Last Updated: 12 Jan 2022
1. POLICY STATEMENT
This Policy is based on the Singapore Personal Data Protection Act 2012 ("PDPA") and all the associated regulations and guidelines as may from time to time be issued by the Personal Data Protection Commission ("PDPC") of Singapore.
2. COLLECTION OF INFORMATION
We may collect certain types of personal data. As used in this Policy, "personal data" means data, whether true or not, about an individual who can be identified: (a) from that data; or (b) from that data and other information to which the organisation (in this case CMPL, all CMPL's subsidiaries and all authorised third parties of relevance) has or is likely to have access. Personal data includes, among other things, your name; street or mailing address; telephone number(s)/Fax number(s); email addresses; date of birth/age; gender; nationality; ID/NRIC number as well as numeric psychometric data based on your responses to the online PEAKS assessment and corresponding personality profiles and raw scores generated from your online PEAKS assessment submission.
We may collect additional personal data about you that you knowingly and voluntarily provide in connection with certain activities at or transactions with CMPL or our website, such as participation in certain meetings and events, participation in social media offerings (such as signing up through our Facebook pages), use of CMPL’s mobile applications and applications for employment.
In addition to personal data that you provide to us, we may collect certain information about you that is not generally or uniformly considered personal data and which we consider to be non-personal data. We collect this information to create a better user experience and to identify areas of improvement on our websites and for our services. Data that is collected may include information such as the type of Internet browser you are using; your IP address; the pages you visited on our websites; how you arrived at our websites (i.e., through a search engine or a referring website), and other types of information.
Cookies and Other Technologies
When you visit our website, we may assign your computer or mobile device one or more "cookies." By accessing our website, you agree that we can place cookies on your device.
Most browsers automatically accept cookies, but you can modify your browser setting to decline cookies. Generally, you can remove these cookies by following directions provided in your Internet browser's "help" file. If you choose not to allow us to place a cookie on your computer, you may be restricted from some services and some of the interactive features offered on our websites may be similarly restricted or rendered inoperable.
In addition to cookies, we may also use other Internet technologies, such as pixel tags, to deliver or communicate with cookies and track your use of our website. We may also include web beacons in e-mail messages or newsletters to determine whether messages have been opened and acted upon, and how. The information we obtain in this manner enables us to customize the services we offer and measure the overall effectiveness of our online content, advertising campaigns, and the products and services we offer through our website. By accessing our website and agreeing to receive our e-mail messages or newsletters, you agree that we can use other Internet technologies such as those mentioned above on your device.
Combining Information We Collect with Information from Other Sources
We may obtain personal and non-personal data about you from other sources and combine it with information you provide to us. In situations in which a third party under contract with CMPL collects personal data about you, we will require the third party to exercise reasonable care in protecting your information so that it is in compliance with the PDPA.
3. HOW CMPL USES CUSTOMER PERSONAL INFORMATION
CMPL may use your Personal Information for any of the following purposes:
· To manage your account, such as password reset
· To notify you of special events, promotions and offers
· To provide you with personalized content on our website
· To improve the content and the navigability of our website
· To verify your identity
· To process and respond to inquiries
· To analyse online questionnaire submissions and generate psychometric profiles/personality scores for those who have completed the online PEAKS psychometric test
· To process purchase or credit transactions
· To develop new products
· For the purposes for which you provided the information (e.g., to register for a course, purchase a personality profile etc.)
· For the purpose of compiling data and conducting statistical or demographic analysis
· To protect and defend the rights or property of CMPL or any of its subsidiaries or authorised & licensed PEAKS franchisees
· To comply with a court order or other legal process or other legal requirements of any governmental authorities.
CMPL will not use or disclose or sell, rent, or lease any Personal Information about its customers or former customers to any third parties except as stated in this Policy. Personal Information may be transferred across national and state borders for the purposes of data consolidation, storage, and customer data management, including sharing your information with relevant CMPL entities/subsidiaries or authorised & licensed PEAKS franchisees.
Sale of Information
4. DISCLOSURE OF CUSTOMER PERSONAL INFORMATION
Please note that CMPL may disclose Personal Information of current and former clients to affiliated and non-affiliated third-party entities in the following cases:
· To CMPL’s affiliates & subsidiaries, who are permitted to disclose and use the information only to the extent that CMPL may disclose and use the information under this Policy
· In the ordinary course of business to CMPL’s attorneys, accountants, and auditors
· To government, regulatory or law enforcement agencies to the extent permitted or required by law, or to comply with applicable legal requirements; or
· To comply with civil, criminal or regulatory investigations or judicial process, subpoena, summons or warrant by relevant authorities.
5. DO-NOT-CALL REGISTRY
From time to time, CMPL and our partners may contact you via call or SMS (text messages) to inform you about our latest products, services, benefits, and promotions.
If you have previously consented to receiving such calls and messages, you will continue to be updated on our promotions and marketing campaigns. However, if you no longer wish to continue to receive marketing calls or messages, you may withdraw your consent by contacting our Data Protection officer at email@example.com
For potential customers, we will only contact you via the telephone for marketing and promotional messages/calls after ascertaining that you have not registered with the national Do Not Call (DNC) Registry administered by the Personal Data Protection Commission of Singapore. However, as we may rely on the one-month validity period of our search results, you may inadvertently still receive marketing or promotional messages/calls.
If you have received a telemarketing call from someone representing CMPL although you have registered with the DNC Registry or withdrawn your consent, please inform us at firstname.lastname@example.org
6. PERMISSION TO DISCLOSE PERSONAL INFORMATION
7. TRANSFER OF PERSONAL INFORMATION OVERSEAS
In certain circumstances, we may need to transfer your personal information outside of Singapore. Any such transfer of your personal information outside of Singapore will be carried out in accordance with the Personal Data Protection Act (PDAP) requirements.
Generally, when we request personal information in the course of providing you with a service and/or product and you provide us with such personal information, there is implied consent that you agree to provide us with personal information in order for us to provide you with the requested service and/or product.
In some circumstances, and as required by applicable laws, we will seek your express consent when collecting your personal information. For example, where there are new purposes for the use of your personal information, we will seek fresh consent.
9. SITUATIONS NOT REQUIRING CONSENT
We may share non-personal, non-individual information in aggregate form with third parties for research purposes, but your personal information will remain anonymous.
10. PROCEDURES TO SAFEGUARD PERSONAL INFORMATION
CMPL uses reasonable precautions to protect your personal data and store it securely. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures. CMPL’s website has security measures in place that strive to protect against the accidental loss, misuse, and unauthorized access to your personally identifiable information while under our control. Such security measures include, but are not limited to, password controls, firewalls, and other industry standard security measures.
We will use all reasonable efforts to safeguard your personal information. However, you should be aware that the use of the Internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any personal information which is received from you or sent to you via the Internet.
11. RETENTION OF PERSONAL INFORMATION
CMPL only keeps Personal Information on file for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws. We shall cease to retain personal information, or remove the means by which the personal information can be associated with particular individuals, as soon as it is reasonable to assume that the purpose for which that personal information was collected is no longer being served by retention of the personal information and retention is no longer necessary for legal or business purposes. Destruction of customers’ personal data will be performed in a secure manner.
CMPL attempts to ensure the accuracy of the Personal Information collected. CMPL records the dates when Personal Information was obtained from customers, and will periodically ask customers to review the Personal Information CMPL has on file and update any Personal Information that may have changed.
We endeavour to ensure that the personal information we hold is accurate and up-to-date. We realise that certain data that we hold about individuals may change more frequently, for example, residential address, phone number and email address, income, savings and net-worth, etc. In order to ensure that your personal information is current, complete, and accurate, please update us by contacting us through email at email@example.com
We can generally update your personal information over the phone and at our discretion, may require relevant and reliable documents to verify the amendment(s) that you request for.
13. CUSTOMER RECOURSE
Any concerns a customer may have regarding CMPL’s privacy practices, or any specific complaints about how a client’s Personal Information has been collected, used or disclosed should be forwarded to our Data Protection Officer at the following email address: firstname.lastname@example.org
CMPL will thoroughly investigate the complaint and will take whatever actions are warranted and notify the client once this has been done. Under the Act, you have the right to obtain a copy of any personal information which we hold about you and to advise us of any inaccuracy that requires a correction. In addition, you are entitled to know how your personal information has been used or disclosed in the past year. The PDPA does set out some exceptions to this: for instance, where the amount of effort and resources needed to provide access would be unreasonable or disproportionate to your interests or if we have satisfied ourselves on reasonable grounds that the correction should not be made.
To make a request, you will need to contact our Data Protection Officer at email@example.com and specify what data you require correcting. We may charge a reasonable administrative fee for this service to cover the cost of verifying the application and locating, retrieving, reviewing, and amending any material requested. If the personal information sought is extensive, we will advise an estimated cost in advance and can help to refine your request if required.
We will acknowledge your request within 30-days and respond promptly to it. In exceptional circumstances, we reserve the right to deny you access to your personal information and may provide an explanation as required by applicable laws
15. GOVERNING LAW
16. CHANGES TO POLICY
17. CONTACT US