USE AND COLLECTION OF DATA
Personal Data refers to data, whether true or not, about an individual who can be identified from that data; or from that data and other information to which Hello Tomorrow APAC has or likely to have access.
We will collect, use and disclose your Personal Data in accordance with the Act. The Act establishes a data protection law that comprises various rules governing the collection, use, disclosure and care of Personal Data. It recognises both the rights of individuals to protect their Personal Data, including rights of access and correction, and the needs of organisations to collect, use or disclose Personal Data for legitimate and reasonable purposes.
In general, subject to applicable exceptions permitted in the Act, 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 consent for the collection, use and/or disclosure of your Personal Data for the intended purpose.
Hello Tomorrow APAC organises activities in which external stakeholders or the general public are invited to participate. While it is impossible to list all the events in which we hope the public will participate, some events that you as a member of the public can look forward to include community outreach programmes, talks, seminars, conferences, the Hello Tomorrow APAC Challenge and many others (“Events”). Naturally, in encouraging a vibrant interaction with the public, there will be opportunity, and often a need, to collect, use and/or disclose Personal Data from members of the public. Some of the reasons/ purposes are as follows:
• For security/ verification purposes for certain Events
• For logistical/ administrative purposes for certain Events (e.g. food catering)
• To keep you updated of future Events/ products which we feel may interest you
• For marketing/ publicity purposes (e.g. photographs)
In almost all of the above situations, it will be totally up to you as to whether, and to what extent, you wish to provide us with your Personal Data. For Events where such provision of Personal Data is a pre-requisite to attendance, you shall be informed in advance so that you may make an informed decision as to whether to attend. Hello Tomorrow APAC will also endeavour at all times to inform you of the purposes for which Personal Data collected from you will be used. Should you at any time feel that the manner in which Hello Tomorrow APAC has acted, or seeks to act, in respect of the collection, use or disclosure of Personal Data for an Event is inappropriate, please feel free to make your concerns known to the Data Protection Officer, who can be contacted at [email@example.com].
DISCLOSURE OF INFORMATION
Hello Tomorrow APAC will not disclose your information beyond what is reasonable. Generally, we will not disclose your Personal Data to any third parties without first obtaining your consent permitting us to do so or unless any such disclosure is permitted under any of the statutory exemptions under the Act. In this respect, please note that we may disclose your Personal Data to third parties in certain circumstances without first seeking your consent, if such disclosure is either required or permitted under the Act, including without limitation, if the disclosure is required by law and/or regulations or if there is an emergency. Subject to any applicable law or regulations, Hello Tomorrow APAC may reasonably disclose your information to the following parties:
• as may be required by any government, statutory, or regulatory authority, or to comply with any applicable law, court order, directive, or proceeding of such authority;
• our agents, affiliates, professional advisors;
• as may be required for Hello Tomorrow APAC to enforce any of its rights or defend any action;
• any of your agents;
• any other party to whom you authorise us to disclose your Personal Data to;
• to the Hello Tomorrow Organisation or its affiliates.
Hello Tomorrow APAC will under no circumstances sell or rent your information to third parties.
AMENDMENTS AND REMOVAL OF INFORMATION/WITHDRAWAL OF CONSENT
You may amend or remove any Personal Data you have provided us, and/or withdraw your consent to allow us to use your information by sending us an email to Hello Tomorrow APAC’s designated data protection officer at [firstname.lastname@example.org]. For a request to withdraw consent, we will process your request within a reasonable time from such a request for withdrawal of consent being made. In some cases, requests for withdrawal of consent may adversely impact your relationship with Hello Tomorrow APAC as it may hinder Hello Tomorrow APAC’s ability to continue to interact with you. We will notify you in advance of such impact, if any.
You agree to submit to the non-exclusive jurisdiction of the courts of the Republic of Singapore.
The GDPR framework applies to all businesses processing and holding the personal information of natural persons residing in the European Union, regardless of where the business is located. More information on the GDPR is available on https://www.pdpc.gov.sg/-/media/Files/PDPC/PDF-Files/Resource-for-Organisation/eu-gdpr-factsheet--041017.pdf and https://www.eugdpr.org/
Science & Stories Pte. Ltd. (“Hello Tomorrow APAC”) would need to collect, store and process your personal data for legitimate purposes in order to carry out its functions and activities to serve you. Hello Tomorrow APAC may either be a Controller or a Processor of your personal data. Either way, Hello Tomorrow APAC is committed to full compliance with the GDPR with respect to your personal data.
