We Value Your Privacy

Country-Specific Privacy Addendum for Singapore, last updated: 14 November 2024

This Country-Specific Privacy Addendum for Singapore (“Addendum”) applies to all IDC customers and website visitors based in Singapore. This Addendum supplements the information contained in the Privacy Policy.

IDC is respectful of data privacy and adopts best practices in compliance with applicable privacy law and regulations, including the Singapore Personal Data Protection Act 2012 (“PDPA”).

The following terms included in the Privacy Policy shall be replaced by their corresponding counterparts under PDPA:

• The “controller” shall mean the “organisation”,
• The “processor” shall mean the “data intermediary”,
• The “data subject” shall mean the “individual”.

1. How Do We Collect, Use, and Disclose Your 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, use and disclosure of your personal data for those purposes, or (b) collection, use or disclosure 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 or disclosing your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).

   For further details about how we collect, use, and disclose your personal data, please refer to clause 3 of the Privacy Policy.

2. Reliance on the Legitimate Interest Exception

   In certain instances, we may also process your personal data without your consent based on the legitimate interests of IDC or another person. In relying on the legitimate interests’ exception of the PDPA, we will assess the likely adverse effects on the individual and determine that the legitimate interest outweighs any adverse effect.

   In line with the legitimate interests’ exception, IDC may collect, use or disclose your personal data for the following purposes: IDC’s legitimate interests include offering and delivering our products and services to business customers, enhancing our customer base, exchanging professional knowledge about the industry, exercising our legal rights, detecting or preventing fraud or imminent harm, detecting and preventing misuse of services and user accounts, performing credit analysis, and ensuring the security and operability of our network and services such as network analysis to prevent fraud and financial crime and to prevent data loss on company-issued devices.

   In specific cases, we process your data based on consent or other permitted legal bases.

3. For How Long Do We Store Your Data?

   This clause fully replaces clause 5 of the Privacy Policy.

   We will store your personal data for as long as is necessary to fulfill the purposes we have collected it for, for any other legal or business purposes (including any accounting or reporting requirements), or for as long as we are legally obliged or permitted by applicable laws.

   You have the right to withdraw your consent at any time. For more details on the withdrawal of your consent, please see the Your Rights section of the Privacy Policy.

4. Data Transfers

   Where your personal data is transferred by IDC out of Singapore, we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to the PDPA.

5. Data Subject Rights

   This clause fully replaces clause 8 of the Privacy Policy.

   Under PDPA, individuals have the following rights:

   1. The Right to Access. Upon your request, we will provide you with access to the personal data in our possession or under our control and information about the ways in which such personal data has been or may have been used or disclosed by IDC within a year before the date of the request. We will send you a copy of that data as soon as reasonably possible from the time the request is received.

   2. The Right to Receive Information. You may contact us at any time with a request to receive more information regarding the following:

      1. the purposes for which we have used or disclosed, or may have used or disclosed, your personal data;
      2. the recipients of your personal data; and
      3. your rights as a data subject.
   3. The Right to Portability. You have the right to receive a copy of your personal data from us in a structured and commonly used machine-readable format. You may also request us to transfer such data to another data controller.
   4. The Right to Rectification. If you discover that any of the data we possess about you is incorrect or incomplete, you can request to have such data amended via the contact information provided in clause 1 of the Privacy Policy.
   5. The Right to Withdraw Consent. You have the right to withdraw your consent at any time to our use of your personal data by giving reasonable notice to IDC. Please note that a withdrawal of your consent does not affect the legality of the use of your personal data prior to your consent being withdrawn. You may withdraw consent and request us to stop collecting, using, or disclosing your personal data by submitting your request through the contact details provided in clause 1 of the Privacy Policy. Upon receipt of your written request to withdraw your consent, IDC 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 seek to process your request within [ten (10)] 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. 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.

6. Changes to this Addendum

   1. We may periodically modify the provisions of this Addendum and encourage you to review it from time to time in order to stay up to date with the most recent developments in the area of the protection of your personal information. In the event of significant changes, we may also choose to notify you via email should we have your email address in our records.
   2. Updated versions of this Addendum will be published on our website.
   3. This Addendum was last updated on 14 November 2024.