Singapore – PDPA Policy Statement

 

Personal Data Protection Policy Statement

  1. Introduction

1.1. JB Foods Global Pte Ltd (“JBFG”)

1.2. acts as the (main subsidiary of JB Foods Ltd).  JB Foods Global Pte Ltd shall be referred to as “JBFG”.

1.3. This document outlines the policy implemented by JB Foods Global Pte Ltd in regards to  the management, collection, usage and disclosure of personal data.

1.4. This Policy applies to Contractors, Vendors, Customers and/or any external parties.

1.5.  If there is conflict between this policy and current legislation, the latter shall prevail.

 

  1. Purpose

2.1. Organisations that collect, use and disclose personal data are required to develop and implement policies and practices that comply with the Personal Data Protection Act 2012 (“PDPA”). The intention of the PDPA is to address concerns from individuals about how their personal data is being used and maintain their trust in organisations that manage the data.

2.2. JB Foods Global Pte Ltd will ensure that:

2.2.1. only fair, proper and legitimate means are employed to collect personal data;

2.2.2. personal data collected and used is accurate;

2.2.3. personal data is protected by appropriate safeguards and made available only to authorised persons; and

2.2.4. individuals have the right to access and request the editing of their personal data.

 

  1. Compliance with PDPA

3.1. JB Foods Global Pte Ltd is required to:

3.1.1. Develop and implement policies that are necessary to meet the obligations of the PDPA;

3.1.2. Develop a process to receive and respond to complaints that may arise with respect to the application of the PDPA;

3.1.3. Communicate to Contractors information about JB Foods Global Pte Ltd’s policies and practices; and

3.1.4. Make information available on request about the policies and practices and complaint process

 

  1. Personal Data Protection Principles

4.1. In handling personal data, JB Foods Global Pte Ltd abides by the following personal data protection principles:

4.2. Notification of purpose and consent

4.2.1. Unless otherwise required or permitted by law, JB Foods Global Pte Ltd will notify the individual of the purposes for which JB Foods Global Pte Ltd intends to collect, use and/or disclose personal data. This will occur on or before the time of the collection, use and/or disclosure. JB Foods Global Pte Ltd will limit the personal data collected to that which is necessary for, or related to, these purposes;

4.2.2. Unless otherwise required or permitted by law, JB Foods Global Pte Ltd will only collect, use or disclose personal data with consent; and

4.2.3. An individual may withdraw their consent for JB Foods Global Pte Ltd to collect, use and disclose their personal data.

4.3. Access and correction

4.3.1. Upon request, JB Foods Global Pte Ltd will provide an individual with access to their personal data and information about the ways in which their personal data may have been used and/or disclosed in the past year, as required or permitted by laws;

4.3.2. An individual may also verify the accuracy and completeness of their personal data, and may request that it be amended, if appropriate. JB Foods Global Pte Ltd will respond to these requests in accordance with its personal data practices and policies and in accordance with the law.

4.4. Accuracy

4.4.1. JB Foods Global Pte Ltd aims to keep records of personal data accurate and up to date as is necessary to fulfil the purposes for which the data was collected and used. For this reason, individuals are required to update their personal data by informing JB Foods Global Pte Ltd of any changes promptly.

4.5. Safeguards

4.5.1. JB Foods Global Pte Ltd will protect personal data with security safeguards that are reasonable and appropriate to the sensitivity of the personal data, in order to protect it from unauthorized access, use or disclosure.

4.6. Retention

4.6.1. JB Foods Global Pte Ltd complies with applicable regulatory requirements with respect to the retention of personal data.

4.7. Openness

4.7.1. JB Foods Global Pte Ltd has appointed designated individuals who are responsible for monitoring ongoing compliance with the PDPA.

4.7.2. JB Foods Global Pte Ltd will make information about personal data protection policies, practices and complaint process available to you through this Statement, and upon request.

 

  1. Personal Data

5.1. Personal data is defined in the PDPA as “data, whether true or not, about an individual who can be identified:

5.1.1. From that data; or

5.1.2. From that data and other information which the organisation has or is likely to have access”.

5.2. Examples of personal data include:

5.2.1. Personal particulars, such as name, NRIC Number, Passport number or other personal identification number;

5.2.2. Contact details such as your telephone number, email address, or fax number;

5.2.3. Information about personal use of JB Foods Global Pte Ltd.’s websites and services, including cookies, IP addresses, subscription account details and membership detail; and

5.2.4. Any other information relating to you which you have provided us in any form you may have submitted to us, or in other forms of interaction with individuals.