Hello Tomorrow APAC’s Data Protection Officer is responsible for informing and advising Hello Tomorrow APAC and its staff on its data protection obligations, and for monitoring compliance with those obligations. If you have any questions or comments about the content of this Privacy Statement or if you need further information, you should contact the Data Protection Officer via email at [email@example.com].
“Personal data” means any information relating to an identified or identifiable natural person (referred to as a ‘data subject’); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that person.
“EU Data Subjects” in this Privacy Statement means natural persons who are citizens of any Member State of the European Union (EU) or non-EU citizens who reside in the EU.
2. Protection principles
Hello Tomorrow APAC will comply with the following data protection principles when processing personal data:
(1) we will process personal data of EU Data Subjects lawfully, fairly and in a transparent manner;
(2) we will collect personal data of EU Data Subjects for specified, explicit and legitimate purposes only, and will not process it in a way that is incompatible with those legitimate purposes;
(3) we will only process the personal data of EU Data Subjects that is adequate, relevant and necessary for the relevant purposes;
(4) we will keep accurate and up to date personal data of EU Data Subjects, and take reasonable steps to ensure that inaccurate personal data are deleted or corrected without delay;
(5) we will keep personal data of EU Data Subjects in a form which permits identification of EU Data Subjects for no longer than is necessary for the purposes for which the personal data are processed; and
(6) we will take appropriate technical and organisational measures to ensure that personal data of EU Data Subjects are kept secure and protected against unauthorised or unlawful processing, and against accidental loss, destruction or damage.
Hello Tomorrow APAC is also responsible to demonstrate compliance with the above data protection principles.
3. Basis for processing personal data
In relation to any processing activity that involves personal data, we will before the processing starts for the first time:
(1) review the purposes of the particular processing activity, and select the most appropriate lawful basis for that processing, that is:
• that the EU Data Subject has consented to the processing;
• that the processing is necessary for the performance of a contract to which the EU Data Subject is party or in order to take steps at the request of the EU Data Subject prior to entering into a contract;
• that the processing is necessary for compliance with a legal obligation to which Hello Tomorrow APAC is subject;
• that the processing is necessary for the protection of the vital interests of the EU Data Subject;
• that the processing is necessary for the performance of a task carried out in the public interest or exercise of official authority by Hello Tomorrow APAC; or
• where Hello Tomorrow APAC is not carrying out tasks as a public authority, that the processing is necessary for the purposes of the legitimate interests Hello Tomorrow APAC or a third party, except where those interests are overridden by the interests of fundamental rights and freedoms of the EU Data Subject.
(2) except where the processing is based on consent, satisfy ourselves that the processing of personal information of EU Data Subjects is necessary for the purpose of the relevant lawful basis;
(3) document our decision as to which lawful basis applies, to help demonstrate our compliance with the data protection principles with respect to the personal information of EU Data Subjects;
(4) include information about both the purposes of the processing and the lawful basis for it in our privacy notices to EU Data Subjects; and
(5) in the event that Hello Tomorrow APAC processes sensitive personal data of EU Data Subjects, Hello Tomorrow APAC will identify a lawful special condition for processing that information (see paragraph 4 below), and document it.
4. Sensitive personal data
Sensitive personal data are personal data, revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership; data concerning health or sex life and sexual orientation; genetic data or biometric data. At the present moment the processing of sensitive personal data of EU Data Subjects is prohibited regardless of the legal basis set out in paragraph 3(1), above. We do not collect sensitive personal data.
5. Data privacy impact assessment (“DPIA”)
Where processing is likely to result in a high risk to an EU Data Subject’s data protection rights (e.g. where Hello Tomorrow APAC is planning to use a new form of technology), we will, before commencing the processing, carry out a DPIA to assess:
(1) whether the processing is necessary and proportionate in relation to its purpose;
(2) the risks to EU Data Subjects; and
(3) what measures can be put in place to address those risks and protect personal data.
6. Documentation and records
We will keep records of processing activities in accordance with the requirements of the GDPR with respect to the processing of personal information of EU Data Subjects. We will conduct regular reviews of the personal data of EU Data Subjects we process and update our documentation accordingly. This may include reviewing our policies, procedures, contracts and agreements to address areas such as retention, security and data sharing.
