1. Introduction
1.1 AEM Holdings Ltd., its subsidiaries and its affiliates (collectively, “AEM Group” or as appropriate in the context, “we”, “us” or “our”) take the responsibilities under applicable data protection laws and regulations, including the Singapore Personal Data Protection Act 2012 (“PDPA”), seriously.
1.2 This Privacy Policy (“Policy”) sets out:
- (a) how we manage your Personal Data;
- (b) the types of Personal Data we collect, use, process, disclose and/or retain;
- (c) how we collect, use, process, disclose and/or retain your Personal Data;
- (d) the purpose(s) for which we collect, use, process, disclose and/or retain your Personal Data;
- (e) the measures we take to protect the security of information you provided to us, including without limitation through this website; and
- (f) how you can reach out to us to update your Personal Data, ask questions you may have about our Personal Data protection practices and provide feedback on our Personal Data protection practices.
1.3 “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. Depending on the nature of your interaction with us, some examples of Personal Data include but are not limited to an individual’s:
- (a) full name;
- (b) identification or passport number;
- (c) date of birth;
- (d) gender;
- (e) nationality;
- (f) mobile telephone number;
- (g) residential and/or mailing addresses;
- (h) personal email address;
- (i) resume;
- (j) educational qualifications;
- (k) professional qualifications and certifications;
- (l) employment references;
- (m) employment and training history; and
- (n) photographs and video images.
1.4 Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context so permits).
2. Consent
By voluntarily providing any Personal Data to us in the course of interacting with or transacting with us, calling or sending messages to us, accessing our websites and/or submitting information to us via forms or other data collection means or processes:
- (a) you confirm that you have read, understood and agreed to our collection, use, processing, disclosure and/or retention of your Personal Data in the manner set forth in this Policy.
- (b) you thereby consent to the collection, use, processing, disclosure and/or retention of such Personal Data by us for the purpose for which such Personal Data was disclosed and/or for any reasonable purpose or for which you have been notified (which includes any of the purposes set out in the section below), until and unless you notify us otherwise.
- (c) where you give us Personal Data about other individuals, you confirm that you are authorised to disclose and consent, on their behalf, to the use, processing, disclosure and/or retention of such Personal Data for the purpose for which such Personal Data was disclosed and/or for any reasonable purpose or for which you have been notified (which includes any the purposes set out in the section below), until and unless you notify us otherwise.
3. Collection, Use, Processing, and Disclosure of Personal Data
3.1 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 (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 written consent to the collection, use, and processing of your Personal Data for those purposes, or (b) collection, use, and processing of Personal Data without consent is permitted or required by the PDPA or other applicable data protection laws or regulations. We shall seek your consent before collecting any additional Personal Data and before using or processing your Personal Data for a purpose which has not been notified to you (except where permitted or authorised by law).
3.2 We may collect, use, and process your Personal Data for any or all of the following purposes:
- (a) performing obligations in the course of or in connection with, our provision of the goods and/or services requested by, the provision of goods and/or services provided by, you;
- (b) verifying your identity (including for security clearance/entry access into AEM Group);
- (c) responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
- (d) managing your relationship with us;
- (e) processing payment or credit transactions;
- (f) 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;
- (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, professional advisers, and relevant governmental and/or regulatory authorities, whether locally or abroad, for the aforementioned purposes;
- (i) conducting due diligence/background checks that are mandated by legislation or internal policies and practices of AEM Group;
- (j) evaluating and acquiring products and services;
- (k) keeping you updated on changes to the policies of AEM Group;
- (l) evaluating and improving AEM Group’s products and services;
- (m) communicating with you (e.g., to respond to queries, complaints or comments on the products and services of AEM Group; to inform you of any developments to the products and services of AEM Group, the business of AEM Group and/or other corporate events or updates); and
- (n) any other incidental business purposes related to or in connection with the above.
3.3 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, professional advisers, and other organisations we have engaged to perform any of the functions with reference to the above mentioned purposes.
3.4 If you are a job applicant (i.e., if you have applied for any position with us), in addition to the purposes outlined in Clauses 3.2 and 3.3, your Personal Data will be collected, used and processed by us for the following purposes and we may disclose your Personal Data to third parties where necessary for the following purposes:
- (a) assessing and evaluating your suitability for employment in any current or prospective position within the organisation;
- (b) verifying your identity and the accuracy of your personal details and other information provided;
- (c) performing obligations under or in connection with your contract of employment with us, including payment of remuneration and tax;
- (d) all administrative and human resources related matters within our organisation, including administering payroll, granting access to our premises and computer systems, processing leave applications, administering your insurance and other benefits, processing your claims and expenses, investigating any acts or defaults (or suspected acts or defaults) and developing human resource policies;
- (e) managing and terminating our employment relationship with you, including monitoring your internet access and your use of our intranet email to investigate potential contraventions of our internal policies or external compliance regulations, and resolving any employment related grievances;
- (f) assessing and evaluating your suitability for employment/appointment or continued employment/appointment in any position within our organisation;
- (g) ensuring business continuity for our organisation in the event that your employment with us is or will be terminated;
- (h) performing obligations under or in connection with the provision of our goods or services to our clients;
- (i) facilitating any proposed or confirmed merger, acquisition or business asset transaction involving any part of our organisation, or corporate restructuring process; and
- (j) facilitating our compliance with any laws, customs and regulations which may be applicable to us.
