LEGAL DISCLAIMER
The information contained in this site is for general guidance on matters of interest only. The application and impact of laws can vary widely based on the specific facts involved. Given the changing nature of laws, rules and regulations, and the inherent hazards of electronic communication, there may be delays, omissions or inaccuracies in information contained in this site. Accordingly, the information on this site is provided with the understanding that the authors and publishers are not herein engaged in rendering legal, accounting, tax, or other professional advice and services. As such, it should not be used as a substitute for consultation with professional accounting, tax, legal or other competent advisers. Before making any decision or taking any action, you should consult a Jed Tax professional.
While we have made every attempt to ensure that the information contained in this site has been obtained from reliable sources, Jed Tax is not responsible for any errors or omissions, or for the results obtained from the use of this information. All information in this site is provided “as is”, with no guarantee of completeness, accuracy, timeliness or of the results obtained from the use of this information, and without warranty of any kind, express or implied, including, but not limited to warranties of performance, merchantability and fitness for a particular purpose.
In no event will Jed Tax, its related partnerships or corporations, or the partners, agents or employees thereof be liable to you or anyone else for any decision made or action taken in reliance on the information in this Site or for any consequential, special or similar damages, even if advised of the possibility of such damages.
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JED TAX PRIVACY POLICY (“POLICY”)
This Policy sets out the manner in which Jed Tax Consulting Pte. Ltd. (“Jed Tax”) collects, uses, manages and protects Personal Data (as defined below) in compliance with the provisions of the Personal Data Protection Act 2012 (“PDPA”).
This Policy applies to all Individuals (as defined below) who provide Jed Tax with Personal Data or whose Personal Data is otherwise collected, used and/or disclosed by Jed Tax in connection with and/or for the purposes of its operations.
This Policy supplements but does not supersede or replace any previous consent which an Individual may have provided to Jed Tax, nor does it affect any rights that Jed Tax may have at law in connection with the collection, use and/or disclosure of any Individual’s Personal Data.
Subject to that, Jed Tax will not collect any Personal Data from an Individual unless the Individual has voluntarily chosen to provide us with the Personal Data or as required for the purposes of providing services to the Individual or by law.
Jed Tax may from time to time update this Policy to ensure it is consistent with its future developments or business purposes or to accommodate future changes to applicable legal or regulatory requirements. All updates to this Policy will be published at www.jedtax.com (“Jed Tax Website”) and appropriate notifications of any material revisions will be published on the Jed Tax Website and may be issued separately to relevant persons such as may be determined by Jed Tax. Subject to an Individual’s rights at law, the prevailing terms of the Policy from time to time shall apply. By continuing their relationship with Jed Tax after any amendments have been introduced and published on the Jed Tax Website, Individuals shall be deemed to have accepted the Policy as amended.
For the avoidance of doubt, this Policy forms part of the terms and conditions, if any, governing an Individual’s specific relationship with Jed Tax (“Terms and Conditions”) and should be read in conjunction with such Terms and Conditions. In the event of any conflict or inconsistency between the provisions of this Policy and the Terms and Conditions, the provisions of the Terms and Conditions shall prevail to the fullest extent permissible by law.
Definitions: For purposes of this Policy:“Individual” means a natural person, whether living or deceased and “Individuals” shall be construed accordingly; “CCTV” means Closed-circuit Television; Personal Data means data that is capable of identifying an Individual, whether on its own or in conjunction with other data accessible to Jed Tax; “Personnel” means any Individual engaged under a contract of service with Jed Tax, a contract for service with Jed Tax, permanent or temporary employees as well as trainees and interns engaged by Jed Tax from time to time; and “Potential Personnel” means any Individual who has submitted an application to be engaged by Jed Tax as Personnel.
Personal Data collected by Jed Tax
Jed Tax will only collect, use or disclose Personal Data about an Individual which it reasonably considers necessary for the relevant purposes underlying such collection, use or disclosure. Depending on the specific nature of an Individual’s interaction with Jed Tax, Personal Data which Jed Tax collects, uses or discloses concerning an Individual may variously include but is not limited to the following:
1) the Individual’s name, gender and contact particulars, including telephone number(s), residential/mailing address(es) and email address;
2) details of the Individual’s identification documents (such as, NRIC or passport numbers), and applicable visa or permits (such as employment pass, work permit, permanent residency status);
3) details of the Individual’s employment history and academic qualifications;
4) the name and contact particulars of the Individual’s next-of-kin;
5) the Individual’s network usage data and other information gathered automatically by our computer systems, including the Individual’s computer IP address, links visited and other activities conducted online or using our computer systems;
6) photographs and video or CCTV recordings of the Individual; and
7) other information which the Individual may provide to Jed Tax, from time to time, in the course of such Individual’s interaction with Jed Tax.