5.2.5. Financial, bank details and other personal data including credit card details, gender, nationality, race, marital status, including details of nominees;

5.2.6 Service performance and conduct reports, and service fee reviews, records relating to non-availability for service;

5.3. Provisions of the PDPA do not apply to the following categories of personal data:

5.3.1. Personal data about an individual contained in a record that has been in existence for at least 100 years;

5.3.2. Personal data about a deceased individual who has been dead for more than 10 years; and

5.3.3. Business contact information, which is defined as “an individual’s name, position name or title, business telephone number, business address, business email address, or business fax number or any other similar information about the individual, not provided by the individual solely for his/her personal purpose.”

 

  1. How Personal Data is Collected

6.1. A non-exhaustive list of how data is collected:

6.1.1. When an individual contacts JB Foods Global Pte Ltd via form submission on our website or through email;

6.1.2. When an individual interacts with JB Foods Global Pte Ltd during face-to-face meetings or through tele-conferencing;

6.1.3. When an individual submits a job application

6.1.4. When an individual asks to be included in an email or mailing list;

6.1.5. When an individual responds to any market surveys conducted by JB Foods Global Pte Ltd;

6.1.6. When an individual browses JB Foods Global Pte Ltd’s website and social media pages.

 

  1. How Personal Data is Used

7.1. JB Foods Global Pte Ltd might use personal data to:

7.1.1. confirm personal identity;

7.1.2. confirm the accuracy of the information collected;

7.1.3. properly administer the services JB Foods Global Pte Ltd provides;

7.1.4. communicate and respond to queries or instructions;

7.1.5. provide ongoing information and services;

7.1.6. make payments;

7.1.7. recover any debts owed to JB Foods Global Pte Ltd;

7.1.8. detect, investigate and prevent fraud, or other unlawful or improper activities;

7.1.9.  comply with all legal and regulatory requirements within and outside Singapore including disclosures to judicial, regulatory, government, statutory authorities and industry entities;

7.1.10.  resolve complaints, and handle requests for data access or correction;

7.1.11.  conduct compliance monitoring and audit reviews;

7.1.12. compile statistics to design and improve services, or participate in industry exercises and studies;

7.1.13. conduct research to understand current and future needs, for example, to conduct surveys and other forms of market research and analysis;

7.1.14. perform any functions and activities related to products or services, including but not limited to marketing, audit, reporting, research, analysis and finance;

7.1.15. conduct checks with the National Do Not Call Registry and our internal Do Not Call Registry;

7.1.16. comply with any contractual or other commitment or arrangement with local or foreign regulators, governmental bodies, or industry recognised bodies (whether within or outside Singapore) that is assumed by or imposed on us

7.1.17. exercise any rights JB Foods Global Pte Ltd may have in connection with the provision of services;

7.1.18. enable an actual or proposed assignee, transferee, participant or sub-participant of our rights or business to evaluate the transaction intended to be the subject of the assignment, transfer, participation or sub-participation;

7.1.19. for any other purposes specifically provided for in any particular product or service offered by JB Foods Global Pte Ltd or permitted or required by law or the relevant authorities.

7.2.

7.2.1. to administer the relationship, including the verification of your identity and/or the identity of your proxy (as may be applicable);

7.2.2. to inform you of JB Foods Global Pte Ltd’s performance and any relevant information and disclosures through the sending of circulars, reports, newsletters and communications;

7.2.3. to communicate changes and development to JB Foods Global Pte Ltd policies, terms and conditions and other administrative information; and

7.2.4. any other purpose relating to any of the above.

7.3. If an individual is a prospective Contractor/Vendor:

7.3.1. to provide or to obtain references for background screening/vetting;

7.3.2 processing service applications including quotations from you;

7.3.3 determining and reviewing service fee and/or package and terms;

7.3.4 consideration for service determination and allocation and/or development, secondment or transfer, performance monitoring, health and safety administration and security and access control;

7.3.5. monitoring compliance with our internal rules and guidelines, policies and SOPs;

7.3.6. complying with the compliance and disclosure requirements of any and all governmental and/or quasigovernmental departments and/or agencies, regulatory and/or statutory bodies;

7.3.7. to enforce our rights under any applicable laws to defend our rights under the law including but not limited to any disciplinary action or actions relating to the termination or dismissal of contract service;

7.3.8. to process service and declarations forms that require the transfer of Personal Data into it: Application Forms for the purposes of Access Card, Car Sticker; This list is non-exhaustive;

7.3.9. to process and tract service providers attendance through the use of biometric systems inclusive but not limited to electronic fingerprint collection or signature matching;

7.3.2. any other purposes relating to the aforesaid.

