PERSONAL DATA
PROTECTION AND PRIVACY POLICY
The terms “we”, and “our” in
this Policy refer to GME. This Policy is designed to assist you in
understanding how we collect, use, disclose and/or process the personal data
you have provided to us.
Application. Each member of GME is committed to complying with the Personal Data
Protection Act 2012 (“PDPA”) and this Policy in its collection, use,
disclosure and/or processing of personal data, to ensure that there is
accountability and uniformity in the way we protect your personal data.
Although this Policy is in common use by GME. GME is responsible to you to the
extent of its own collection, use and disclosure of your personal data, and its
own actions.
Compliance with
this Policy. This Policy applies to all personal data you provide
to us, or that we may collect about you. Please do not provide any personal
data to us if you do not accept and consent to the collection, use, disclosure
and/or processing of your personal data under this Policy.
We may also require you to
accept this Policy when you contact, interact, transact or deal with us, or
when you access and use our websites, applications or services. If you do not
accept and consent to the collection, use, disclosure and/or processing of your
personal data under this Policy, we may not be able to transact with you or
provide our services to you.
Concerns and
Contacting Us. If you have any feedback or issues in relation to
your personal data, or about this Policy, or wish to make a complaint to us,
you may contact our Data Protection Officer whose contact details are set out
below.
Data Protection Officer
Dr. Michael Foth
Email
address: privacy@gme-chemicals.com
Amendment to
this Policy. We may amend this Policy from time to time to comply
with applicable laws or as we update our personal data usage and handling
processes. The amended Policy will take effect when made available at
https://www.gme-chemicals.com/privacy. The updated Policy will supersede
earlier versions and will apply to personal data provided to us previously. By
continuing to contact, interact, transact or deal with us, you agree to be
bound by the terms of the amended Policy.
What personal
data we collect. “Personal data” is defined under the PDPA to mean
data, whether true or not, about an individual who can be identified from that
data, or from that data and other information to which an organisation has or
is likely to have access. The personal data we collect
depends on the purposes for which we require the personal data and what you
have chosen to provide. This may include your name, address, contact
information (e.g. telephone number and email address), orders, payment information,
and any other information that may identify you.
How we collect
personal data. We collect personal data relevant to our relationship
with you. We may collect your personal data directly or indirectly through
various channels, including when:
Depending on your relationship
with us, we may also collect your personal data from third parties, including:
Our website and applications
may also contain or involve certain technologies that automate the collection
of data (including personal data). These technologies include cookies, web
beacons and web analytics. If you do not wish to have your data collected
through such technologies you may disable the operation of these technologies
on your devices (where possible), or you may refrain from using our websites
and applications.
Voluntary
provision of personal data. Your provision of personal
data to us is voluntary and you have the right to withdraw your consent for us
to use your personal data at any time by contacting and submitting a request to
us. Your withdrawal will take effect after your request is processed. However,
if you choose to withdraw your consent for us to collect, use, disclose and/or
process some or all of the personal data we require, it may not be possible for
us to fulfill the purposes for which we require such personal data, including
providing some or all of the products and services which you need from us.
Providing
personal data belonging to others. In certain
circumstances, you may also provide the personal data of persons other than
yourself. If you do so you are responsible for informing them of the purposes
for which we require their personal data and you hereby warrant that you are
validly acting on behalf of them and that you have obtained their consent to
disclose their personal data to us for the purposes for which we will be
collecting, using and/or disclosing their personal data.
Accuracy and
Completeness of personal data. You must
ensure that all personal data that you provide is true, accurate and complete
and promptly inform us of any changes to the personal data.
Minor. If you are a child, minor or not of legal age, please inform and seek the
consent of your parent or guardian, before you provide your personal data to
us. If you are a parent or guardian and you have reason to believe your child
or ward has provided us with their personal data without your consent, please
contact us to request for us to cease the use, disclosure and/or processing of
such personal data.
We collect, use and disclose
your personal data where:
General
purposes. Generally, we collect, use and disclose your personal
data for purposes connected or relevant to our business, including:
Marketing
purposes. Where you have previously given us consent to provide
you with marketing messages, we may use your personal data for the following
purposes:
Legitimate
business interests. Our legitimate business interests include:
Purposes
involving Biesterfeld Group. For
administrative efficiencies and to allow us to better serve your needs, your
personal data will also be collected, used and disclosed to an organisation
within the Biesterfeld Group for the following purposes:
Use permitted
under applicable laws. We may also collect, use, disclose and process your
personal data for other purposes, without your knowledge or consent, where this
is required or permitted by law.
Contacting you. When using your personal data to contact you for the above purposes, we may
contact you via email, WhatsApp, SMS, or any other means.
We will not contact you for
marketing purposes unless you have consented to such purposes. When contacting
you for marketing purposes, we will not contact you through your telephone
number, unless you have specifically consented to such a mode of communication.
If you do not wish to receive any communication or information from us or wish
to restrict the manner by which we may contact or send you information, you may
contact us to do so.
Disclosure to GME
and Biesterfeld Group. We may disclose or share your personal data with
other members of the GME and Beisterfeld Group (whether located in Singapore or
overseas) for the purposes described in paragraph before.
Other Disclosures. We may also disclose or share your personal data in
connection with the purposes described in paragraphs above, including to the
following parties (whether located in Singapore or overseas):
When disclosing personal data
to third parties, we will (where appropriate and required by applicable law)
enter into contracts with these third parties to protect your personal data in
a manner that is consistent with applicable laws and/or ensure that they only
process your personal data in accordance with our instructions.
Safeguards. We may transfer your personal data out of Singapore for the purposes set
out in paragraph 3 above. When transferring personal data outside Singapore, we
will require recipients of the personal data to protect personal data at a
standard comparable to that under the laws of Singapore, in compliance with the
PDPA. For example, we may enter into legally enforceable agreements or put in
place binding corporate policies with the recipients to ensure that they
protect your personal data. You may obtain details of these safeguards by
contacting us.
Period of
retention. We keep your personal data only for so long as we
need the data to fulfil the purposes we collected it for and to satisfy our
business and legal purposes, including audit, accounting or reporting
requirements. How long we keep your personal data depends on the nature of the
data, e.g. we keep personal data for at least the duration of the limitation
period for bringing claims if the personal data may be required to commence or
defend legal proceedings. Certain information may also be retained for longer,
e.g. where we are required to do so by law.
Anonymised data. In some circumstances, we may anonymise your personal data so that it no
longer identifies you, in which case we are entitled to retain and use such
anonymised data without restriction, including for data analytics.
Unauthorised
access and vulnerabilities. We will protect
personal data in our possession or under our control by making reasonable
security arrangements to prevent (a) unauthorised access, collection, use,
disclosure, copying, modification or disposal, or similar risks; and (b) the
loss of any storage medium or device on which personal data is stored. However,
we cannot be held responsible for unauthorized or unintended access that is
beyond our control. We also do not guarantee that our websites and applications
are invulnerable to security breaches, or that your use of our websites and
applications is safe and protected from viruses, worms, Trojan horses, and
other vulnerabilities.
You enjoy certain rights at
law in relation to your personal data that we hold or control. These rights include:
Exercising your
rights. If you wish to exercise your rights, you may contact
us to do so (see paragraph 1 above for contact details of our data protection
officer). We may require that you submit certain forms or provide certain
information to process your request. Where permitted by law, we may charge you
a fee to process your request. We may also be permitted under applicable laws
to refuse a request.
Limitations. We may be permitted under applicable laws to refuse a request you have made
in respect to your personal data. For example, we may refuse (a) a request to
cease the use and/or disclosure of your personal data where it is required in
connection with disputes / claims; or (b) a request to not collect, use, and/or
disclose your personal data where we have legitimate interests to do so.
Cookies. A number of places on our Sites and web-based applications make use of
cookies. These are essentially small text files stored on your computer’s hard
drive or your user device by your web browser. We can use cookies to identify
the vistor for oprimzed and better services on our website. Cookies help to
make our Sites or our web-based applications more user-friendly, effective and
secure. The cookies usually used by us are so-called “session
cookies”, which are automatically deleted at the end of the visit to the
relevant website. By default, web browsers enable the use of cookies but this
function can be disabled by selecting the appropriate settings on your browser.
This may however result in some services not being available. It is also
possible to manually delete cookies after their use via the web browser. More
information may be available from your web browser provider.
Web beacons and tracking links. Web beacons (also known as pixel tags and clear
GIFs) involve graphics that are not apparent to users. Tracking links and/or
similar technologies consist of a few lines of programming code and can be
embedded in our Sites. In conjunction with cookies, these are primarily used
for statistical analysis purposes. This technology can also be used for tracking
traffic patterns on websites, as well as finding out if an e-mail has been
received, opened, and responded to.
Web analytics. Web analytics is the term given to a method of collecting and assessing
the behaviour of visitors to websites and mobile applications. This includes
the analysis of traffic patterns, for example, to determine the frequency of
visits to certain parts of a website or mobile application or to find out what
information and services our visitors are most interested in. For these
purposes, we primarily make use of click-stream data and the other techniques
listed above. Web analytics are carried out by Google Analytics and/or other
selected parties. You can find out below more about the processing of web
analytics data.
Our Sites may
contain links to external sites, such as those of our business partners. Some
of these sites may feature our logo or trademark. However, these sites are
neither owned nor maintained by us and we are not responsible for the privacy
policies and practices of these Sites. Please contact the owner of the
respective Sites should you have questions on their privacy policies.
GME Enable’s
Sites and web-based applications may provide you with social plug-ins from
various social networks (e.g. LinkedIn). If you interact with such social
networks, your activity on our Sites or via our web-based applications will be
made available to these networks.
If you do not
wish for such a data transfer, please log off on your social network before
entering our Sites or web-based applications.
We cannot
influence data collection and data transfer via the social plug-ins. Please
read the privacy policies of those social networks for details about their
collection and transfer of personal data, and how you can achieve satisfactory
privacy settings.
GME sites may
offer location-enabled services, such as Google Maps. If you use such
applications, they may receive information about your actual location (such as
GPS signals sent by a mobile device) or information that can be used to
approximate a location. You are always asked if the geo-location service can be
activated and you can disallow the geo-location service within the application.
GME´s
web-based applications may contain web analytic services provided by Google
Analytics or such third parties from time to time. When you visit or use our
Sites or any mobile or web-based applications, a cookie will be stored on your
computer or mobile device, except when your browser settings disallow such
cookies. Personal data collected will be sent to Google Analytics or such third
parties for analysis for and on behalf of us.
Google
Analytics or these third parties act only as our agent and we determine the
purposes for which the data is being used and which will be consistent with
purposes and provisions stated herein. You can find out more about the relationships
between Google Analytics or these third parties and us in their respective
privacy policies.
If you do not
wish for information about your behaviour at our sites or web-based
applications to be collected and assessed by Google Analytics, you can install
the Google Analytics opt-out browser add-on at https://tools.google.com/dlpage/gaoptout.
GME Chemicals, September 2024