DATA PROTECTION POLICY
This document (“Data Protection Policy”) explains how your personal data is collected and used by the Prad Pte Ltd of Singapore (referred to herein as “PRAD”, “us”, “we” or “our”) and also details your statutory rights. Our contact details are set out below.
PRAD may from time to time update this Data Protection Policy to ensure that it is consistent with our future developments, industry trends, and/or any changes in legal or regulatory requirements. Accordingly, we may update this Data Protection Policy via our website https://www.pradpteltd.com/data-protection-policy and we will communicate any significant changes to you.
In certain circumstances, and pursuant to the data protection laws of Singapore, by interacting with us, submitting information to us, or signing up for any products and services offered by us, you agree and consent to PRAD, as well as our respective representatives and/or agents collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to PRAD’s authorised service providers and relevant third parties in the manner set forth in this Data Protection Policy.
If you have any questions about this Data Protection Policy or our privacy practices, please contact us by email at pradpteltd@gmail.com.
You have the right to make a complaint at any time to the relevant data protection supervisory authority, such as the Personal Data Protection Commission Singapore, for data protection issues. We would, however, hope to deal with any such concerns before you approach these bodies.
1. Personal Data
1.1 We may process different kinds of personal data as follows:
- Identity data includes first name, last name, NRIC, passport, Advocates and Solicitors of the Singapore Bar number or other identification number, job title, name of your organisation;
- Contact data includes telephone number(s), mailing address and email address;
- Details of the events you want to attend or have attended;
- Images of you participating in events; and
- Images on our CCTV systems; and
- Any other information relating to any individuals which you have provided in any forms you may have submitted to us, or via other forms of interaction with you.
1.2 Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a service you have with us, but we will notify you if this is the case at the time.
2. Collection of personal data
2.1 Generally, we collect personal data in the following ways:
- when you submit an application form or registration form, or other forms relating to any of our products and services;
- when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our services;
- when you interact with our customer service officers, for example, via telephone calls, letters, face-to-face meetings, social media platforms and emails;
- when you use our electronic services, or interact with us via any of our websites or use services on any of our websites;
- when you request that we contact you or request that you be included in an email or other mailing list;
- when you respond to our promotions, initiatives or to any request for additional personal data;
- when your images are captured by us via CCTV cameras while you are within our premises, or via photographs or videos taken by us or our representatives when you attend events at our premises;
- when you are contacted by, and respond to, our marketing representatives and customer service officers;
- when we receive references from business partners and third parties, for example, where you have been referred by them;
- when you fill up surveys administered by our third party surveying service providers;
- when we seek information from third parties about you in connection with the products and services you have applied for; and/or
- when you submit your personal data to us for any other reason.
2.2 In addition, we may also collect personal data from third parties, including third party event partners who, in turn, collect personal data from you. Event partners organise and facilitate programmes, courses and events, or otherwise offer products and services that are complimentary to those offered by PRAD . These third party event partners must provide you with privacy information at the time your personal data is collected by them.
2.3 When you browse our websites, or use our applications and/or digital services, you generally do so anonymously but please see the section below on cookies. We do not, at our websites, applications and digital services, automatically collect personal data unless you provide such information or login with your account credentials.
2.4 If you provide us with any personal data relating to a third party (e.g., information of your spouse, and/or employees), by submitting such information to us, you confirm to us that you have obtained the consent of the third party to provide us with their personal data for the respective purposes.
2.5 If you provide us with any personal data relating to a minor who is less than 13 years of age, by submitting such information to us, you confirm that you are legally able to consent on their behalf to provide us with their personal data for the respective purposes.
2.6 You should ensure that all personal data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with the products and services you have requested.
3. Purposes for the Collection, Use and Disclosure of Your Personal Data
3.1 We have set out below, in the table format, a description of all the ways in which we may use your personal data, and the legal basis we rely on to do so.
3.2 Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one basis has been set out in the table below.
