LabyrinthX Technologies Pte. Ltd., its holding companies, respective subsidiaries and/or related corporations (individually and collectively, the “Labyrinth X Group”) are fully committed to safeguarding your online privacy and personal data in accordance with the Personal Data Protection Act 2012 (“PDPA”) and any other applicable data protection laws.
(a) “Personal Data” refers to any 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 data in our records as may be updated from time to time; and
(b) “Web Site” includes but is not limited to the information, materials, data, reports, text, images, links, sounds, graphics and video sequences displayed herein.
2. Types of Personal Data or Information Collected
Depending on the nature of your interaction with us, we may collect Personal Data such as, but not limited to the following:
(a) name, NRIC, passport or other identification number, personal photo, telephone number, mailing address, email address;
(b) your payment related information, such as your bank accounts;
(c) your employment history, education background and income levels; and
(d) any other information which you have provided via any other forms of interaction with us.
3. Purposes for Collection, Use and Disclosure of your Personal Data
Generally, we collect, use, and disclose your Personal Data for the following purposes:
(a) providing a service and/or product to you;
(b) the execution or administration of any transaction(s) requested and/or authorised by you;
(c) the maintenance, servicing and/or termination of any account relationship with us;
(d) communicating with you on matters relating to your account relationship with us and your interest in our products and/or services;
(e) responding to your queries and requests;
(f) enhancing the content and user experience of the Web Site and/or any of our services or products;
(g) disseminating information for marketing purposes about services or products;
(h) providing events or activities to you, including but not limited to seminars, webinars and promotions;
(i) verifying due diligence or Know-Your-Customer checks and the status of your financial standing;
(j) managing the administrative and business operations of the Labyrinth X Group and complying with internal policies and procedures;
(k) matching any Personal Data held which relates to you for any of the purposes listed herein;
(l) resolving complaints and handling requests and enquiries;
(m) preventing, detecting and investigating crime, including fraud and money-laundering, and analysing and managing commercial risks;
(n) providing media announcements and responses;
(o) meeting or complying with any applicable laws, regulations, directives, rules, codes of practice or guidelines issued by any legal or regulatory bodies which the Labyrinth X Group may be subject, whether local or overseas (including but not limited to disclosures to regulatory bodies, conducting audit checks, surveillance and investigation);
(p) legal and accounting purposes (including but not limited to obtaining legal advice and dispute resolution);
(q) disclosure to other entities of the Labyrinth X Group, business partners, or third party service providers; and
(r) all other purposes which are reasonably related to the aforesaid.
In relation to particular products or services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.
If you are an employee of an external service provider of the Labyrinth X Group, we may collect, use and disclose your Personal Data for the following purposes:
(a) issuing building access passes and maintaining building security;
(b) managing project tenders;
(c) processing and payment of vendor invoices;
(d) profiling in media activities; and
(e) all other purposes reasonably related to any of the above.
If you submit an application to us as a candidate for any employment openings, the Labyrinth X Group may also collect, use and disclose your Personal Data for the following purposes:
(a) processing your application (including background checks and screening);
(b) conducting interviews;
(c) evaluating and assessing your suitability for the position applied for; and
(d) all other purposes reasonably related to any of the above.
4. To whom we may disclose Personal Data
In order that we may provide you with effective and satisfactory services and products, and in accordance with the purposes set out above, your Personal Data may be disclosed to the following parties:
(a) entities belonging to the Labyrinth X Group;
(b) agents, contractors or third party service providers who provide operational services to the Labyrinth X Group, including but not limited to courier services, telecommunications, information technology, payment, payroll, processing, training, survey, market research, storage, archival or other service providers;
(c) vendors and other third party service providers in connection with promotions, online campaigns, products and services offered by the Labyrinth X Group;
(d) credit bureaus and credit reporting agencies;
(e) any business partners, other financial institutions and their respective service providers, agents and business providers;
(f) our professional advisers such as financial advisors, auditors and lawyers;
(g) relevant regulatory bodies, government agencies, statutory boards, administrative bodies, authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes to which the Labyrinth X Group may be subject, whether situated locally or overseas;
(h) counterparties, billing organisations and banks in relation to fund transfers, payments and drawing of cheques;
(i) brokerage houses, fund houses, registrars, custodians, external banks and investment vehicles in relation to any custodial services and settlement processing;
(j) external businesses and partners in relation to the marketing and promotion of products, gift redemptions and corporate promotional events; and
(k) any other party to whom you authorise us to disclose your Personal Data to.
