Privacy and Data Protection Policy

Scope: Users of the Sabisuu platform
Last updated: 24 March 2021

1. Definitions
   1. “Sabisuu” refers to Sabisuu Pte. Ltd., its owners, members, managers, employees, directors, officers, agents, affiliates, Sabisuu Partners and/or licensors, collectively.
   2. “Entity” refers to any individual, company, organization or any other legal entity.
   3. “Platform” is defined as any platform created and maintained by Sabisuu, including websites and mobile applications, for Users to transact by receiving and providing services for a monetary value.
   4. “User” refers to any Entity accessing and using the Platform.
   5. “Customer” refers to any Entity using the Platform to purchase services.
   6. “Service Provider” refers to any Entity using the Platform to sell services.
   7. “Data” refers to information recorded by Sabisuu which can be stored electronically or physically.
   8. “Data Processors” include any person who processes Personal Data. This definition could include Service Providers which handle Customer’s Personal Data.
   9. “Personal Data” means any information relating to an individual who can be identified from that information. Such information is factual (such as a name, address or date of birth) or an opinion (such as ratings and reviews). Personal Data also include electronic mail addresses.
   10. “Processing” refers to the use of Data, including obtaining, recording, or holding the Data, or carrying out any operation on the Data including organising, amending, retrieving, using, disclosing, erasing or destroying it.
2. Preface

   At Sabisuu, we take our responsibilities under Singapore’s Personal Data Protection Act 2012 (“PDPA”) seriously. We also recognize the importance of the Personal Data you have entrusted to us. We understand our duty to manage, protect and process your Personal Data safely, and our commitment to protecting your privacy.

