Data Protection Policy
- We at Nikkei Group Asia Pte Ltd and Nikkei China (Hong Kong) Ltd. take our responsibilities under the laws and regulations relating to personal data protection (the “LAWS”) seriously. We also recognize the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data.
- This Data Protection Policy is designed to assist you in understanding how we collect, use and/or disclose the personal data you have provided to us, as well as to assist you in making an informed decision before providing us with any of your personal data.
- If you, at any time, have any queries on this policy or any other queries in relation to how we may manage, protect and/or process your personal data, please do not hesitate to contact our Data Protection Officer (the “DPO”) at: [email protected]
- 1. INTRODUCTION
- 1.1 “Personal Data” is defined under the LAWS 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 organization has or is likely to have access. Common examples of personal data could include names, identification numbers, contact information, medical records, photographs and video images.
- 1.2 We will collect your personal data in accordance with the LAWS. 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/or disclosed, as well as obtain your consent for the collection, use and/or disclosure of your personal data for the intended purposes.
- 1.3 Your personal data may also be collected, used or disclosed if we have assessed that to do so would be in our legitimate interests and beneficial to the public. Before doing so, we will take steps to ensure that any adverse effects that might arise for you have already been identified and eliminated, reduced or mitigated.
- 2. PURPOSES FOR COLLECTION, USE & DISCLOSURE OF PERSONAL DATA
- 2.1 The personal data which we collect from you may be collected, used and/or disclosed for the following purposes :
- (a) Registering and managing your subscription with us;
- (b) Delivering the newspapers / magazines / publications to you according to the terms of your subscription with us;
- (c) Collecting the subscription fees;
- (d) Identity verification on making inquiries
- (e) Introducing items such as publications and events such as seminars and exhibitions
- (f) Questionnaires and surveys for marketing
- 2.2 In order to conduct our business operations more smoothly, we may also be disclosing the personal data you have provided to us to our third party service providers, agents and/or our affiliates or related corporations, which may be sited outside of Singapore, for one or more of the above-stated Purposes. This is because such third party service providers, agents and/or affiliates or related corporations would be processing your personal data on our behalf for one or more of the above-stated Purposes.
- 3. SPECIFIC ISSUES FOR THE DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES
- 3.1 We respect the confidentiality of the personal data you have provided to us.
- 3.2 In that regard, we will not disclose any of your personal data to any third parties without first obtaining your express consent permitting us to do so. However, please note that we may disclose your personal data to third parties without first obtaining your consent in certain situations, including, without limitation, the following :
- (a) cases in which the disclosure is required based on the applicable laws and/or regulations;
- (b) cases in which the purpose of such disclosure is clearly in your interests, and if consent cannot be obtained in a timely way provided that we shall, as soon as may be practicable, notify you of the disclosure and the purposes of the disclosure;
- (c) cases in which the disclosure is necessary to respond to an emergency that threatens the life, health or safety of yourself or another individual;
- (d) cases in which there are reasonable grounds to believe that the health or safety of yourself or another individual will be seriously affected and consent for the disclosure of the data cannot be obtained in a timely way, provided that we shall, as soon as may be practicable, notify you of the disclosure and the purposes of the disclosure;
- (e) cases in which the disclosure is necessary for any investigation or proceedings;
- (f) cases in which the personal data is disclosed to any officer of a prescribed law enforcement agency, upon production of written authorisation signed by the head or director of that law enforcement agency or a person of a similar rank, certifying that the personal data is necessary for the purposes of the functions or duties of the officer; and/or
- (g) cases in which the disclosure is to a public agency and such disclosure is necessary in the public interest.
- 3.3 The instances listed above at paragraph 3.2 are not intended to be exhaustive. For an exhaustive list of exceptions, you are encouraged to peruse the First and Second Schedules of the PDPA which is publicly available at https://sso.agc.gov.sg/.
- 3.4 In all other instances of disclosure of personal data to third parties with your express consent, we will endeavour to provide adequate supervision over the handling and administration of your personal data by such third parties, as well as to provide for adequate forms of protection over such personal data.