 

  1. Whom Personal Data is Disclosed to

8.1. Personal data held by JB Foods Global Pte Ltd will be kept confidential, but it may be disclosed or transferred to the following persons and/or entities (whether within or outside Singapore) for any of the purposes set out in paragraph below:

8.1.1. any other purposes relating to the aforesaid.

8.1.2. any person in connection with any claims made by or against or otherwise involving an individual in respect of any services;

8.1.3. any agent, contractor or third-party service provider who provides administrative, consultative, telecommunications, computer, information technology, payment, data processing or storage in connection with the operation of our business, including any custodian, administrator, investment manager, investment advisor or distributor;

8.1.4. any credit reference agencies or, in the event of default, any debt collection agencies;

8.1.5. any financial advisor, bank partner, broker, introducer or other intermediary (including their employees);

8.1.6. reinsurers (including proposed reinsurers) and medical service providers;

8.1.7. any person which has undertaken to JB Foods Global Pte Ltd to keep such personal data confidential;

8.1.8. any person to whom JB Foods Global Pte Ltd is under an obligation or otherwise required to make disclosure under the requirements of any laws, rules, regulations, codes of practice, guidelines or guidance binding on or applicable to us including but not limited to any local or foreign regulators, governmental bodies, or industry recognised bodies; or

8.1.9. any person to whom are under an obligation or otherwise required to make disclosure pursuant to any contractual or other commitment or arrangement with local or foreign regulators, governmental bodies, or industry recognised bodies that is assumed by or imposed on us by reason of its financial, commercial, business or other interests or activities in or related to the jurisdiction of the relevant local or foreign regulators, governmental bodies, or industry recognised bodies

 

  1. Withdrawal of Consent

9.1. An individual may withdraw consent for JB Foods Global Pte Ltd to collect, use and/or disclose his/her personal data for any purpose (e.g. the sending of marketing messages) by contacting JB Foods Global Pte Ltd directly. Upon receipt of notice to withdraw consent, JB Foods Global Pte Ltd will inform of the likely consequences of the consent withdrawal. In some cases, withdrawing consent may have an impact on JB Foods Global Pte Ltd ability to provide information and applicable services to the individual.

 

  1.  Failure to supply personal data
  • Contractors’ ought to be aware that failure to supply such data will result in us being unable to process service applications, or that it would affect our ability to perform our obligations under any potential or existing service contract and/or your ability to enjoy the benefits of your partnership with us.
  • If an application for service is successful, data about Contractors, including sensitive personal data, may also be collected from Contractors during the period of their service with us and from other sources such as third-party background checks, any registered credit reporting agency, any regulatory authorities and any authority, central depository or depository agent in relation to the securities industry.

 

11.     Transfer of Personal Data Outside Singapore

11.1. JB Foods Global Pte Ltd operates its business in Singapore and for contractual, legal or business reasons, it may transfer personal data to service providers located outside of Singapore. JB Foods Global Pte Ltd will use legally binding instruments and other safeguards to ensure that appropriate levels of necessary protection to maintain the security of personal data are in place and that any transferred personal data is processed only in accordance with the Act and any other applicable laws and regulations.

 

12.     Use of Cookies

12.1. Cookies are small text files that may be automatically stored on a web browser that can be retrieved by JB Foods Global Pte’s website. JB Foods Global Pte Ltd may use cookies to enable or enhance the functionality of the website, and/or to analyse visitor traffic for marketing or other purposes. JB Foods Global Pte Ltd may also use web analytic consultants to research certain usage and activities on parts of the website. Cookies can make our website more useful by storing information about your preferences, thus enabling us to provide a more personalised service.

12.2. Most web browsers are initially set to accept cookies. Individuals can adjust settings on their web browser so that they will be notified when receiving a cookie. If preferred, an individual can set your web browser to disable cookies. However, by disabling them, certain functions of the website might be disabled

 

13.     Changes to Statement of Personal Data Protection

13.1. JB Foods Global Pte Ltd reserves the right to modify or change this Policy at any time. The date as stated below indicates the last time this Statement was materially revised. JB Foods Global Pte Ltd urges individuals to review this webpage periodically to read and understand latest policies regarding the handling of personal data.

 

Contact Information
The Data Protection Officer
Data.protection@jbcocoa.com