Privacy Policy

SPECTRUM and its subsidaries  (“we” or “us”) respects the privacy rights of our users and is strongly committed to protecting your privacy. This Privacy Policy aims to give you information on how we collect and process your personal information through websites owned and operated by us e.g when you sign up for our newsletter or such other electronic services provided by us,  when you purchase our products or services or when you attend any of our events.

 

This Privacy 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 of Singapore. If you are an EU resident, our GDPR privacy statement can be found here.

 

Please review this Privacy Policy carefully before visiting or using our website, or otherwise providing us with any of your personal information. This Privacy Policy supplements other notices and privacy policies and is not intended to limit or override them.

 

Information We collect

 

We may collect and process certain types of personal information. Personal information includes, among other things, personal information that you voluntarily provide on this web site, which may include your: name; address; e-mail addresses; telephone number(s); date of birth; gender; nationality; passport number; payment information; credit card numbers; billing information; academic or employment records, and any other types of information that you choose to provide to us or that we may collect about you through your transactions with us.

 

How we use your personal information

 

We may collect, use and/or process your personal information for the following purposes:

 

  • carrying out your instructions or responding to your enquiries, requests for information submitted by your or on your behalf;
  • to check or verify the identity of the client and/or suitability of the client for certain products and services;
  • administering and managing our relationship with you;
  • for any promotional, business developmental or marketing purposes, for example photographs, videos, or such other audio-visual content;
  • for any logistical or administrative purposes in connection with any of our services or events;
  • contacting or corresponding with you through various means including voice calls, text messages, email, or post to administer and manage your relationship with us;
  • to (a) comply with the law or in response to a subpoena, court order, government request, or other legal process; (b) to produce relevant documents or information in connection with litigation, arbitration, mediation, adjudication, government, or internal investigations, or other legal or administrative proceeding;
  • any other incidental or ancillary purposes related to or in connection with the above, which may include without limitation, audit requirements and carrying out market-related, evaluative, or similar research and analysis to review, develop, improve or enhance our products and services;
  • to protect and enforce our contractual, legal rights and obligations;
  • to operate SPECTRUM’s systems properly.

 

Disclosure of Personal Information and Other Information

 

We may disclose your personal information:

 

  • to our affiliated or related group companies, where they are directly or indirectly involved in the provision of services;
  • where such disclosure is required for performing obligations in the course of or in connection with our provision of the products or services requested by you;
  • to third party service providers, agents and other organisations we have engaged to perform any of the functions listed in the section above for us.

 

Accuracy and Security of Personal Information

 

We strive to protect the security of your information and are constantly reviewing and enhancing our information security measures. We take reasonable effort to implement appropriate administrative, technical, personnel, and physical measures (a) to safeguard personal information against loss, theft, unauthorized use, copying,  disclosure, or modification; and (b) to ensure the integrity of the personal information. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is 100% secure, in particular the transmission of data over open or public networks. Therefore, we recommend against transmitting any confidential or sensitive data over open or public networks.

 

Access, Correction and Withdrawal

 

You may request to access and/or correct the personal information currently in our possession pr withdraw your consent for the collection, use and disclosure of your personal information in our possession or under our control at any time by contacting us at concierge@spectrum.global.

 

For a request to access personal information, we will process your request and provide a copy of the requested information within a reasonable amount of time from when the request is made.

 

For a request to correct personal information, we will process your request as soon as practicable after the request has been made. Such correction may involve necessary verification, which may include sending the corrected personal information to other organisations to which the personal information was disclosed by SPECTRUM within a year before the date the correction was made (unless that other organisation does not need the corrected personal information for any legal or business purpose), or if you so consent, only to specific organisations to which the personal information was disclosed by us within a year before the date the correction was made.

 

We may also charge a reasonable fee for the handling and processing of your requests to access and/or correct your personal information. You will be notified in advance of such costs.

 

For a request to withdraw your consent to the processing of your personal information, we will process your request within a reasonable amount of time from when the request is made. Our ability to provide services to you after such withdrawal may be affected. We will notify you of any impact before processing your request.

 

 

Retention of Data

 

Any personal information in our possession or under control will be destroyed and/or anonymised when:

 

  • the purpose for which the personal information was collected is no longer served by the retention of such personal information; or
  • the retention is no longer necessary for any legal, regulatory, or business purposes.

 

Transfer of Personal Information to Other Countries

 

Some of the uses and disclosures mentioned in this Privacy Policy may involve the transfer and processing of your personal information to and in various countries around the world that may have different levels of privacy protection than your country. By submitting your personal information, you consent to such transfers and processing. We take reasonable steps to ensure that appropriate levels of protection necessary to maintain the security and integrity of your personal information are in place and that any transferred data is processed only in accordance with the PDPA, the GDPR and any other applicable law.

 

Cookies and Other Electronic Tools

 

In addition to personal information that you provide to us, we may collect certain information about you that is not generally or uniformly considered personal information and which we consider to be non-personal information. This information is collected through cookies, web server logs, web beacons, or other similar technologies when you browse our websites or use any applications created by us or on our behalf.

 

This information may include the IP address of your computer, browser type, language, operating system, your mobile device, geo-location data, the state or country from which you accessed the web site, the web pages visited, the date and the time of a visit, the number of links you click within the web site, the functions you use on this web site, the databases you view and the searches you request, the data you save on or download from this Website but does not identify you individually.

 

Most browsers are set to accept cookies by default. If you prefer, you can usually set your browser to disable cookies, or to alert you when cookies are being sent. Likewise, most mobile devices allow you to disable the ability for geo-location information to be collected from your mobile device. However, if you disable cookies or refuse to accept a request to place a cookie, it is possible that some parts of the web site, will not function properly.

 

Links to Third Party Websites

 

We may provide links to third-party websites, including social networking websites. Since we do not control third-party sites and are not responsible for any information you may provide while on such sites, we encourage you to read the privacy policies on those websites before providing any of your information on such sites.

 

Telemarketing Policy

 

If you have registered your Singapore telephone number with the relevant Singapore DNC registers, we will not send you promotional and marketing messages via SMS, fax, calls and other means (as applicable).    However, if you have previously consented to our sending you such messages to your Singapore telephone number(s), we will continue to do so until you withdraw such consent, regardless of your DNC nominations.

 

Also, if you currently have an existing, ongoing relationship with us, depending on the nature of that relationship, we may continue to send you promotional or marketing messages via SMS, fax, calls or any means, about products and services which are related to that ongoing relationship notwithstanding your registration with the DNC Registry, unless you opt-out of receiving such messages.

 

Questions or Feedback

 

If you have any questions about this privacy policy or any other queries in relation to how we manage, protect and/or process your personal information, please contact us at concierge@spectrum.global.

 

Updates

 

This privacy policy may be updated from time to time.

 

Last updated 1 December 2021