – Corporate (via submission forms, emails)
  • Customer Service/Support

 

External Collection Channels

  • Educational Instituitions (internships etc)
  • Referral (Web)
  • Government & Ministries
  • Other Outsourced Providers
  • Market Researchers / Direct Marketing
  • Associates

 

Data Collectors

  • Support Services
  • Sales
  • Accounts
  • Finance
  • Agents / Associates / Affiliates
  • Technical Support
  • Information Technology
  • Information Security

 

Types of Personal Data About You that We Process

 
The types of personal data we collect about you and process (or have a service provider process on our behalf) may include:
 

  • Authentication
  • Behavioural
  • Communication and Correspondence
  • Computer Device
  • Demographic
  • Personal Contact Information
  • Personal Details
  • Online Activity

 

Our Purpose(s) for Processing Personal Data About You

 
We use and otherwise process the personal data we have collected about you for one or more of the following purposes:
 

General

  • Billing, payment processing and other credit-related activities
  • Carry out our obligations arising from any contracts entered into between you and us
  • Comply with or fulfil legal obligations and regulatory requirements
  • Conduct risk assessment, or analyse risk and business results
  • Customer care and account management
  • Enhance or improve our applications, products or services
  • Fulfil requests, orders and delivery of products and services
  • Internal purposes for accounting, audting and booking
  • Internal purposes for auditing, data analysis and research
  • Investigate complaints, claims and disputes
  • Market and provide products or services
  • Process applications and registrations for our services or memberships
  • Process contract renewals and upgrades
  • Respond to queries and feedback, and provide customer service and support
  • Update records in our database

 

General Data Processing

  • Email customers of the clients (eMarketing service)

 

Legal

  • Manage board of director and committee meetings and ensure statutory and regulatory compliance.

 

Marketing

  • Conduct market research and analysis
  • Conduct needs analysis and requirements

 

Online

  • Analyze website visits
  • Communicate with customers, members and website visitors
  • Customisation of content and advertising
  • Determine geographical information
  • Email marketing
  • Ensure content is presented in most effective manner
  • Improve site and service performance and delivery
  • Manage website and social media platforms
  • Personalize website experience and services
  • Protect the security or integrity of our websites and our business
  • Provide usage of online services
  • Register, setup and manage accounts
  • Remarketing and behavioral targeting – Adwords
  • Remarketing and behavioral targeting – Google Analytics for display advertising

 

Who We Disclose Personal Data About You To

 
We disclose some of the personal data we have collected about you to the following parties or organisations outside T2 Web Pte Ltd:
 

  • Other Business Associates
  • Cloud Service Providers
  • IT/Technical Support
  • Webhosting Companies
  • Accounting Services
  • Customer Support Specialists
  • Information Technology Service Providers
  • Legal Services
  • Other Oursourced Vendors
  • Other Professional Services
  • Application Service Providers
  • Email Service Vendors
  • Other Contracted Service Providers

 

How We Manage the Collection, Use, Disclosure and Storage of Your Personal Data

 

Obtaining Consent

If we collect personal data directly from you, we will ordinarily first notify you of the purposes for which we are collecting it and obtain your express consent to us collecting, using and disclosing it for those purposes. However, when you voluntarily provide personal data to us for a purpose and it is reasonable that you do so we may rely on you being deemed to have consented to us collecting, using and disclosing your personal data for that purpose.
 
Under certain circumstances, we may collect, use and/or disclose personal data about you without your consent for example, so that we can comply with our statutory obligations or where personal data is publicly available.
 

Third-Party Consent

If you have a one-on-one meeting with us or do a transaction with us on behalf of another individual, you must first obtain consent from that individual in order for us to collect, use or disclose his/her personal data.
 

How You Can Limit Processing of Personal Data About You

 

Withdrawal of Consent

If you have given us consent to collect, use, disclose and otherwise process personal data about you, you may withdraw that consent at any time. You should give us reasonable advance notice of your withdrawal of consent. We will notify you of the likely consequences of your withdrawal of consent, e.g. without your personal contact information we may not be able to inform you of future updates or that the quality of our service may be impacted.
 
Your request for withdrawal of consent can take the form of an email or letter to us, or through the UNSUB feature in an online service.
 