| S/N | Purpose/Activity | Type of Data | Lawful basis for processing including, if applicable, basis of legitimate interest |
| a. | To respond to your queries, feedback, complaints, and requests | All of the personal data we collect (apart from CCTV data) | a. Necessary for our legitimate interests (resolution of queries, feedback, complaints, and requests, and developing our products and services based on your use of them and any feedback) |
| b. | Verifying your identity | All of the personal data we collect | a. Necessary for our legitimate interests (preventing identity fraud, protecting privacy and security) |
| c. | Managing the administrative and business operations of PRAD and complying with internal policies and procedures | All of the personal data we collect |
a. Necessary to comply with a legal obligation (for internal and statutory audits) b. Necessary for our legitimate interests (for the efficient running of PRAD , including compliance with policies and procedures and provision of administration and IT services) |
| d. | Facilitating business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving PRAD | All of the personal data we collect | a. Necessary for our legitimate interests (facilitating business reorganisation or group restructuring) |
| e. | Matching any personal data held which relates to you. For example, if you register for Event A, then subsequently register for Event B with updated personal details, we may use the information given in relation to Event B to update your profile in respect of Event A. | All of the personal data we collect (apart from CCTV data) | a. Necessary for our legitimate interests (to ensure that the personal data we hold is accurate and up to date, and to improve the provision of services) |
| f. | Requesting feedback or participation in surveys, as well as conducting market research and/or analysis for statistical, profiling, or other purposes | All of the personal data we collect (apart from CCTV data and images of you participating in events) |
a. Necessary for our legitimate interests (to review, develop and improve the quality of our products and services) b. Your consent |
| g. | Preventing, detecting and investigating crime and analysing and managing commercial risks | All of the personal data we collect |
a. Necessary to comply with a legal obligation (preventing crime, protecting privacy) b. Necessary for our legitimate interests (managing commercial risks) |
| h. | Facilities management (including but not limited to maintaining the security of our premises) | CCTV data |
a. Necessary to comply with a legal obligation (health and safety) b. Necessary for our legitimate interests (security, health and safety and provision of services) |
| i. | Managing the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances) | CCTV data |
a. Necessary to comply with a legal obligation (preventing crime, protecting privacy, health and safety) b. Necessary for our legitimate interests (preventing crime, protecting privacy, security and health and safety) |
| j. | Monitoring or recording phone calls and customer-facing interactions | All of the personal data we collect (apart from images of you participating in events) |
a. Necessary for our legitimate interests (quality assurance, employee training purposes and performance evaluation, and identity verification purposes) |
| k. | In connection with any claims, actions or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution), and/or protecting and enforcing our contractual and legal rights and obligations | All of the personal data we collect |
a. Necessary to comply with a legal obligation (protecting and enforcing our contractual and legal rights and obligations) b. Necessary for our legitimate interests (protecting and enforcing our contractual and legal rights and obligations) |
| l. | Conducting investigations relating to disputes, billing or fraud | All of the personal data we collect |
a. Necessary to comply with a legal obligation (fraud and prevention of crime) b. Necessary for our legitimate interests (resolving issues related to disputes, billing or fraud, and prevention of crime) |
| m. | Meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on PRAD(including but not limited to responding to regulatory complaints, disclosing to regulatory bodies and conducting audit checks, due diligence and investigations) | All of the personal data we collect |
a. Necessary to comply with a legal obligation (complying with legal obligations and applicable codes of practice and/or guidelines) b. Necessary for our legitimate interests (complying with legal obligations and applicable codes of practice and/or guidelines) |
3.3 If you are an existing or prospective participant (including an invited speaker or lecturer) of our courses, events and programmes, we may also use your personal data as follows:
| S/N | Purpose/Activity | Type of Data | Lawful basis for processing including, if applicable, basis of legitimate interest |
| a. | Assessing and processing any applications or requests made by you for any courses, events and programmes offered by us | All of the personal data we collect (apart from CCTV data and images of you participating in events) |
a. Necessary for our legitimate interests (attendance at our events) b. Your consent |
| b. | Creating and maintaining your profile in our system database for internal records and reference | All of the personal data we collect (apart from CCTV data and images of you participating in events) | a. Necessary for our legitimate interests (keeping our records up to date, working out which products and services you use and may be of interest to you) |
| c. | Providing customer service and support | All of the personal data we collect (apart from CCTV data and images of you participating in events) | a. Necessary for our legitimate interests (customer service and support, resolving service issues and queries) |
| d. | Administering debt recovery and debt management | All of the personal data we collect (apart from CCTV data and images of you participating in events) | a. Necessary for our legitimate interests (to recover any debts due to us) |
| e. | Facilitating your use of our online portals | All of the personal data we collect (apart from CCTV data and images of you participating in events) | a. Necessary for our legitimate interests (efficient use of our online portals) |
