Redward Associates - Privacy Policy

Privacy Policy

Effective 1 December 2020

Data Protection Policy

The purpose of this document (the “Policy”) is to inform you of how Redward Associates Private Ltd. (“Redward”) manages Personal Data (as defined in paragraph 1 below) which is subject to the Personal Data Protection Act 2012 (No. 26 of 2012) of Singapore (the “PDPA”). Please read this policy so that you know and understand the purposes for which Redward collects, uses and discloses your Personal Data.

By interacting with Redward, submitting information to Redward, or subscribing for any Products and Services (as defined in paragraph 3 below) offered by Redward, you agree and consent to Redward (including its representatives and/or agents) collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing your Personal Data to Redward’s authorised service providers and relevant third parties in the manner set forth in this Policy.

This Policy supplements but does not supersede nor replace any other consents you may have previously provided to Redward in respect of your Personal Data, and your consents herein are additional to any rights which Redward may have at law to collect, use or disclose your Personal Data.

Redward believes in protecting your Personal Data, and will ensure that all reasonable security arrangements are in place to prevent any unauthorised access, collection use, disclosure, copying, modification or disposal of your Personal Data. Where necessary, Redward will required any person to whom it provides your Personal Data to agree to comply with this Policy. While Redward will use all reasonable efforts to ensure that such persons comply with this Policy, Redward will not be liable to you if any person fails to do so.

As part of Redward’s efforts to ensure that it properly manages, protects and processes your Personal Data, Redward may from time to time update this Policy to ensure that this Policy is consistent with future developments, industry trends and/or changes in legal or regulatory requirements. Subject to any rights that you may have at law, you agree to be bound by the prevailing terms and conditions of this Policy as updated from time to time.

Personal Data

In this Policy, “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 Redward has or is likely to have, including data in Redward’s records as may be updated from time to time.

Personal Data that you may provide to Redward include (depending on the nature of your interaction with Redward), amongst others, your name, NRIC, passport or other identification number or information, telephone number, mailing address, email address, geographical location and any other information relating to any individual which you have provided Redward in any document submitted to Redward or via other forms of interaction with you.

Collection of Personal Data

Generally, Redward collects Personal Data in the following ways:

when you submit a document relating to any of the Products and Services;
when you interact with Redward’s representatives and/or agents, for example, via telephone calls, letters, emails or face-to-face meetings;
when you request that Redward contacts you and when you request to be included in an email or other mailing list;
when you respond to any request for additional Personal Data;
when you are contacted by, and respond to, Redward’s representatives and/or agents;
when Redward receives references from business partners and third parties;
when Redward seeks information from third parties about you in connection with the Products and Services you have subscribed for; and
when you submit your Personal Data to Redward for any other reasons, including when you express your interest in any of the Products and Services.

If you provide Redward with any Personal Data relating to a third party (e.g. information of your employees), by submitting such information to Redward, you represent to Redward that you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes set out in this Policy.

You should ensure that all Personal Data submitted to Redward is complete, accurate, true and correct. Failure on your part to do so may result in Redward’s inability to provide you with the Products and Services you have subscribed for.

Purposes for the Collection, Use and Disclosure of your Personal Data

Generally, Redward collects, uses and discloses your Personal Data for the following purposes:

to respond to your queries and requests;
to manage Redward’s administrative and business operations, and complying with internal policies and procedures;
to match any Personal Data held which relates to you for any of the purposes set out in this Policy;
to resolve complaints, and handle requests and enquires;
to prevent, detect and investigate crime, and analyse and manage any commercial risks;
to provide media announcements and responses;
to monitor or record phone calls and face-to-face meetings for quality assurance, employee training, performance evaluation and identity verification purposes;
legal purposes (including obtaining legal advice and dispute resolution);
to conduct investigations relating to disputes, billing, suspected illegal activities or fraud;
to meet or comply with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on Redward (including responding to regulatory complaints, disclosing to regulatory bodies and conducting audit checks, due diligence and investigations; and
purposes which are reasonably related to any of the above purposes in this
paragraph 1 or for any other purpose which Redward may notify you at the time of obtaining your consent.

In addition, if you are a licensee, an end user or an employee of a licensee of Redward (including the subscription or use of Redward’s products and services, such as Asia-Pacific Today, Indicator Model Update, MacroMonday, Dairy Monthly, Gold Monthly, PowerPoint presentations and face-to-face meetings (collectively, the “Products and Services”)), Redward collects, uses and discloses your Personal Data for the following purposes:

providing you with the Products and Services you have subscribed for;
facilitating the continuation or termination of your subscription to the Products and Services (including administering subscription arrangements, processing renewal of subscriptions and relationship management);
facilitating the daily operation of the Products and Services (including billing, customer service, technical support and troubleshooting);
processing of payment instructions, GIRO, direct debit facilities and/or credit facilities requested by you;
enforcement of payment obligations (including debt collection and filing of claims);
credit and internal risk management (including performing credit checks and disclosures to law enforcement agencies);
generating internal reports (including annual, operational and management reports);
processing referral payments and commission fees to Redward’s external partners;
administering fee adjustments, refunds and waivers;
analysing your use of the Products and Services so as to help Redward improve, review, develop and efficiently manage the Products and Services offered by Redward; and
purposes which are reasonably related to any of the above purposes in this
paragraph 2 or for any other purpose which Redward may notify you at the time of obtaining your consent.

Furthermore, where permitted under the PDPA, Redward may also collect, use and disclose your Personal Data for the following additional purposes (the “Additional Purposes”):

analytics and tracking;
conducting market research and surveys to enable Redward to understand and determine preferences and demographics to improve, review, develop and efficiently manage the Products and Services offered by Redward;
providing additional Products and Services and benefits to you;
matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision, marketing or offering of the Products and Services;
communicating to you advertisements involving details of the Products and Services either to licensees, end users or employees of licensees of Redward generally or which Redward has identified to be of interest to you;
purposes which are reasonably related to any of the above purposes in this
paragraph 3 or for any other purpose which Redward may notify you at the time of obtaining your consent.

In addition, where permitted under the PDPA and subject to the provisions of any applicable law, your Personal Data may be disclosed for the Additional Purposes to vendors or other third party service providers.

If you have provided your Singapore telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your Singapore telephone number(s), Redward may, from time to time, contact you using such Singapore telephone number(s) (including voice calls, text, fax or other means) with information about the Products and Services.

In relation to particular Products and Services or in your interaction with Redward, Redward may also have specifically notified you of other purposes for which Redward collects, uses or discloses your Personal Data. If so, Redward will collect, use and disclose your Personal Data for these additional purposes as well, unless Redward has specifically notified you otherwise.

You have a choice to withdraw your consent for receiving marketing or promotional materials/communication. To do so, you may contact Redward using the contact details in paragraph 6

Disclosure of Personal Data

Subject to paragraph 2 below, Redward may share aggregated, non-personally identifiable information with the public and with its partners, such as its vendors, advertisers and other service providers.

Redward will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provision of any applicable law, your Personal Data may be disclosed for the purposes set out in paragraph 3 above, or for any purpose allowed under any applicable law or regulations, to the following parties:

Redward’s representatives, agents and employees to provide the Products and Services to you, address your questions and requests in relation to your subscription and billing arrangements with Redward as well as the Products and Services, and to maintain and operate Redward’s systems and/or services;
companies providing services relating to insurance and consultancy to us;
agents, contractors or third party service providers who provide operational services to us, such as courier services, telecommunications, information technology, payment, printing, billing, processing, technical services, training, market research, security or any other services;
vendors or third party service providers in connection with marketing promotion and services offered by Redward;
collection and repossession agencies in relation to the enforcement of payment obligations;
credit bureaus for the purpose of preparing credit reports or evaluation of creditworthiness;
external banks, credit card companies and their respective service providers;
our professional advisers, such as auditors and lawyers;
relevant government regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and
any other party to who you authorise Redward to disclose your Personal Data to.

You understand that the transmission of information via the internet is not completely secure. Although Redward will do its best to protect your Personal Data, Redward cannot guarantee the security of your Personal Data transmitted through its website, online Products and Services, and any transmission is at your own risk. In addition, Redward cannot assume responsibility for any unauthorised use of your Personal Data by third parties which are wholly attributable to factors beyond Redward’s control.

If such disclosure involves transfer of your Personal Data outside Singapore, a standard of protection that is comparable to that under this Policy shall be provided.

Use of Cookies

In this Policy, “cookies” refers to small pieces of information that is placed on your computer or other digital device when you visit certain websites.

Redward uses cookies on its website for the following purposes:

to enable certain features and functions on Redward’s website (e.g. remembering your user-id, browsing and other service preferences);
to build up a profile of who you and other users use Redward’s website and/or other third party websites;
to improve the efficiency of Redward’s website;
to administer Products and Services to you and to advertisers;
to establish usage statistics;
to enable authentication cookies to identify you when you perform online transactions with Redward.

Most internet browsers provide you the option of turning off the processing of cookies (please refer to the “help” section of your browser), but this may result in the loss of functionality, restrict you use of Redward’s website and/or delay or affect the way in which Redward’s website operates.

Advertisements on Redward’s website may be provided by third party advertisers and their agencies. These may generate cookies to track how many people have seen a particular advertisement (or use services of third parties to view a particular advertisement), and to track how many people have seen it more than once.

Redward is not responsible for the Personal Data policies (including Personal Data protection and cookies), content or security of any third party websites linked through Redward’s website.

Withdrawal of Consent, Access and Correction of your Personal Data

If you would like to withdraw your consent to any use of your Personal Data as set out in this Policy, please contact us through email at nathalie@redwardassociates.com , or in writing at the following address:

Redward Associates Private Ltd.

20 Collyer Quay

#09-01 20 Collyer Quay

Singapore 049319

Attention: Data Protection Officer

Please be aware that once Redward receives confirmation that you wish to withdraw your consent for marketing or promotional materials/communication, it may take up to 30 working days for your withdrawal to be reflected in Redward’s systems. In the meantime, you may still receive marketing or promotional materials/communication from Redward. Please note that even if you withdraw your consent for the receipt of marketing or promotional materials/communication, Redward may still contact you for other purposes in relation to the Products and Services that you have subscribed for.

If you would like to obtain access and make corrections to your Personal Data records, please contact us through email at nathalie@redwardassociates.com , or in writing at the following address: