Astute Practice PAC (“Astute”, “we” or “us”) takes the security of and our legal responsibilities around your personal data seriously. This statement explains relevant information about our processing of your personal data collected via this website.
1. General Provisions
1.1 The purpose of this policy is to inform you and provide you with an understanding of how we handle, collect, use, disclose and process personal data about you that you give us.
1.2 The data controller collecting the data described herein is Astute, the firm to which the visitor has submitted their data.
1.3 Personal data collected by Astute may be transferred to Astute’s affiliated firms, where it is necessary to meet the purpose for which the visitor has submitted their information.
1.4 By submitting data on Astute’s website, the visitor is providing consent to transborder transmission of data collected on the website for the fulfilment of their voluntary requests.
1.5 The data protection policy which is established in Singapore, governs the collection, use and disclosure of personal data submitted to Astute Practice PAC, and explains how we collect and handle personal data of individuals and comply with the requirements of the Personal Data Protection Act 2012 of Singapore and its regulation(s) (the “PDPA”).
2. Data Subject Rights
2.1 If Astute processes personal information about you, you have the following rights:
(a) Access – you have the right to access any personal data that we hold about you, subject to the requirements of the PDPA.
(b) Correction – note that the PDPA exempts certain types of personal data from being subject to your correction request as well as provides for situation(s) when correction need not be made by us despite your request.
(c) Object to Processing – you have the right to object to us processing your personal information if we are not entitled to use it any more.
(d) Deletion - when requested and practical, Astute will delete identifying information from current operational systems.
2.2 Before carrying out any request in relation to personal information, we may ask for proof of identity as well as the nature of the request, so as to assure ourselves of your identity and to be able to adequately deal with your request.
2.3 When personally identifiable information is retained, Astute assumes responsibility for keeping an accurate record of the information once a visitor has submitted and verified the data. Astute does not assume responsibility for verifying the ongoing accuracy of the content of personal information. When practically possible, if Astute is informed that any personal data collected through a website is no longer accurate, we will make appropriate corrections based on the updated information provided by the authenticated visitor.
2.4 If you would like to request for a copy of your personal data being held by us (such right being subject to applicable exemptions), or to update and/or correct the personal data which you have previously provided to us, you can send your enquiry / request to the Data Protection Officer (DPO) of Astute Practice PAC at firstname.lastname@example.org or to the below address:
Astute Practice PAC
1 Paya Lebar Link, #06-07, Paya Lebar Quarter, Singapore 408533
2.5 We will make all reasonable and practical efforts to comply with your requests, so long as it is consistent with applicable laws and professional standards.
2.6 Do note that your withdrawal of consent will not affect our ability to collect, use or disclose your personal data for a specific purpose without your consent, if the PDPA or a provision in applicable law permits us to.
3. Use of Personal Data
3.1 We may process your personal data collected through our website for the purposes outlined below:
Contract entry and performance: Should you indicate an interest in becoming a client of Astute we will use the personal data in order to take steps to enter into a contract for services with you. We may continue to use the data provided through our website in order to perform our duties under a contract with you.
Our legitimate interests: We process personal data in order to run our business, including managing our relationship with you, meeting our administrative, accounting and corporate rights and obligations, maintaining and using our IT systems and developing our business and services.
Recruitment and personnel administration: If you apply for a job through our website, we collect personal data from job applicants in order to recruit new employees.
Security, quality and risk management: Personal data may be processed in the context of maintaining security and within the scope of internal quality and risk analysis.
Direct marketing: we may process personal data for direct marketing purposes to promote and develop our services and to provide you with information we think will be of interest to you. In all cases we will give you the opportunity to opt-out of our direct-marketing activities. Opt-out can be achieved by responding using the unsubscribe options contained within the information you have received or by contacting us.
Complying with legal requirements, regulations or a professional body of which we are a member of: We are subject to legal, regulatory and professional obligations. We need to keep certain records to demonstrate that our services are provided in compliance with those obligations and those records may contain personal data.
3.2 All personal data submitted through this site may be used by us in an anonymised form to assess and improve the services delivered herein and for our wider business development activities.
4. All Data Transfers
Sharing and Transfer between Astute affiliated firms
4.1 We may provide your personal information to affiliated entities of Astute and other third parties in order to respond to your requests or inquiries, as part of a corporate transaction such as a sale, divestiture, reorganization, merger or acquisition, or where those parties handle information on our behalf.
4.2 All of these disclosures may involve the transfer of personal information to countries or regions without data protection rules similar to those in effect in Singapore or your area of residence.
