Privacy Policy

Introduction

1. Capelle Consulting (the “Company”) respects your privacy and we acknowledge that you have certain rights related to any personal data we collect from you and we have certain obligations in respect of the same.
2. This privacy policy (“Privacy Policy”) discloses our privacy principles and/or our practices for gathering, collecting, storing, using and/or disclosing your personal data. We encourage you to review this Privacy Policy so that you

   may understand how we may collect, use, disclose, and process your personal data in accordance with the Personal Data Protection Act (“PDPA”).

3. For the avoidance of doubt, “personal data” means data, whether true or not, about an individual (customer) who can be identified (a) from that data; or (b) from that data and other information to which the organization has or is likely

   to have access. References to “us” or “we” shall refer to the Company.

Personal Data

1. As used in this Policy: “Customer” means an individual who (a) has contacted us through any means to find out more about any goods and/or services we provide, or (b) may, or has, entered into a contract with us for the supply of any goods

   and/or services by us.

2. Depending on the nature of interaction with us, some examples of personal data, which we may collect from you may include:
   1. Name
   2. Identification information, such as NRIC
   3. Contact information, such as your address, email address or telephone number
   4. Nationality
   5. Gender
   6. Date of Birth
   7. Material Status
   8. Photographs and other audio-visual information
   9. Employment information
   10. Financial information, such as bank account information
3. Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context permits).

Collection, Use, and Disclosure of Personal Data

1. We generally do not collect your personal data unless
   1. (a) it is provided to us voluntarily by you directly or via your organization who has been duly authorized by you to disclose your personal data to us after (i) you or your organization have been notified of the purposes for which

      the data is collected, and (ii) you or your organization have provided written consent to the collection and usage of your personal data for those purposes, or

   2. (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 authorized by law).

2. We may collect and use your personal data for any or all of the following purposes:
   1. Performing obligations in the course of or in connection with our provision of the goods/ services requested by you;
   2. Verfing your identiy;
   3. Responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
   4. Managing your relationship with us;
   5. processing payment or credit transactions;
   6. Sending you marketing information about our goods and/or services including notifying you of our programs and events;
   7. Any other purposes fir which you have provided the information;
   8. Transmitting to relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
   9. Any other incidental business purposes related to or in connection with the above.
3. We may disclose your personal data where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods and/or services requested by you.
4. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including,

   where applicable, a period to enable us to enforce our rights under any contract with you).

Withdrawing Your Consent

1. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time (i) it is being withdrawn by you in writing or (ii) it is required by relevant governmental and/or regulatory authorities

   whether in Singapore or abroad. You may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection

   Officer at the contact details provided below.

2. Upon receipt of your written request to withdraw your consent, we 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 shall seek to process your request within ten (10) business days of receiving it.

3. 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 and/or services to you and we shall, in such circumstances,

   notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 4.1 above.

4. 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 law.

Accessing and Correction of Personal Data

1. If you wish to make (a) an access request for access to a copy of 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.

2. 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.
3. We will respond to your request as soon as reasonably possible. 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 with any personal data or to make a correction requested by you, we shall inform you of the reasons why we are unable to do so (except where are not required to do

   under the PDPA Act).

Protection of Personal Data

1. To safeguard your personal data from unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus

   protection , encryption and the use of privacy filters to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorized third party service providers and agents only on a

   need-to-know basis.

2. You should be aware, however, that no method of transmission over the Internet or method or electronic storage is completely secure. Capelle Consulting will not be responsible for any unauthorized use or misuse of such information and risks

   which are inherent in internet communications. 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

1. We generally rely on personal data provided by you or your organization. In order to ensure thar 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.

Retention of Personal Data

1. 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.
2. 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.

Transfer of Personal Data Outside of Singapore

1. We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and 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 Act.

Data Protection Officer

1. You may contact our Data Protection Officer if you have any queries or feedback on our personal data protection policies and procedures, or if you wish to make any request, you may send an email to: [email protected]

Effects of Notice and Changes to Notice

1. 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.
2. 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 goods and/or services constitutes

   your acknowledgment and acceptance of such changes.