Last updated: 10 September 2021
- 2. To safeguard your personal data, all electronic storage and transmission of personal data is secured with appropriate security technologies. However, data transmission over the internet can be subject to security gaps. A complete protection of the data against access by third parties is not possible.
II. Data Controller and Data Protection
- 3. The name and address of the data controller of this website is:
- Singapore Economic Development Board (EDB)
- 250 North Bridge Road, #28-00, Raffles City Tower, Singapore 179101
- 4. If you have any questions regarding the collection, processing or use of your personal data, please contact our Data Protection Officer at:
- 250 North Bridge Road, #28-00, Raffles City Tower, Singapore 179101
- Tel: +65 6832 6832
- Email: firstname.lastname@example.org
III. Data Process on our Website
1. Membership & Gated Content
- 5. The Singapore Global Network (SGN) warmly invites you to be a part of our vibrant and exciting global network of family, friends and fans of Singapore. SGN organises regular social and professional get-togethers and events in various cities around the world, and keeps our members updated on the latest news on Singapore and our global community through e-newsletters. If you wish to become a member of SGN, we require the following information from you:
- a. your salutation;
- b. your name;
- c. your email address;
- d. your nationality;
- e. whether you are a Singapore Citizen or Permanent Resident;
- f. your country or region of residence;
- g. your city of residence;
- In addition, if you are working:
- h. your occupation;
- i. your industry;
- j. the name of your company or organisation;
- k. your job function; and
- l. your job level.
- In addition, if you are studying:
- m. the name of your school or institution;
- n. your course of study;
- o. the qualification that you are pursuing; and
- p. your expected year of graduation.
- 6. There are forms on our website through which you can sign up as an SGN member and access gated content. When you submit the form, the data entered in the input mask will be transmitted to us and stored. The following data will also be stored at the time the form is submitted:
- a. your IP address; and
- b. the date and time of your registration.
- 7. We use the data in paragraph 5 exclusively for the following purposes:
- a. Tailor our products and services to what would best meet your needs and help you get the most out of the network. These could include:
- i. Professional networking, e.g., to help you find other members of the network in the same occupation/industry.
- ii. Social communities, e.g., to see if there are community groups within the network in your country/city that you might be interested in.
- iii. Jobs and internship opportunities, e.g., to give you exclusive invitations to events by our partners with hiring needs.
- iv. Content, e.g., to curate e-newsletters to provide information that is more likely to be relevant to you.
- b. Reach out to you to offer the aforementioned products and service, e.g., using your email address.
- c. Better understand the profile of members of the network and how we can better serve them through data analysis.
- a. Tailor our products and services to what would best meet your needs and help you get the most out of the network. These could include:
- 8. If we should ever wish to use your data for purposes other than those listed above, we will first seek your explicit consent via an e-mail or a form on our website or other digital channels. Until you have provided consent, we will not use your data for purposes other than those listed above.
- 9. We may share your data with relevant Singapore government agencies where it helps to achieve the above purposes (in paragraph 7). We do not share your personal data with advertisers.
- 11. As we will need to use your data to serve you as a member, we will store your data until you indicate that you wish to (i) withdraw membership, and (ii) revoke consent for the storing and processing of your data. You may do so at any time by emailing us at email@example.com. The legality of the data processing operations that might have already taken place would remain unaffected by the revocation. This also does not affect data stored by us for other purposes.
- 12. We do not knowingly collect or solicit any personal information from anyone under the age of 16. If a child under the age of 16 has provided us with personal information without parental or guardian consent, the parent or guardian may contact us by emailing us at firstname.lastname@example.org. We will remove the information as quickly as possible and unsubscribe the child from any of our electronic marketing lists. Where required by applicable law, we may seek consent from the child’s parent or guardian before we provide a service or product to them.
- 14. “Necessary” cookies are required for the purpose of measuring the effectiveness of social media marketing efforts, to give real human users a better experience through bot detection, and manage the consent for other types of cookies. Examples of data that could be transmitted include popularity of outgoing links and drop-off rates for form completion.
- 15. “Statistics” cookies are used for the purpose of improving the quality of our website and its contents to serve you better. The statistics cookies tell us how the website is used and enable us to constantly optimise our services for you. Examples of data that could be transmitted include entered search terms, frequency of page views, and use of website functions.
- 16. “Others” cookies are used for the purpose of improving the page load time of our website through use of Content Delivery Network providers.
