Apart from this Policy, AIS has also prepared internal rules on the handling of personal data, and will strive to manage and protect personal data. This includes periodically providing internal education to AIS staff on the importance of protecting personal data.
1. Personal Data
Depending on the circumstances, AIS will collect, handle, and use a range of personal data (“Personal Data”), including but not limited to:
a. Employee information – personally identifiable information including fingerprint, palm vein, finger vein, facial information, name, NRIC, passport or other identification number as well as date of birth, gender, marital status, race, religion, nationality, employment status, department, hire date, job grade, nature of employment, contract type, country of residence, salary, and any other information relating to any individual which you have provided to AIS.
b. Contact information – personally identifiable information (as per above), residential address, addresses, zip code, phone numbers, email addresses, GPS information which you have provided to AIS.
c. Payment information – financial and bank account details, credit and debit card information, inclusive of the cardholder’s name, billing address, as well as the identities of designated payees under the cardholder’s account.
d. Technical information - IP addresses, cookies.
2. Non-Personal Data
Please note that this policy does not apply to the collection, use, and disclosure of data and information which do not amount to Personal Data (“non-Personal Data”). This includes data which does not refer an individual, data from which an individual cannot be identified, and Personal Data which has been anonymized such that the data can no longer be used to identify any particular individual. AIS will collect and retain non-Personal Data to the extent required to provide the best service to our clients.
3. Collection, Use, and Disclosure of Personal Data
(1) Purpose for the Collection, Use, and Disclosure of Personal Data
In general, AIS will collect, use, and disclose Personal Data for the purposes of developing, providing, operating, and maintaining our products and services. This shall include, but is not limited to collecting, using, and disclosing Personal Data in order to:
- Provide services to customers such as processing transactions;
- Provide technical assistance;
- Carry out marketing and communication activities
- Carry out recruitment activities; and/or
- Ensure Safety, security and legal compliance.
(2) Request for Notification of Purpose
In the event that you are unsure of the purpose for which certain Personal Data is being collected, used, or disclosed, you may contact AIS at the contact details provided for at paragraph 9 below, and we will notify you of the purpose.
(3) Collection of Personal Data without Consent
While AIS will generally only collect your Personal Data for the above purposes and with your consent (whether deemed or expressed), please note that AIS will be able to collect your personal data without your consent, in the situations set out at Schedule 2 of the PDPA. This includes the collection of Personal Data which is publicly available.
(4) Use of Personal Data without Consent
While AIS will generally only use the Personal Data for the above purposes and with your consent (whether deemed or expressed), please note that AIS will be able to use your personal data without your consent, in the situations set out at Schedule 3 of the PDPA. This includes the use of Personal Data where the use is necessary for any purpose which is clearly your interests, if consent for its use cannot be obtained in a timely way, or where you would not reasonably be expected to withhold consent.
(5) Disclosure of Personal Data without consent
While AIS will generally only disclose the Personal Data for the above purposes and with your consent (whether deemed or expressed), please note that AIS will be able to disclose your personal data without your consent, in the situations set out at Schedule 4 of the PDPA. This includes the disclosure of Personal Data which is necessary for any investigation or proceedings, or where disclosure may be required by law.
4. Personal Data received via AIS’ website
Without prejudice to the generality of the above, please note that for Personal Data which is received via AIS’ websites (namely, www.aismaritime.com, www.smartkinta.com, www4.kinta.ne.jp), whether through online inquiries or otherwise, shall be used and/or disclosed for responding to such inquiries, and may also be used/disclosed to introduce you to our products and notices of upcoming exhibitions/seminars.
5. Refusal and Withdrawal of Consent
You may refuse to provide Personal Data to AIS, however please note that your refusal may affect AIS’ ability to develop, provide, operate, and maintain our products and services for you.
