INTRODUCTION

At Adsan Law LLC (hereinafter referred to as “we”, “us” and “our”), we are committed to maintaining information relating to our clients and potential clients (hereinafter referred to as “your”, and “your” and “yours”) private and confidential, consistent with our professional obligations. 

This Policy is intended to assist you to understand the type of information we collect, how we use that information and the safeguards we have in place to protect that information and your privacy. 

PERSONAL DATA 

1. “Personal Data” means data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which we have or are likely to have access.

2. Examples of Personal Data which we may collect from you include:
   a.  name and identification information (such as your NRIC number);
   b.  contact information (such as your address, email address or telephone number);
   c.  nationality;
   d.  gender;
   e.  date of birth;
   f.  marital status;
   g.  photographs and other audio-visual information;
   h.  employment information; and
   i.  financial information such as credit card numbers, debit card numbers or bank account information.

3. Other terms used in this Notice shall have the meanings given to them in the Personal Date Protection Act 2012 (“PDPA”) (where the context so permits).

COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA 

4. Personal Data may be collected:
   a.  from you directly;
   b.  from third parties and as agents on behalf of you where we or they have obtained the requisite consent, or as otherwise permitted or required by law;
   c.  through information publicly available;
   d.  in the case of application for employment with us, from your employment application and the information and documents submitted ; and/or
   e.  through our website, although such information is normally limited.

5. We may collect and use your Personal Data for any or all of the following purposes:
   a.  to facilitate the provision of our professional services and legal advice;
   b.  verifying your identity;
   c.  for conflict checking;
   d.  administrative and relationship management purposes (including to develop and manage our knowledge management systems, organising seminars, events and to market and deliver our services);
   e.  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;
   f.  responding to complaints, queries and/or requests;
   g.  any other purposes for which you have provided the information;
   h.  transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
   i.  any other incidental business purposes related to or in connection with the above.

6. We may disclose your Personal Data:
   a.  where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods or services requested by you; or
   b.  to third party service providers, agents and other organisations we have engaged to perform any of the functions listed in clause 5 above for us.

7. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us has been terminated or altered in any way, for a reasonable period thereafter.

8. By providing your Personal Data to us, you consent to our collection, use and disclosure of such Personal Data in accordance with this Policy and as permitted or required by law. Consent to our collection, processing or disclosure of your Personal Data may be provided orally or in writing or may be deemed. This includes providing Personal Data to us in the course of our representation in legal proceedings or other matters we have been appointed to act on your behalf, which may subsequently require disclosure of your Personal Data as part of such representation.

9. Insofar as Personal Data of another individual provided by you to us is concerned, it is your representation to us that you have the necessary consent, permission and authority to allow us to collect, use and disclose such Personal Data for the purposes set out in this Policy.

10. For purposes of discharging our professional or ethical obligations, we may from time to time allow or be required to allow third parties to access your Personal Data to process data on our behalf in connection with the conduct of our business or where such disclosure is in your interest or is otherwise permitted, required or authorised under the applicable law. In such situation, we will take reasonable steps to ensure that such third parties provide at least a level of privacy protection equivalent to that offered by us in this Policy prior to any access, process or disclosure. 

WITHDRAWING YOUR CONSENT 

11. 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.

12. 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 clause 5 above by submitting your request to our Data Protection Officer in accordance with clause 28.

13. 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.

14. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our professional services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 11 above.

15. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose Personal Data where such collection, use and disclose without consent is permitted or required under applicable laws. 

ACCESSING AND CORRECTING YOUR PERSONAL DATA 

16. If you wish to:
    a. verify our use of your Personal Data;
    b. exercise your right to access, verify, amend, erase or block your Personal Data;
    c. submit a written request for us to cease to process your Personal Data; or
    d. make a complaint under this Policy, please submit your request to our Data Protection Officer in accordance with clause 28:

17. As permitted by applicable law, a fee reflective of the costs may be charged by us for each Personal Data access request made which right of access is subject to the exceptions prescribed under the applicable law.

18. 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). 

SECURITY 

19. Your Personal Data is treated as private, confidential information which we strive to ensure that it remains protected and kept secure at all times. We will take all commercially reasonable steps in line with industry practice to protect your Personal Data, such as up-to- date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of Personal Data by us, and disclosing Personal Data both internally and to our authorised third party service providers and agents only on a need-to-know basis. We cannot assume responsibility for any unauthorised use of your personal data by third parties which are wholly attributable to factors beyond our control.

20. However, as you are aware, no method of transmission over the Internet or method of electronic storage is completely secure, and extensive security measures may hinder efficient/prompt communication. To facilitate communication, e-mail is a frequently used mode of communication and unless you object we may use unencrypted plain text e-mails for our communication with you. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

ACCURACY OF PERSONAL DATA 

21. 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 accordance with clause 28. 

RETENTION OF PERSONAL DATA 

22. 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.

23. 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. 

TRANSFER OF PERSONAL DATA OUTSIDE OF SINGAPORE 

24. We generally do not transfer your Personal Data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and we will 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. 

OUR WEBSITE 

25. There is no electronic means to automatically collect Personal Data from any visitor or user of our website. Information collected through our website will be the information voluntarily supplied by you if you contact us through our website. This information is normally limited to your name and e-mail address and other information which you may voluntarily input. Our website may however contain links to other websites which may collect your Personal Data and we do not assume the responsibility of any third party website operators for the contents of such websites and any Personal Data collected through such websites. We advise that you read the privacy policies of these websites before making an informed decision whether or not to provide your Personal Data to the websites’ operators.

26. When you visit our website our server will record your IP address together with the date, time and duration of your visit. The IP address enables us to identify which organisations have visited our website. We use this information to compile statistical data on the use of our website to track how users navigate through our site. We
    do this so we can evaluate and improve our site.

27. Our website may also allow third parties to download cookies to your device. These third party cookies are not under our control.

DATA PROTECTION OFFICER 

28. You may contact our Data Protection Officer in writing or via email if you have any enquiries or feedback on this Policy and procedures, or if you wish to make any request, at the address below:
    
    300 Beach Road
    Level 26 The Concourse
    Singapore 199555
    Email: dpo@adsanlaw.com

EFFECT OF POLICY AND CHANGES TO POLICY 

29. In providing any Personal Data to us, you consent to our collection, use or disclosure of that information in accordance with this Policy.

30. This Policy applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your Personal Data by us.

31. We reserve the right to change, modify, delete or amend any part of this Policy from time to time without any prior notice and you are encouraged to make regular reference to this Policy. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.