How Jed Tax collects Personal Data
Generally, Jed Tax may collect Personal Data from an Individual in one or more of the following ways or circumstances:
1) when the Individual interacts with Jed Tax’s staff via telephone calls, emails, other correspondence and/or face-to-face meetings;
2) when the Individual visits Jed Tax’s premises;
3) when the Individual specifically requests that Jed Tax contact him or her or requests to be included in an email or any mailing list maintained by Jed Tax;
4) when the Individual responds to any request by Jed Tax for the provision of Personal Data;
5) when Jed Tax receives references or referrals from its business partners or other third parties;
6) when the Individual attends or participates in any event organised by Jed Tax;
7) when the Individual submits his or her Personal Data to Jed Tax pursuant to a job application;
8) when the Individual subscribes to Jed Tax’s publication(s); and/or
9) when the Individual submits his or her Personal Data to Jed Tax for any other reason related to Jed Tax’s ordinary course of business operations.
Purposes of collection, use and disclosure of Personal Data
Generally, Jed Tax collects, uses and/or discloses Personal Data from Individuals for one or more of the following purposes:
Provision of services
1) administering and managing the Individual’s relationship with Jed Tax;
2) providing the Individual with information about Jed Tax’s services and/or the services of any external vendor that is providing services or products in partnership or collaboration with Jed Tax;
3) responding to the Individual’s complaints, queries and/or requests;
4) facilitating and/or organising events;
5) informing the Individual of changes and/or updates to Jed Tax’s policies, terms and conditions and/or other administrative information;
Security measures
1) verifying the Individual’s identity or monitoring the Individual’s activities, including without limitation via CCTV observation and/or recording;
2) preventing, detecting and investigating fraud, misconduct, any unlawful action, omission or dispute, and whether or not there is any suspicion of the aforementioned;
General business operations of Jed Tax
1) staff training, quality assurance and performance evaluation;
2) record-keeping;
3) compliance purposes (including but not limited to the Individual obtaining corporate governance advice);
4) meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines which are binding on Jed Tax (including but not limited to responding to regulatory complaints, disclosure to regulatory bodies and conducting audit checks, due diligence and investigations);
Managing Personnel and Potential Personnel
1) administering, managing and/or terminating Jed Tax’s relationship with Personnel and Potential Personnel;
2) evaluating the performance of Personnel;
Marketing where Jed Tax circulates Jed Tax’s publications or marketing information to an Individual or to any person which may be disseminated to and individual relating to services offered by Jed Tax (whether by Jed Tax or Jed Tax’s business partners) which Jed Tax thinks is or may be of benefit or interest to him/her via postal mail, electronic transmission to his or her or any email address(es), and/or voice call or phone call and/or fax to his or her or any telephone number(s);
1) for promotional and publicity purposes, including recording or taking photographs of participants at events or functions organised, hosted or participated by Jed Tax;
Others
1) for transfer to third party data intermediaries to facilitate any of the aforesaid purposes;
2) for any purposes reasonably related to any of the above purposes; and
3) for any other purposes in relation to which Jed Tax has specifically obtained the Individual’s consent.
Consent
Unless otherwise authorised under the PDPA or any other applicable law, Jed Tax will not collect, use or disclose an Individual’s Personal Data without his or her consent.Jed Tax will take reasonable steps to highlight the purposes relevant to an Individual, by appropriate means, at the point or time of collection of the Personal Data from such Individual, including:
1) via express provisions in contracts, application forms and/or registration forms to be signed with or submitted to Jed Tax;
2) via notifications on Jed Tax’s websites;
3) in the course of verbal communications;
Where feasible, Jed Tax will inform the Individual of purposes that are intrinsic to the relationship between Jed Tax or to the provision of services to such Individual, as well as purposes that are optional.
In so far as any purpose(s) are intrinsic to the relationship or provision of services, Jed Tax reserves the right to decline to engage in the relevant relationship or to provide the relevant services to the Individual if he or she does not consent to Jed Tax’s collection, use or disclosure of his or her Personal Data for such purpose.
Individuals who:
1) Jed Tax voluntarily provide their Personal Data to Jed Tax for the specified purposes;
2) use or access Jed Tax’s website(s) or computer network;
3) enter Jed Tax’s premises or using any of the facilities thereon; and/or
4) attend or participate in events or programmes organised by Jed Tax.
will be deemed to agree and consent to Jed Tax collecting, using and/or disclosing their Personal Data in the manner and for the purposes set forth in this Privacy Policy.