You may, via reasonable notice in writing (see contact details at paragraph 9 below), withdraw your consent (whether given or deemed) for the collection, use, or disclosure of your Personal Data. You may withdraw your consent entirely, or in part (i.e. withdrawing consent for your Personal Data to be disclosed to third parties). Upon receiving your written notice, AIS will inform you of how the withdrawal of consent is likely to affect our ability to develop, provide, operate, and maintain our products and services for you. Once you have confirmed that you wish to withdraw your consent, we will cease collecting, using, or disclosing the Personal Data (unless otherwise required to or authorised under applicable laws).
6. Retention of Personal Data
AIS will only retain your Personal Data for such time as is required for the purposes set out above, or as may be required under the applicable laws.
7. Management and Protection of Personal Data
(1) AIS will take adequate and reasonable measures to prevent any unauthorized access to, and loss, damage, alteration and leakage of the Personal Data. Except as mentioned in this Policy, the Personal Data will not be disclosed to a third party without your consent.
(2) AIS is committed to a continuous improvement of the protective measures in place for the Personal Data, and the management of the Personal Data.
8. Transfer of Data to third parties and out of Singapore
(1) Without prejudice to the generality of paragraph 3(4) above, AIS may disclose and/or transfer your Personal Data to third parties for the purposes set out above. AIS will only disclose and/or transfer Personal Data to third parties which AIS has determined to have met the data protection standards of AIS, and which are able to ensure that the Personal Data is safely handled. Where necessary, AIS will enter into confidentiality agreements with the third party for this purpose.
(2) In the event that it is necessary to transfer your Personal Data to a territory outside of Singapore, we will ensure that the transfer will be in accordance with the PDPA, so as to ensure that even after the transfer, the Personal Data will receive a standard of protection comparable to the PDPA.
9. Management and Manager of Personal Information
Director: [KUNIHIKO SUSUKIDA]
Contact: Email & TEL and Address [Email: firstname.lastname@example.org,
TEL: +65-6220-0735 & Address : 143 Cecil Street, #03-01, GB Building, Singapore 069542]
(2) Please contact the person(s) identified above if you wish to:
a. withdraw your consent (as per paragraph 5 above);
b. access, and correct your Personal Data (as per paragraph 10 below);
c. inform us of any concerns or further queries that you might have; and/or
d. highlight any problems or submit any complaints regarding the Personal Data
AIS will promptly respond to you.
(3) For the purposes of requests, emails, queries (etc.) made to AIS, all Personal Data received will only be used for the request, and will be promptly deleted after the request has been dealt with. AIS will take commercially reasonable and technically possible steps to ensure that the data so deleted is irrecoverable and irreproducible in accordance with law.
(4) AIS seeks the understanding of customers to provide updated and accurate information when making any request or query to AIS. This is because the information provided may or is likely to be used in the processing of your request.
10. Requests for Access/Correction
Upon request in writing to the contact details provided at Paragraph 9 above, AIS will provide you with access to your personal data, and allow you to make such corrections as you may request, in accordance with the requirements of the PDPA.
a. Please make your request in writing to the contact details provided for at Paragraph 9 above. Please also identify if you are requesting for access to your Personal Data, or if you seek to make a correction to your Personal Data. AIS will send you a form titled “Request for Access/Correction of Personal Data” regarding the request for access/correction.
b. Please fill in the form, and enclose therewith a formal document of your identification. Please refer to the form for details.
- In case of a request by an agent, please enclose formal documents of your identification and the agent’s identification and a letter of proxy with the form.
c. AIS will conduct investigations/procedures without delay and respond to your request in writing after AIS confirms the details of your request.
(2) Costs for Procedures
You will only have to bear the cost of postage (if applicable) for your request.
(3) Limitation of Access
Please note that AIS will not be able to provide you with access with your Personal Data, in the situations set out at Section 21(3) PDPA. AIS is also not required to provide you with access to your Personal Data, in situations set out at Schedule 5 of the PDPA, and for situations set out at Schedule 5, access shall be granted at the discretion of AIS.
(4) Limitation of Correction
Please note that AIS will not be obliged to make any corrections where AIS is satisfied that there are reasonable grounds that a correction should be made, or in respect of matters set out at Schedule 7 of the PDPA. In such circumstances, any corrections to be made shall be at the discretion of AIS.