- 17. As soon as you visit our website, we will give you the opportunity to choose between different cookie settings. The cookies will only be set after you have given your consent through your selection.
- 19. For users from the European Union, the legal basis for the processing of personal data using cookies is Art. 6 (1) lit. f GDPR or Art. 6 (1) lit. a GDPR if you have given your consent. Our legitimate interest in the processing of personal data in accordance with Art. 6 (1) lit. f GDPR also lies in the purposes as articulated in paragraphs 14-16.
3. Server log files
- 20. The provider of the pages automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These data are stored in the log files of the server and not together with your personal data. The following data is sent to us each time you access the website:
- a. browser type and browser version;
- b. operating system;
- c. date and time of access;
- e. IP address;
- f. referral URL; and
- g. websites accessed by the your system through our website.
- 21. The temporary storage of the IP address by the system is necessary to enable delivery of the website to your computer. For this purpose, your IP address must remain stored for the duration of the session. Log files are stored to ensure the functionality of the website. The data is also used to optimise the website and to ensure the security of our information technology systems.
- 22. As long as you still interact with us, the aforementioned uses of the data would still apply. For this reason, we will store the data specified in paragraph 20 until such time that you cease to interact with us and seem unlikely to interact with us again, i.e., if there is no activity on your part (through website visits, email interactions, form submissions, event registration etc.) for more than 2 years.
- 23. For users from the European Union, the legal basis for the temporary storage of data and log files is Art. 6 (1) lit. f GDPR. Our legitimate interest in data processing pursuant to Art. 6 (1) lit. f GDPR lies in the purposes articulated in paragraph 21.
4. Third party modules
a. Google Analytics
- 25. The information generated by this text file about the use of our website is transferred to a Google server in the USA and stored there. Google will use this information for the purpose of evaluating your use of our website, compiling reports on website activity for website operators and providing website operators with information about website activity. If this is required by law or if third parties process this data on behalf of Google, Google will also pass this information on to these third parties. This use takes place anonymously. You can find more information about this directly at Google.
- 26. You can prevent the storage of these cookies by an appropriate setting of your browser software, but this would prevent you from using all the functions of this website to their full extent. You can prevent Google from collecting the data generated by the cookie and related to your use of the website and from processing this data by downloading and installing the browser plugin available under the following link: tools.google.com/dlpage/gaoptout.
- 27. General information on Google Analytics and data protection can be found at www.google.com/analytics/learn/privacy.html. On this website, Google Analytics has been extended to annonymise the IP addresses that are collected.
b. Google Tag Manager
- 28. We use Google Tag Manager, which is a service of Google Inc. that allows us to manage website tags through a single interface. The Tag Manager tool itself (which implements the tags) is a cookie-free domain and does not collect any personally identifiable information. The tool triggers other tags that may themselves collect data. Google Tag Manager does not access this data. If deactivation has been performed at the domain or cookie level, it will persist for all tracking tags implemented with Google Tag Manager.
c. Facebook Pixel
- 29. We use Facebook Pixel, which is a service of Facebook Inc. that allows us to classify the visitors to our website into specific target groups in order to be able to display corresponding advertisements on Facebook. The data collected (e.g. IP addresses, information about the web browser, the location of the website, buttons clicked, possibly pixel IDs and other features) cannot be viewed by us, but can only be used for the display of certain advertisements. Within the framework of the use of the Facebook pixel code, cookies are also set.
- 30. If you have a Facebook account and are logged in, your visit to this website is assigned to your Facebook user account.
- a. To learn how Facebook pixel is used for advertising campaigns, please visit: https://www.facebook.com/business/learn/facebook-ads-pixel
- c. Further information on data processing by Facebook can be found at: https://www.facebook.com/about/privacy
- We use these functions in order to be able to present you with advertising offers corresponding to your interests.
- 31. The deactivation of the “Facebook Custom Audiences” function is possible for logged in users at: https://www.facebook.com/settings/?tab=ads#.
- 32. You can change your settings for advertisements in Facebook at https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen if you are logged in to Facebook.
- 33. We use the LinkedIn Insight tag for this website. The LinkedIn Insight tag creates a LinkedIn “browser cookie” that collects the following information:
- a. IP address;
- b. timestamp;
- c. side activities; and
- d. demographic data of LinkedIn if the user is an active LinkedIn member.
