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Personal Data Protection Act

Curator Selects Pte Ltd Data Protection Policy

This Data Protection Policy (the ‘Policy’) applies to the collection, use and disclosure of an individual customer’s Personal Data (hereinafter defined) arising from goods and/or services offered by Curator Selects Pte Ltd (‘Curator Selects’).

1. General

1.1 This Policy statement provides information on the obligations and policies of Curator Selects in respect of an individual customer’s Personal Data. Curator Selects undertakes to use reasonable efforts in applying, where practicable, those principles and the processes set out herein to its operations.

1.2 Curator Selects’s officers, management, and members of staff shall use reasonable endeavours to respect the confidentiality of and keep safe any and all Personal Data collected and/or stored and/or disclosed and/or used for, or on behalf of, Curator Selects. Curator Selects shall use reasonable endeavours to ensure that all collection and/or storage and/or disclosure and/or usage of Personal Data by Curator Selects shall be done in an appropriate manner and in accordance with the Act and this Policy.

1.3 By interacting with us, submitting information to us, or signing up for any products or services offered by us, you agree and consent to Curator Selects as well as to its respective representatives and/or agents (Representatives”) (collectively referred to herein as “Curator Selects”, “us”, “we” or “our”) collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to Curator Selects’s authorised service providers and relevant third parties in the manner set forth in this Policy Statement.

1.4 This Policy supplements but does not supersede nor replace any other consents you may have previously provided to us in respect of your Personal Data, and your consents herein are additional to any rights which we may have at law to collect, use or disclose your Personal Data.

1.5 For the purposes of this Policy, in line with the provisions under the Singapore Personal Data Protection Act 2012 (No. 26 of 2012) (the ‘Act’), ‘Personal Data’ shall mean data, whether true or not, about an individual customer who can be identified – from that data; or from that data and other information which an organisation has or is likely to have access. Such Personal Data shall also refer to that which is already in the possession of Curator Selects or that which shall be collected by Curator Selects in future.

2. Contacting the Data Protection Officer

2.1 Where you legitimately request access to and/or correction of Personal Data relating to you, such Personal Data which is in the possession and control of Curator Selects, Curator Selects shall provide and/or correct that data in a reasonable time and manner in accordance with its standard procedures as stated hereinafter.

2.2 In accordance with the Act, Curator Selects has established a process for receiving and responding to any query or complaint that may arise with respect to the application of this Act. To ensure that Curator Selects receives your complaints and enquiries, please send the same via email to the Data Protection Officer’s Team (the ‘DPO’g) of Curator Selects at the following email address: dpo@curatorselects.com.sg

2.3 Please note that if your personal data has been provided to us by a third party (e.g. a member via a referral process), you should contact that individual to make such queries, complaints, and access and correction requests to Curator Selects on your behalf.

2.4 Should you not wish Curator Selects to use your Personal Data for any of the purposes listed in Clauses 3.2 to 3.4, or not to receive promotional materials from Curator Selects, you may opt out by sending a clearly worded email to the DPO via the email address provided in Clause 2.2. Your request shall be processed within a reasonable time.

3. Statement of Practices

Types of Personal Data Collected:

3.1 As part of its day-to-day activity, Curator Selects may collect from you, through various means, including via our websites, smart phone applications, events such as road shows and any forms used by Curator Selects from time to time, some or all of the following Personal Data:

– Name (first and surname);

– Postal Address;

– Phone number (including mobile);

– Office number;

– Fax number;

– Email address;

– Gender;

– Personal Data of your emergency contacts; and

– Photographs and images.


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Purpose of Collection of Personal Data

3.2 The above Personal Data mentioned in Clause 3.1 is collected for the purposes of processing your application and registration of your application for the position opening and to ascertain if you are eligible for the position opening or other related purposes; to conduct screening and profiling; through voice calls; text messages; email; direct mail and facsimile messages; to notify you of any changes to our policies or services which may affect you; to respond to queries and feedback; maintaining and updating your personal particulars; and informing you of new developments, services of Curator Selects and other third parties which we are associated with.

Disclosure of Personal Data

3.3 In order to carry out the functions described above, Curator Selects may, from time to time, disclose your Personal Data between Curator Selects’s companies.

3.4 Without derogating from any of the above, Curator Selects may also disclose your Personal Data to the following third parties:

– Regulators and law enforcement officials;

– Lawyers;

– Auditors;

– Third party service providers and consultants;

– Credit, debit and charge card companies, banks and other entities processing payment;

– Potential buyers or investors of Curator Selects or any of Curator Selects’s companies; and

– Any agent or subcontractor acting on Curator Selects’s behalf for the provision of Curator Selects’s services.

3.5 Curator Selects may disclose your Personal Data to the abovementioned parties also in the occurrence of any of the following events:

– To the extent that Curator Selects is required to do so by the law;

– In connection with any legal proceedings or prospective legal proceedings;

– To establish, exercise or defend Curator Selects’s legal rights;

– To the purchaser (or prospective purchaser) of any business or asset which Curator Selects is (or is contemplating) selling;

– To any person and/or entity for the purpose of processing such information on Curator Selects’s behalf;

– To third parties who provide services to Curator Selects or on its behalf;

– To any third party that purchases Curator Selects or Curator Selects’s business or any part of Curator Selects or Curator Selects’s business;
– With your consent; and

– For the purposes of disaster recovery.

