Sunright Privacy Policy

About this policy

1. This Policy applies to Sunright Limited ("Sunright");
2. In this Policy, "we", "us" or "our" refers to Sunright, who shall be responsible to you in relation to its collection and use of your personal data.



General

3. We are committed to safeguarding your personal data. We treat all personal data provided by you in strict confidence, and will only use your personal data in the manner set out in this Policy. This Policy applies to all personal data that you provide to us and the personal data we hold about you. This Policy describes how we may collect, use, disclose, process and manage your personal data. By providing us with your personal data, accessing or using our website ("Website") and/or any mobile application ("App") provided by us, you consent to our collection, use and disclosure (including transfer) of your personal data in accordance with this Policy. Please DO NOT provide any personal data to us if you do not accept this Policy.

4. What is personal data. "Personal data" is data that can be used to identify a natural person. Examples of personal data include name, address, contact details, NRIC, or other identification number, financial information such as your PayNow/credit card details, IP address, transactional information based on your activities on the Website and App, telephone numbers, email address, photograph, video image, personal data of family members, education background, employment history, references and results of employment checks, medical conditions and any other information relating to any individuals which you have provided us in any form(s) you may have submitted to us, or via other forms of interaction with you. Information provided by organisations to us for business purposes is not considered as personal data. This Policy does not apply to business contact information.

5. Voluntary provision of personal data. Your provision of personal data to us is voluntary. However, if you choose not to provide us with the personal data we require, it may not be possible for us to contact you, provide products or services which you need from us, process your job application, consider your employment, and/or process employment related matters. By providing us with personal data, you agree to the terms of this policy and you consent for yourself and on behalf of such other persons to our collection, use and disclosure of personal data on these terms.

6. Providing personal data belonging to others. If you provide the personal data of anyone other than yourself (including your family members), you warrant that you have informed him/her of the purposes for which we are collecting his/her personal data and that he/she has consented to your disclosure of his/her personal data to us for those purposes.

7. Accuracy and completeness or personal data. You must ensure that all personal data that you provide is true, accurate and complete.




Amendments to this policy

8. We review and may amend this Policy from time to time without notice to you. The current version is available at our Website. The updated Policy will supersede earlier versions and will apply to personal data provided to us previously. The updated Policy will take effect when made available through the website. The updated Policy will be made available upon request from us and on our Website. If you do not accept any amendment to the Policy, please contact our Data Protection Officer (see paragraph 26 below).




When we collect personal data

9. We only collect personal data that is relevant to our business or employment relationship with you.

10. Generally, we may collect your personal data when:

    1. you transact with us, send us an email, request that we contact you;
    2. you register for a user account in order to access and use the Website and App;
    3. you attend our events;
    4. you contact us or interact with our employees through various communication channels, for example, through social media platforms, face-to-face meetings, telephone calls, emails, fax and letters;
    5. you request to be included in an email or our mailing list;
    6. your images are captured via CCTV cameras while you are within our premises;
    7. your images are captured via photographs or videos taken by us or our representatives when you attend events organised by us;
    8. you submit an employment application or when you provide documents or information including your resume in connection with any employment application; and/or
    9. you submit your personal data to us for any other purposes or reasons.

11. If you are our shareholder, director, corporate officer, manager or employee, we may collect your personal data if it is relevant to our business or employment relationship with you.




How we collect personal data

12. We usually collect personal data directly from you. This may be done in person when you meet our staff or representatives, or over the phone, WhatsApp, SMS, by email or through websites we operate.

13. We may also collect your personal data about you from third party sources without directly involving you. For example, we may obtain your personal data from your family members.




