1. Personal Data
1.1. “Personal Data” refers to any data, whether true or not, about an individual who can be identified from that data; or from that data and other information to which the PDG Group has or is likely to have access to, including existing data in our records which you have provided us, in any submissions you may have made to us or via any form of interaction with us.
1.2. Examples of Personal Data include, but are not limited to, the following:
(d) telephone number,
(e) birth date,
(f) photograph, image, picture, recording, film footage, likeness or other characteristics or identification, or such other medium in which your likeness may appear,
(g) credit card number/bank details, and/or
(h) other non-public information such as your IP or device MAC ID Address.
2. How we Collect Personal Data
2.1. We may collect, use, disclose and/or process Personal Data about you when you make any submissions via our Website, or in the course of providing us with information in order for us to render our Services to you or for the purposes of any actual or potential transaction with us. The purposes for which we may collect, use, disclose and/or process such Personal Data are set out below at paragraph 3.
2.2. Our service providers also mass aggregate client data as part of their general business practices. Such aggregated data is used to identify and analyze trends to improve our systems and to create derivative materials that may be marketed to potential clients and used to service current clients; it does not contain your Personal Data.
2.3. We also may supplement the information we collect with information from other sources to assist us in providing our Services to you. In addition, we may use this supplemental information in evaluating and improving our Website or Services and to determine your preferences so that we can tailor our Website and Services to your needs.
2.4. When data is aggregated, we remove all personally identifiable information prior to use.
3. Purposes for the Collection, Use and Disclosure of your Personal Data
3.1. Generally, the PDG Group collects, uses and discloses your Personal Data in respect of the following purposes:
(a) to provide our Services to you in accordance with any agreements;
(b) to communicate with you on our promotions, Services, events, programmes, and initiatives;
(c) to communicate with you on our vendors’, agents’, contractors’ third party service providers’ or business partners’ (collectively referred to as our “Partners”) promotions, Services, events;
(d) to respond to your enquiries, requests, or feedback on our Website or Services, including suggested improvements;
(e) to process and administer your actual or potential transactions with us (including, but not limited to, provision by us of Services or provision of products or services by you to us);
(f) to process your registrations as a registered user of the Website;
(g) to verify your identity and/or eligibility for discounts and promotions or activities or events organised by or on behalf of the PDG Group;
(h) to facilitate our and/or our Partners’ provision of products and services to you;
(i) to manage our administrative and business operations and to comply with our internal policies and procedures, including any employment policies and practices;
(j) to facilitate business asset transactions (including, but not limited to, asset sales, mergers or acquisitions involving any of our companies);
(k) to obtain your feedback or participation in surveys, market research and/or analysis for statistical, profiling or other purposes to enable us to customise, review, improvise and develop our Services, to understand customer preferences, behaviour and market trends;
(l) to manage the safety and security of our premises including but not limited to conducting security clearances and carrying out CCTV surveillance, granting or refusing admission to our premises;
(m) to respond to any claims, actions or proceedings and/or to safeguard and enforce our contractual and legal rights and obligations;
(n) to manage and prepare any reports regarding incidents or accidents;
(o) to comply with any applicable rules, laws, regulations, codes of practice or guidelines as well as to assist in investigations and law enforcement by the relevant authorities; and/or
(p) any other purpose reasonably related to any of the above.
3.2. For any other purpose(s) not set out herein, the PDG Group may notify and seek your further consent in accordance with the requirements of any applicable laws, regulations, codes of practice, guidelines or rules before using your Personal Data for that other purpose(s).
3.3. You can generally use and browse our Website without disclosing your Personal Data to us (subject to paragraph 3.1 above), except where such disclosures may be necessary to allow us to respond to your requests, or in cases where you contact us directly in respect of our Services.
4. Disclosure of Personal Data to Third Parties
(a) related corporations or affiliates of the PDG Group;
(b) Partners contracted by the PDG Group to perform functions including those listed at paragraph 3.1 above;
(c) Partners contracted by the PDG Group (and the sub-contractors of such Partners) to provide our Services, such as operational services, including, but not limited to courier services, insurance, telecommunications, information technology, payment, payroll, processing training, market research, storage, archival, customer support investigation services or other services, in all instances, being reasonably related to our lines of businesses;
(d) banks or other financial institutions, credit card companies, payment processors or gateways, secretarial agents, billing organisations, or similar, and their respective service providers;
(e) our Partners, investors, assignees or transferees (actual or prospective) to facilitate business transactions which may include any merger, acquisition or asset sale or transfer;
(f) our professional advisors, which may include lawyers, auditors, accountants or other consultants;
(g) law enforcement agencies, relevant government ministries, regulators, statutory boards or authorities in compliance with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and/or
(h) any other person to whom you authorise us to disclose your Personal Data to.