- 34. This technology enables us to generate reports on the performance of our advertisements and information about website interaction. To do this, the LinkedIn Insight tag is embedded on this website, connecting to the LinkedIn server when you visit this website and are logged into your LinkedIn account at the same time.
- 35. We process your information to evaluate campaigns and collect information about website visitors who may have reached us through our campaigns on LinkedIn.
- The collected data is encrypted.
- 42. We may share your data with relevant Singapore government agencies where it helps to serve you better (as described in paragraph 7). We do not share your personal data with advertisers.
V. Your Rights
- 43. You have the following rights as articulated in paragraphs 44 to 58, within the framework of the applicable legal provisions.
1. Right of Information
- 44. You may obtain information free of charge at any time about your stored personal data by contacting us at email@example.com. You may request for the following information:
- a. the purposes for which your personal data will be processed;
- b. the categories of your personal data processed;
- c. the recipients or categories of recipients to whom your personal data has been or will be disclosed;
- d. the planned duration of the storage of your personal data or, if this is not possible, criteria for determining the duration of the storage;
- e. all available information on the origin of the data, if the personal data are not collected from the data subject;
- f. the existence of automated decision-making, including profiling, on your personal data and – at least in these cases – meaningful information on the logic involved and the scope and intended effects of such processing. For users from the European Union, this is in accordance with Article 22(1) and (4) GDPR); and/or
- g. whether your personal data will be transferred to a third country or to an international organisation. For users from the European Union, you may request to be informed of the appropriate guarantees pursuant to Art. 46 GDPR in connection with the transfer.
2. Right to Rectification
- 45. You may ask to have your personal data corrected and/or completed by us if it is inaccurate or incomplete. We will rectify the data without delay.
3. Right to Limit Processing
- 46. You may ask to restrict processing of your personal data under the following conditions:
- a. if you dispute the accuracy of your personal data – you may request restricted processing for a period of time to enable verification of the accuracy of your personal data;
- b. if you believe that the processing is unlawful and you refuse to delete your personal data but wish instead to restrict its use;
- c. if we no longer need your personal data and would normally be required to delete it, but you would like us to continue to store the data as you need them to assert, exercise or defend legal claims; or
- d. for users from the European Union, if you have lodged an objection against the processing pursuant to Art. 21 GDPR and it has not yet been determined whether the justified reasons of SGN as the data controller outweigh your reasons.
- 47. If processing has been restricted in accordance with the above conditions, you will be informed by the controller before the restriction is lifted.
- 48. For users from the European Union, If the processing of your personal data has been restricted, such data – apart from their storage – may only be processed with your consent or for the assertion, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of an important public interest of the Union or a Member State.
4. Right to Deletion
- 49. You may ask for your personal data to be deleted and we will comply immediately if one of the following reasons apply:
- a. your personal data is no longer necessary for the purposes for which they were collected or you revoke your consent on which the processing was based – this would be the case if you withdraw your SGN membership, and you may do so at any time by emailing us at firstname.lastname@example.org;
- b. you object to the processing of your personal data and there are no overriding legitimate reasons for the processing (for user from the European Union, this would be pursuant to Art. 21 (1) GDPR);
- c. your personal data has been processed unlawfully; or
- d. the deleting of the personal data concerning you is necessary for the fulfilment of a legal obligation.
- 50. If you have asked for your personal data to be deleted, we will take all reasonable measures to do so, including technical measures, taking into account the available technology and the implementation costs. For users from the European Union, this is in accordance with Art. 17 GDPR.
- 51. The right to deletion does not apply if the processing is necessary:
- a. For the exercise of freedom of expression and information;
- b. to fulfil a legal obligation which processing is subject to or to perform a task carried out in the public interest or in the exercise of public authority;
- c. for reasons of public interest in the field of public health (for users from the European Union, this is pursuant to Art. 6 GDPR);
- d. for archive purposes in the public interest, scientific or historical research purposes or for statistical purposes (for users from the European Union, this is pursuant to Art. 86 (1) GDPR, insofar as the law referred to in (1) presumably makes the realisation of the objectives of such processing impossible or seriously impairs them); or
- e. to assert, exercise or defend legal claims.
5. Right of Information of Recipients
- 52. If you have exercised your right to rectify, delete or limit the processing of your personal data, we will notify all recipients to whom your personal data has been disclosed of this rectification or cancellation or limitation of processing, unless this proves impossible or involves a disproportionate effort. We will also inform you of these recipients.
