Our Privacy Policy

This Privacy Policy applies to https://asprigroup.com (the “Website”) which is owned by Aspri Group Pte. Ltd. (the “Company”, “we”, “our”, “us”). This Policy applies to all personal data you provide to us when you access this Website.

This Policy will assist you in understanding how we collect, use, disclose and process any personal information (“Personal Data”) in compliance with the Personal Data Protection Act 2012 (“PDPA”).

We believe that an individual’s Personal Data is important and should be treated as such. This Privacy Policy (“Policy”) is intended to help you in making an informed decision before providing us with any Personal Data.

Personal Data refers to data about an individual who can be identified using that data (such as a combination of: the individual’s name, contact details, date of birth, gender, identity card/passport number and e-mail address); or from that data and other information to which an organization has or is likely to have access.

Further, your access and use of our Website, the information made available and the services we provide are all subject to this Policy.

Should you, at any time, require any further information or clarification on this Policy or how we manage, protect and/or process your Personal Data, please do not hesitate to contact our Data Protection Officer at dpo@asprigroup.com

Your Acceptance of Our Privacy Policy

When you provide any Personal Data to us, you are deemed to have accepted of our Privacy Policy. Therefore, before you provide any Personal Data, please read this Policy to understand how we collect, use, disclose (including transfer), process and manage Personal Data in compliance with PDPA.

Please do not provide us with any Personal Data if you are below 18 years of age or do not accept this Policy.

Collection, Use and Disclosure of Personal Data

Please note that Personal Data may be collected in many ways . Personal Data may be collected by us in instances such as, but not limited to the following, namely, when you:

Browse this Website;
Register yourself on this Website for the purpose of creating an account in this Website or receiving information or downloadable brochures (including Newsletters) and marketing materials from us;
Make enquiries with us;
Engage or place orders for our services and/or transacting with us;
Use our services;
Wish to communicate with us, whether via online, or otherwise like postal mail, telephone or by OTT messaging, or any combination of the foregoing, for purposes such as but not limited to the engagement and delivery of our services, as well as other service enquiries;
Apply for potential employment with us, or enquire about possible opportunities to work with us or collaborate;
Provide Personal Data on this Website for any other purposes as you may consent to, from time to time.

You are under no obligation to provide any Personal Data, and you are entirely at liberty to refuse to provide any Personal Data. However, should you refuse to provide any Personal Data such as your name and contact details, then we may not be able to attend to your interest or answer any queries which you may have.

The Personal Data we may collect about you when you use our services may include any of the following:

Your contact details – your name, address, telephone number, email address and any other contact details you provide to us.
Your personal characteristics – including your gender, race, profession, job title, marital status,
Your communication data – your requests, complaints you may have and any data we receive through our communication with you via email, telephone or any other means.
Any other personal data – this includes any other Personal Data which you may disclose to us during the course of your business relationship with us as required.

Personal Data which you provide to us will only be used, disclosed, and/or processed by us for the purposes of facilitating your business requirements with us and to keep you informed of updates, changes, and developments relating to us, the scope of which may include:

Carrying out identity checks;
Deciding whether to engage in a business relationship with you;
Providing services based on your required business profile, in particular, company, partnership or business registration, Singapore visa and business accounts or license applications, financial reporting, regulatory reporting, management reporting, audit and record keeping purposes (if and where so applicable);
Administering and maintaining your client account with us;
General management and reporting purposes, such as invoicing and account management;
Communicating with you on matters relating to your client account with us;
Keeping you informed of the services we offer, industry development, services offering, seminars and other events we are holding that may be of interest, if they/you have separately indicated your consent;
In connection with any claims, actions or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution), and/or protecting and enforcing our contractual and legal rights and obligations;
Responding to queries or feedback from you;
Coaching our employees for customer service quality assurance training purposes;
For recruitment purposes;
For purposes relating to the employment of our personnel;
Notifying you about important changes to our Privacy Policy, Terms of Service and any other service delivery matters which may affect you.

In compliance with the PDPA, we will not send our marketing materials to you unless you have given us clear and unambiguous consent to do so – as reiterated in “Other Uses”. If you have given us consent, we may send you marketing messages until you advise us in writing that you wish to withdraw your consent.

Other Uses

Apart from such uses as mentioned above, Personal Data may be used to:

Compile statistical information, create reports, and to conduct research (including but not limited to data analytics, surveys and/or profiling) for market analysis, and/or for the purposes of improving our product, services and facilities;
Perform due diligence checks (including know-your-client checks and anti-money laundering due diligence checks) in accordance with legal or regulatory obligations (whether Singapore or a foreign country), and risk management procedures, which we determine are applicable to us or our affiliates/associated companies;
Detect and prevent any fraud, unlawful activity, misconduct or complaints, and/or investigate into any such acts or even any suspicion thereof;
Initiate and/or pursue any form of legal redress;
Comply with orders, directions, requirements, guidelines and/or requests made or existing under any applicable laws, and/or by or from any courts, governmental, statutory or regulatory bodies, (whether of Singapore or elsewhere), with which we or our affiliates/associated companies are expected to comply;
Conduct direct marketing via email, telephone and/or other means of communication if you have separately indicated your consent to receiving such direct marketing materials;
Facilitate services from third party service providers to whom such Personal Data as may be relevant has to be disclosed for such services provided you have previously consented to such disclosure.

We will not disclose your Personal Data without your consent unless it falls under an exception.

Exceptions to the Requirement of Consent

Notwithstanding anything to the contrary in the foregoing, the Second, Third and Fourth Schedules of the PDPA (which are publicly available at https://sso.agc.gov.sg/Act/PDPA2012) set out the exceptions that permit the collection, use and disclosure of Personal Data without your consent.

We may disclose your Personal Data without obtaining your consent in certain conditions, such as the following:

Where the disclosure is required based on the prevailing laws and/or regulation;
Where disclosure is clearly in your best interest, and if consent cannot be obtained in a timely way that would otherwise cause you great inconvenience;
Where disclosure is necessary to address imminent health or safety issues to yourself or another individual and consent for disclosure would cause detriment;
Where disclosure is necessary for any investigations or proceedings or any audits;
Where disclosure is to a public agency.

Disclosure and Transfer of Personal Data to Third Parties and/or Outside of Singapore

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 us. Any such third parties whom we may engage at your request will be bound contractually to keep all information confidential.

We will endeavour to provide adequate protection and supervision over the handling of your Personal Data that is transferred by us to third parties.

In the event your Personal Data is transferred outside Singapore, we will implement measures to ensure that such overseas recipients are legally bound to provide a standard of protection comparable to the PDPA.

Your Rights – Access, Withdrawal of Consent, and Updates

You may request access to your Personal Data collected by us, at any time, by notifying our Data Protection Officer.

You may withdraw your consent to our collection, use and/or disclosure of your Personal Data at any time by notifying our Data Protection Officer.

If you believe that any information, we hold about you is incorrect, incomplete and/or outdated or has been provided to us without your consent, please contact our Data Protection Officer.

Within 30 days upon receipt of your notification (access, withdrawal of consent or updates) we will act upon your request in accordance with the requirements of the PDPA.

We may charge a fee for requests for access to your Personal Data in accordance with the requirements of the PDPA. If so, we will provide you with a written estimate of the fee. We will begin to process your request only upon receipt of the fee payment.

You may choose to unsubscribe from our mailing lists or registrations, or elect not to receive further marketing information from us by contacting our Data Protection Officer. Where applicable, you may also “unsubscribe” from receiving automated e-mails from us by using the “unsubscribe” function provided.

Security and Management of Personal Data

We have implemented generally accepted standards of technology and operational security to protect the Personal Data that we collect. We will take appropriate security measures to protect such Personal Data from any unauthorised access, modification, use or disclosure, and from any other similar risks. We require our staff to undergo privacy and security training. However, we shall not be responsible or liable for any such unauthorised access, modification, use (such as the collection or copying of Personal Data), or disclosure of Personal Data by third parties where such acts are attributable to factors beyond our control.

Whilst we will make reasonable efforts to ensure that the Personal Data you provide are collected and recorded faithfully, accurately and without modification, we will not be responsible for the accuracy, truthfulness, and completeness of the Personal Data which you provide. In the event of any changes or inaccurate details, you must update us accordingly.

Retention of Personal Data

We will cease to retain your Personal Data as soon as it is reasonable to assume that the purpose of 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. We cannot delete your Personal Data when the maintenance of such record is required by any laws, statute, order, regulation, government guidelines or regulating authorities.

Further to the above, we will make reasonable efforts to destroy such Personal Data that have become redundant according to industry standards.

Withdrawal Of Consent

If you wish to withdraw consent, you should give us reasonable advance notice. We will advise you of the likely consequences of your withdrawal of consent, e.g. without your personal contact information we may not be able to inform you of future services offered by us.

Data Protection Officer

We have appointed a Data Protection Officer who can be reached via e-mail at: dpo@asprigroup.com.

In the event you have any queries, complaints or grievance regarding our collection, handling, use or disclosure of Personal Data, or should you wish to withdraw your consent with respect thereto, you may contact our Data Protection Officer.

Updates on our Privacy Policy

We reserve our right to review and make changes to this Policy at our absolute discretion. The most current version of the Policy will govern our collection, use, and disclosure of Personal Data. Any such changes to this Policy will be posted on this Website. Your continued use of our Website or services constitutes your agreement to this Policy and to our collection, use, management, retention or disclosure of your information as described. You are encouraged to visit this Policy regularly.

General

We treat your privacy seriously and any information provided to us will be protected accordingly. Your consent that is given pursuant to this Policy is additional to and does not supersede any other consents that you provided to the Company with regard to processing of your Personal Data.

Last updated on 04 January 2022