This Policy (together with any other documents referred to in it) sets out the basis on which personal data we collect from you, or that you provide to us, will be processed by us. Please read the Policy carefully to understand our views and practices regarding your personal data and how we will treat it.
For the purpose of the relevant data protection legislation, the data controller responsible for your personal data is Cammillion Capital Pte. Ltd. of registered address 12, Purvis Street, 188591 Singapore.
We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this privacy notice.
If you have any questions about this privacy notice, including any requests to exercise any of your legal rights, please contact the DPO using the details set out below:
Full name of legal entity: Cammillion Capital Pte. Ltd.
Name of DPO: Dr. Lim Kim Hwa
Email address: firstname.lastname@example.org
Postal address: 12, Purvis Street, 188591 Singapore
This 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 third-party website you visit.
1.0 Information we collect or you provide
1.1 In order to provide a better service to you, develop new services, and obtain additional customers for our services we may collect and process the following data about you:
- Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, posting material, or requesting further services. We may also ask you for information at other times, for example in connection with a promotion or when you report a problem with our Website;
- If you contact us, we may keep a record of that correspondence;
- We may also ask you to complete surveys that we use for research purposes, although you do not have to respond to them;
- Details of your visits to our Website and the resources that you access;
1.2 Requests to subscribe to mailing lists or other offerings, Cookies and similar technologies. Like many online services, we sometimes use the following technologies:
- Cookies, or text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, and helping us understand user activity and patterns.
- Local storage technologies, like HTML5 and Flash, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.
- Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.
2.0 How we collect your personal data
2.1 We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us through the Website, by email, post, phone, or otherwise.
- Automated technologies or interactions. As you interact with our Website, we may automatically collect Technical Data about your equipment, browsing actions and patterns through cookies, logs and other similar technologies.
- Third parties or publicly available sources. We may receive personal data about you from third-parties and public sources as set out below: i. Technical Data from the following parties: 1. analytics providers such as Google based outside the EU; 2. advertising networks based inside and outside the EU; and 3. search information providers based inside and outside the EU. ii. Contact, Financial and Transaction Data from providers of technical, payment and delivery services. iii. Identity, Technical and Contact Data from data brokers or aggregators, any member of our group, which means our subsidiaries, business partners, our ultimate holding company and its subsidiaries iv. Identity and Contact Data from publicly available sources.
3.0 Uses made of the information
3.1 The purposes for which information may be used by us include:
- Ensuring that content from our Website is presented in the most effective manner for you and for your computer;
- Providing you with alerts, newsletter, education materials or information that you requested or signed up to receive;
- Carrying out our obligations arising from any contracts entered into between you and us;
- Allowing you to participate in interactive features of our service, when you choose to do so;
- Designing and conducting surveys/questionnaires;
- Complying with laws and regulations applicable to us or any of our affiliates in or outside Singapore;
- Legal proceedings, including collecting overdue amounts and seeking professional advices;
- Researching, designing and launching services or products including seminars/events/forums;
- Promoting and marketing services and products subject to your exercise of the opt-out right (please see further details in clause 2.2 below);
- Purposes directly related or incidental to the above; or
- Purposes not specifically listed here, which we will use as described in this Policy or as otherwise disclosed at the time of collection.
3.2 By using our Website, you consent to direct marketing utilizing the following information, should you provide it: your name, contact details (including address, contact number, email address), products and services information, transaction pattern and behaviour, background and demographic data. We utilise this information for the following types of direct marketing:
- Services and products related to our Website and/or our affiliates (including marketing affiliates programs we are a part of);
- Reward, loyalty or privileges programmes, promotional offers and related services; and
- Invitations to events such as seminars/webinars/tele-seminars, conferences, live programs or events.
We may conduct direct marketing via fax, email, direct mail, telephone and other means of communication or send e-newsletters to you. You may choose not to receive promotional materials, by simply telling us (see below for contact details), and we will cease to do so, without charge.
4.1 We employ technical, organisational and physical safeguards designed to protect the personal information we collect.
4.2 Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
4.3 Unfortunately, the transmission of information via the internet is not completely secure. Although we employ industry standard tools to protect your personal data, we cannot guarantee the security of your data transmitted to our Website; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
We retain personal data for so long as it is necessary to achieve a purpose listed above. Data may be archived for as long as the purpose for which the data was used still exists.
7.0 Data transfers
We may hold your data on servers based in Singapore, Malaysia or any other territories as we see fit. We may also transfer your data to our overseas offices or in accordance with the “Disclosure of your information” section above, who may be located in or outside of Singapore.
8.0 Your consent and rights
8.1 By using our service, making an application or visiting our Website, you consent to the collection and use of your information and other activities as outlined in this policy.
8.2 Under the Singapore Personal Data Protection Act 2012 (“PDPA”), you have the following rights:
- the right to give and withdraw consent at any time by giving reasonable notice, unless it would frustrate the performance of a legal obligation;
- the right to request for access to your personal data in Cammillion’s possession or control, subject to the exceptions in the Fifth Schedule of the PDPA;
- the right to request Cammillion to correct any inaccurate data that is in Cammillion’s possession or control, subject to the exceptions in the Sixth Schedule of the PDPA.
8.3 Under the General Data Protection Regulation (GDPR), you have the following rights to your personal data:
- The right to access – You have the right to request Cammillion for copies of your personal data. We may charge you a small fee for this service.
- The right to rectification – You have the right to request that Cammillion correct any information you believe is inaccurate. You also have the right to request Cammillion to complete the information you believe is incomplete.
- The right to erasure – You have the right to request that Cammillion erase your personal data, under certain conditions.
- The right to restrict processing – You have the right to request that Cammillion restrict the processing of your personal data, under certain conditions.
- The right to object to processing – You have the right to object to Cammillion’s processing of your personal data, under certain conditions.
- The right to data portability – You have the right to request that Cammillion transfer the data that we have collected to another organization, or directly to you, under certain conditions.
8.4 If you wish to object to the use of your personal data for direct marketing purposes, access your data, correct your data or obtain information regarding Cammillion’s data policies and practices, utilise the contact information below.
8.5 In accordance with the terms in the PDPA, we have the right to any may charge a reasonable fee for processing any data access request.
9.0 Governing law and jurisdiction
The Website is not intended for use by children under 18 years of age.
11.0 How to contact us
Any other questions or comments should be directed to:
12, Purvis Street,