1. PRIVACY STATEMENT

1.1 We, at Helmsman LLC, value your privacy and understand the importance of your personal data. This Privacy Statement explains how we collect, use, disclose and/or otherwise process the Personal Data (as defined below) you have provided to us.

1.2 If you, at any time, wish to:

1. Send us any enquiries or comments about this policy;
2. Send us any complaint about how we handle your Personal Data;
3. Withdraw any consent you have provided to us previously in relation to your Personal Data; or
4. Access or correct your Personal Data in our control or possession in accordance with your statutory rights under the Personal Data Protection Act 2012 of Singapore (“PDPA”),

You may contact our Data Protection Officer (the “DPO”) at dpo@helmsmanlaw.com.

2. THE PDPA

2.1 “Personal Data” is defined under the PDPA to mean data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organisation has or is likely to have access. Common examples of personal data would include an individual’s name, residential address, email address, telephone number, nationality, gender, date of birth, marital status, photograph, employment information and financial information.

2.2 We will collect your personal data in accordance with the PDPA. Subject to any specific data protection notice we may give to you and the terms and conditions of any contract which may be agreed between us, if you provide any Personal Data to us, whether directly or indirectly through another party, you agree and consent to our collection, use and disclosure of such data in accordance with this Privacy Statement.

3. PURPOSES

3.1 We may collect, use, disclose and/or process the Personal Data we collected from you for various purposes, including:

1. providing services to you;
2. verifying your identity;
3. managing your relationship with us;
4. complying with any applicable law, regulation, code of practice, guideline or rule, including complying with any request or direction made by any governmental authority, public agency, ministry, statutory board or other similar authority;
5. conducting research, analysis and development activities (such as web analytics, surveys and/or profiling) to improve our services and facilities;
6. storing, hosting, backing up (whether for disaster recovery or otherwise) of your Personal Data, whether within or outside Singapore;
7. responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
8. sending you information on any administrative changes, updates, modifications and/or amendments to our policies, terms and conditions;
9. organising seminars, events or other marketing / promotional activities;
10. providing you with our complimentary electronic publications and updates;
11. any other incidental business purposes related to or in connection with the above and/or
12. any other purposes which we notify you of at the time of obtaining your consent (unless processing of your Personal Data without your consent is permitted by the PDPA or by law).

(collectively, the “Purposes”).

3.2 To facilitate our business operations, we may also disclose the Personal Data you have provided to us to our third-party service providers, agents and/or our affiliates or related corporations, and/or other third parties whether sited in Singapore or outside of Singapore, for one or more of the Purposes. Such third parties may process your Personal Data either on our behalf or otherwise, for one or more of the Purposes. Where we disclose your Personal Data to third parties, we will employ our best efforts to require such third parties to ensure your personal data is safely protected.

4. WITHDRAWAL OF CONSENT

4.1 You may withdraw your consent for the collection, use and/or disclosure of your Personal Data in our possession or under our control at any time by submitting your request in writing to the DPO via the email address set out above.

4.2 We will process your request within a reasonable time from such a request for withdrawal of consent being made.

4.3 While we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our services to you and, in such circumstances, we shall notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing to the DPO via the email address set out above.

5. MANAGEMENT OF PERSONAL DATA

5.1 We will employ our best efforts to ensure that your Personal Data is protected and kept confidential. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as minimised collection of personal data, authentication and access controls (such as good password practices), up-to-date antivirus protection, regular patching of operating system and other software, and web security measures against risks. However, please be aware that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

5.2 We will also put in place measures such that your personal data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes.

5.3 We will take reasonable efforts to ensure that your Personal Data is accurate and complete, if your Personal Data is likely to be (i) used by us to make a decision that affects you, or (ii) disclosed to another organisation. However, it is your responsibility to update us of any changes in your Personal Data. We are not liable for relying on inaccurate or incomplete Personal Data resulting from your failure to update us of any changes in your Personal Data.

5.4 If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, please inform us in writing to the DPO via the email address set out above. 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 process your request within a reasonable time.

5.5 Where your Personal Data is to be transferred out of Singapore, we will comply with the PDPA in doing so. We will take appropriate steps to ascertain that the foreign recipient organisation of the Personal Data is bound by legally enforceable obligations to provide to the transferred Personal Data a standard of protection that is at least comparable to the protection under the Act.

6. UPDATES ON PRIVACY STATEMENT

6.1 To ensure that we properly manage, protect and process your Personal Data, we will, at our absolute discretion, periodically review, amend and update our policies, procedures and processes.

6.2 We will post our amended Privacy Statement on our website at https://www.helmsmanlaw.com/.

6.3 You are advised to visit the above website on a regular basis to ensure that you are well informed of our latest policies in relation to Personal Data protection.