Toshin Development Singapore Pte. Ltd. ("Toshin", "we", “us” or “our”) is committed to respecting and protecting the personal data of individuals. This Privacy Policy ("Policy") sets out the basis upon which we collect, use, disclose, store and/or process personal data. Please read the following carefully to understand our practices regarding personal data and how we will treat it.

APPLICATION OF THIS POLICY

1. This Policy applies to personal data collected, used, disclosed, stored and/or processed by us in Singapore.
   
   
2. Unless you opt-out in accordance with the procedure set forth in this Policy, we may share the personal data that we collect from you with our affiliates and subsidiaries as permitted under the Personal Data Protection Act 2012 ("PDPA") and other applicable law. Such personal data may also, subject to the PDPA and other applicable law, be transferred to and used by us outside of Singapore. When personal data is collected by or transferred to us, it will be treated according to the privacy practices set forth in this Policy.
   
   

PERSONAL DATA

3. We may collect certain types of personal data in accordance with the PDPA. As used in this Policy, "personal data" means data, whether true or not, about an individual who can be identified: (a) from that data; or (b) from that data and other information to which we (and all our affiliates and subsidiaries and all relevant third parties as mentioned in this Policy) have or is likely to have access.
   
   
4. We may collect your personal data provided to us through different sources including but not limited to the following:
   1. in connection with or through the use of our website;
   2. in connection with the services we provide; and/or
   3. in connection with any prospective employment.
      
      
5. Personal data includes, without limitation, an individual's name; address; telephone number(s); email addresses; date of birth; gender; nationality; marital status; passport number, date and place of issue; NRIC number; driver's licence number and expiration; photographs and other audio-visual material; employment information; payment information; credit card numbers; preferred communication methods; and any other types of information that you choose to provide to us or that we may collect about you through their transactions with us and our affiliates and subsidiaries.
   
   

USE OF INFORMATION COLLECTED

6. We currently use and/or may in the future use your personal data for one or more of the following purposes set out below:
   1. to notify you of any marketing or promotional activities;
   2. conducting research, analysis and development activities (including but not limited to data analytics, surveys and/or profiling) to improve our products and services in order to enhance our relationship with you;
   3. to verify your identity;
   4. for managing or terminating the employment relationship;
   5. for assessing the suitability, eligibility or qualifications of a prospective job candidate;
   6. to process and respond to inquiries, requests, applications, complaints and/or feedback;
   7. for record-keeping purposes;
   8. to store, host and/or back up (whether for disaster recovery or otherwise) personal data, whether within or outside Singapore;
   9. to comply with a court order or other legal process or other statutory and/or regulatory requirements of any governmental and/or regulatory authorities; or
   10. in exceptional circumstances, such as a national emergency, security concern.
       
       

SHARING OF INFORMATION

7. We may share your personal data with and among other affiliates and subsidiaries, or with third parties including our third-party service providers and the relevant governmental and/or regulatory authorities, whether in Singapore or abroad for the aforementioned purposes.
   
   
8. In the event that we sell or buy any business or assets, we may disclose an individual's personal data to the prospective seller or buyer of such business or assets.
   
   
9. We may share anonymous or aggregate information among our affiliates and with third parties. Aggregate or anonymous information does not contain any personal data, and accordingly its use and disclosure are not subject to the terms of this Policy.
   
   
10. In circumstances where an individual has ceased to be an employee or client of ours, we may still retain that individual's records and use the information for legal and/or business purposes, including for compliance with the PDPA or other laws.
    
    

INTERNATIONAL TRANSFERS OF INFORMATION

11. In situations where we transfer your personal data to countries outside of Singapore, we shall take steps to ensure that appropriate levels of protection necessary to maintain the security and integrity of an individual's personal data are in place.
    
    

OPT-OUT

12. If you do not want your personal data to be collected, used, and/or disclosed by us in the aforementioned manner, you may withdraw your consent via email to DPO@toshin.com.sg who shall direct you to fill in the relevant form(s) accordingly.
    
    

ACCESS TO AND CORRECTION OF PERSONAL DATA

13. You may request to access or correct (including update) your personal data via email to DPO@toshin.com.sg who shall direct you to fill in the relevant form(s) accordingly. Please note that subject to the PDPA, not all information that we have collected may be available for review and that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing the access request.
    
    

DATA SECURITY

14. Toshin uses reasonable precautions to protect its personal data and store it securely. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is 100% secure.
    
    

DATA PROTECTION OFFICER / CONTACT DETAILS

15. For questions regarding this Policy or concerns on how we process personal data, please contact our Data Protection Officer: DPO@toshin.com.sg
    
    

CHANGES TO POLICY

16. As part of our efforts to ensure that we properly manage, protect and process individuals’ personal data, we will be reviewing our policies, procedures and processes from time to time.

17. We reserve the right to modify or change this Policy at any time at our sole discretion. The effective date, as stated below, indicates the last time this Policy was materially revised. Any amended Privacy Policy will be posted on our website and can be viewed at [https://www.takashimayasc.com.sg/privacy/]. Individuals are encouraged to visit our website from time to time to ensure that they are well informed of our latest policies in relation to personal data protection.

Last updated on 15 August 2022