Optional Provision of Personal Data

3.6 In some instances, you may also be requested to provide certain Personal Data that may be used to further improve Curator Selects’s products and services and/or better tailor the type of information presented to you. In most cases, this type of data is optional although, where the requested service is a personalised service, or provision of a product or dependent on your providing all requested data, failure to provide the requested data may prevent Curator Selects from providing the service to you. This type of data includes, but is not limited to:

– Your age;

– Gender;

– Salary range and employment details;

– Education and Profession;

– Hobbies and leisure activities;

– Other related products and services subscribed to; and

– Family and household demographics.

3.7 Under certain circumstances, telephone calls made to any of Curator Selects’s companies to order and/or service hotlines and/or inquiry telephone numbers are recorded for the purposes of quality control, appraisal, as well as staff management and development. In such an event, by agreeing to this Policy, you hereby give your clear and unambiguous consent for the collection, use and disclosure of such Personal Data in accordance to this Policy.

4. Transfer of Personal Data Overseas

Your Personal Data may be processed by Curator Selects, its affiliates, agents and third parties providing services to Curator Selects, in jurisdictions outside of Singapore. In this event Curator Selects will comply with the terms of the Act.

5. Accuracy of Personal Data

Where possible, Curator Selects will validate data provided using generally accepted practices and guidelines. This includes the use of check sum verification on some numeric fields such as account numbers or credit card numbers. In some instances, Curator Selects is able to validate the data provided against pre-existing data held by Curator Selects. In some cases, Curator Selects is required to see original documentation before we may use the Personal Data such as with Personal Identifiers and/or proof of address. To assist in ensuring the accuracy of your Personal Data in the possession of Curator Selects, please inform us of any updates of any parts of your Personal Data by sending a clearly worded email to the DPO at the email address provided at Section 2.2.

6. Protection of Personal Data

Curator Selects uses commercially reasonable physical, managerial, and technical safeguards to preserve the integrity and security of your Personal Data and will not knowingly allow access to this data to anyone outside Curator Selects, other than to you or as described in this Policy. However, Curator Selects cannot ensure or warrant the security of any information you transmit to Curator Selects and you do so entirely at your own risk. In particular, Curator Selects does not warrant that such information may not be accessed, altered, collected, copied, destroyed, disposed of, disclosed or modified by breach of any of Curator Selects’s physical, technical, or managerial safeguards.

7. Access and Correction of Personal Data


7.1 In accordance with Clause 2.1 of this Policy, you have the right to:

a) check whether Curator Selects holds any Personal Data relating to you and, if so, obtain copies of such data; and

b) require Curator Selects to correct any Personal Data relating to you which is inaccurate for the purpose for which it is being used.

7.2 Curator Selects reserves the right to charge a reasonable administrative fee in order to meet your requests under Clause 7.1. Upon payment of the requisite fee, your request shall be processed within a reasonable time.

7.3 If you wish to verify the details you have submitted to Curator Selects or if you wish to check on the manner in which Curator Selects uses and processes your personal data, Curator Selects’s security procedures mean that Curator Selects may request proof of identity before we reveal information. This proof of identity will take the form of full details of name and NRIC or Passport or Fin number. You must therefore keep this information safe as you will be responsible for any action which Curator Selects takes in response to a request from someone using your Personal Data details.

8. Storage and Retention of Personal Data

Curator Selects will delete, as reasonably possible, or otherwise anonymise any Personal Data in the event that the Personal Data is not required for any reasonable business or legal purposes of Curator Selects and where the Personal Data is deleted from Curator Selects’s electronic, manual, and other filing systems in accordance with Curator Selects’s internal procedures and/or other agreements.

9. Contacting you

To the extent that any of the communication means which you have provided Curator Selects with (which may include, your telephone number and fax number) is/will be listed on the Do Not Call Registry (the ‘DNC’), by agreeing to this Policy through your signing of the Application Form with Terms and Conditions, or by any other means of indication, you hereby grant Curator Selects your clear and unambiguous consent to contact you using all of your communication means you have provided to Curator Selects including using via voice calls, SMS, Whatsapp, MMS, fax or other similar communications applications or methods, for the purposes as stated above in Paragraph 3.2. This will ensure your continued enjoyment of Curator Selects’s services

10. Change Policy

Curator Selects reserve the right to alter any of the clauses contained herein in compliance with local legislation and/or to meet its global policy requirements, and for any other purpose deemed reasonably necessary by Curator Selects. You should look at these terms regularly. If you do not agree to the modified terms, you should inform us as soon as possible of the terms to which you do not consent. Pending such notice, if there is any inconsistency between these terms and the additional terms, the additional terms will prevail to the extent of the inconsistency.

11. Governing Law

This Policy is governed by and shall be construed in accordance with the laws of Singapore. You hereby submit to the non-exclusive jurisdiction of the Singapore courts.

12. Miscellaneous

12.1 This Policy only applies to the collection and use of Personal Data by Curator Selects. It does not cover third party sites to which we provide links, even if such sites are co-branded with our logo. Curator Selects does not share your Personal Data with third party websites. Curator Selects is not responsible for the privacy and conduct practices of these third party websites, so you should read their own privacy policies before disclosure of any Personal Data to these websites.

12.2 Curator Selects will not sell your personal information to any third party without your permission, but we cannot be responsible or held liable for the actions of third party sites which you may have linked or been directed to Curator Selects’s website.