PRIVACY & CONFIDENTIALITY POLICY
This Notice has been prepared by us, PKWA Law Practice LLC, in connection with the Personal Data Protection Act (No. 26 of 2012) (“the Act”) to inform you how we manage personal data (as defined below) which is subject to the Act. The security of your personal data and confidential information is important to us. We have in place safeguards to protect your personal data and confidential information that are stored with us. This Notice describes how we may collect, use, disclose, process and manage your personal data and confidential information.
Your use or continued use of our services shall be deemed as your acceptance and agreement to be bound by the provisions of this Notice.
PKWA Law Practice LLC’s Privacy and Confidentiality Principles
1. We only collect personal information that we believe to be relevant and required to provide our legal services to you.
2. We will not use or disclose information collected about you otherwise than for the purpose made known to you, a purpose you
would reasonably expect, a purpose required, authorised or permitted by or under any law or a purpose otherwise authorised by you.
3. We may be required from time to time to disclose your personal information to Governmental or judicial bodies or agencies, but we will only do so under proper authority.
4. We aim to keep your personal information on our records accurate and up-to-date.
5. We maintain strict security systems designed to prevent unauthorised access to your personal information by anyone, including our staff.
6. All our staff and all parties with permitted access to your personal information including any third party to whom we have outsourced a part of our work to are specifically required to observe our confidentiality obligations.
What personal data we collect
“Personal data” is data that can be used to identify a natural person.
Some examples of your personal data that we may collect are:-
(a) personal particulars (e.g. name, contact details, residential address, date of birth, identity card or passport details, education details);
(b) specimen signature or signatures;
(c) financial details (e.g. CPF balances, credit history);
(d) images of our conversations with you (e.g. text messages);
(e) employment details (e.g. occupation, directorships and other positions held, employment history, salary benefits);
(f) tax information;
(g) information about your investments, business interests, assets;
(h) banking information (e.g. account numbers); and/or
(i) personal opinions made known to us (e.g. feedback).
How personal data is collected
Generally we collect personal data in the following ways:-
(a) when you submit any form, including but not limited to, application and declaration forms;
(b) when you enter into any agreement or provide other documentation or information in respect of your interactions and transactions with us, or when you use our services;
(c) when you interact with our staff via telephone calls, text messages, letters, fax email and face-to-face meetings;
(d) when you request that we contact you, be included in an email or other mailing list; or when you respond to our request for additional personal data and other initiatives;
(e) when you submit an employment application or when you provide documents or information including your resume and/or curriculum vitae in connection with any appointment or any position;
(f) when you use our electronic services, or interact with us via our websites or use services as our websites;
(g) when we seek information about you and receive your personal data in connection with your relationship with us, from business partners, public agencies, your ex-employer and relevant authorities;
(h) when we receive references from business partners and third parties, for example, when you have been referred by them; and/or
(i) when you submit your personal data to us for any other reason.
How personal data is used
Generally we may collect, use and/or disclose your personal data for the following purposes:-
(a) providing you with the services which you have requested;
(b) verification of your identity for the purpose of providing you with our services;
(c) responding to your queries and requests and handling complaints, feedback and suggestions;
(d) providing you with personalised service, including at our customer service touchpoints;
(e) networking to maintain customer relationship, customer outreach and relationship management, including sending you newsletters and materials which we think may be of interest to you;
(f) sanctions screening and due diligence checks as may be required under applicable law, regulation or directive;
(g) preventing, detecting and investigating crime, including fraud and money-laundering or terrorist financing and analyzing and managing commercial risks;
(h) legal purposes (including but not limited to obtaining legal advice and dispute resolution);
(i) complying with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities; and/or
(j) any other purpose relating to any of the above.
Parties to whom personal data may be disclosed
We will take reasonable steps to protect your personal data against unauthorised disclosure. Subject to the provisions of any applicable law, your personal data may be provided, for the purposes listed above, on a need to know basis, to the following entities or parties, whether they are located overseas or in Singapore:-
(a) any person in connection with the services you have requested us to provide for you
(b) our professional advisers such as our auditors and lawyers;
(c) surveyors, valuers or other third parties in relation to loans, cpf applications or other transactions;
(d) any liquidator, receiver, official assignee/trustee, judicial manager or any other person appointed under or pursuant to any applicable law or court order in connection with the bankruptcy, liquidation, winding up, judicial management or any other analogous process in respect of any individual, company or business;
(e) the Commissioner of Stamp Duties and any other government department, agency, ministry, body or statutory board or any relevant authority;
(f) any person to whom disclosure is allowed or required by law, regulation or any other applicable instrument;
(g) any court, tribunal regulator (including national and/or international regulator), enforcement agency, exchange body, tax or other authority (including HDB, CPF or an authority investigating an offence) where we are required to do so by applicable
law and/or regulation; any authority or regulator, any directive, order or request of any authority or regulator, or any agreement with a regulator or an authority;
(h) any third party to whom we have outsourced a part of our work to, to the extent it is necessary for them to carry out the assigned tasks; and/or
(i) any other party to whom you authorise us to disclose your personal data.