| f. | Taking photograph(s) and/or video(s) of you for (i) internal dissemination within PRAD and (ii) generating publicity materials for our courses, events and programmes | Images of you participating in events | a. Necessary for our legitimate interests (promotion of our activities and training purposes) |
| g. | Facilitating and providing opportunities for business networking between yourself and other existing or prospective (including invited speakers or lecturers) of our courses, events and programmes | All of the personal data we collect (apart from CCTV data and images of you participating in events) | a. Your consent |
| h. | Administering and conducting information sessions, courses, events and programmes (including facilitating registration, recording attendance, processing payment for courses, conducting tests and examinations, event budgeting and contacting you for administrative purposes) | All of the personal data we collect |
a. Necessary for our legitimate interests (attendance at our events) b. Your consent |
| i. | Where a course, event or programme is being held by a third-party event partner, transferring your data to that third-party event partner | All of the personal data we collect (apart from CCTV data and images of you participating in events) | b. Necessary for our legitimate interests (attendance at events) |
| j. | Where you have registered for, or expressed an interest in a course, event or programme, we may process your data as described in paragraph 3.6 below to provide information about similar products or services which may be of interest to you. | All of the personal data we collect (apart from CCTV data and images of you participating in events) |
a. Your consent b. Necessary for our legitimate interests (marketing and promotion of similar events, courses, or programmes) |
| k. | Where you have registered for, or expressed an interest in a course, event or programme, transferring your data to a third party event partner so that the third party event partner can offer you similar products or services which may be of interest to you. | All of the personal data we collect (apart from CCTV data and images of you participating in events) |
a. Your consent b. Necessary for our legitimate interests (marketing and promotion of similar events, courses, or programmes) |
| l. | Facilitating your applications to other educational institutions which you may apply to | All of the personal data we collect (apart from CCTV data and images of you participating in events) |
a. Necessary for our legitimate interests (facilitating the processing of your applications to other educational institutions) b. Your consent |
| m. | Maintaining an alumni network and organising alumni activities such as information sessions and talks | All of the personal data we collect (apart from CCTV data and images of you participating in events) |
a. Necessary for our legitimate interests (maintaining an alumni network and participation in alumni network) b. Your consent |
| n. | Administering continuing professional development points | All of the personal data we collect (apart from CCTV data and images of you participating in events) |
a. Necessary for our legitimate interests (to administer points to you under the continued professional development scheme introduced for advocates and solicitors of the Singapore Bar, and to aid education and your continued professional development) b. Your consent |
3.4 If you are required to take examinations and tests administered by PRAD , including the IP Knowledge Test (for example if you are an employee of PRAD ), we may also use your personal data as follows:
| S/N | Purpose/Activity | Type of Data | Lawful basis for processing including, if applicable, basis of legitimate interest |
| a. | Administering the relevant examinations and tests | All of the personal data we collect (apart from CCTV data and images of you participating in events) |
a.Performance of a contract with you b. Necessary for our legitimate interests (facilitating and administering the test) c. Your consent |
| b. | Notifying you of test details and updates | All of the personal data we collect (apart from CCTV data and images of you participating in events) |
a. Performance of a contract with you b. Necessary for our legitimate interests (facilitating and administering the test) c. Your consent |
3.5 If you have submitted any applications to PRAD and/or PRAD ’ registries, we may also use your personal data as follows:
| Purpose/Activity | Type of Data | Lawful basis for processing including, if applicable, basis of legitimate interest |
| Conducting research and surveys on behalf of PRAD | All of the personal data we collect (apart from CCTV data and images of you participating in events) |
a. Necessary for our legitimate interests (to evaluate our products and services, to improve products and services) b. Your consent |
3.6 Furthermore, where you have provided your consent to PRAD separately, or in connection with our legitimate interests, PRAD may also process all types of personal data we collect (other than CCTV data) for the following additional purposes:
- providing or marketing services, products and benefits to you, including but not limited to special events and promotions from PRAD ;
- 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 products and services by PRAD ;
- administering and organising contests, lucky draws, promotional events, competitions and marketing campaigns, and personalising your experience at PRAD’s touchpoints;
- conducting market research, analytics and surveys to enable PRAD to understand and determine customer preferences and demographics for us to offer you products and services as well as special offers and marketing programmes which may be relevant to your preferences and profile; and/or
- any other purpose reasonably related to the above.
3.7 Where we rely on consent as the lawful basis for processing your personal data, you have the right to withdraw consent at any time by contacting us.
3.8 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), then from time to time, the PRAD may continue to contact you using such Singapore telephone number(s) (including via voice calls, text, fax, or other means) with information about our products and services, unless you have withdrawn your consent.
4. Disclosure of personal data
4.1 PRAD will take reasonable steps to protect your personal
data against unauthorised disclosure.