7. Privacy notices
Hello Tomorrow APAC will issue privacy notices from time to time, informing the EU Data Subjects from whom we collect information about the personal data that we collect and hold relating to them, how they can expect their personal data to be used and for what purposes.
We will take appropriate measures to provide information in privacy notices in a concise, transparent, intelligible and easily accessible form, using clear and plain language.
8. Individual rights
EU Data Subjects have the following rights in relation to their personal data:
(1) to be informed about how, why and on what basis that data is processed;
(2) to obtain confirmation that their data is being processed and to obtain access to it and certain other information, by making a subject access request;
(3) to have data corrected if it is inaccurate or incomplete;
(4) to have data erased if it is no longer necessary for the purpose for which it was originally collected/processed, or if there are no overriding legitimate grounds for the processing (this is sometimes known as ‘the right to be forgotten’);
(5) to restrict the processing of personal data where the accuracy of the information is contested, or the processing is unlawful (but the EU Data Subject does not want the data to be erased), or where Hello Tomorrow APAC no longer needs the personal data but the EU Data Subject requires the data to establish, exercise or defend a legal claim; and
(6) to object to the processing of personal data based on the legal basis stated in paragraph 3(1) unless Hello Tomorrow APAC demonstrates compelling legitimate grounds for the processing which override the EU Data Subject’s interests or for the establishment, exercise or defence of legal claims.
9. Information security
Hello Tomorrow APAC will use appropriate and proportionate technical and organisational measures in accordance with the Hello Tomorrow APAC’s IT Security Policy and related policies to keep personal data of EU Data Subjects secure, and in particular to protect against unauthorised or unlawful processing and against accidental loss, destruction or damage. These may include:
(1) making sure that, where possible, personal data of EU Data Subjects is password-protected or pseudonymised or encrypted;
(2) ensuring the ongoing confidentiality, integrity, availability and resilience of processing systems and services;
(3) ensuring that, in the event of a physical or technical incident, availability and access to personal data of EU Data Subjects can be restored in a timely manner; and
(4) a process for regularly testing, assessing and evaluating the effectiveness of technical and organisational measures for ensuring the security of the processing of the personal data of EU Data Subjects.
Where Hello Tomorrow APAC uses external organisations to process personal data of EU Data Subjects on its behalf, if necessary and where appropriate, additional security arrangements shall be implemented in contracts with those organisations to safeguard the security of personal data. In particular, contracts with external organisations shall provide that:
(1) the organisation may act only on the written instructions of Hello Tomorrow APAC;
(2) those processing the data are subject to a duty of confidence;
(3) appropriate measures are taken to ensure the security of processing;
(4) sub-contractors are only engaged with the prior consent of Hello Tomorrow APAC and under a written contract;
(5) the organisation will assist Hello Tomorrow APAC in providing subject access and allowing individuals to exercise their rights in relation to data protection;
(6) the organisation will assist Hello Tomorrow APAC in meeting its obligations in relation to the security of processing, the notification of data breaches and data protection impact assessments;
(7) the organisation will delete or return all personal data to Hello Tomorrow APAC as requested at the end of the contract; and
(8) the organisation will provide Hello Tomorrow APAC with whatever information it reasonably needs to ensure that they are both meeting their data protection obligations.
10. Retention of Personal Data
Personal data will be kept securely for no longer than is necessary for the purposes for which the data are processed save for where there are regulatory requirements on Hello Tomorrow APAC to retain such information. Personal data would not be retained for any longer than necessary. The length of time over which data would be retained will depend upon the circumstances, including the reasons why the personal data was obtained. Personal data that is no longer required will be deleted permanently from our information systems and any hard copies will be destroyed securely.
11. Data breaches
Hello Tomorrow APAC will:
(1) investigate any reported actual or suspected data security breach;
(2) where applicable, make the required report of a data breach to the relevant supervisory authority without undue delay and, where possible within 72 hours of becoming aware of it, if it is likely to result in a risk to the rights and freedoms of individuals; and
(3) notify the affected individuals if a data breach is likely to result in a high risk to their rights and freedoms and notification is required by law.
12. International transfers
Hello Tomorrow APAC may transfer personal data to a third country or an international organisation only if the recipient has provided appropriate safeguards (for example, by way of standard data protection clauses) or where we obtain the EU Data Subjects’ explicit consent to such transfers after they have been informed of the possible risks of such transfers.
14. Right to Amend Terms