top of page
Privacy Policy
This Privacy Policy (this “Policy”) applies to collection,
use and disclosure of Personal Data (hereinafter defined) by Creal Asia Pte. Ltd. (“we”, “us”, or “our”).
1. General
1.1
For the purposes of this Policy, in line with the provisions under the Personal Data Protection Act 2012 (the “PDPA”), “Personal Data” shall mean data, whether true or not, about an individual who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access, including but not limited to name, NRIC, birth date and contact information.
2. Collection, Use and Disclosure of Personal Data
2.1
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 (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the Personal Data is collected, and (ii) you (or your 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).
2.2
We may collect and use your Personal Data for any or all of the following purposes:
(a) evaluating, processing, administering and/or dealing in any recruit or employment related activities;
(b) performing other obligations in the course of or in connection with our employment and/or our provision of services requested by a data subject;
(c) verifying your identity;
(d) managing your relationship with us;
(e) processing payment or credit transactions;
(f) sending marketing information about our services including notifying you of our marketing events, initiatives and promotions, or campaigns;
(g) carrying out customer surveys, analysis and market research;
(h) 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;
(i) responding to, handling and processing queries, requests, applications, complaints and feedback from you;
(j) any other purposes for which you have provided the information;
(k) transmitting to any third parties including our affiliates, data intermediaries, third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and/or
(l) any other incidental business purposes related to or in connection with the above.
2.3
We may disclose your Personal Data:
(a) where such disclosure is necessary for performing obligations in the course of or in connection with your employment and/or our provisions of the services requested by you;
(b) where such disclosure is required by 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; and/ or
(c) to any third parties including our affiliates, data intermediaries, third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the purposes listed in clause 2.2 above.
2.4
The purposes listed in the clauses 2.2 and 2.3 above 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).
3. Withdrawing Your Consent
3.1
The consent that you provide for the collection, use and disclosure of your Personal Data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop using and/or disclosing your Personal Data for any or all of the purposes listed in clauses 2.2 and 2.3 above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.
3.2
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.
3.3
Please note that withdrawing consent does not affect our right to continue to collect, use and disclose your Personal Data where such collection, use and disclose without consent is permitted or required under applicable laws.
4. Access to and Correction of Personal Data
4.1
If you wish to make (a) an access request for access to your Personal Data which we hold 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, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
4.2
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.
4.3
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 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).
5. Protection of Personal Data
5.1
We aim to treat your Personal Data with the care and diligence. To safeguard your Personal Data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we, to the extent required by the PDPA, have introduced appropriate administrative, physical and technical measures such as minimised collection of personal data, up-to-date antivirus protection, and authentication and access controls (such as good password practices, need-to-know basis for data disclosure, etc.).
5.2
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.
6. Accuracy of Personal Data
6.1
We generally rely on Personal Data provided by you (or your 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.
7. Retention of Personal Data
7.1
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.
7.2
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.
8. Transfer of Personal Data Outside Singapore
8.1
Our head quarter is based in Japan. As such, we transfer and disclose your Personal Data to our head quarter and other subsidiaries of our head quarter in Japan, for the purposes listed in clause 2.2 above, in accordance with the PPDA, in particular, subject to the data transfer agreement between us and the head quarter in Japan.
8.2
If we transfer your Personal Data to additional third party which is sited outside Singapore, including but not limited to our affiliates in Japan, data intermediaries, third party service providers and agents, or for other purposes than the ones you have provided consent for, we will obtain your consent for the transfer to be made and 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.
9. Reporting A Personal Data Breach
9.1
If we encounter suspected Personal Data Breach, we will conduct an assessment of whether the Personal Data Breach is a notifiable Personal Data Breach (hereinafter defined). “Personal Data Breach” shall mean (a) the unauthorised access, collection, use, disclosure, copying, modification or disposal of Personal Data; or (b) the loss of any storage medium or device on which Personal Data is stored in circumstances where the unauthorised access, collection, use, disclosure, copying, modification or disposal of the personal data is likely to occur.
9.2
We will notify the Personal Data Protection Commission, as soon as practicable, but in any case, no later than three (3) calendar days after the day we make that assessment, if the Personal Data Breach:
(a) results in, or is likely to result in, significant harm to an affected individual; or
(b) is, or is likely to be, of a significant scale (“notifiable Personal Data Breach”).
9.3
We will also notify you if you are affected by a notifiable Personal Data Breach mentioned in clause 9.2 above in any manner that is reasonable in the circumstances.
10. Data Protection Officer
10.1
If you have any enquiries or wish to make any request relating to your Personal Data, you may contact our Data Protection Officer at:
Name: Wei Tien-Hao
Email: hao@creal.jp
Telephone: 98927149
Weekdays: Monday-Friday 10AM-5PM
11. Changes of this Policy
11.1
We may revise this Policy from time to time without any prior notice. Any amended Policy will be informed to you accordingly.
Effective date: 26th December 2023
Last updated: 26th December 2023
bottom of page