A. Introduction
This Personal Data Protection Statement has been prepared to help you understand how Asia Pacific Sales & Marketing Academy (APACSMA) collects, uses and discloses your personal data.
APACSMA will collect, use and disclose your personal data in accordance with the Personal Data Protection Act 2012 (“Act”). In general, before we collect any personal data from you, we will notify you of the purposes for which your personal data may be collected, used and disclosed, as well as obtain consent for the intended purposes.
B. Purposes for the Collection, Use & Disclosure of Personal Data
Depending on your relationship with APACSMA (whether as a student, employee, alumnus, donor or service provider, etc), the personal data which we collect from you may be used and/or disclosed for the following purposes:
Student
Alumnus
Employee
General
C. Disclosure of Personal Data to Third Parties, Disclosure Permitted By Statutory Exemption under the Act
In order to conduct our operations more smoothly, APACSMA may disclose your personal data to our third party service providers, and affiliates or related corporations. This is because such third parties would be processing your personal data on APACSMA’s behalf for the purposes mentioned above.
APACSMA will not disclose your personal data to any third parties without first obtaining your consent permitting us to do so or unless any such disclosure is permitted under any of the statutory exemptions under the Act, e.g.
For the full list of exemptions, please refer to the Act which is publicly available at https://sso.agc.gov.sg/Act/PDPA2012.
D. Request for Access, Correction and/or Withdrawal of Personal Data
Subject to certain exceptions in the Act, you may request to review and update the personal data currently in our possession or withdraw your consent for the collection, use and disclosure of your personal data in our possession. Please submit your request to edu@apacsma.com.
If you request to access your personal information, we will ask you to verify your identity and specify what information you wish to access. APACSMA will provide you with the relevant personal data within a reasonable time after the request has been made. A fee may be charged for handling the request and you will be notified in advance of this.
For a request to correct your personal data, APACSMA will correct your personal data as soon as practicable after verifying your identity. We will send the corrected personal data to every other organization to which the personal data was disclosed by APACSMA within a year before the date the correction was made, unless that other organization does not need the corrected personal data, or if you so consent, only to specific organizations to which the personal data was disclosed by us.
APACSMA will similarly process your request within a reasonable time after a request to withdraw consent has been made. In some cases, the request to withdraw consent may adversely impact your relationship with APACSMA. We will notify you in advance of any such impact.
E. Administration and Management of Personal Data
APACSMA will take appropriate measures to keep your personal data accurate, complete, and updated.
We will also take reasonable efforts to take appropriate preventive measures to ensure that your personal data is adequately protected and secured. Appropriate security arrangements will be put in place to prevent any unauthorized access or misuse of your personal data.
We will similarly take reasonable efforts to ensure that the personal data in our possession is destroyed or anonymized as soon as (i) the purpose for which that personal data was collected is no longer being served by the retention of such data, and (ii) retention is no longer necessary for any other legal or business purposes.
F. Additional information to deal with the European Union General Data Protection Regulation (EU) 2016/679 (“GDPR”)
This section F applies only if a particular circumstance or activity applicable to APACSMA requires the application of the GDPR to APACSMA. Subject to the aforesaid, in such cases, this section F would apply to residents of the European Union only.
Generally, we process personal data on the basis of consent. Apart from consent, under the GDPR, we may also lawfully process your personal data on one or more of the following bases:
Lawful basis for processing
Further, we may process your personal data for the legitimate interests of promoting the good of APACSMA and/or alumni community, and maintaining APACSMA’s relationship with its former students (i.e. alumni) to grow the APACSMA spirit in its students and former students. The latter would apply to an alumnus.
We practice data minimization and strive to collect only what is necessary in relation to the purposes for which such personal data is processed and to maintain the relevant relationship between us such as the student relationship in the case where you are a student. The consequence of not providing such requested personal data may result in our inability to start that relationship with you, to maintain that relationship with you or to provide you with our products or services.
Where your personal data is transferred to a country for which the European Commission has not made an adequacy decision, we will take appropriate steps to ensure that the foreign recipient organization of the personal data is bound by legally enforceable obligations to protect the transferred personal data. This may include us entering into an appropriate contract with the foreign recipient organization dealing with the personal data transfer.
Where the GDPR is applicable, you have the following rights (subject to any exceptions under the GDPR):
Further, you have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes, subject to condition(s) in the GDPR.
You also have the right to lodge a complaint with the local data protection authority or the European data protection authority applicable to you if you believe that we have not complied with applicable data protection laws.
In general, we do not use automated individual decision-making for the formation and management of your relationship with us. If we should rely on such processing in a particular situation, we will do so in accordance with the GDPR.
G. Updates on the APACSMA Personal Data Protection Statement
As part of our effort to ensure that we properly manage, protect, and process your personal data, we will be continually reviewing our policies, procedures, and processes.
We may amend the terms of this APACSMA Personal Data Protection Statement at our absolute discretion. The amended APACSMA Personal Data Protection Statement will be posted on our website.
We recommend that you check our website from time to time to remain updated as to any changes in our personal data policy or any other policies.