This Data Protection Notice (“Notice”) sets out the basis which Alpha Development Partnership Ltd. (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of our customers in accordance with the Personal Data Protection Act (“PDPA”). This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.
As used in this Notice:
“customer” means an individual who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us; and
“personal data” means data, whether true or not, about a customer who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.
Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include name, residential address, email address and date of birth.
Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).
COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
We may collect and use your personal data for any or all of the following purposes:
(a) performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
(b) verifying your identity;
(c) responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
(d) managing your relationship with us;
(e) processing payment or credit transactions;
(f) complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
(g) any other purposes for which you have provided the information;
(h) transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
(i) any other incidental business purposes related to or in connection with the above.
We may disclose your personal data:
(a) where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods and services requested by you; or
(b) to third party service providers, agents and other organisations we have engaged to perform any of the functions with reference to the above mentioned purposes.
WITHDRAWING YOUR CONSENT
The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.
Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within thirty (30) business days of receiving it.
Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing.
Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
ACCESS TO AND CORRECTION OF PERSONAL DATA
If you wish to make (a) an access 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 (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
We will respond to your request as soon as reasonably possible. In general, our response will be within thirty (30) business days. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).
PROTECTION OF PERSONAL DATA
To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption, use of privacy filters, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis.
You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
ACCURACY OF PERSONAL DATA
We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.
RETENTION OF PERSONAL DATA
We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.
TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.
Alpha Development Partnership Ltd. internal employees may be located outside Singapore and may access personal data stored in Singapore for their daily business operations. If Alpha Development Partnership Ltd. employees process data outside of Singapore, they will do so only with internal authorized IT equipment that strictly meets all internally defined protection and security requirements. All Alpha Development Partnership Ltd. employees undergo the necessary awareness training to comply with data protection obligations and ensure secure data processing.
DATA PROTECTION OFFICER
You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:
Please visit following link to reach out to us for any query: Data Protection Request
EFFECT OF NOTICE AND CHANGES TO NOTICE
This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.
We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.
Every time an user visits our website, technical information of the user is collected for the contributions to the subject of information security, information (also referred to as server log files) is automatically collected by us or the webspace provider.
Among other information this includes: website name, file, date, data volume, web browser and web browser version, operating system, the domain name of your Internet provider, the referrer URL (the page from which you accessed our offer) and the IP address.
Without this information, it would not be technically possible to deliver and display the website content. In this respect, collecting data is absolutely necessary. Furthermore, we use this information for statistical purposes. They help us to optimise our services and technology.
We also reserve the right to check the log files in case of suspected illegal use of our services.
Alpha Development Partnership Ltd. does not track its customers over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals.
Cookies have two main purposes. They help us make it easier for you to navigate through our services and they also enable the website to be displayed correctly. They are not used to spread viruses or to open programs.
Integrating third-party services and content
Our range includes content, services and services from other suppliers. For example, this might be videos, graphics or images from other websites. In order for this data to be retrieved and displayed in the user’s browser, transmitting the IP address is absolutely necessary. The providers (hereinafter referred to as “third-party providers”) detect the IP address of the respective user.
If you contact us via the online contact form or by email, we will save the information you provide, your IP address and the time it was sent. This allows us to answer your request and ask possible follow-up questions.
In exceptional cases, the full IP address will be transmitted and truncated on a Google (US) server.
The data collected by Google Analytics is evaluated to generate reports on user activity and to optimize your user experience. In order to contradict the storage of the cookies, please make the appropriate setting in your browser. Please note that you can only use other areas of this website to a limited extent.
If you apply to Alpha Development Partnership Ltd., we process your personal data as a controller. Providing your personal data is necessary for an application to proceed. You are entitled to the data subject rights outlined in this document.
We process your personal data to take steps prior to an employment at your request. Any additional processing beyond this application process is based on another, separately declared legal basis.
Our application process is mostly conducted by email and includes following steps:
(1) Letter of motivation
(2) Curriculum vitae
(3) Description of your qualification and education
(4) Attestation of your qualification and education
The extent of your application documents is determined by you. We will only collect data necessary to proceed with the application process.
If we invite you to an interview, we collect further personal data encompassing your personal interests and particulars of your professional aspirations and qualification.
Transfer of application data
We share your application data within our organisation with persons involved in the application process: human resources managers, subject matter experts and potential superiors.
Storage and record keeping
If you enter into an employment contract with us, we keep your application data until the conclusion of that contract’s retention periods.
