Data Protection Policy

This Data Protection Policy serves to inform you on how RSVP ProGuide Pte Ltd (“PROGUIDE”) manages Personal Data which is subject to the Singapore Personal Data Protection Act (No. 26 of 2012) (“the Act”). Please read this document so that you know and understand the purposes for which we collect, use and disclose your Personal Data.

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

This Data Protection Policy applies across all platforms used by ProGuide in the conduct for our businesses, including, but not limited to, our website, our enterprises management systems (such as our email marketing system, training management system and learning management system), and all other communication means and touchpoints. This policy supplements and does not supersede nor replace any other consents you may have previously provided to PROGUIDE in respect of your Personal Data.

PROGUIDE may from time to time update this Data Protection Policy to ensure that this Data Protection Policy is current. Subject to your rights at law, you agree to the prevailing terms of this Data Protection Policy as updated from time to time on our website www.proguide.com.sg/pdpa. Please check back regularly for updated information on the handling of your Personal Data on our website.

Personal Data

In this Data Protection Policy, “Personal Data” refers to any 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 have or are likely to have access, including data in our records as may be updated from time to time.

Examples of such Personal Data you may provide to us your name, NRIC or other identification number, telephone number(s), mailing address, email address, academic and employment records, personal lifestyle data and any other information which you have provided us in any forms you may have submitted to us.

Collection of Personal Data
- Generally, we collect Personal Data in the following ways:
  - when you submit any form, including but not limited to application, declaration, proposal, appeal, referral forms or uploaded documents;
  - when you enter into any agreement or provide other documentation or information in respect of your interactions and transactions with us, or when you use our services;
  - when you interact with our staff, including customer service officers, relationship managers and other representatives, for example, via telephone calls (which may be recorded), letters, fax, face-to-face meetings and email;
  - when you use our services provided through online and other technology platforms, such as websites and apps, including when you establish any online accounts with us;
  - when your images are captured by us while you are within our premises or when you attend any event organised by us, via photographs or videos taken by us or our representatives
  - when you are contacted by, and respond to, our marketing representatives and agents and other service providers and provide us information for contacting you or in response to our request for additional information for additional Personal Data for any of our initiatives;
  - when you submit an employment application or when you provide documents or information including your resume and/or curriculum vitae in connection with any appointment as an officer, director, representative or any other position;
  - when you submit your Personal Data to us for any other reason and any other mean not stated above
  - If you provide us with any Personal Data relating to a third party (g. information on your customers, spouse, children, parents, and/or employees), by submitting such information to us, you represent to us that you have obtained the consent of such third party provide us with their Personal Data.
  - You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with products and services you have request

Purposes for the Collection, Use and Disclosure of Your Personal Data
- Generally, PROGUIDE collects, uses and discloses your Personal Data for the following purposes:
  - responding to, processing and handling your complaints, queries, requests, feedback and suggestions;
  - verifying your identity;
  - managing the administrative and business operations, and complying with internal policies and procedures;
  - facilitating business transactions
  - matching any Personal Data held which relates to you for any of the purposes listed herein;
  - requesting feedback or participation in surveys, as well as conducting market research and/or analysis for statistical, profiling or other purposes for us to design our products/services, understand customer behaviour, preferences and market trends, and to review, develop and improve the quality of our products and services;
  - managing the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances);
  - project management;
  - providing media announcements and responses;
  - organising promotional events;
  - in connection with any claims, actions or proceedings and/or protecting and enforcing our contractual and legal rights and obligations;
  - managing and preparing reports;
  - complying with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities; and/or
  - any other purpose relating to any of the abov

These purposes may also apply even if you do not maintain any account(s) with us, or have terminated these account(s).

