- This Policy applies to Sunright Limited ("Sunright");
- 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.
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.
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.
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.
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.
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
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
When we collect personal data
We only collect personal data that is relevant to our business or employment
relationship with you.
Generally, we may collect your personal data when:
- you transact with us, send us an email, request that we contact you;
- you register for a user account in order to access and use the Website and App;
- you attend our events;
- 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;
- you request to be included in an email or our mailing list;
- your images are captured via CCTV cameras while you are within our premises;
- your images are captured via photographs or videos taken by us or our representatives when you attend events organised by us;
- you submit an employment application or when you provide documents or information including your resume in connection with any employment application; and/or
- you submit your personal data to us for any other purposes or reasons.
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
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.
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
Purposes for collection, use or disclosure of your personal data
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
manage the administrative and business operations of the Sunright Group and
complying with laws and regulations, internal policies and procedures;
process your request(s) for products and services, and to provide those
products and services to you;
notify you of our products, services, programmes and events;
process your job application and assess your suitability for the position
- to resolve disputes;
- to assist you with your enquiries, and to attend to complaints;
- to seek and respond to your feedback;
- for use in collaterals, newsletters and online resources;
- for use in bids, proposals, tenders and pitches;
- for conducting research and analysis;
- for conducting appraisals;
- 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
other reasonable purposes related to the aforesaid.
We may also use your personal data for purposes connected or relevant to our
business, such as:
with our legal obligations and requirements;
obligations owed to us;
into the development of new products and services or improvement of our
existing products and services;
risk management and record keeping;
out research, planning and statistical analysis; and
welfare and training.
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
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
Disclosure of personal data
We will not
sell or rent your personal data to third parties.
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.
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.).
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
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
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
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.
keep your personal data only for so long as we need the personal data for our
business and/or legal purposes.
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 firstname.lastname@example.org.
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.
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.
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.
This Policy is governed by the laws of the Republic of Singapore.