An Individual who provides Jed Tax with Personal Data relating to a third party (e.g. information of his or her spouse or children) for any particular purpose, represents to Jed Tax that he/she has obtained the consent of the relevant third party to Jed Tax collecting, using or disclosing such Personal Data for the relevant purpose.
In so far as Jed Tax collects Personal Data of an Individual from any third party(ies), Jed Tax will take reasonable steps to inform the relevant third party(ies) of Jed Tax’s purposes for collecting the Personal Data and to verify that consent from the Individual has been obtained by the relevant third party(ies) to such disclosure for the intended purpose.
Disclosure of Personal Data
In carrying out one or more of the above Purposes, Jed Tax may need to disclose Individuals’ Personal Data to the following third parties for one or more of the above Purposes:
1) to Jed Tax’s third party service providers or agents;
2) any external vendor Jed Tax;
3) to Jed Tax’s auditors and professional advisors;
4) any person to whom disclosure is permitted or required by any statutory provision or law;
5) any permitted assigns; and/or
6) to any local or foreign regulatory body, government agency, statutory board, ministry, department or other government body and/or its officials.
Withdrawal of Consent
Any Individual who wishes to withdraw his or her consent to any use or disclosure of his or her Personal Data by Jed Tax as set out in this Policy may do so by contacting Jed Tax’s Data Protection Officer at contact@jedtax.com. Depending on the extent to which an Individual withdraws consent to the use or disclosure of his or her Personal Data by Jed Tax, such withdrawal of consent may result in Jed Tax’s inability to provide services to the Individual and may be considered as a termination by the Individual of any agreement between Jed Tax and the Individual. Jed Tax’s legal rights and remedies are expressly reserved in such event. In so far as an Individual’s data is being collected by cookies, the Individual may disable the use of cookies on his or her internet browser when accessing Jed Tax’s Website. However, this may result in the loss of functionality, restrict the Individual’s use of the website and/or delay or affect the way in which Jed Tax’s website operates.
Verification of Personal Data & Notification of Changes.
Where feasible, Jed Tax will take reasonable steps to verify the accuracy of Personal Data received at the point of collection but Individuals remain primarily responsible and liable to ensure that all Personal Data submitted by them to Jed Tax is complete and accurate. Information voluntarily provided by an Individual to Jed Tax shall prima facie be deemed complete and accurate.Jed Tax will also take reasonable steps to periodically verify Personal Data in its possession, taking into account the exigencies of its operations, but Individuals are nonetheless responsible for notifying Jed Tax, from time to time, of any applicable changes to such Personal Data. Jed Tax shall not be held liable for any inability on its part to provide services to an Individual who fails to ensure that his or her Personal Data submitted to Jed Tax is complete and accurate or who fails to notify Jed Tax of any relevant changes to such Personal Data.
Protection of Personal Data.
Jed Tax shall make reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks to Personal Data in its possession.
If Jed Tax transfers Personal Data outside Singapore, Jed Tax will take reasonable steps to ensure that such Personal Data transferred receives a standard of protection comparable to the protection received under the PDPA and such transfer shall be subject to this Policy. Jed Tax will ensure that third parties who receive Personal Data from Jed Tax protect such Personal Data in a manner consistent with this Policy and not use such Personal Data for any purposes other than those specified by Jed Tax, by incorporating appropriate contractual terms in its written agreements with these third parties. Jed Tax is not responsible in any way for the security and/or management of Personal Data shared by Individuals with third party websites accessible via links on Jed Tax’s website.
Contacting Jed Tax-Access and Correction of Personal Data
Any Individual who:
1) has questions or feedback relating to this Policy;
2) would like to obtain access to his or her Personal Data held by Jed Tax;
3) would like to obtain information about the ways in which his or her Personal Data held by Jed Tax has been or may have been used or disclosed by Jed Tax in the year preceding the request; and/or
4) would like to update or make corrections to his or her Personal Data held by Jed Tax,
should contact Jed Tax’s Data Protection Officer at contact@jedtax.com.
Individuals should note that Jed Tax is not required, under the PDPA, to provide access and correction to Personal Data in certain exempted situations as set out in the PDPA.
The PDPA allows and Jed Tax reserves the right to charge a reasonable fee for the handling and/or processing of access requests by an Individual pursuant to paragraphs (b) or (c) above.
Governing Law
This Policy shall be governed by and construed in accordance with the laws of Singapore. Any dispute arising out of or in connection with this Policy including any question regarding its existence, validity or termination, shall be referred to and finally resolved by the Courts of Singapore.
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