In addition, PROGUIDE collects, uses and discloses your Personal Data for the legitimate purposes depending on the nature of our relationship:
- If you are an employee of ProGuide, or an employee, business partner, sole proprietor, investor , proxy voter, corporate shareholder, guardian, director, nominee director or guarantor, agent or representative of an organisation that has a business relationship with PROGUIDE.
- If you are an employee or agent of a referrer or other intermediary:
  - marketing and leads management;
  - processing remuneration; and/or
  - any other purpose relating to our relationshi
- If you are an employee, officer or owner of an external service provider or vendor outsourced or prospected by PROGUIDE:
  - managing project procurement or tenders for the supply of goods and services;
  - processing and payment of vendor invoices;
  - complying with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities (which includes disclosure to regulatory bodies or audit checks); and/or
  - any other purpose relating to our relationshi
- If you are an PROGUIDE shareholder:
  - maintaining statutory registers and to manage the publication of shareholder statistics on annual reports and circulars;
  - providing shareholding listing for preference shares, subordinated debt and senior term issuances;
  - facilitating the implementation of projects (including but not limited to seeking approvals for new investments, additional fund raising exercises or bonus);
  - processing claims (including but not limited to processing claims for unclaimed cash distribution); and/or
  - any other purpose relating to any of the abov
- If you are a party or counterparty to a transaction (for example, a beneficiary of a fund transfer or payment):
  - providing cash, payment and transactional services (including but not limited to the execution, settlement, reporting and/or clearing of the relevant transaction); and/or
  - any other purpose relating to any of the abov
- If you submit an application to us as a candidate for an employment or representative position:
  - conducting interviews;
  - processing your application which includes pre-recruitment checks involving your qualifications and facilitating interviews;
  - providing or obtaining employee references and for background screening;
  - processing staff referrals; and/or
  - any other purposes relating to any of the above
  - If you are an existing employee of PROGUIDE:
    - providing remuneration, reviewing salaries and bonuses, conducting salary benchmarking reviews, staff appraisals and evaluation, as well as recognising individuals for their services and conferring such recognition;
    - administrative and support processes relating to your employment, tools and/or facilities to enable or facilitate the performance of your duties, contact lists for business continuity, conducting analytics and research for human resource planning and management, and for improvement of work-related practice and productivity;
    - ensuring that the administrative and business operations of PROGUIDE function in a secure, efficient and effective manner (including but not limited to examining or monitoring any computer software and/or hardware installed within PROGUIDE, your work emails and personal digital and storage devices);
    - compliance with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities (including but not limited to disclosures to regulatory bodies, conducting audit checks or surveillance and investigation);
    - any other purposes relating to any of the abov
    - If you sit on the PROGUIDE Board of Directors:
      - facilitating appointment to the Board (including but not limited to managing the publication of directors’ statistics on annual reports and circulars);
      - complying with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities (including but not limited to disclosures to regulatory bodies or conducting due diligence);
      - administrative matters (including but not limited to the maintenance of statutory registers and lodgement of directors’ fee); and/or
      - any other purpose relating to any of the abov
    - In addition, where permitted under the Act, PROGUIDE may also collect, use and disclose your Personal Data for the following additional purposes:
    - providing or marketing services, products and benefits to you, including promotions, loyalty and reward programmes;
    - administering contests and competitions, and personalising your experience at PROGUIDE’s touchpoints;
    - sending you details of products, services, special offers and rewards, either to our customers generally, or which we have identified may be of interest to you; and/or
    - conducting market research, understanding and analysing customer behaviour, location, preferences and demographics for us to offer you products and services as well as special offers and marketing programmes which may be relevant to your preferences and profil
      - If you have provided your Singapore telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your Singapore telephone number(s), then from time to time, PROGUIDE may contact you using such Singapore telephone number(s) (including via voice calls, text , fax or other means) with information about our products and servi

Disclosure of Personal Data
- PROGUIDE will take reasonable steps to protect your Personal Data against unauthorised disclosur Subject to the provisions of any applicable law, your Personal Data may be provided, for the purposes listed above (where applicable), to the following entities or parties, whether they are located overseas or in Singapore:

PROGUIDE’s related organisations;
agents, contractors or third party service providers who provide operational services to PROGUIDE, such as courier services, telecommunications, information technology, payment, payroll, processing, training, market research, storage, archival, customer support investigation services or other services to PROGUIDE;
vendors or other third party service providers in connection with promotions and services offered by PROGUIDE;
our professional advisers such as our auditors and lawyers;
relevant government regulators, government ministries, statutory boards or authorities and/or law enforcement agencies, whether local or overseas;
any other party to whom you authorise us to disclose your Personal Data t

Use of Cookies
- When you interact with us on our websites, we automatically receive and record information on our server logs from your browser.
- All web-browsers offer the option to refuse any cookie, and if you refuse our cookie then we do not gather any information on that visitor. Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser. However, you may not be able to enter certain part(s) of our websit

Data Security
- PROGUIDE will take reasonable efforts to protect Personal Data in our possession or our control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risk However, we cannot completely guarantee the security of any Personal Data we may have collected from or about you, or that for example no harmful code will enter our website (for example viruses, bugs, trojan horses, spyware or adware). You should be aware of the risks associated with using websites and any of our technology-enabled management systems.
- While we strive to protect your Personal Data, we cannot ensure the security of the information you transmit to us via platforms not managed by ProGui We urge you to take every precaution to protect your Personal Data when you use such platforms.
- If applicable, you undertake to keep your username and password secure and confidential and shall not disclose or permit it to be disclosed to any unauthorised person, and to inform us as soon as reasonably practicable if you know or suspect that someone else knows your username and password or believe the confidentiality of your username and password has been lost, stolen or compromised in any way or that actual or possible unauthorised transactions have taken pl We are not liable for any damages resulting from any security breaches, on unauthorised and/or fraudulent use of your username and password.

Third-Party Sites
- Our website and enterprise management systems may contain links to other websites operated by third parti We are not responsible for the privacy practices of websites operated by third parties that are linked to our website. We encourage you to learn about the privacy policies of such third party websites. Some of these third party websites may be co-branded with our logo or trademark, even though they are not operated or maintained by us. Once you have left our website and enterprise management systems, you should check the applicable privacy policy of the third party website to determine how they will handle any information they collect from you.