3.5 The purposes listed in the above Clauses 3.2, 3.3 and 3.4 may continue to apply even in situations where your relationship with us (e.g., 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).
4. Reliance on Legitimate Interests Exception
4.1 In compliance with the PDPA or other applicable data protection laws or regulations, we may (to the extent permitted) collect, use, process or disclose your Personal Data without your consent for the legitimate interests of AEM Group or another person. In relying on the legitimate interests exception of the PDPA or other applicable data protection laws or regulations, AEM Group will assess the likely adverse effects on the individual and determine that the legitimate interests outweigh any adverse effect.
4.2 In line with the legitimate interests’ exception, we will collect, use, process or disclose your Personal Data including for the following purposes:
- (a) fraud detection and prevention.
- (b) detection and prevention of misuse of services.
- (c) network analysis to prevent fraud and financial crime, and perform credit analysis.
- (d) collection, use and processing of Personal Data on company-issued devices to prevent data loss.
4.3 The purposes listed in Clause 4.2 may continue to apply even in situations where your relationship with us (e.g., pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter.
5. Withdrawing Your Consent
5.1 The consent that you provide for the collection, use, processing 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, processing 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 in Clause 12 below.
5.2 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.
5.3 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 or progress your job application (as the case may be). 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 5.1 above.
5.4 Please note that withdrawing consent does not affect our right to continue to collect, use, process and disclose Personal Data where such collection, use, processing and disclosure without consent is permitted or required under applicable laws.
6. Access to and Correction of Personal Data
6.1 If you wish to make (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, process 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 in Clause 12 below.
6.2 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.
6.3 We will respond to your request as soon as reasonably possible and in general, within thirty (30) days after receiving your request. Should we be unable to do so, 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 or other applicable data protection laws or regulations).
6.4 Please note that depending on the request that is being made, we will only need to provide you with access to the Personal Data contained in the documents requested, and not to the entire documents themselves. In those cases, it may be appropriate for us to simply provide you with confirmation of the Personal Data that our organisation has on record, if the record of your Personal Data forms a negligible part of the document.
7. Protection of Personal Data
7.1 We have introduced appropriate administrative, physical and technical measures to safeguard your Personal Data from unauthorised access, collection, use, processing, disclosure, copying, modification, disposal or similar risks.
7.2 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.
8. Retention of Personal Data
8.1 We may retain your Personal Data for as long as it is necessary to fulfil the purposes for which they were collected, or as required or permitted by applicable laws.
8.2 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 purposes for which the Personal Data were collected, and are no longer necessary for legal or business purposes.
9. Accuracy of Personal Data
9.1 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 in Clause 12 below.
10. Transfers of Personal Data to foreign jurisdictions
10.1 We generally do not transfer your Personal Data to foreign jurisdictions. However, if we do so, we will take steps to ensure that your Personal Data continues to receive a standard of protection that is in accordance with applicable data protection laws and regulations.
11. Use of Cookies
11.1 This website may place and access certain cookies on your computer and/or any other electronic device used to access the website. We use cookies to improve your experience using the website and to improve the efficacy of our services. We have carefully chosen these cookies and had taken steps to ensure that your privacy is protected and respected at all times.
11.2 Users of this website are advised that if they wish to deny the use and saving of cookies from this website onto their computers and/or other electronic devices, they should take the necessary steps within their internet browsers’ security settings to block all cookies from this website.
11.3 You can choose to delete the cookies at any time. However, you may lose any information that enables you to access the website more quickly and efficiently including but not limited to personalisation settings.
12. Contacting our Data Protection Officer
12.1 You may contact us:
- (a) if you have any enquiries or feedback on this Policy, and our other data protection policies and procedures;
- (b) to request to access and/or correct your Personal Data in our possession;
- (c) to withdraw your consent to the continued use, processing and/or disclosure of any Personal Data for all or any particular purpose; or
- (d) if you have any questions or complaints regarding how we are handling your Personal Data.
12.2. You may contact us either by email or by post to AEM Group’s designated Data Protection Officer at:
| aem.dataprivacy@aem.com.sg | |
| Address | AEM Holdings Ltd., 52 Serangoon North Ave 4 Singapore 555853 |
12.3. When contacting us, please state the purpose for which you are contacting us, your name and an email address or mailing address at which we can contact you, and the nature of our relationship with you.
12.4. AEM Group will endeavour to respond to you as soon as possible within ten (10) business days (if related to the withdrawal of consent) or within thirty (30) days (if related to any matter with regard to personal data other than the withdrawal of consent). If we are unable to do so for any reason, we will inform you accordingly and the time by which we will respond to the request.
13. Changes to this Policy
13.1 This Policy applies in conjunction with any other policies, notices, contractual clauses and consent clauses that apply in relation to the collection, use, processing and disclosure of your Personal Data by us.
13.2 We may revise this Policy 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 Policy was last updated. Your continued use of our services or employment and participation in our recruitment process constitutes your acknowledgement and acceptance of such changes.
13.3 We recommend that you review this Policy from time to time so you are aware of any changes or updates to the Policy.
Effective date : 1st October 2021
Last updated : 29th August 2023