In general, the Labyrinth X Group may share your personal data to third parties with your consent for the purpose for which the information was collected to be used, and any other reasonable ancillary purposes, for legal reasons, or where permitted under the PDPA and any other applicable laws, such as in response to law enforcement agencies.
5. Transfer of Personal Data out of Singapore
Where there is a necessity to transfer Personal Data outside of Singapore, whether to our affiliates, related companies, business partners, authorised agents, third party service providers or to data storage facilities, we endeavour to do so in accordance with the requirements of the PDPA to ensure that the standard of protection applied to the Personal Data so transferred is comparable to the protection under the PDPA.
Generally, when we request for your Personal Information in the course of providing a service or product to you, and where you provide us with such Personal Data, there is implied consent that you agree to provide us with your Personal Data in order that we may provide you with the requested product and/or service.
In some circumstances and as required by applicable law, we will seek your express consent when collecting your Personal Data. This is particularly where fresh consent is required for a new purpose in which your Personal Data will be used.
In addition to the consents you have provided to our collection, use and disclosure of your Personal Data, we may also collect, use and disclose your Personal Data without your consent where permitted under the PDPA and other applicable law for our legitimate interests or third party’s legitimate interests, such as management of threats to safety and security (including but not limited to Labyrinth X Group’s premises, services, IT and network security).
With respect to any withdrawal of your consent for marketing or promotional activity, we will require some time to process your withdrawal request. During this period of time, you may still receive marketing or promotional materials or communications from us.
7. Marketing Communications
It is in Labyrinth X Group’s legitimate interests to process your Personal Data to selectively contact you and/or send you information about our products and services, activities and/or events that may be relevant to you (“Marketing Communications”). To the extent that Labyrinth X Group’s processing of your Personal Data for Marketing Communications is subject to the European General Data Protection Regulation, you have the right to object to such processing by the Labyrinth X Group. Please contact us using the contact details set out below if you wish to exercise this right.
8. Security of your Personal Data
The security of your Personal Data is our utmost priority. We endeavour to take all reasonable steps to properly safeguard your Personal Data.
Should we disclose your Personal Data to a third party (such as our business partners, authorised agents, or service providers), we will require them to appropriately safeguard the Personal Data provided to them.
While we have put in place measures to ensure that your Personal Data remain safe, secure and private, you should be aware that transmission over the Internet is not entirely secure and therefore we cannot guarantee the security or integrity of any Personal Data which is transferred from you or to you via the Internet.
We will only retain your Personal Data for so long as it is necessary to fulfil the purposes for which it was collected or to comply with legal, regulatory and internal requirements. We will take reasonable measures to destroy any Personal Data that is no longer necessary to meet those purposes.
10. Access to your Personal Data
You are also entitled to certain access rights to your Personal Data. Should you wish to make a request, you may contact us using the contact details found below. We will endeavour to provide a response within thirty (30) days of receiving your request, and will inform you should we be unable to accede to your request for any reason.
Kindly note that we may charge an administrative fee in connection with any requests made for accessing your Personal Data. We will notify you of such administrative fees (if any) in advance.
11. Accuracy and Correction
We endeavour to ensure that your Personal Data is as accurate and up-to-date as possible. However, should you wish to correct, amend or update your Personal Data, you may contact us using the contact details found below.
13. Third-party Web Sites
14. Governing Law
15. Contact Details