Data Protection Policy
Last revised on 01 March 2021

This data protection policy applies to BaaSid International Labs (S) Pte Ltd which is established in Singapore (“BaaSid” or “we”). This policy governs the collection, use and disclosure of personal data submitted to BaaSid including through baasid.sg, and explains how we collect and handle personal data of individuals and comply with the requirements of the Personal Data Protection Act 2012 of Singapore and its regulation(s) (“PDPA”). In this policy, “personal data” shall have the meaning as described to it in the PDPA.

BaaSid International Labs (S) Pte Ltd shall also comply with the requirements of the BaaSid International Labs network requirements in a number of ways including through this policy. We also have other policies which deal with data protection, which may be in connection with specific functions or business activities. For more information about: (i) our recruitment data protection policy, please refer to our (i) Recruitment Data Protection Policy, (ii)  our Marketing Data Protection Policy, and (iii) our Website Data Protection Policy.

This policy does not override data protection requirements in the other above mentioned policies to the extent those requirements are in addition to the requirements of this policy or protect personal data to at least the same standard as this policy. This policy overrides the data protection requirements in the other above-mentioned policies to the extent this policy imposes additional requirements or requires a higher standard of protection of personal data. For the avoidance of doubt, nothing herein shall require BaaSid International Labs to act in breach of applicable Singapore laws.

Main Data Protection Policy

Summary
We will collect, use or disclose personal data for reasonable business purposes only if there is consent or deemed consent from the individual and information on such purposes have been notified. We may also collect, use or disclose personal data if it is required or authorised under applicable laws.

Collection of Personal Data
We collect personal data from clients, customers, business contacts, partners, personnel, contractors and other individuals. Such personal data may be provided to us in forms filled out by individuals, face to face meetings, email messages, telephone conversations, through our websites or provided by third parties. If any individuals contact us, we may keep a record of that contact.

We collect these personal data when it is necessary for business purposes or to meet the purposes for which the individuals have submitted the information.
We will only collect, hold, process, use, communicate and/or disclose such personal data, in accordance with this policy. If any party is acting as an intermediary or otherwise on behalf of a third party individual or supplying us with information regarding a third party individual (such as a friend, a colleague, an employee etc), such intermediary party undertakes that you are an authorised representative or agent of such third party individual and that you have obtained all necessary consents from such third party individual to the collection, processing, use and disclosure by us of their personal data. Because we are collecting the third party individual’s data from you, you undertake to make the third party individual aware of all matters listed in this policy preferably by distributing a copy of this policy to them or by referring them to our website.

Use of Personal Data
We use personal data for the following purposes:
•    to provide our services
•    to respond to the individual’s request or for the purposes for which it was provided to us as stated at the time of the collection (or as is obvious from the
      context of collection)
•    to maintain contact with clients and other contacts
•    to keep clients and other contacts informed of the services we offer, industry developments,  service offerings, seminars and other events we are holding,
      that may be of interest to them
•    for general management and reporting purposes, such as invoicing and account management
•    for recruitment purposes
•    for purposes related to the employment of our personnel and providing internal services to our personnel
•    all other purposes related to our business.

Any individual may choose to unsubscribe from mailing lists, registrations, or elect not to receive further marketing information from us by contacting our Data Protection Officer, or if we have contacted such individual by email, such individual may use the unsubscribe function in that email to notify us. Such requests will be processed within 28 days.

Disclosure of Personal Data to Third Parties
We do not disclose personal data to third parties except when required by law, when we have the individual’s consent or deemed consent or in cases where we have engaged third parties such as data intermediaries or subcontractors specifically to assist with our firm’s activities.  Any such third parties whom we engage will be bound contractually to keep all information confidential.

We may disclose personal data to other member within the, where it is necessary
(i) to meet the purpose for which such individual has submitted the information; or
(ii) to enable such individual to be provided with information at a later date which may be of relevance and interest to such individual based on the nature and purpose of such individual’s voluntary requests.  We may also transfer all data in our possession to a successor-in-interest to our business or assets.

Access to and Correction of Personal Data
Upon request, we will provide the individual with access to their personal data or other appropriate information on their personal data in accordance with the requirements of the PDPA.

