Your privacy matters and we recognise the importance of being transparent about how we manage the personal data shared with us.
The Personal Data Protection Act (“PDPA”) is the principal data protection law in Singapore governing the collection, use, disclosure and care of personal data. We are committed to comply with the PDPA provisions and other applicable data protection laws in Singapore in our collection, use and disclosure of personal data.
1.1. This Policy statement provides information on our obligations and policies in respect of an individual User’s Personal Data. We undertake to use reasonable efforts in applying, where practicable, those principles and the processes set out herein to its operations.
1.2. Our officers, management, and members of staff shall use reasonable endeavours to respect the confidentiality of and keep safe any and all Personal Data collected and/or stored and/or disclosed and/or used for, or on behalf of, us. We shall use reasonable endeavours to ensure that all collection and/or storage and/or disclosure and/or usage of Personal Data by us shall be done in an appropriate manner and in accordance with the Act and this Policy.
1.3. By interacting with us, submitting information to us, or signing up for any products and/or services offered by us, you agree and consent to us as well as to our respective representatives and/or agents (“Representatives“) (collectively referred to herein as “HQV“, “us“, “we” or “our“) collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to our authorised service providers and relevant third parties in the manner set forth in this Policy.
1.4. This Policy supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your Personal Data, and your consents herein are additional to any rights which we may have at law to collect, use or disclose your Personal Data.
1.5. For the purposes of this Policy, in line with the provisions under the Singapore Personal Data Protection Act 2012 (No. 26 of 2012) (the “Act”), “Personal Data” shall mean data, whether true or not, about an individual User who can be identified — from that data; or from that data and other information which an organisation has or is likely to have access. Such Personal Data shall also refer to that which is already in our possession or that which shall be collected by us in future.
2.1. The purposes for which we collect your personal data is related to the provision of Brand Development & Marketing, Website Design & UI/UX, Technology, and Sales & Distribution services, such as but not limited to:
We also collect personal data for the purposes of marketing products and/or services which you may be interested in, monitoring the performance of our marketing effort, internal job training, and informing you of new developments and services of HQV and other third parties which we are associated with.
2.2. As the purposes for which we may/will collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of your personal data without your consent is permitted by the PDPA or by law.
3.1. In the course of engaging our services, we would have obtained your personal data either via phone, email, and website or in person; there may be occasions when we collect your personal data from a third party.
3.2. As part of its day-to-day activity, HQV may collect from you, through various means, including via our websites, marketing events (e.g. trade shows) and any forms used by HQV from time to time, some or all of the following Personal Data:
HQV retains Personal Data as needed to provide our products and/or services, respond to enquiries, comply with our legal obligations, and meet our regulatory agreements.
We will delete, as reasonably possible, or otherwise anonymise any Personal Data in the event that the Personal Data is not required for any reasonable business or legal purposes of HQV and where the Personal Data is deleted from HQV’s electronic, manual, and other filing systems it is in accordance with HQV’s internal procedures and/or other agreements.
We will not disclose, share, transfer, sell or rent any of your Personal Data to any third party. We do not send unsolicited marketing emails to our customers. We ensure all information is accurate and up-to-date, and only authorised staff have access to our systems.
6.1. We respect the confidentiality of the Personal Data you have provided to us. In that regard, we will not disclose your Personal Data to third parties without first obtaining your consent permitting us to do so. However, please note that we may disclose your Personal Data between our brands, subsidiaries, related corporations, affiliates and agents.
We will not disclose your Personal Data to other third parties without first obtaining your consent in certain situations, including, without limitation, the following:
6.2. Our Technology and Sales & Distribution businesses lines may require us to share specific Personal Data with our strategic partners that work with us to provide services.
6.3. For more information on exceptions, you are encouraged to peruse the Second, Third and Fourth Schedules of the PDPA which is publicly available at statutes.agc.gov.sg.
Where possible, HQV will validate data provided using generally accepted practices and guidelines. This includes the use of check sum verification on some numeric fields such as account numbers or credit card numbers. In some instances, HQV can validate the data provided against pre-existing data held by HQV. In some cases, HQV is required to see original documentation before we may use the Personal Data such as with Personal Identifiers and/or proof of address. To assist in ensuring the accuracy of your Personal Data in the possession of HQV, please inform us of any updates of any parts of your Personal Data by sending a clearly worded email to the Data Protection Officer at the email address provided at Section 14.2.