5. Sharing and Transfer to Third Parties
5.1 In addition, we may transfer certain information to countries across geographical borders to third parties working with us or on our behalf.
5.2 We may store your personal information in a jurisdiction outside the country where the purpose is provided or where you are based. By providing personal information on our website, you consent to this transfer and/or storage of personal information across borders. We ensure that a standard of protection is accorded to your personal information so transferred in accordance with applicable law.
5.3 Personal information may also be disclosed to law enforcement, regulatory, or other government agencies, or to other third parties, in each case to comply with legal or regulatory obligations or requests.
5.4 Astute will not transfer the personal information you provide to any third parties for their own direct marketing use unless you give us your permission to do so or we first notify you of our intention to share data for this purpose.
6. Duration of Processing
6.1 We will retain your personal information for as long as the information is reasonably required to fulfil the purpose collection of the information or until you request that we delete that information.
6.2 We will put in place measures such that your personal data in our possession or under our control is destroyed and/or anonymised as soon as it is reasonable to assume that (a) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (b) retention is no longer necessary for any other legal or business purposes.
7. Data Security
7.1 Security of your personal data is important to us. We take appropriate action to protect personal data from loss, misuse, unauthorised access or disclosure, alteration or destruction using the same safeguards as we use for our own proprietary information. All information you provide to us is stored on secure servers.
7.2 Astute has implemented generally accepted standards of technology and operational security in order to protect personally identifiable information from loss, misuse, alteration or destruction.
7.3 Despite Astute’s best efforts, however, security cannot be absolutely guaranteed against all threats. To the best of our ability, access to your personal information is limited to those who have a need to know. Those individuals who have access to the data are required to maintain the confidentiality of such information.
7.4 We have in place reasonable commercial standards of technology and operational security to protect all information provided by visitors via this Website from unauthorised access, disclosure, alteration, or destruction.
8. Automatic Collection of Personal Information
8.1 Cookies – cookies will typically be placed on your computer or internet-enabled device whenever you visit us online, however by themselves do not tell us your email address or otherwise identify you personally. Further information about managing cookies and our detailed cookies policy can be found on our website under “Cookies Information” https://www.astutepractice.com.sg/Cookies-information
8.2 IP Addresses – in our analytical reports, we may obtain other identifiers including IP addresses, but this is for the purpose of identifying the number of unique visitors to our web sites and geographic origin of visitor trends, and not to identify individual visitors. Site statistics are compiled by third parties, and therefore your IP address will be passed to third parties for statistical reporting only.
8.3 Google Analytics – Astute uses Google Analytics to collect information about how people use our website and gain a better understanding of their expectations. This allows us to constantly improve the site. Astute does not allow Google to use or share data about browsing on our website with a third party. More information about how Google Analytics is used by Astute can be found here: http://www.google.com/analytics/learn/privacy.html
8.4 Web Beacons – Astute only uses web beacons in accordance with applicable laws. You have the option to render some web beacons unusable by rejecting the associated cookies. The web beacon may still record an anonymous visit from your IP address but cookies information will not be recorded.
9. Social Media Widgets and Applications
9.1 The main aim of the Social Media Platforms (namely, our LinkedIn) is to facilitate and allow you to share content. However, Astute cannot be held responsible if you share personal information on Social Media Platforms that is subsequently used, misused or otherwise appropriated by another user.
9.2 Astute may also provide links to other social media platforms maintained on separate servers by individuals or organizations over which Astute has no control. Astute makes no representations or warranties regarding the accuracy or any other aspect of the information located on such servers.
10.1 Our website contains links to other websites but this Privacy Statement applies only to the personal data collected via the website(s) operated by Astute, and to how Astute processes personal data.
10.2 A link to a third party’s website should not be construed as an endorsement by either Astute or that third party of the other or its products and services. Astute makes no representations or warranties regarding how user data is stored or used on third-party servers. We recommend reviewing the privacy statement of each third-party site linked from Our Site to determine their use of your personal information.
11. Changes to this Statement
11.1 Astute reserves the right to modify or amend this Statement at any time, with or without notice. We recommend that you check this page regularly.
11.2 The effective date will be displayed at the end of this Statement.
12. Policy Enquiries and Enforcement
12.2 For the avoidance of doubt, in the event that Singapore personal data protection law permits an organisation such as us to collect, use or disclose your personal data without your consent, such permission granted by the law shall continue to apply.
Astute Practice PAC
1 Paya Lebar Link, #06-07, Paya Lebar Quarter, Singapore 408533
Updated on 14 September 2023