4.3. We may also disclose or share your Personal Data, without notice, but only if required to do so by law or in the good faith belief that any such action is necessary to: (a) comply with any legal requirements or comply with legal process served on us or the Website; (b) protect and defend the rights or property of the PDG Group; and (c) act under exigent circumstances to protect the personal safety of our customers, users of our Website, or the general public.
5. Consent to Collection, Use and Disclosure of Personal Data
5.2. When you provide the PDG Group with any Personal Data relating to a third party (including, but not limited to, information on your dependants, spouse, children and/or parents), you represent and warrant that you are authorised to do so and/or the consent of that third party has been obtained for the collection, use and disclosure of the Personal Data by us for any of the purposes listed herein.
6. Withdrawing your Consent
6.1. 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 herein by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.
6.2. 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. In general, we shall seek to process your request within thirty (30) days of receiving it.
6.3. Please note that the withdrawal of your consent does not affect our right to continue to collect, use and disclose your Personal Data where such collection, use and disclosure without consent is permitted or required under the applicable laws.
7. Accuracy of Personal Data
7.1. Subject to paragraph 7.2, we will take reasonable efforts to ensure that your Personal Data is accurate and complete in particular, if your Personal Data is likely to be used by us to make a decision that affects you, or is to be disclosed to another organisation.
7.2. In order to ensure that your Personal Data is current, complete and accurate, please update us if there are changes to your Personal Data via the process at paragraph 8 below. We will not be responsible for any loss or damage suffered by you arising from our reliance on inaccurate or incomplete Personal Data due to you not updating us of any changes in your Personal Data that you had initially provided us with.
8. Access and Correction of Personal Data
8.1. 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, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
8.2. 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.
8.3. 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 any relevant laws).
9. Protection of Personal Data
9.1. The PDG Group will take reasonable steps to secure your Personal Data against any unauthorised access, collection, use, disclosure, copying, modification or similar risks and ensure that access to your Personal Data is limited to persons whom we reasonably believe require access for effective delivery of our Services to you for the purposes listed herein (where applicable) or any other purpose as consented by you.
9.2. Unfortunately, even with these measures, we cannot guarantee the security of Personal Data. By using our Website, you acknowledge and agree that we make no such guarantee, and that you use our Website at your own risk.
10. Retention of Personal Data
10.1. We may retain your Personal Data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
10.2. We will cease to retain your Personal Data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the Personal Data was collected, and is no longer necessary for legal or business purposes.
11. International Transfers of Personal Data
11.1. Your Personal Data may be transferred from the country, state and city in which you are present while accessing our Website or using our Services (“Home Country”) to another country, state and city (“Alternate Country”). This may include transfers to other entities under the PDG Group which are located outside your Home Country. The transfers to the Alternate Country may be required where PDG Group’s servers and/or PDG Group’s Partners are located in the Alternate Country. Your Personal Data may be further stored and processed in the Alternate Country.
11.3. When we transfer your Personal Data from your Home Country to the Alternate Country, we will comply with our legal and regulatory obligations in relation to your Personal Data, including putting appropriate safeguards in place to ensure an adequate level of protection for your Personal Data. We will also comply with any applicable legal and regulatory obligations so that the recipient in the Alternate Country is also obliged to protect your Personal Data at a standard of protection comparable to the protection under the applicable laws of your Home Country.
12. IP Addresses
12.1. When you use or access our Website, we may collect and store information about your computer (including, but not limited to, your IP address, operating system and browser type) for the purposes of system administration, processing, and related analysis.
13.2. Should you wish to disable the cookies of our Website, you may do so by changing the settings on your browser. However, you may not be able to enter, view or experience certain part(s) of our Website.
14. Third Party Websites
14.1. Our Website may, from time to time, contain links to and from third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please ensure you carefully read and review the privacy policies of these websites before you submit any Personal Data to these websites.
15. Data Protection Officer
Attention: Data Protection Officer
Email Address: DPO@princetondg.com
15.2. Please note that for any Personal Data provided to us by a third party (including, but not limited to, your company or a recruiter or a parent), you should contact such party to write to us in respect of any queries, feedback, complaints, or access and correction requests regarding your Personal Data on your behalf.
17. Governing Law
18.1. TO THE MAXIMUM EXTENT PERMITTED BY LAW, WE SHALL NOT BE LIABLE IN ANY EVENT FOR ANY SPECIAL, EXEMPLARY, PUNITIVE, INDIRECT, INCIDENTAL OR CONSEQUENTIAL DAMAGES OF ANY KIND OR FOR ANY LOSS OF REPUTATION OR GOODWILL, WHETHER BASED IN CONTRACT, TORT (INCLUDING NEGLIGENCE), EQUITY, STRICT LIABILITY, STATUTE OR OTHERWISE, SUFFERED AS A RESULT OF UNAUTHORISED OR UNINTENDED USE, ACCESS OR DISCLOSURE OF YOUR INFORMATION (INCLUDING ANY PERSONALLY IDENTIFIABLE INFORMATION).