Your Personal Data may be processed by HQV, its subsidiaries, related corporations, affiliates, agents and third parties providing services to HQV, in jurisdictions outside of Singapore. In this event, HQV will comply with the terms of the Act.
You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control by submitting your request to the email address provided in Clause 14.2. We will process your request within a reasonable timeframe from such a request for withdrawal of consent being made, and will thereafter not collect, use and/or disclose your personal data in the manner stated in your request.
10.1. Google Analytics
Our website may contain web analytic services provided by Google Analytics. This means that when you visit our website, a cookie will be stored on your computer or mobile device, except when your browser settings do not allow for such cookies. Google Analytics acts as our agent, which means that we solely determine the purposes for which the data is being used.
10.2. Web Cookies
HQV uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your Personal Data and will not knowingly allow access to this data to anyone outside HQV, other than to you or as described in this Policy. However, HQV cannot ensure or warrant the security of any information you transmit to HQV and you do so entirely at your own risk. In particular, HQV does not warrant that such information may not be accessed, altered, collected, copied, destroyed, disposed of, disclosed or modified by breach of any of HQV’s physical, technical, or managerial safeguards.
We reserve the right to alter any of the clauses contained herein in compliance with local legislation, and for any other purpose deemed reasonably necessary by us. You should look at these terms regularly. If you do not agree to the modified terms, you should inform us as soon as possible of the terms to which you do not consent. Pending such notice, if there is any inconsistency between these terms and the additional terms, the additional terms will prevail to the extent of the inconsistency.
As part of our efforts to ensure that we properly manage, protect and process your personal data, we will review and update our policies, procedures and processes from time to time. You are encouraged to visit our website from time to time to ensure that you are well informed of our latest policies in relation to personal data protection.
To the extent that any of the communication means which you have provided HQV with (which may include, your telephone number) is/will be listed on the Do Not Call Registry (the “DNC”), by checking the box on the Consent Form, or by any other means of indication, you hereby grant HQV your clear and unambiguous consent to contact you using all of your communication means you have provided to HQV including using via voice calls, SMS, WhatsApp, MMS, fax or other similar communications applications or methods, for the purposes as stated above in Clause 2.1. This will ensure your continued enjoyment of HQV’s services.
14.1. Where you legitimately request access to and/or correction of Personal Data relating to you, such Personal Data which is in the possession and control of HQV, we shall provide and/or correct that data within thirty (30) days and in a manner in accordance with its standard procedures as stated hereinafter.
14.2. In accordance with the Act, HQV has established a process for receiving and responding to any query or complaint that may arise with respect to the application of this Act. To ensure that HQV receives your complaints and enquiries, and for the purpose of withdrawing your consent for the collection, use and/or disclosure of your Personal Data in our possession, please email to the Data Protection Officer (the “DPO”). We will process your enquiry or request within a reasonable timeframe.
14.3. Please note that if your Personal Data has been provided to us by a third party (e.g. a member via a referral process), you should contact that individual to make such queries, complaints, and access and correction requests to HQV on your behalf.
14.4. Should you not wish HQV to use your Personal Data for any of the purposes listed in Clause 2.1, or not to receive promotional materials from HQV, you may opt-out by sending a clearly worded email to the DPO via the email address provided in Clause 14.2. Your request shall be processed within thirty (30) days. Please note however that this may affect our ability to attend to your needs in the event where there is already an existing business relationship.
15.1 This Policy only applies to the collection and use of Personal Data by HQV. It does not cover third party sites to which we provide links, even if such sites are co-branded with our logo. HQV does not share your Personal Data with third party websites. HQV is not responsible for the privacy and conduct practices of these third party websites, so you should read their own privacy policies before disclosure of any Personal Data to these websites.
15.2 HQV will not sell your Personal Data to any third party without your permission, but we cannot be responsible or held liable for the actions of third party sites which you may have linked or been directed to HQV’s website.
15.3 HQV’s websites do not target and are not intended to attract children under the age of 18 years old. HQV does not knowingly solicit personal information from children under the age of 18 years old or send them requests for personal data.
This Policy is governed by and shall be construed in accordance with the laws of Singapore. You hereby submit to the non-exclusive jurisdiction of the Singapore courts.