Upon request, we will correct an error or omission in the individual’s personal data that is in our possession or control in accordance with the requirements of the PDPA. We may charge for a request for access in accordance with the requirements of the PDPA.

Withdrawal of Consent
Upon reasonable notice being given by an individual of his withdrawal of any consent given or deemed to have been given in respect of our collection, use or disclosure of his personal data, we will inform the individual of the likely consequences of withdrawing his consent. We will cease (and cause any of our data intermediaries and agents to cease) collecting, using or disclosing the personal data unless it is required or authorised under applicable laws.

Accuracy of Personal Data
We will make a reasonable effort to ensure that personal data collected by us or on our behalf is accurate and complete.

Security and Protection of Personal Data
We have implemented generally accepted standards of technology and operational security to protect the personal data in our possession or under our control and to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. All BaaSid International Labs personnel follow a network-wide security policy. Only authorised BaaSid International Labs personnel are provided access to personally identifiable information and these personnel have agreed to ensure confidentiality of this information. BaaSid International Lab’s policy is to use secure socket layer technology for the protection of information submitted through web forms. This policy is also required for any fulfilment agents of BaaSid International Lab.

Retention of Personal Data
We will cease to retain personal data, as soon as it is reasonable to assume that the purpose for collection of such personal data is no longer being served by such retention, and such retention is no longer necessary for legal or business purposes.

Transfer of Personal Data outside of Singapore
We will ensure that any transfers of personal data to a territory outside of Singapore will be in accordance with the PDPA so as to ensure a standard of protection to personal data so transferred that is comparable to the protection under the PDPA.

Privacy on Our Websites
This Policy also applies to any personal data we collect via our websites. Cookies may be used on some pages of our websites. “Cookies” are small text files placed on your hard drive that assist us in providing a more customised website experience. Cookies are now used as a standard by many websites to improve users’ navigational experience. If individuals are concerned about cookies, most browsers permit individuals to decline cookies. In most cases, a visitor may refuse a cookie and still fully navigate our websites, however other functionality in the site may be impaired. After termination of the visit to our site, a visitor can always delete the cookie from his system if he wishes.

Because we want visitors’ website experience to be as informative and resourceful as possible, we may provide a number of links to third party websites. We assume no responsibility for the information practices of these third party websites that visitors are able to access through ours. When a visitor to our website links to these third party websites, our privacy practices no longer apply. We encourage visitors to review each website’s privacy policy before disclosing any data.

Data Protection Officer
If an individual believes that information we hold about him is incorrect or out of date, or if an individual has concerns or further queries about how we are handling his personal data, or any problem or complaint about such matters, please contact our Data Protection Officer, at dpo@baasid.sg

Modifications
We reserve the right to modify or amend this Policy at any time. The effective date will be displayed at the beginning of this Policy. To keep you informed, we will notify changes to this Policy by prominently identifying the alteration for a period of not less than two weeks on our home page at https://www.baasid.sg









Website Data Protection Policy

Thank you for visiting our website. We know your privacy is important to you, and we want you to know that it is important for us too. To help you understand what information we collect, why we collect and what we do with it. Kindly take your time to review our “Website Data Protection Policy” Thank you.

Introduction
BaaSid International Labs (S) Pte. Ltd. (“BAASID”, “we” or “us”) takes the privacy of your information seriously. This Website Data Protection Policy applies to the baasid.sg website (the “Website”) and governs data collection, processing and usage in compliance with the Personal Data Protection Act 2012 (No. 26 of 2012) of Singapore (“PDPA”). By using the Website, you consent to the data practices described in this statement. Capitalized terms that are not defined in this Privacy Policy have the meaning given to them in our Terms of Service.

Information Collected from All Visitors to our Website
Personal data will not be collected unless various services on the website is being utilised, such as “Contact Us”. When you visit us, we may monitor the use of this Website through the use of cookies and similar tracking devices. For example, we may monitor the number of times you visit our Website or which pages you go to. This helps us to build a profile of our users. Some of this data will be aggregated or statistical for analysis for important reference to enhance our service quality. Which means that we will not be able to identify you individually.
This Website Data Protection Policy applies to all visitors to our Website.