Accessing and Making Correction to Personal Data About You

 
You may ask us in writing to tell you what personal data we hold about you and how we have, or may have, used or disclosed it within a year before the date of your request. We will respond to your request as soon as reasonably possible and, in any event, we will respond to you within 30 days after receiving your request. We may charge a fee for processing your request, but we will let you know the amount of the fee before you incur it.
 
You may also ask us to correct an error or omission in the personal data we hold about you. Unless we are satisfied on reasonable grounds that a correction should not be made, we will correct the personal data as soon as practicable.
 
When you make any such request, we may need to verify your identity – for example, by checking your identity card number or other legal identification document.
 

Accuracy of Your Personal Data

 
We will take reasonable precautions and make reasonable verification checks to ensure that the personal data we hold is reasonably accurate, complete and up-to-date.
 
From time to time, we may do a verification exercise for you to update us on any changes to the personal data we hold about you. If we are in an ongoing relationship with you, it is important that you update us if there are any changes in the personal data we hold about you (such as a change in your home address).
 

Protection of Personal Data

 
We have implemented an Information Security Policy that governs how we protect personal data. We make reasonable security arrangements to protect personal data about you that is in our possession or under our control to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. All our employees will take reasonable and appropriate measures to maintain the confidentiality and integrity of your personal data, and will only share your data with authorised persons on a ‘need to know’ basis.
 
Entities that provide services to us to process personal data on our behalf will be bound by contracts with us that that require them to provide sufficient guarantees in respect of the technical and organisational security measures governing the processing to be carried out and to take reasonable steps ensure compliance with those measures.
 

Retention of Personal Data

 
We will not retain any documents containing personal data about you as soon as it is reasonable to assume that the purpose for which we collected that personal data is no longer being served by retention of it and retention is no longer necessary for legal or business purposes.
 
We have a Document Retention Policy that spells out when we must cease to retain personal data and that requires documents and personal data to be destroyed (paper documents) or deleted (electronic documents and data stored in databases) securely. Certain retention periods are based on statutory or regulatory requirements.
 

Transfer of Personal Data

 
If there is a need for us to transfer personal data about you to a country or territory outside Singapore, we will ensure that the recipient organisation will be obliged to provide a standard of protection to such transferred data that is comparable to the protection it receives under Singapore law.
 

Location Information

 
Note that if you give us the permission to do so via your mobile device, we may use and store information about your location. We use this information to provide features of our Service in order to improve and customize our Service. You can enable or disable location services when you use our Service at anytime, through your mobile device settings.
 

Tracking of User Activity

 
Where we track user activity, we will document this in our Data Inventory, and disclose such activity in our Privacy Notice.
 

We use Tracking Tools such as Google Analytics

 
Cookies
We use “cookies” to collect information about your activity on our web site. Cookies are files with a small amount of data, which may include an anonymous unique identifier. Cookies are sent to your browser from a web site and stored on your computer’s hard drive. You can instruct your browser to refuse all cookies or to indicate them when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our web site.
 

Behavioral Remarketing

 
Where we use remarketing services to advertise on third party web sites to you after you have visited our website, we, and our third party vendors, use cookies to inform, optimize and serve ads based on your past visits to our website.
 
The following is used for remarketing services for purposes of advertising:
 

  • Remarketing and behavioral targeting – Google Analytics for display advertising

 
You can opt out of these re-marketing services by visiting the web site of the relevant third party vendor(s).
 

Compliance With Laws

 
Where required to do so by law, we will disclose personal data about you to the relevant authorities or to law enforcement agencies.
 

Links To Other Sites

 
Our website may contain links to other websites that are not operated by us. If you click on a third party link, you will be directed to that third party’s website. It is important that you review the Privacy Policy of every site you visit. We have no control over, and are unable to assume any responsibility for, the content, privacy policies or practices of any third party sites or services.
 

Changes To This Data Protection Policy

 
We may update our Data Protection Policy from time to time. We will notify you of any changes by posting the policy on this page. Please revisit this page periodically for any changes. Changes to this Policy are effective when they are posted on this page.
 

Contacting Us

 
If you have any questions about our collection, use, and/or disclosure of personal data about you; feedback regarding this Policy, or any complaint you have relating to how we collect, use, disclose and store personal data about you, you may contact our Data Protection Officer(s) at dpo@t2web.com.sg.
 
Any query or complaint should include, at least, the following details:
 

  • Your full name and contact information
  • A brief description of your query or complaint

 
We treat such queries and complaints seriously and will deal with them confidentially and within reasonable time.