4.2 In order to operate our business, we may disclose your
personal data to the following third parties:
- PRAD
International Pte. Ltd. (“PRAD International”); - agents,
contractors or third party service providers who provide operational
services to PRAD, such as courier services, telecommunications,
information technology, payment, printing, billing, payroll, processing,
technical services, training, market research, call centre, security,
employee recognition or other services to PRAD; - agents,
contractors or third party service providers (including but not limited to
external tutors and lecturers) who provide services in connection with the
courses, programmes and events organised, conducted and administered by PRAD; - any
business partner, investor, assignee or transferee (actual or prospective)
to facilitate business asset transactions (which may extend to any merger,
acquisition or asset sale) involving PRAD; - external
banks, credit card companies and their respective service providers; - our
professional advisers such as consultants, auditors and lawyers; - relevant
government ministries, 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/or - any
other party whom you authorise us to disclose your personal data to.
4.3 In addition, where you have registered for a course,
event or programme, we may also disclose your personal data to:
- other
existing or prospective participants (including invited speakers or
lecturers) of our courses, events and programmes; and - our
event partners, other partners or collaborators in our courses, events and
programmes (including but not limited to the National University of
Singapore) for the purposes of facilitating the course, event or programme
(in the instance where such is being held by an event partner) or to allow
these event partners other partners or collaborators to inform you of
other similar products and services which may be of interest to you. Our
event partners, other partners and collaborators change frequently. If you
would like to see a full list of our current event partners, other
partners and collaborators, please contact us at pradpteltd@gmail.com
5. Use of Cookies
5.1 A cookie is a small piece of information that is placed on your computer when you visit certain websites. The cookies placed by the servers hosting our websites are readable only by us, and cookies cannot access, read or modify any other data on an electric device, nor does it capture any data which allows us to identify you individually. All web-browsers offer the option to refuse any cookie, and if you refuse our cookie then we do not gather any information on that visitor.
5.2 Should you wish to disable the cookies associated with these browsers, you may do so by changing the setting on your browser. However, you may not be able to enter certain part(s) of our websites.
6. Data Security
6.1 You should be aware of the risks associated with using websites, applications, and digital services.
6.2 We urge you to take every precaution to protect your personal data when you are on the Internet, when you browse our websites, or use our applications and/or digital services. We recommend that you change your passwords often, use a combination of letters and numbers, and ensure that you use a secure browser.
6.3 If applicable, you undertake to keep your username and password secure and confidential and shall not disclose or permit it to be disclosed to any unauthorised person, and to inform us as soon as reasonably practicable if you know or suspect that someone else knows your username and password or believe the confidentiality of your username and password has been lost, stolen or compromised in any way or that actual or possible unauthorised transactions have taken place. Where you have failed to keep your username and password secure and confidential, or where you have disclosed or permitted it to be disclosed to any unauthorised person, we will not be liable for any damages resulting from any security breaches following the unauthorised and/or fraudulent use of your username and password.
7. International Transfers
7.1 While we are based in Singapore, our external third parties, may be based outside Singapore so the processing of your personal data may involve processing of personal data outside Singapore.
7.2 Whenever we transfer your personal data to third parties who are located outside of Singapore, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
- We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; or
- Where we use certain service providers, we use specific contracts which give personal data the same standard of protection that is required in accordance with data protection obligations applicable to us.
7.3 Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of Singapore.
8. Data Retention
8.1 We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, accounting, or reporting requirements.
8.2 To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
8.3 In some circumstances, you can ask us to delete your personal data. Please see paragraph 9.1 for further information.
9. Your rights
9.1 In certain circumstances, you have the right under data
protection laws to:
- Request
access to your personal data; - Request
correction of your personal data; - Request
erasure of your personal data; - Object
to processing of your personal data; - Request
restriction of processing your personal data; and - Request
transfer of your personal data
9.2 Please contact us if you wish to exercise any of these
rights.
9.3 We may need to request specific information from you to
help us confirm your identity and ensure your right to access your personal
data (or to exercise any of your other rights). This is a security measure to
ensure that personal data is not disclosed to any person who has no right to
receive it. We may also contact you to ask you for further information in
relation to your request to speed up our response.
10. Contacting Us – Feedback, Withdrawal of Consent, Access
and Correction of your Personal Data
10.1 If you:
- have
any questions or feedback relating to your personal data or our Data
Protection Policy; - would
like to withdraw your consent to any use of your personal data as set out
in this Data Protection Policy; or - would
like more information on or access and make corrections to your personal
data records, you can contact our customer service officer at pradpteltd@gmail.com
11. Governing Law
11.1 This Data Protection Policy, your browsing of our
websites, and use of our applications and/or digital services shall be governed
in all respects by the laws of Singapore.