This Privacy Policy (the “Policy”) applies to the collection, use and disclosure of an individual customer’s Personal Data (hereinafter defined) arising from services offered by Frontier Executive Search (referred to as “Frontier”).
| 1 | General |
| 1.1 | This Policy statement provides information on the obligations and policies of Frontier in respect of an individual customer’s Personal Data. Frontier undertakes to use reasonable efforts in applying, where practicable, those principles and the processes set out herein to its operations. |
| 1.2 | Frontier shall use reasonable endeavours to respect the confidentiality of and keep safe any and all Personal Data collected and/or stored and/or disclosed. Frontier shall use reasonable endeavours to ensure that all collection and/or storage and/or disclosure and/or usage of Personal Data 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 or services offered by us, you agree and consent to Frontier collecting, using, disclosing and sharing your Personal Data, and disclosing such Personal Data to Frontier’s authorised service providers and relevant third parties in the manner set forth in this Privacy Statement. |
| 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 customer 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 the possession of Frontier or that which shall be collected by Frontier in future. |
| 2 | Contacting the Data Protection Officer |
| 2.1 | 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 Frontier, Frontier shall provide and/or correct that data within 30 days and in a manner in accordance with its standard procedures as stated hereinafter. |
| 2.2 | In accordance with the Act, Frontier 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 Frontier receives your complaints and enquiries, please send the same via email to the Data Protection Officer (the “DPO”) of Frontier at the following email address: msng@frontierexec.com |
| 2.3 | 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 Frontier on your behalf. |
| 2.4 | Should you not wish Frontier to use your Personal Data for any of the purposes listed in Clauses 3.2 to 3.4, or not to receive promotional materials from Frontier, you may opt out by sending a clearly worded email to the DPO via the email address provided in Clause 2.2. Your request shall be processed within 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. |
| 3 | Statement of Practices |
| Types of Personal Data Collected: | |
| 3.1 | As part of its day-to-day activity, Frontier may collect from you, through various means, including via our websites, social networking sites and any forms used by Frontier from time to time, some or all of the following Personal Data: |
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| Purpose of Collection of Personal Data | |
| 3.2 | The above Personal Data mentioned in Clause 3.1 is collected for the purposes of:, amongst others, conducting data/market research, analysis and evaluation, providing benefits and/or compensation, processing payment, providing you with any goods and/or services, marketing and communication, delivery of products and services, accounting and auditing, investigating complaints, claims and disputes, responding to inquiries and provide customer services, as well as verification of identity of clients. |
| Disclosure of Personal Data | |
| 3.3 | Frontier may disclose the data subject’s Personal Data to third parties such as accounting firms; embassies; service providers; lawyers; credit, debit and charge card companies, banks and other entities processing payment; |
| 3.4 | Frontier may disclose your Personal Data to the abovementioned parties also in the occurrence of any of the following events: |
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| 4 | Accuracy of Personal Data |
| Where possible, Frontier 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. In some cases, Frontier 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 Frontier, please inform us of any updates of any parts of your Personal Data by sending a clearly worded email to the DPO at the email address provided at Section 2.2. | |
| 5 | Protection of Personal Data |
| Frontier 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 Frontier, other than to you or as described in this Policy. However, Frontier cannot ensure or warrant the security of any information you transmit to Frontier and you do so entirely at your own risk. In particular, Frontier does not warrant that such information may not be accessed, altered, collected, copied, destroyed, disposed of, disclosed or modified by breach of any of Frontier’s physical, technical, or managerial safeguards. | |
| 6 | Access and Correction of Personal Data |
| 6.1 | In accordance with Clause 2.1 of this Policy, you have the right to: a) check whether Frontier holds any Personal Data relating to you and, if so, obtain copies of such data; and b) require Frontier to correct any Personal Data relating to you which is inaccurate for the purpose for which it is being used. |
| 7 | Storage and Retention of Personal Data |
| Frontier will delete, as reasonably possible, or otherwise anonymous any Personal Data in the event that the Personal Data is not required for any reasonable business or legal purposes of Frontier and where the Personal Data is deleted from Frontier’s electronic, manual, and other filing systems in accordance with Frontier’s internal procedures and/or other agreements. | |
| 8 | Contacting you |
| To the extent that any of the communication means which you have provided Frontier with (which may include, your telephone number and fax number) is/will be listed on the Do Not Call Registry (the “DNC”), by indicating on the Booking Form, or by any other means of indication, you hereby grant Frontier your clear and unambiguous consent to contact you using all of your communication means you have provided to Frontier including using via voice calls, SMS, Whatsapp, MMS, fax or other similar communications applications or methods, for the purposes as stated above in Paragraph 3.2. This will ensure your continued enjoyment of Frontier’s services | |
| 9 | Change Policy |
| Frontier reserves the right to alter any of the clauses contained herein in compliance with local legislation, and for any other purpose deemed reasonably necessary by Frontier. 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. | |
| 10 | Governing Law |
| 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. | |