We may share personal data with third parties for the purposes of the third party providing a relevant service in connection with the services you have requested us to provide for you.
We do not sell your personal data to any third parties.
Subject to the relevant rules and regulations and any legal professional restrictions which apply to us in Singapore, the following will apply:
(i) We owe a duty of confidentiality to all our clients and accordingly, subject to any overriding legal obligation on you or us and (ii) below, we will keep all documents and information which we receive as a result of acting for you confidential, and in particular, we will not disclose them to any other client of the firm without your express agreement
(ii) Confidential information acquired by us in the course of our engagement may be disclosed, on a need to know basis, to:
(a) any party to whom we are permitted or is required by law, by an order of court, or by a tribunal to make the disclosure;
(b) any party in confidence, for the sole purposes of obtaining advice in connection with our legal or ethical obligations;
(c) a provider or broker of our professional indemnity insurance in confidence, in connection with any claim or potential claim, or any complaint or potential complaint, by any person against us;
(d) any party for the sole purpose of responding to or defending any charge or complaint, relating to our conduct or professional behaviour, brought against the legal practitioner in court, before a Review Committee, an Inquiry Committee or a Disciplinary Tribunal, before a complains committee appointed under section 36S(5) of the Legal Profession Act, or before any relevant professional disciplinary body of a state or territory (other than Singapore) in which we are duly authorised or registered to practise law;
(e) any third party to whom we have outsourced a part of our work to, in confidence, to the extent that it is necessary for them to carry out the assigned tasks; and/or
(f) any other party to whom you authorise us to disclose the information.
Withdrawal of Consent
If you wish to withdraw your consent to any use or disclosure of your personal data or confidential information as set out above, you may contact us.
Please note that if you withdraw your consent to any or all or disclosure of your personal data or confidential information, depending on the nature of your request, we may not be in a position to continue to provide our services to you. Such withdrawal may also result in the termination of any agreement you may have with us. Our rights and remedies are expressly reserved in such event.
use of our websites and to compile statistics about website activities.
A pixel tag, also known as a web beacon, is an invisible tag placed on certain pages of our website but not on your computer. Pixel tags are usually used in conjunction with cookies and are used to monitor the behaviour of users visiting the website.
You may set your browser to block cookies which will in turn disable the pixel tags from monitoring your website visit. You may also remove cookies stored from your computer or mobile device. However, if you do block cookies and pixel tags, you may not be able
to use certain features and functions of our website.
Third party sites
of the third party website to determine how they will handle any information they collect from you.
(a) have any questions or feedback relating to your personal data or confidential information or our privacy and confidentiality policy;
(b) would like to withdraw your consent to any use of your personal data or confidential information as set out in this privacy and confidentiality protection notice; or
(c) would like to obtain access and make corrections to your personal data or confidential information records, you can approach us via the following channels:
(i) email us at email@example.com;
(ii) call our Data Protection Officer at 63976100; or
(iii) write to our Data Protection Officer as follows:-
Data Protection Officer
PKWA Law Practice LLC
480 Lorong 6 Toa Payoh
#16-01 HDB Hub East Wing
This Notice and our privacy and confidentiality policy shall be governed in all respects by the laws of Singapore.
Nothing in this Notice limits or seeks to limit your rights under the Act.
Update of our privacy and confidentiality policy
Please note that we may update our privacy and confidentiality policy from time to time to ensure that our privacy and confidentiality policy is consistent with our future developments, industry trends and/or changes in legal or regulatory requirements. If there are material changes to our privacy and confidentiality policy, we will notify you by posting a notice of such changes on our website or by sending you a notification directly. Do periodically review our privacy and confidentiality policy to stay informed on how we are protecting and managing your personal data and confidential information.
Subject to your rights at law, you agree to be bound by the prevailing terms of our privacy and confidentiality policy.
This Notice was last updated on 5th March 2018.