Additional Personal Information that May be Collected
BAASID may collect and process:
1.    Personally identifiable information, such as:
1.    Your e-mail address and name, when you contact us;
2.    Details contained in the relevant document that you key in when you use our Services. These details may include your name, handphone number, email,        the purpose of your query, and details about your will; (“Personal Information”)
2.    The information can include: your IP address, browser type, domain names, access times and referring website addresses. This information is used by            BAASID for the operation of the Services, to maintain quality of the Services, and to provide general analytics regarding use of the baasid.sg Website.

Use of Personal Information
BAASID uses the collected information:
1.    To operate the Website and deliver the Services;
2.    To process, and where necessary, respond to your application, enquiry or request;
3.    To gather customer feedback;
4.    To inform or update you of other products or services available from BAASID and its affiliates, where you have consented to be contacted for such purposes;
5.    To monitor, improve and administer the Website and Services, and to provide general analytics regarding user of the Website;
6.    To update you on changes to the Website and Services.

Information collected in connection with your usage of services delivered via our BAASID Solutions.
We and our service providers may collect information in connection with your usage of communications services delivered via our sales solutions.
   o    Communications usage information.
        -    This includes information about your communications delivered via our platform such as the time and duration of usage, source and destination 
              identifiers, completion status, location, IP address, and amount of usage;
  o    Device information.
        - Your contact lists and address book.
            •    If you use our mobile apps, we may request your permission to access and store the contact list or address book maintained on your mobile
                 phone, tablet, or other broadband-connected device. Your contact list is considered your personal data. We may use your contact list information
                 to facilitate certain services where selected by you, such as to enable you to make calls easily and to facilitate calls, texts, and other services. You
                 do not have to allow us to access these functions of your device, but if you do not, certain features of our mobile apps may not be available to
                 you. You may at any time opt out from allowing this access via the privacy settings on your device.
       - Mobile device camera, microphone and photos.
            •    If you use our mobile apps, we may request your permission to access the camera, microphone, and photos on your mobile device. You do not
                 have to allow us to access these functions of your device, but if you do not, certain features of our mobile apps may not be available to you. You
                 may at any time opt out from allowing this access via the privacy settings on your device.
            •    Why we collect your information and how we use it depends on which of our products or services you use, how you use them, and the
                  specific preferences you may have communicated to us.

Non-disclosure
BAASID does not sell, rent, lease, or release your Personal Information to third parties. BAASID may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your unique Personal Information is not transferred to the third party without your explicit consent. In addition, BAASID may share data with trusted partners to help us perform statistical analysis, send you email or provide customer support. All such third parties are prohibited from using your personal information except to provide these services to BAASID, and they are required to maintain the confidentiality of your Personal Information.

Disclosure of Personal Information
BAASID will disclose or share your Personal Information, without notice, only if required to do so by law or in the good faith belief that any such action is necessary to: (a) comply with any legal requirements or comply with legal process served on BAASID or the Website; (b) protect and defend the rights or property of BAASID; and (c) act under exigent circumstances to protect the personal safety of users of baasid.sg, or the general public.

Use Of Cookies
The Website uses “cookies” to help you personalize your online experience. A cookie is a text file that is placed on your hard drive by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.
Cookies on the Website may be used to ensure a smooth user experience, perform analytics. Please note that third parties (such as analytics software) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to access all or parts of our Website or to fully experience the interactive features of the BAASID services or websites you visit.

Access to, Updating, and Non-Use of Your Personal Information
Subject to the exceptions referred to in section 21(2) of PDPA, you have the right to request a copy of the information that we hold about you. If you would like a copy of some or all of your personal information, please send an email to dpo@baasid.sg.
We want to ensure that your Personal Information is accurate and up to date. If any of the information that you have provided to BAASID changes, please let us know the correct details by sending an email to dpo@baasid.sg. You may ask us, or we may ask you, to correct information you or we think is inaccurate, and you may also ask us to remove information which is inaccurate.
Revision To This Website Data Protection Policy
BAASID will occasionally update this Privacy Policy at any time in response to customer feedback. BAASID encourages you to periodically review this Privacy Policy to be informed of how BAASID is protecting your information.

Contact Information
BaaSid International Labs (S) Pte. Ltd. welcomes your comments regarding this Website Data Protection Policy. If you believe that baasid.sg has not adhered to this Website Data Protection Policy, please contact us at dpo@baasid.sg.