6. Right to Transfer Data
- 53. You may ask to have your personal data in our possession handed over to you or to another responsible person in a structured, common, machine-readable format. This will only be done as far as it is technically feasible, and only if it does not affect the freedoms and rights of other persons.
7. Right of Objection
- 54. You may object at any time to the processing of your personal data. For users from the European Union, you may do so on the basis of Art. 6 (1) lit. e or f GDPR, and this also applies to profiling based on these provisions. If you object, we will no longer process your personal data unless we can prove compelling grounds for processing worthy of protection which outweigh your interests, rights and freedoms, or the processing serves the assertion, exercise or defence of legal claims.
8. Right to Revoke the Declaration of Consent Under Dara Protection Law
- 55. You may revoke consent for the storing and processing of your data at any time by emailing us at email@example.com. The legality of the data processing operations that might have already taken place would remain unaffected by the revocation.
9. Right to Object to Automated Decision
- 56. You have the right not to be subject to a decision based solely on automated processing which has legal effect in relation to you or which significantly affects you in a similar manner. This shall not apply if the decision made:
- a. is necessary for the conclusion or performance of an agreement between you and SGN – this includes automated processing necessary for the information and services that we provide to you as an SGN member,
- b. is lawful and contains adequate measures to safeguard your rights and freedoms and your legitimate interests; or
- c. with your express consent.
- 57. For users from the European Union, these decisions may not be based on special categories of personal data as specified in the GDPR, unless you have provided consent and appropriate measures have been taken to protect the rights and freedoms as well as your legitimate interests.
10. Right to Appeal to a Supervisory Authority
- 58. For users from the European Union, you may appeal to a supervisory authority, in particular in the Member State of your residence, place of work or alleged infringement, if you consider that the processing of your personal data is in breach of the GDPR. This is without prejudice to any other administrative or judicial remedy.
1. Intellectual Property Rights
- 59. The contents of this website including but not limited to all information, text, graphics, music, sound, scripts, programs, software, technology, design, data compilation and other materials or works (collectively “the Materials”) are protected by copyright, trademark and other forms of proprietary rights. All rights, title and interest in the Materials are owned by, licensed to, or controlled by SGN.
- 60. You are permitted to view, download and print the Materials for personal and non-commercial use provided you do not modify the Materials and retain any copyright or proprietary notice contained in the Materials. Except for the limited permission mentioned above, no part or parts of the Materials may be reproduced, republished, reverse compiled, adapted, modified, distributed, commercially exploited, displayed, broadcast, hyperlinked, framed or transmitted in any manner or by any means or stored in an information retrieval system without the prior written consent of SGN.
- 61. SGN has used reasonable endeavours to ensure that the Materials are correct at the time of posting. However, SGN does not warrant the accuracy, adequacy or completeness of the Materials and expressly disclaims liability for any error or omission in the Materials. No warranty of any kind, express, implied or statutory, including but not limited to warranties of non-infringement of third party rights, title, merchantability, satisfactory quality and/or fitness for a particular purpose, is given in conjunction with the Materials and/or this website.
- 62. SGN does not warrant that any of the Materials or that this website will be provided uninterrupted or free from errors or that any identified defect will be corrected. Further, no warranty is given that this website and the Materials are free from any virus or other harmful program, code or macro.
3. Exclusion of Liability
- 63. To the fullest extent permitted by law, SGN shall in no event be liable for any damages, loss or expense, direct or indirect, including but without limitation, special or consequential damage, or economic loss arising from or in connection with:
- a. Any access, use or inability to access or use this website, or reliance on the Materials;
- b. Any system, server or connection failure, error, omission, interruption, delay in transmission, or computer virus; and
- c. Any use of or access to any other website linked to this website even if SGN or its employees are advised of the possibility of such damages, losses and/or expenses.
4. Severance of Terms
- 64. If any provision of these terms and conditions is determined to be invalid or unenforceable, then such invalidity or unenforceability shall not have any effect on any other provision of these terms and conditions, all of which shall remain valid and enforceable.
5. Governing Law and Jurisdiction
- 65. By accessing this website and/or using the services available within this website, you agree that Singapore Law shall govern such access and the provision of such services, as well as the application of these terms and conditions. Further, you agree to submit to the non-exclusive jurisdiction of the Singapore courts regarding any and all disputes relating to these terms and conditions and/or the use of this website.