Data Protection Notice
Last Updated: 9 March 2023
This Data Protection Notice (“Notice”) sets out the basis on which Crux for X Pte Ltd UEN 201822504W, a limited liability company established under the laws of Singapore (“Cruxdata” “We”, “Us”, or “Our”) may collect, use, disclose or otherwise process Data in accordance with the Personal Data Protection Act (“PDPA”). This Notice applies to Data in Our possession or under Our control, including Data in the possession of organisations which We have engaged to collect, use, disclose or process Data for Our purposes.
In this Data Protection Notice We sometimes refer to “You”. “You” (or “Your”) may be (a) an individual who has contacted Us through any means including as a visitor to one of Our websites (b) a user who may, or has, entered into a contract with Us for the supply of Our Services (a “User”), or (c) a customer of a User.
Where terms are used but are not defined in this Notice, those terms are shall have the meanings given to them in the PDPA (where the context so permits).
Data we collect
The collection and use of data from a variety of sources is inherent in the provision of Our services and the operation of Our business. Our services often include activities that require Us to move, process and/or analyse Data on behalf of Our Users.
“Personal Data” means Data, whether true or not, that identifies, or that could reasonably be used to identify You as an individual: (a) from that data; or (b) from that data and other information to which We have or are likely to have access. It does not include aggregated or statistical data from which it is not possible to identify You. Depending on the nature of Your relationship with Us, some examples of Personal Data that we may collect are:
- Contact details, such as name, postal address, telephone number, email address;
- Financial and transaction Data, such as bank account information; and
- Other Personal Data, such as date of birth, government issued identifiers and employment information
- Browser and device data, such as IP address, device and browser details, screen resolution, language, plug-ins and add-ons;
- Activity data, such as purchases, views and other interactions with services controlled by Us or Our Users;
- Cookie and tracking technology data, such as time spent, pages visited, language preferences, and other anonymous traffic data; and
- Company data, such as a company’s legal structure, product and service offerings, jurisdiction, company records, and other information.
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 ( “Authorised Representative”) after (i) You (or an Authorised Representative) have been notified of the purposes for which the data is collected, and (ii) You (or an 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:
- performing obligations in the course of or in connection with Our provision of the goods and/or services requested by You. For the avoidance of doubt this includes Users providing Us with data about their customers in accordance with a contract for services;
- responding to, handling, and processing queries, requests, applications, complaints, and feedback from You;
- analysing the performance of Our website and services;
- managing Your relationship with Us;
- 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;
- any other purposes for which You have provided the information; and
- 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.
- where such disclosure is required for performing obligations in the course of or in connection with Our provision of the services requested by You;
- 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; or
- To third parties (on a need-to-know basis) in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Our business, assets or stock (including in connection with any bankruptcy or similar proceedings).
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 ten (10) 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 minimised collection of Personal Data, authentication and access controls (such as good password practices, need-to-basis for data disclosure, etc.), encryption of data, up-to-date antivirus protection, regular patching of operating system and other software, securely erasing storage media in devices before disposal, web security measures against risks, and usage of 2 factor authentication (2fa) to secure access.
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 an 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 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.
Data Protection Officeer
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:
Contact No. : 86808185
Email Address : [email protected]
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.