3. Purpose
   1. The purpose of this policy is to provide an understanding of how Personal Data is handled, collected, used, disclosed and processed.
   2. Users who provide Personal Data to Sabisuu through the Platform or otherwise, are deemed to have acknowledged and agreed to have fully read and understood this policy, and have consented to the collection, use, processing and disclosure of Personal Data as described in this policy.
   3. If Users provide the Personal Data of any other third-party to Sabisuu, Users agree that such third-party has fully read and understood this policy, and has consented to the submission of his/her Personal Data for processing as described in this policy.
   4. Policies in the field of privacy and data protection are subject to modification and further development in the light of experience. The Privacy and Data Protection Policy is subject to review and change by Sabisuu without notice.
   5. Distribution of Policy: The Privacy and Data Protection Policy will be available on the Platform, and is available on demand through electronic mail requests. Every User is responsible for familiarizing themselves with the information contained in this policy and any amendments.
   6. Establishing New or Revised Policy: The Privacy and Data Protection Policy may be abolished and recreated under a different named policy of similar nature, abolished and embedded in a separate policy document, or amended with revised terms of similar nature. Sabisuu reserves the right to the Privacy and Data Protection Policy, and registered Users will be informed of any new or revised policies via electronic mail.
4. Policy Statement
   1. Sabisuu collects information when Users access the Platform, submit forms or surveys, and/or other channels and throughout other interactions, communications and related services.
   2. Personal Data collected include but are not limited to:
      1. personal information such as User’s name, NRIC/FIN/Passport number, date of birth, gender;
      2. contact information such as postal addresses, email addresses, mobile phone and land numbers;
      3. past and present work information such as organisation name, job function and skill, designation, portfolio, credentials, testimonials, and business email addresses;
      4. professional qualifications and memberships with professional bodies; and/or
      5. billing and payment information, including bank account details, name of the credit/debit cardholder, credit/debit card number, security code and expiry date.
   3. Other information collected may include professional interest, details of complaints, disciplinary or criminal records, photographs, videos and/or audio recordings on the Platform.
   4. Personal Data will be collected in accordance with the PDPA.
   5. Sabisuu may collect and store certain information automatically when Users visit the Platform. Examples include the internet protocol (IP) address used to connect computers or devices to the Internet, connection information such as browser type and version, operating system and platform details, a unique reference number linked to the Data entered by Users on the Platform, login details, the full URL clickstream to, through and from the Platform (including date and time), cookie identifier and User activity on the Platform, including the pages visited, the searches made and the services purchased.
   6. Sabisuu may receive information from third-parties if Users access websites or social media platforms operated by third-parties (e.g. Facebook, Instagram etc.) and, if such functionality is available, Users have chosen to link Sabisuu profiles with the profiles on those third-party platforms.
5. Note on Cookies
   1. Sabisuu uses cookies to identify Users on The Platform.
   2. A cookie is a small file of letters and numbers that is stored on browsers or the hard drive of computers or devices.
   3. Cookies can be blocked or deactivated in browser settings.
   4. Sabisuu uses log-in cookies to remember Users who have already logged in successfully, for a seamless experience.
   5. Sabisuu uses session cookies to track User movements from page to page and in order to store selected inputs so Users are not constantly asked for the same information.
   6. By continuing to use the Platform, Users agree to the use of cookies on the site as outlined above. However, please note that Sabisuu has no control over the cookies used by third-parties.
   7. For further information on types of cookies and how they work, visit www.allaboutcookies.org.
6. Purposes for which the Personal Data is Collected, Used and Disclosed
   1. Sabisuu may process Personal Data for one or more of the following purposes:
      1. To process User registration and manage User accounts with Sabisuu;
      2. To facilitate, process, deal with and/or administer User’s transactions and User accounts with Sabisuu;
      3. To review and process requests for the verified badge as a Service Provider;
      4. To deal with, process and/or administer User’s transactions for and payments of any services on the Platform;
      5. For the administration of any services to Customers purchased from Service Providers on the Platform;
      6. For any dispute resolution measures of transactions between Customers and Service Providers on the Platform;
      7. To deal with, process and/or administer the use of the online services on the Platform and/or through other digital or telecommunication channels;
      8. For identification and verification purposes in connection with any of the services that may be supplied to Customers by Service Providers;
      9. To carry out User’s instructions, respond to any enquiry or deal with any feedback given by (or purported to be given by) Users or on behalf of, including contacting Users via phone/voice call, text message and electronic mail regarding instructions, enquiries and/or feedback;
      10. To conduct research, analysis and development activities (including but not limited to data analytics, surveys, focus groups and/or profiling) to improve Sabisuu’s services and facilities for Users’ benefit, or to improve any of our programmes or features;
      11. To deal with, process and/or administer contests and marketing initiatives conducted by Sabisuu or on our behalf which Users have participated in;
      12. To contact or communicate with Users via various modes of communication such as phone/voice call, text message, forms, and electronic mail for the purposes of administering, dealing with and/or managing User registration, User accounts, or any other applications (including applications for marketing initiatives) Users make with/through Sabisuu. Users acknowledge and agree that such communication by Sabisuu could involve disclosure of certain Personal Data about Users to bring about delivery of the same;
      13. To carry out due diligence or other screening activities (including security and background checks) in accordance with risk management procedures that may have been put in place by Sabisuu;
      14. To prevent or investigate any fraud, unlawful activity or omission or misconduct, whether or not there is any suspicion of the aforementioned; dealing with conflict of interests or dealing with and/or investigating complaints and disputes;
      15. To comply with or as required by any applicable law, governmental or regulatory requirements of any jurisdiction applicable to Sabisuu or our affiliates/associated companies, including meeting the requirements to make disclosure under the requirements of any law binding on Sabisuu or our affiliates/associated companies, and/or for the purposes of any guidelines issued by regulatory or other authorities (whether of Singapore or elsewhere), with which Sabisuu is expected to comply;
      16. To comply with or as required by any request or direction of any governmental authority; or respond to requests for information from hospitals, embassies, public agencies, ministries, statutory boards or other similar authorities (including but not limited to the Ministry of Defence, Ministry of Trade and Industry, Ministry of Education, Immigration and Checkpoints Authority, Ministry of Health, Ministry of Home Affairs, Ministry of Manpower, Ministry of Foreign Affairs, Ministry of Social & Family Development and Central Provident Fund Board);
      17. For marketing purposes where Sabisuu disseminates news, information, materials and/or updates about events, marketing campaigns, products and/or services provided. In this regard, Sabisuu will be doing so by way of electronic transmission to your email address(es). You may unsubscribe from this service in the manner set out in Clause 9 below;
      18. To facilitate and/or deal with payment for services provided by Sabisuu or Service Providers including verification of credit card details and additionally, using the Personal Data to conduct matching procedures against Databases of known fraudulent transactions (maintained by us or third-parties);
      19. To deal with, handle and/or conduct disciplinary, security and quality assurance processes, matters and/or arrangements. Without prejudice to the generality of the aforesaid, Sabisuu would like to emphasise that all information Users input on The Platform are stored for security reasons and Users acknowledge that Personal Data will be collected and processed by Sabisuu consequently;
      20. To perform internal administrative, operational and technology tasks to facilitate, administer or manage User registrations and accounts;
      21. To produce statistics and research for internal and/or statutory reporting and/or record-keeping requirements and performing Sabisuu policy/process reviews;
      22. To disclose to a third-party to comply with any law, legal requirements, orders, directions or requests from any court, authority or government body of any jurisdiction;
      23. To help Sabisuu improve services offered; and/or
      24. To store, host, back up (whether for disaster recovery or otherwise) of Personal Data, whether within or outside Singapore.
   2. Sabisuu may disclose Personal Data to third-parties, including to banks, payment service providers and/or other payment gateways, whether located within or outside Singapore, for one or more of the above Purposes, as such third-parties would be processing Personal Data for one or more of the above Purposes. In this regard, Users hereby acknowledge, agree and consent that Sabisuu is permitted to disclose Personal Data to such third-parties (whether located within or outside Singapore) for one or more of the above Purposes and for the said third-parties to subsequently collect, use, disclose and/or process Personal Data for or more of the above Purposes. Without limiting the generality of the foregoing, such third-parties include:
      1. any of Sabisuu’s collaborative partners, registered Service Providers or third-party Service Providers that process or will be processing Personal Data including but not limited to those which provide administrative or other services to Sabisuu such as telecommunication companies, registered Service Providers, information technology companies and Data centres; and
      2. third-parties to whom disclosure by Sabisuu is for one or more of the Purposes and such third-parties would in turn be collecting and processing Personal Data for one or more of the Purposes.
   3. Users may withdraw consent for the collection, use and/or disclosure of Personal Data in Sabisuu’s possession or under Sabisuu’s control by contacting our Data Protection Officer. However, User’s withdrawal of consent could result in certain legal consequences arising from such withdrawal, including Sabisuu being unable to perform the transactions requested by Users on the Platform. Do note that Users’ withdrawal of consent will not affect Sabisuu’s ability to collect, use or disclose Personal Data for a specific purpose without Users’ consent, if the PDPA or a provision in applicable law permits us to.
   4. Sabisuu may collect, use, disclose or process Users’ Personal Data for other purposes that do not appear above. However, Sabisuu will provide notifications of such other purposes at the time of obtaining consent, unless processing of Personal Data without consent is permitted by the PDPA or by law.
   5. Sabisuu may also be collecting from sources other than Users, Personal Data for one or more of the above Purposes, and thereafter using, disclosing and/or processing such Personal Data for one or more of the above Purposes. Sabisuu may combine information received from other sources with information Users provided and information collected about Users. Sabisuu may use this information and the combined information for the Purposes set out above (depending on the types of information received).
7. Storage of Personal Data
   1. Security of Personal Data is important to Sabisuu. Appropriate action is taken to protect Personal Data from loss, misuse, unauthorised access or disclosure, alteration or destruction using the same safeguards as used for Sabisuu’s own proprietary information. All information provided to Sabisuu is stored on secure servers and any payment transactions will be encrypted using SSL technology . Any passwords issued by Sabisuu or created by Users for the purpose of accessing certain parts of the Platform, Users are responsible for keeping passwords confidential. Sabisuu advises against sharing of passwords.
   2. Sabisuu will put in place measures such that Personal Data in Sabisuu’s possession or under Sabisuu’s control is destroyed and/or anonymized as soon as it is reasonable to assume that (a) the purpose for which that Personal Data was collected is no longer being served by the retention of such Personal Data; and (b) retention is no longer necessary for any other legal or business purposes.
8. Link to other websites

