Introduction
In the course of the provision of our services and in order to operate effectively, Luther LLP and Luther Corporate Services Pte. Ltd. (collectively referred to as “Luther”, “We”, “Us”, “Our”) collect, use and disclose personal information about individuals, including but not limited to personal information of individuals related to or provided by our individual or corporate clients.
This Privacy Policy (the “Policy”) shall also govern the collection, use and disclosure of any Personal Data entered through Luther’s corporate secretarial online platform (the “Platform”).
The purpose of this Policy is to detail our approach to the protection of Personal Data (as defined below) and to ensure the consistent handling of Personal Data and compliance with the regulations of the Singapore Personal Data Protection Act 2012 (“PDPA”).
Personal Data
“Personal Data” is defined by the PDPA as data, whether true or not, about an individual who can be identified from that data or from that data and other information to which an organisation has or is likely to have access.
Please note that “business contact information” is not covered by the PDPA or this Policy. “Business contact information” refers to an individual’s name, position name or title, company name, business telephone number, business address, business electronic mail address or business fax number and any other similar information about the individual, not provided by the individual solely for their personal purposes.
Where we refer to a “Client” in this Policy, we refer to the persons and entities for whose benefit we provide our services, whether through the Platform or through any other means.
What Personal Data We Collect
Personal Data collected, used and disclosed by Luther includes a variety of information which depend on the services that we have been engaged for; and may include data such as full name, personal contact details, NRIC/Passport number, FIN, information about income, bank account information, education, work experience, date and place of birth, marital status, religion and such other information as may be required for the purposes stated below.
How We Collect Personal Data
We may obtain Personal Data from our clients or data subjects in several ways, including but not limited to receiving it by email, handover of hard copies, obtaining it from government authorities like ACRA or IRAS, or through data entry or document upload via our Platform.
Platform Cookies
On our Platform, we only use ‘strictly necessary’ session cookies exclusively for the purpose of displaying the technical functions of our Platform. We do not use the information collected through these cookies for the purposes of creating user profiles or evaluating your activities on the Internet. By using our Platform, you consent to the storage and use of our cookies on your device.
Purposes of Collection, Use and Disclosure of Personal Data
Luther collects, uses and discloses Personal Data for the following purposes:
- Providing services to Clients, including corporate secretarial services, tax and accounting services, and payroll processing;
- Auditing the Client;
- Client relationship management (including sending updates and information relating to our services);
- Regulatory compliance (e.g. filings with ACRA or IRAS) and internal record keeping;
- Where we have obtained consent: sending updates, newsletters, and marketing materials. You may object at any time by emailing Stephan.yeong@luther-services.com.
Disclosure and Transfer of Personal Data
We may disclose your Personal Data to related companies or third parties (such as auditors, professional advisors, governmental bodies and authorities) where such disclosure is required for performing our obligations in connection with our provision of services.
We will only transfer Personal Data outside of Singapore in accordance with the requirements of the PDPA.
Protection
Appropriate technical, organisational and administrative security measures are in place to protect Personal Data against unauthorised access, collection, use, disclosure, copying, alteration, or destruction. In the unlikely event of a data breach, we will notify the Singapore Personal Data Protection Commission as well as affected individuals in accordance with the provisions of the PDPA.
Retention
Luther will keep Personal Data no longer than is necessary for the purpose it was collected for or any business or legal purposes. Luther will take all reasonable steps to ensure that all Personal Data is destroyed, permanently deleted or anonymised if it is no longer required.
Rights of Data Subjects
Under the PDPA, the data subject has the right to withdraw consent to the collection, use and disclosure of their Personal Data. Data subjects also have the right to access and correct information held about them by Luther.
Data Protection Officer
Luther has appointed a Data Protection Officer to whom any requests and complaints shall be addressed. The Data Protection Officer can be contacted at dpo@luther-services.com.
Last updated January 2024
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