- 3.5 Where personal data is transferred by us to any third parties outside of Singapore, we will ensure that such transfers are compliant with the requirements under the PDPA. In this regard, we will take such necessary measures to ensure that such overseas recipients are bound by legally enforceable obligations to ensure that these overseas recipients provide a standard of protection to the personal data so transferred that is comparable to the protection under the PDPA.
- 4. REQUEST FOR ACCESS AND/OR CORRECTION OF PERSONAL DATA
- 4.1 You may request to access and/or correct the personal data currently in our possession at any time by submitting your request through the following methods :
E-mail : [email protected]
- 4.2 For a request to access personal data, once we have sufficient information from you to deal with the request, we will seek to provide you with the relevant personal data within 30 days. Where we are unable to respond to you within the said 30 days, we will notify you of the soonest possible time within which we can provide you with the information requested. Note that the PDPA exempts certain types of personal data from being subject to your access request.
- 4.3 For a request to correct personal data, we will undertake the following :
- (a) once we have sufficient information from you to deal with the request, we will correct your personal data within 30 days. Where we are unable to do so within the said 30 days, we will notify you of the soonest practicable time within which we can make the correction. Note that the PDPA exempts certain types of personal data from being subject to your correction request as well as provides for situation(s) when correction need not be made by us despite your request; and
- (b) subject to paragraph 4.4, we will send the corrected personal data to every other organisation to which the personal data was disclosed by the organisation within a year before the date the correction was made, unless that other organisation does not need the corrected personal data for any legal or business purpose.
- 4.4 Notwithstanding paragraph 4.3(b), we may, if you so consent, send the corrected personal data only to specific organisations to which the personal data was disclosed by us within a year before the date the correction was made.
- 4.5 Depending on the nature of the work required to process your access request, we may be required to charge you a reasonable fee for the handling and processing of your requests to access your personal data to recover administrative costs. Our Data Protection Officer will determine whether such a fee should be imposed on a case-by-case basis. Where such a fee is to be imposed, we shall provide you with a written estimate of the fee for your consideration. We shall only begin processing your access request upon receiving your agreement to the payment of the fee.
- 5. REQUEST TO WITHDRAW CONSENT
- 5.1 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 through the following methods :
E-mail : [email protected]
- 5.2 Please note that we may require 10 business days to process your request and to give effect to the withdrawal, and will thereafter refrain from collecting, using and/or disclosing your personal data in the manner stated in your request.
- 5.3 However, if you choose to withdraw your consent, we may not be able to fulfil the purposes for which we require the personal data, including for us to contact you or to provide some or all of the products or services which you may need from us.
- 6. ADMINISTRATION AND MANAGEMENT OF PERSONAL DATA
- 6.1 We will take appropriate measures to keep your personal data accurate, complete and updated.
- 6.2 We will also take commercially reasonable efforts to take appropriate precautions and preventive measures to ensure that your personal data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorized access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data. However, we cannot assume responsibility for any unauthorized use of your personal data by third parties which are wholly attributable to factors beyond our control.
- 6.3 We will also take commercially reasonably efforts to ensure that the 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.
- 7. COMPLAINT PROCESS
- 7.1 If you have any complaint or grievance regarding about how we are handling your personal data or about how we are complying with the LAWS, we welcome you to contact us with your complaint or grievance.
- 7.2 Please contact us through one of the following methods with your complaint or grievance :
E-mail: [email protected] (Attention it to the ‘Data Protection Officer’.)
- 7.3 Where it is an email or a letter through which you are submitting a complaint, your indication at the subject header that it is a complaint regarding Personal Data would assist us in attending to your complaint speedily by passing it on to the relevant staff in our Company to handle. For example, you could insert the subject header as “Personal Data Complaint”.
- 7.4 We will certainly strive to deal with any complaint or grievance that you may have speedily and fairly.
- 8. UPDATES ON DATA PROTECTION POLICY
- 8.1 As part of our efforts to ensure that we properly manage, protect and process your personal data, we will be reviewing our policies, procedures and processes from time to time.
- 8.2 We reserve the right to amend the terms of this Data Protection Policy at our absolute discretion. Any amended Data Protection Policy will be posted on our website and can be viewed at https://www.nikkeiasia.com/policy/.
- 8.3 You are encouraged to visit the above website from time to time to ensure that you are well informed of our latest policies in relation to personal data protection.
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