   The Platform and any other Sabisuu’s digital and telecommunication channels may contain links to other sites that are operated by third-party companies with different privacy practices. Users should remain alert and read the privacy statements of other sites. Sabisuu has no control over Personal Data that Users submit to or receive from these third-parties.

9. Withdrawal of Consent for Marketing Purposes

   Users have the right to ask Sabisuu not to use Personal Data for marketing purposes. If Users no longer wish to receive marketing messages from Sabisuu, requests for withdrawal of consent can be done by submitting the Withdrawal of Consent Form .

10. Data Access and Correction
    1. Users have the right to access and/or correct any Personal Data that Sabisuu holds, subject to the requirements of the PDPA. If Users would like to request for a copy of the Personal Data being held by Sabisuu, or to update and/or correct the Personal Data which was previously provided to Sabisuu, please write to [email protected] .
    2. Sabisuu will need enough information from Users in order to ascertain the User’s identity as well as the nature of the request, so as to be able to deal with the request. Sabisuu reserves the right, or may, charge a reasonable fee for the processing of any Data access request.
    3. For a request to access Personal Data, once Sabisuu has sufficient information from Users to deal with the request, Sabisuu will seek to provide Users with the relevant Personal Data within 30 days. Where Sabisuu is unable to respond to Users within the said 30 days, Sabisuu will notify Users of the soonest possible time within which the requested information can be provided.
    4. For a request to correct Personal Data, once Sabisuu has sufficient information from Users to deal with the request, Personal Data will be corrected within 30 days. Where Sabisuu is unable to do so within the said 30 days, Users will be notified of the soonest practicable time within which Sabisuu can make the correction. Note that the PDPA exempts certain types of Personal Data from being subject to correction requests as well as provides for situation(s) when corrections need not be made despite requests. Sabisuu will make use of the corrected Personal Data upon successful updates in the Sabisuu system, which may differ from the date and time when a request to correct Personal Data was submitted.
    5. Users agree and acknowledge that they are responsible for ensuring the accuracy of Personal Data. Users may also access and correct Personal Data with their existing Usernames and passwords on the Platform.
11. Complaint Process
    1. If Users have any complaint or grievance regarding how Sabisuu handles Personal Data or about how Sabisuu complies with the PDPA, Users are welcomed to contact us by writing to [email protected].
    2. Where Users are sending an email to submit a complaint, please indicate at the subject header that it is a PDPA complaint. This would assist Sabisuu in attending to the complaint speedily.
    3. Sabisuu will certainly strive to deal with any complaint or grievance that Users may have efficiently and fairly.
12. General
    1. Users’ consent that is given pursuant to this Privacy Policy is additional to and does not supersede any other consents that was provided to Sabisuu with regard to processing of Personal Data.
    2. For the avoidance of doubt, in the event that Singapore Personal Data protection law permits an organisation to collect, use or disclose Personal Data without Users’ consent, such permission granted by the law shall continue to apply.
13. Enquiries

    For any enquiries on our Privacy and Data Protection Policy, please write to [email protected].