If we do not close an employment contract, we keep your application data for twelve months. If you want to receive updates on open positions, you may grant us your separate, written consent to do so.
We are committed to protecting and respecting your privacy.
Everyone has rights with regard to the way in which their personal information is handled. During the course of our activities we will collect, store and process personal information about our customers, suppliers and other third parties, and we recognise that the correct and lawful treatment of this data will maintain confidence in the organisation and will provide for successful business operations.
This policy sets out the basis on which any personal information we collect from you, or that you provide to us, will be processed by us. Please read the following carefully to understand our views and practices regarding your personal information and how we will treat it.
The GDPR (Regulation (EU) 2016/679) is a regulation of the European Parliament, the Council of the European Union and the European Commission intended to strengthen and unify data protection for all individuals within the European Union (EU) and became law in the UK on 25th May 2018.
Under the GDPR, we are required to publish information about what data we collect, why we need to store it, and your rights under the GDPR legislation.
In these matters we are subject to the rulings of the Information Commissioner’ Office (ICO), the UK’s independent authority set up to uphold information rights and data privacy for individuals.
When processing your information, we must comply with the six enforceable principles of good practice. These provide that your personal information must be:
Information you give to us
We may collect, use, store and transfer different kinds of personal information about you, including:
‘Special category’ data: Information relating to your racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, criminal convictions, sexual orientation, or certain types of genetic or bio-metric data is known as ‘special category’ data.
At no point during the course of providing you with our services, should we need to collect ‘special category’ data, unless the service we are providing, specifically request us to process that data.
During any third party reviews, supplier new client acquisitions or recruitment processes to join Alpha, we would not ask to hold any special data.
We may obtain personal information by directly interacting with you, such as:
We may also collect personal information from third parties or publicly-available sources, such as:
We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances:
We will only use ‘special category’ information:
We may use your personal information for a number of different purposes. For each purpose, we are required to confirm the basis that allows us to use your information, as follows:
We will only use your personal information for the purpose(s) for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
It is a statutory requirement for you to provide us with certain information, namely sufficient information to verify your identity. If you do not provide us with that information, we will be unable to accept your instructions and provide you with our services.
It is also a contractual requirement for you to provide us with certain information. If you do not provide us with that information, we may be unable to accept your instructions and/or provide you with the full range of our services.
We may share your personal information with the parties set out below:
We require all third parties to respect the security of your personal information and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal information for their own purposes and only permit them to process your personal information for specified purposes and in accordance with our instructions.
All information you provide to us is stored on our secure servers in the United Kingdom, or on secure cloud-based services in a country within the European Economic Area.
We will take all steps reasonably necessary to ensure that your data is treated securely, including taking the following safeguards:
The length of time that we will store your data will depend on the basis for why we are using that data:
To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your information and whether we can achieve those purposes through other means, and the applicable legal requirements.
You have various legal rights in relation to the information you give us, or which we collect about you, as follows:
If you wish to exercise any of your legal rights, please contact us by:
You also have the right, at any time, to lodge a complaint with the Information Commissioner’s Office if you believe we are not complying with the laws and regulations relating to the use/storage of the information you give us, or that we collect about you.
You can ask us to stop sending you marketing communications at any time by opting out by clicking the unsubscribe option on your email.
We do not use automated decision-making processes.
Our website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
Telephone calls made to and by Alpha are not recorded as standard practice. If for any services we are required to record telephone calls with the intention of legitimate business interest, this will be declared at the beginning of any call to all parties. The recordings are stored on the firm’s servers in the United Kingdom and or on our third party conference line PowWowNow server. Where a call recording has been instructed we may process information about the recording files (“call recording data”). The call recording data may be processed for the purposes of the preparation and storage of your call recording. We will never disclose your call recording data, unless we are legally obliged to do so. The legal bases for this processing are:
If you are a business client, we may identify you as a client of the firm in our marketing material or in legal directories, although we will never publicly disclose any confidential information about your matters without having obtained your prior consent. If you do not agree to us identifying you as a customer of the firm, and have not already done so, please notify us by:
Any changes we make to our policy in the future will be posted on our website and, where appropriate, notified to you by email or via social media. Please check our website frequently to see any updates or changes to our policy.
We have always, and continue to, treat all data we receive and works submitted as strictly confidential.
For the purpose of UK data protection laws, the data controller is Alpha Development Partnership LTD.
Questions and requests regarding this policy are welcomed. If you do wish to contact us please do via: