Privacy Policy
Privacy Policy
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This Data Protection Notice (“Notice”) sets out the basis which InnoArk Pte. Ltd. (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of our customers in accordance with the Personal Data Protection Act (“PDPA”). This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.
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PERSONAL DATA
1. As used in this Notice:​
“customer” means an individual who
(a) has contacted us through any means to find out more about any goods or services we provide, or
(b) may, or has, entered into a contract with us for the supply of any goods or services by us; and “personal data” means data, whether true or not, about a customer who can be identified:
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(a) from that data; or
(b) from that data and other information to which we have or are likely to have access.
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2. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include name and business email address.
3. Other terms used in this Notice shall have the meanings given to them in the PDPA
(where the context so permits).
COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
4. We generally do not collect your personal data unless
(a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to
disclose your personal data to us (your “authorised representative”) after
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(i) you (or your authorised representative) have been notified of the purposes for which the data is
collected, and
(ii) you (or your authorised representative) have provided writte consent to the collection and usage of
your personal data for those purposes, or
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(b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We
shall seek your consent before collecting any additional personal data and before using your personal data
for a purpose which has no been notified to you (except where permitted or authorised by law).
5. We may collect and use your personal data for any or all of the following purposes:
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(a) performing obligations in the course of or in connection with our provision of the goods and/or services requested by you; and
(b) verifying your identity.
(c) responding to, handling, and processing queries, requests, applications, complaints and feedback from you; and
(d) managing your relationship with us.
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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 and services requested by you; or
(b) to third party service providers, agents and other organisations we have engaged to perform any of the functions with reference to the above mentioned purposes.
RELIANCE ON THE LEGITIMATE INTERESTS EXCEPTION
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7. In compliance with the PDPA, we may collect, use or disclose your personal data without your consent for the legitimate interests of InnoArk Pte. Ltd. or another person. In relying on the legitimate interests exception of the PDPA, InnoArk Pte. Ltd. will assess the likely adverse effects on the individual and determine that the legitimate interests outweigh any adverse effect.
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8. In line with the legitimate interests’ exception, we will collect, use or disclose your personal data for the following purposes:
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(a) Fraud detection and prevention; and
(c) Detection and prevention of misuse of services
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The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under a contract with you).
WITHDRAWING YOUR CONSENT
9. 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. You may withdraw consent and request us to stop collecting,
using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request
in writing or via email to our Data Protection Officer at the contact details provided below.
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10. 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
fourteen (14) business days of receiving it.
11. 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 goods or 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 7 above.
11. 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
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ACCESS TO AND CORRECTION OF PERSONAL DATA
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12. If you wish to make
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(a) an access request for access to a copy of the personal data which we hold about you or information about
the ways in which we use or disclose your personal data, or
(b) a correction request to correct or update any of your personal data which we hold about you, you may
submit your request in writing or via email to our Data Protection Officer at the contact details provided
below.
13. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.
14. We will respond to your request as soon as reasonably possible. In general, our response will be within seven (7) business days. 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).
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PROTECTION OF PERSONAL DATA
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15. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification,
disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such
as minimised collection of personal data, authentication and access controls (such as good password
practices, need-to-basis for data disclosure, etc.), usage of one time password(otp)/2 factor authentication
(2fa)/multi-factor authentication (mfa) to secure access, encryption of data, data anonymisation, up-to-date antivirus protection, regular patching of operating system and other software, securely erase storage media in devices before disposal, web security measures against risks, and security review and testing performed regularly.
16. You should be aware, however, that no method of transmission over the Internet or method of electronic
storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your
information and are constantly reviewing and enhancing our information security measures.
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ACCURACY OF PERSONAL DATA
17. 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 writing or via email at the contact details provided below.
RETENTION OF PERSONAL DATA
18. 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.
19. 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.
TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
20. 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.
DATA PROTECTION OFFICER
21. You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data
protection policies and procedures, or if you wish to make any request, in the following manner:
Report Link: https://www.innoark.com/contact-us
and enter subject: DPO
EFFECT OF NOTICE AND CHANGES TO NOTICE
22. This Notice 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.
23. We may revise this Notice from time to time without any prior notice. You may determine if any such revision has
taken place by referring to the date on which this Notice was last updated. Your continued use of our services
constitutes your acknowledgement and acceptance of such changes.