Data Protection and Privacy Policy

ANGELS PRIVACY POLICY

16. Governing law

We want you to understand why and how Angels Business Consulting Pte. Ltd. (“ANGELS”, “we”, “us” and/or “our”) collects, uses, discloses and or/processes your Personal Data (as defined below) under Singapore’s Personal Data Protection Act 2012 (the “PDPA”).

This Privacy Policy (“Policy”) applies to you and all Individuals (as defined below) who provide ANGELS  with Personal Data or whose Personal Data is otherwise collected, used, processed, stored and/or disclosed by ANGELS in connection with and/or for the purposes of its operations.

This Policy supplements but does not supersede or replace any previous consent which you may have provided to ANGELS, nor does it affect any legal rights that ANGELS may have regarding the collection, use, processing and/or disclosure of any Individual’s Personal Data. 

ANGELS  may from time to time update this Policy to ensure that it is consistent with our business needs or to accommodate amendments to applicable legal or regulatory requirements. All updates to this Policy will be published online at www.angelsbizsvcs.com (the “ANGELS Website”). Notification of any material revisions will also be published on the ANGELS Website. You shall be deemed to have accepted the Policy as amended by continuing your relationship with ANGELS after any amendments have been published on the ANGELS Website, .

This Policy forms part of the terms and conditions, if any, governing your specific relationship with ANGELS (“Terms and Conditions”) and it should be read in conjunction with the Terms and Conditions. In the event of any conflict or inconsistency between the provisions of this Policy and the Terms and Conditions, the provisions of the Terms and Conditions shall prevail to the fullest extent permissible by law.

1) Definitions: For the purposes of this Policy: 

Individual (or “you) means a natural person, whether living or deceased and “Individuals” (and “your”) shall be construed accordingly;

Personal Data” means data that is capable of identifying an Individual, whether on its own or in conjunction with other data accessible to ANGELS;

Personnel” means any Individual engaged under a contract of service with ANGELS including permanent or temporary employees as well as trainees and interns engaged by ANGELS  from time to time; and

Potential Personnel” means any Individual who has submitted an application to be engaged by ANGELS as Personnel.

Purposes for collection, use and disclosure of Personal Data

ANGELS  will only collect, use and disclose Personal Data from/or related to an Individual that is reasonably considered necessary for the relevant purposes underlying such collection, use or disclosure, which may include but is not limited to the following:
  • a) Facilitating ANGELS’s provision of products and services which are used by you and from time to time with newsletters, marketing or promotional materials and any other information that may be relevant to you;
  • b) Communicating with you to assist you with your enquiries;
  • c) Dealing with administrative matters relating to the product and/or services purchased and/or subscribed to by you;
  • d) Conducting market research and customer satisfaction surveys;
  • e) Any other purposes that we notify you of at the time of obtaining consent (collectively known as the “Purposes”).
The Purposes for which we may/will collect, use, or disclose your Personal Data depend upon the circumstances at hand. We will notify you of the purpose at the time of obtaining your consent to collect the data.

2) How ANGELS collects Personal Data

Generally, ANGELS may collect Personal Data from you in one or more of the following ways or circumstances:

a) Information provided directly: You may be asked to provide Personal Data when you visit or use some parts of our websites and/or services. You do not have to provide us with your Personal Data; however, it could mean that you are not able to access some parts of our website or use our services. 

b) Information collected automatically: Some information is collected automatically, such as an IP address and device type, when you visit our websites or use our services. This information is useful to us as it provides us with a better understanding of how you are interacting with our websites and services so that we can continue to provide you with the best experience possible.

c) Information from third parties: The majority of information that we collect is collected directly from you. Some data may be collected from other sources, such as information that is available in the public domain. We use this information to supplement the Personal Data that we have collected from you.

3) Processing Personal Data

Where we collect Personal data, we will only process it:

a) To perform a contract with you, or

b) Where we have a legitimate interest to protect the Personal Data which is not overridden by your rights, or 

c) In accordance with a legal obligation, or

d) Where we have your consent.

4) Consent

Unless otherwise authorised under the PDPA, or any other applicable law, ANGELS  will not collect, use or disclose your Personal Data without your knowledge and consent. ANGELS will highlight the Purposes relevant to you, by appropriate means, at the point or time of collection of your Personal Data. ANGELS may obtain your consent by any of the following means:
  • a) via express provisions in a contract, application form and/or registration form to be signed with or submitted to ANGELS;
  • b) via notifications on ANGELS’s websites;
In so far as any Purpose(s) are intrinsic to the relationship or provision of services, ANGELS reserves the right to decline to engage in the relevant relationship or to provide the relevant services to you if you do not consent to ANGELS’s collection, use or disclosure of your Personal Data for such purposes. If you:
  • voluntarily provide Personal Data to ANGELS for any specified purpose;
  • use or access ANGELS’s website(s) or computer network;
  • enter ANGELS’s premises or use any of the facilities thereon; and/or
  • attend or participate in events or programmes organised by ANGELS
You will be deemed to have agreed and consented to ANGELS collecting, using and/or disclosing their Personal Data in the manner and for the purposes set forth in this Privacy Policy. If you provide ANGELS with Personal Data relating to a third party (e.g. information of his or her spouse or children) for any particular purpose, you represent to ANGELS that you have obtained the consent of the relevant third party for ANGELS to collect, use or disclose such Personal Data for the relevant purpose.

5) Disclosure of Personal Data

There may be occasions where we may need to share your Personal Data with third parties. ANGELS  will disclose your Personal Data only in the following circumstances:
  • a) to ANGELS’s third party service providers or agents;
  • b) to ANGELS’s auditors and professional advisors;
  • c) to regulators, law enforcement bodies, government agencies, courts or any other third party to whom disclosure is permitted or required by any applicable law or regulation;
  • d) to other parties where we have your consent.

6) Request to Withdraw Consent

You have the right to withdraw your consent to the collection, use and/or disclosure of your Personal Data in the possession of ANGELS by submitting your request to ANGELS’s Data Protection Officer at dpo@.com at any time.

We will process your request for the withdrawal of consent within a reasonable period of time from such a request being made. After that time, we will not collect, use and/or disclose your Personal Data in the manner stated in your request.

Your withdrawal of consent could affect the services that we are able to provide to you. Depending on the extent of your withdrawal of consent for us to process your Personal Data, it may mean that we are not able to continue with our existing business relationship.

With regards to data that is collected by cookies, you may disable the use of cookies on your internet browser when accessing ANGELS’s Website. However, disabling the use of cookies may result in the loss of functionality, restrict your use of the website and/or delay or affect the way in which ANGELS’s website operates.

7) Security of Personal Data.

ANGELS  shall make reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks to Personal Data in its possession.

If ANGELS transfers Personal Data outside of Singapore, ANGELS will take reasonable steps to ensure that such Personal Data transferred receives a standard of protection comparable to the protection received under the PDPA and such transfer shall be subject to this Policy.

ANGELS  will ensure that third parties who receive Personal Data from ANGELS protect such Personal Data in a manner consistent with this Policy and not use such Personal Data for any purposes other than those specified byANGELS, by incorporating appropriate contractual terms in its written agreements with third parties.

ANGELS is not responsible in any way for the security and/or management of Personal Data shared by you with third party websites accessible via links on ANGELS’s website. 

8) Accuracy of Personal Data

Information voluntarily provided by you to ANGELS shall be deemed complete and accurate.

ANGELS will take reasonable steps to verify the accuracy of Personal Data received at the point of collection, but you will remain primarily responsible and liable to ensure that all Personal Data submitted by you to ANGELS is complete and accurate. 

ANGELS  will also take reasonable steps to periodically verify the Personal Data in its possession, taking into account the scope of its operations. However, you remain responsible for notifying ANGELS, from time to time, of any applicable changes to your Personal Data. You can amend your Personal Data  by notifying through the Contact Us Form  of any changes to your Personal Data, or you may contact the Personal Data Officer by email at  Angela@angelsbizsvcs.com  at any time.

ANGELS shall not be held liable for any inability on its part to provide services to you if you fail to ensure that your Personal Data submitted to ANGELS  is complete and accurate.

9) Access to and correction of Personal Data

You may request (i) access to any Personal Data that is currently in our possession or control; and/or (ii) correction of any data that is currently in our possession or control by contacting us by email at Angela@angelsbizsvcs.com

When you request access to your Personal Data within our possession or control, we will seek to provide you with the relevant information within 14 days. 

Upon your written request, we will correct any inaccurate Personal Data that is within our possession or control within 14 days.

With your consent, once we have corrected your Personal Data, we will send the corrected Personal Data to all organisations to which your Personal Data was disclosed by ANGELS  within a year before the correction was made, unless that organisation does not require the corrected Personal Data for any legal or business purpose.

ANGELS is not required, under the PDPA, to provide access and correction to Personal Data in certain exempted situations as set out in the PDPA.

10) Retention of Data

The length of time that we keep your Personal Data depends on what it is and whether we have an ongoing business need to retain it.

We will only retain your data for as long as we have a business relationship with you and for a period of time afterwards where we have an ongoing business need to retain it, or where we are required by law to retain it.

Upon the expiry of time relating to any business needs or legal requirements to retain your Personal Data we will ensure that your Personal Data is deleted or anonymised.

11) Making a complaint

You are welcome to contact us if you have any complaint or grievance about how we are handling any Personal Data in our control or possession.

To make a complaint you can:

a) Contact our Data Protection Officer via email at Angela@angelsbizsvcs.com

b)Contact us by telephone during our office hours (9:00am to 6:00 pm) at +65 9133 3633           

c) Visit us in person at our Singapore office during our office hours (9:00am to 6:00pm).