Purposes for collection, use or disclosure of your personal data

14. Primary purposes. Generally, we collect, use or disclose your personal data to manage your relationship with us. We may collect your personal data for one or more of the following purposes:

1. to manage the administrative and business operations of the Sunright Group and complying with laws and regulations, internal policies and procedures;
2. to process your request(s) for products and services, and to provide those products and services to you;
3. to notify you of our products, services, programmes and events;
4. to process your job application and assess your suitability for the position applied for;
5. to resolve disputes;
6. to assist you with your enquiries, and to attend to complaints;
7. to seek and respond to your feedback;
8. for use in collaterals, newsletters and online resources;
9. for use in bids, proposals, tenders and pitches;
10. for conducting research and analysis;
11. for conducting appraisals;
12. to manage the safety and security of our premises and event premises (including but not limited to carrying out CCTV surveillance and conducting security clearances); and
13. any other reasonable purposes related to the aforesaid.

15. Business purposes. We may also use your personal data for purposes connected or relevant to our business, such as:

1. complying with our legal obligations and requirements;
2. enforcing obligations owed to us;
3. research into the development of new products and services or improvement of our existing products and services;
4. accounting, risk management and record keeping;
5. carrying out research, planning and statistical analysis; and
6. staff welfare and training.

16. Other purposes. If we need to use your personal data for any other purposes, we will notify you and obtain your consent beforehand. You will be given the opportunity to withhold or withdraw your consent for the use of your personal data for these other purposes.

17. Contacting you. When using your personal data to contact you for the above purposes, we may contact you via regular mail, fax, e-mail, WhatsApp, SMS, telephone or any other means.




Disclosure of personal data

18. We will not sell or rent your personal data to third parties.

19. Consent for disclosure to others. If you have consented to our disclosure of your personal data to our related entities, strategic business partners and associates, we may disclose your personal data to them. They will use your personal data only for the purposes you have consented to.

20. You agree that in order to achieve the purposes stated in this Policy, we may disclose or share your personal data with third parties who provide necessary services to us, including entities within the Sunright Group, and those that are located outside of Singapore; service providers and data processors working on our behalf and providing services such as hosting and maintenance services, analysis services, e-mail messaging services, delivery services, handling of payment transactions, marketing, human resources, travel arrangements, etc.; and our professional advisers (such as accountants, lawyers, auditors, tax agents, financial advisers, insurers, share registrars, etc.).

21. We may also disclose your personal data as required or permitted by law such as for the purpose of court proceedings, and/or to regulatory authorities, statutory bodies or public agencies for the purposes of complying with their respective requirements, policies and directives.




Transfer of personal data out of Singapore

22. Transfer outside Singapore. You fully understand and unambiguously consent that we may transfer your personal data to any location outside of Singapore for the purposes set out above.

23. Protection of your personal data. If we transfer your personal data to a country or territory outside of Singapore, we will ensure that the recipient of the personal data provides a standard of protection that is comparable to the protection which your personal data enjoys under the laws of Singapore. Where these countries or territories do not have personal data protection laws which are comparable to that in Singapore, we will enter into legally enforceable agreements with the recipients to ensure that they protect your personal data to the same standard as required under the laws of Singapore.




Protection and Retention of personal data

24. While precautions will be taken to ensure that the information you provide is protected against unauthorised or unintended access, we cannot be held responsible for unauthorised or unintended access that is beyond our control.

25. We keep your personal data only for so long as we need the personal data for our business and/or legal purposes.




Contact Us

26. If you have any issues about this Policy, if you wish to correct your personal data or have access to your personal data, if you wish to withdraw any consent you have given us, or if have any complaints please contact our Data Protection Officer at dpo@sunright.com.

27. We may charge you a fee for responding to your request for access to your personal data held by us, or for information about the ways in which we have (or may have) used your personal data in the one-year period preceding your request.

28. While we will use reasonable efforts to comply with your requests to provide you with, correct or delete our records of your personal data, we may be prevented by law from complying with your request. We may also decline your request if the law permits us to do so.

29. You may withdraw your consent for us to use your personal data at any time. If you withdraw your consent, it may not be possible for us to continue to serve you or provide you with the products and services that you require.




Governing Law

30. This Policy is governed by the laws of the Republic of Singapore.