Marketing Data Protection Policy

BaaSid International Labs (S) Pte Ltd which is established in Singapore (“BaaSid” or “we”) believe that privacy is an important individual right and this policy provides information regarding our use and disclosure of personal data collected from individuals including via our websites for marketing purposes. BaaSid’s information handling practices are in accordance with current privacy and data protection legislation in Singapore.

For more general information about the privacy practices of BaaSid, please refer to our Main Data Protection Policy.

Why do we collect personal data and how do we use it?
The personal data submitted to BaaSid will be used by the BaaSid for the purposes of any relevant promotional activities organised by BaaSid such as, but not limited to, seminars, firm events and news alerts on publications. We may also send you communications from time to time, for example, to advise you of technical updates or ask you to participate in surveys which may be of interest to you. By submitting the information in this website, you acknowledge that you have consented to our processing data in accordance with the privacy statement for the purposes described.

Retention of Personal Data
Personal data which is kept by BaaSid will be destroyed after a reasonable period from the time when it becomes outdated or is no longer required for the purpose for which it was collected or when we receive your request to delete it.

How is this personal data secured?
The personal data submitted to BaaSid is stored in our contacts database or similar system and is available to only authorised BaaSid partners, staff, and contractors.

Access to and Correction of Personal Data
If you wish to access, delete or correct your personal data provided to us or if you have any concerns about how we handle information about you, please send your request to our Data Protection Officer, at dpo@baasid.sg

Upon request, we will provide the individual with access to their personal data or other appropriate information on their personal data in accordance with the requirements of the PDPA.

Upon request, we will correct an error or omission in the individual’s personal data that is in our possession or control in accordance with the requirements of the PDPA.
We may charge for a request for access in accordance with the requirements of the PDPA.

Withdrawal of Consent
Upon reasonable notice being given by an individual of his withdrawal of any consent given or deemed to have been given in respect of our collection, use or disclosure of his personal data, we will inform the individual of the likely consequences of withdrawing his consent. We will cease (and cause any of our data intermediaries and agents to cease) collecting, using or disclosing the personal data unless it is required or authorised under applicable laws.

Transfer of Personal Data outside of Singapore
Personal data collected may be transferred and shared internationally between BaaSid global network, in order to meet the purpose for which you have submitted the information and activities directly related to it. By submitting personal data in this website, you are providing explicit consent to trans-border transmission of such data as described above. We will ensure that any transfers of personal data to a territory outside of Singapore will be in accordance with the PDPA so as to ensure a standard of protection to personal data so transferred is comparable to the protection under the PDPA.

Disclosure of Data to Third Parties
The personal data submitted will not be disclosed to third parties except when required by law, when we have your explicit consent or in cases where the third party is a contractor or supplier whom we have engaged specifically to assist with the Firm’s activities. All such contractors will be bound contractually to keep all information confidential.

Contact our Data Protection Officer
If an individual believes that information we hold about him is incorrect or out of date, or if an individual has concerns or further queries about how we are handling his personal data, or any problem or complaint about such matters, please contact our Data Protection Officer, at dpo@baasid.sg.









Recruitment Data Protection Policy

BaaSid International Labs (S) Pte Ltd which is established in Singapore (“BaaSid” or “we”) believe that privacy is an important individual right and this policy provides information regarding our use and disclosure of personal data collected from individuals including via our websites for recruitment purposes. BaaSid information handling practices are in accordance with current privacy and data protection legislation in Singapore.
For more general information about the privacy practices of BaaSid, please refer to our Main Data Protection Policy.

Why do we collect personal data?
As part of our recruitment process, we collect necessary personal data about you to consider you for employment with our firm. During the course of the recruitment and selection process, we may request further information about you to assess your suitability for positions with our firm. In doing so, we only collect personal data that is necessary for recruitment decisions. The procedures used by the firm to gather further information about you might include:
•    selection interviews;
•    assessment centres;
•    written skills tests;
•    referee reports;
•    security vetting; and,
•    necessary pre-employment activities.

References from your current or former employer(s) or other sources will only be obtained with your consent. In some cases, pre-employment checking may be necessary. Any checking is "tailor-made" and the extent and nature of information sought is no more than is justified by the particular position being filled. Failure to provide requested information may influence the processing and outcome of your application.

