Updated as of 7th September 2023
In this policy, “we”, “us”, “our” or “RPH” means Roxy-Pacific Holdings Pte Ltd and/or its subsidiary and affiliated companies (including associated companies that are managed by RPH), “you”, “your” or “yours” means the persons to whom this policy applies. “Personal Data” has the same meaning as that defined in the Personal Data Protection Act 2012 (the “PDPA”).
Your personal data privacy is important to us, and we are committed to protecting and managing your Personal Data in a responsible manner in line with this Policy.
We may collect, use, and disclose the following data about you:
We may collect the following kinds of Personal Data through the different channels mentioned above:
Additionally, if you are applying for employment with RPH, RPH will collect the following:
We may use the information we collect from you for any of the following purposes:
We may also contact you by any means of communication for which you have given us contact details, including but not limited to via email, telephone numbers, and post, for the purpose of getting your feedback or for providing you with information which we believe could be of interest to you or your organisation.
By your submission of your Personal Data to us, you consent to the onward disclosure of your Personal Data to these agents or service providers (as set out in no.3 of “What purposes does RPH collect, use and disclose personal data?”) and the processing of your Personal Data by these agents or service providers.
We only collect, process, use or disclose such Personal Data, in accordance with this policy. If you are acting as an intermediary, or otherwise on behalf of a third party, or supply us with information regarding a third party, you undertake that you are an authorised representative or agent of such third party and that you have obtained consent from such third party to our collection, processing, use and disclosure of their Personal Data. Because we are collecting the third party’s data from you, you undertake to make the third party aware of all matters listed in this policy by referring them to our agencies’ website.
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 and usage of your personal data for those purposes, or
(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 not been notified to you (except where permitted or authorised by law).
Deemed Consent by Notification.
We may collect or use your personal data or disclose existing personal data for secondary purposes that differ from the primary purpose which it had originally collected for. If RPH intends to rely on deemed consent by notification for such secondary purposes, RPH will notify you of the proposed collection, use or disclosure of his personal data through appropriate mode(s) of communication.
Before relying on deemed consent by notification, RPH will assess and determine that the collection, use and disclosure of the personal data will not likely have an adverse effect on you. You will be given a reasonable period to inform us if you wish to opt-out of the collection, use and disclosure of your personal data for such purposes.
After the lapse of the opt-out period, you may notify us that you no longer wish to consent to the purposes for which your consent was deemed by notification by withdrawing your consent for the collection, use or disclosure of your personal data in relation to those purposes.
Reliance on Legitimate Interests Exception
In compliance with the PDPA, we may collect, use, or disclose your personal data without your consent for the legitimate interests of RPH or another person. In relying on the legitimate interests exception of the PDPA, RPH will assess the likely adverse effects on the individual and determine that the legitimate interests outweigh any adverse effect.
In line with the legitimate interests’ exception, we will collect, use, or disclose your personal data for the following purposes:
The purposes listed in the above clause 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.
Withdrawal of Consent
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 RPH’s Data Protection Officer (“DPO”) at DPO@roxypacific.com.sg.
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.
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 able 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 or via email to our DPO at DPO@roxypacific.com.sg 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.
We may disclose your Personal Data to any member of our group, which means our subsidiaries, our ultimate holding company, and its subsidiaries, as defined in the Companies Act (Cap. 50).
We may also disclose your Personal Data to third party agents and service providers whom we engage to assist us in the processing of your Personal Data as outlined under "What purposes does RPH Collect, Use and Disclose Personal Data
RPH generally do not transfer Personal Data outside Singapore but if we do, we will take steps to ensure that the Personal Data will be accorded a level of protection which is comparable to the protection under the PDPA.
We will cease to retain Personal Data, as soon as it is reasonable to assume that the purpose for collection of such personal data is no longer being served by such retention, and such retention is no longer necessary for legal or business purposes.
When you visit any of RPH’s websites, RPH may collect or analyse anonymized information from which individual information will not be identified. The information collected may include your IP address, the website from which you visit us, the number of users and the amount of time you stay on our website, which countries you are from, and what mode of device you are currently using to view our website, as well as domain information that helps us to learn our client’s profile, the frequency of viewing. We use this information to improve our website’s content and navigation.
Note that our cookies do not have an expiration date and do not collect personally identifiable information.
The Personal Data that we hold about you may be stored on local servers located at RPH’s Singapore office as well as back up hosted on an offsite location in Singapore or overseas. RPH implements a variety of security measures to maintain the safety of your submitted information. All electronic storage and transmission of personal data is secured and stored on managed servers with controlled access and appropriate security technologies.
Although every reasonable effort has been made to ensure that all personal data will be so protected, RPH cannot be responsible for any unauthorised use or misuse of such information and from risks which are inherent in all internet communications.
Your Personal Data will only be disclosed for the express purpose of delivering the product or service requested and shall not be sold or disclosed to any other company for any other reason whatsoever without your consent.
Please contact us via DPO@roxypacific.com.sg should you wish to have access to or seek to correct your Personal Data. Your email should identify yourself and state which Personal Data and information about its use and/or disclosure is requested. 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.
We will respond to your request as soon as reasonably possible. 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).
RPH reserves the right to change this Policy with or without notice from time to time and will make the updated statement available on our website.