How do we use personal data?
We use the personal data for the following purposes:  
•    managing your application(s) for employment, evaluating you for open positions throughout the BaaSid network, and managing your candidate profile;
•    evaluating your suitability for employment with BaaSid (including for example providing your personal information to third parties to conduct background checks);
•    sending you email notifications and other announcements, requesting additional information, or otherwise contacting you about your candidacy;
•    conducting statistical analyses and reports including for example, demographic analyses of candidates, reports on BaaSid recruitment activities, and
      analyses of candidate sourcing channels; and
•    relating to any other purposes for which you provided the information to BaaSid.

We will not collect or use personal data in ways other than as described in this policy unless we have obtained your consent. In some cases we may specifically request a consent form to be signed. In other cases consent may be implied (for instance, you give us information after being fully advised of how it will be used).

Cookies and log files
This policy also applies to any personal data we collect via our websites. Cookies may be used on some areas of our website. “Cookies” are small text files placed on your hard drive that assist us in providing a more customised website experience. Cookies are now used as a standard by many websites to improve users' navigational experience. If you are concerned about cookies, most browsers permit individuals to decline cookies. In most cases, a visitor may refuse a cookie and still fully navigate our websites, however other functionality in the site may be impaired. After termination of the visit to our site, you can always delete the cookie from your system if you wish.

In order to properly manage our website and related email services, we may anonymously log information on our operating systems about the number and duration of visits to our website and identify categories of visitors by items such as domains and browser types, and to track document identification number by way of email acknowledgement or return receipt. These statistics are reported in the aggregate to our webmaster and system administrators. In addition, site statistics are compiled by third parties, and therefore your IP address will be passed to third parties for statistical reporting only. This is to ensure that our website presents the best web experience for visitors and is an effective information resource.
Whenever a registered member visits our website, they may be required to identify themselves in order to gain entry. This data is logged by BaaSid primarily to measure website performance and in assisting to resolve any website technical difficulties.

Disclosure of personal data
Your personal data will be used only by partners and staff directly involved in the recruitment process. Information will not be disclosed to third parties except when required by law, when we have your consent or in cases where the third party is a contractor or supplier whom we have engaged specifically to assist with our firm's activities. All such contractors will be bound contractually to keep all information confidential.

Transfer of Data to Other Countries
Personal data collected by BaaSid may be transferred internationally to other BaaSid International Labs' entities world-wide, where it is necessary to meet the recruitment purposes. By submitting your personal data to BaaSid whether through our websites or otherwise, you are providing explicit consent to transborder transmission of such data collected by BaaSid whether through our websites or otherwise for the fulfilment of recruitment applications.

How is this information secured?
BaaSid has implemented generally accepted standards of technology and operational security in order to protect your personal information from loss, misuse or destruction. In particular, BaaSid has put in place appropriate confidentiality obligations and technical and organisational security measures to prevent any unauthorised or unlawful disclosure or processing of such information and the accidental loss or destruction of or damage to such information.

How long is information kept?
Because BaaSid must process your personal data in order to consider you for a position as part of the recruitment process, if you revoke your consent, BaaSid may need to terminate your application. BaaSid may retain certain information related to your application for a reasonable but limited period to meet applicable legal or records retention requirements. To request us to delete your personal data submitted to BaaSid whether through our websites or otherwise, please send your request to dpo@baasid.sg

Access to your personal data can be made by request to us unless granting access would infringe another person's privacy. If you wish to gain access to your personal data, please send your request to dpo@baasid.sg
 
Correction and Concerns
If you believe that information we hold about you is incorrect, if you have concerns about how we are handling your personal data, or if you changed your mind about our usage of your data, please email us at dpo@baasid.sg and we will try to resolve those concerns.

Changes to the BaaSid Recruitment Data Protection Policy
BaaSid reserves the right to modify or amend this policy at any time and for any reason. However, BaaSid commits to ensure that the privacy rights of individuals are maintained.

In order to keep visitors informed, BaaSid will ensure that we notify users of changes to our Recruitment Data Protection Policy by identifying the alteration for a period of not less than two weeks on the our home page and identifying the effective date at the beginning of this policy.

Contact our Privacy Office
We welcome your enquiries or comments about our Recruitment Data Protection Policy and any queries or concerns that you may have about this website.