Contacting Us – Feedback, Withdrawal of Consent, Access and Correction of your Personal Data
- If you have any questions or feedback relating to your Personal Data or our Data Protection Policy, you can contact us via the channels stated below:

Email us at proguide@rsvp.org.sg
Call us at 6485 6141
Write to: Data Protection Officer, RSVP Proguide Pte Ltd, 9 Bishan Place, #09-03, Junction 8 (Office Tower), Singapore 579837.

Please note that if your Personal Data has been provided to us by a third party (e.g. your employer) you should contact such party directly to make any queries, feedback, and access and correction requests to PROGUIDE on your behalf.

If you withdraw your consent to any or all use of your Personal Data, PROGUIDE may not be in a position to continue to provide its products or services to you or administer any contractual relationship already in pl This may also result in the termination of any agreements you have with PROGUIDE, and your being in breach of your contractual obligations or undertakings. PROGUIDE’s legal rights and remedies in such event are expressly reserved.

Governing Law
- This Data Protection Policy and your use of our website and/or our enterprise management systems shall be governed in all respects by the laws of Singapore.

Personal Data

Collection of Personal Data

Generally, we collect Personal Data in the following ways:

when you submit any form, including but not limited to application, declaration, proposal, appeal, referral forms or uploaded documents;

when you enter into any agreement or provide other documentation or information in respect of your interactions and transactions with us, or when you use our services;

when you interact with our staff, including customer service officers, relationship managers and other representatives, for example, via telephone calls (which may be recorded), letters, fax, face-to-face meetings and email;

when you use our services provided through online and other technology platforms, such as websites and apps, including when you establish any online accounts with us;

when your images are captured by us while you are within our premises or when you attend any event organised by us, via photographs or videos taken by us or our representatives

when you are contacted by, and respond to, our marketing representatives and agents and other service providers and provide us information for contacting you or in response to our request for additional information for additional Personal Data for any of our initiatives;

when you submit an employment application or when you provide documents or information including your resume and/or curriculum vitae in connection with any appointment as an officer, director, representative or any other position;

when you submit your Personal Data to us for any other reason and any other mean not stated above

If you provide us with any Personal Data relating to a third party (g. information on your customers, spouse, children, parents, and/or employees), by submitting such information to us, you represent to us that you have obtained the consent of such third party provide us with their Personal Data.

You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with products and services you have request

Purposes for the Collection, Use and Disclosure of Your Personal Data

Generally, PROGUIDE collects, uses and discloses your Personal Data for the following purposes:

responding to, processing and handling your complaints, queries, requests, feedback and suggestions;

verifying your identity;

managing the administrative and business operations, and complying with internal policies and procedures;

facilitating business transactions

matching any Personal Data held which relates to you for any of the purposes listed herein;

managing the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances);

project management;

providing media announcements and responses;

organising promotional events;

in connection with any claims, actions or proceedings and/or protecting and enforcing our contractual and legal rights and obligations;

managing and preparing reports;

complying with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities; and/or

any other purpose relating to any of the abov

These purposes may also apply even if you do not maintain any account(s) with us, or have terminated these account(s).

In addition, PROGUIDE collects, uses and discloses your Personal Data for the legitimate purposes depending on the nature of our relationship:

If you are an employee of ProGuide, or an employee, business partner, sole proprietor, investor , proxy voter, corporate shareholder, guardian, director, nominee director or guarantor, agent or representative of an organisation that has a business relationship with PROGUIDE.

If you are an employee or agent of a referrer or other intermediary:

marketing and leads management;

processing remuneration; and/or

any other purpose relating to our relationshi

If you are an employee, officer or owner of an external service provider or vendor outsourced or prospected by PROGUIDE:

managing project procurement or tenders for the supply of goods and services;

processing and payment of vendor invoices;

complying with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities (which includes disclosure to regulatory bodies or audit checks); and/or

any other purpose relating to our relationshi

If you are an PROGUIDE shareholder:

maintaining statutory registers and to manage the publication of shareholder statistics on annual reports and circulars;

providing shareholding listing for preference shares, subordinated debt and senior term issuances;

facilitating the implementation of projects (including but not limited to seeking approvals for new investments, additional fund raising exercises or bonus);

processing claims (including but not limited to processing claims for unclaimed cash distribution); and/or

any other purpose relating to any of the abov

If you are a party or counterparty to a transaction (for example, a beneficiary of a fund transfer or payment):

providing cash, payment and transactional services (including but not limited to the execution, settlement, reporting and/or clearing of the relevant transaction); and/or

any other purpose relating to any of the abov

If you submit an application to us as a candidate for an employment or representative position:

conducting interviews;

processing your application which includes pre-recruitment checks involving your qualifications and facilitating interviews;

providing or obtaining employee references and for background screening;

processing staff referrals; and/or

any other purposes relating to any of the above

If you are an existing employee of PROGUIDE:

providing remuneration, reviewing salaries and bonuses, conducting salary benchmarking reviews, staff appraisals and evaluation, as well as recognising individuals for their services and conferring such recognition;

compliance with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities (including but not limited to disclosures to regulatory bodies, conducting audit checks or surveillance and investigation);

any other purposes relating to any of the abov

If you sit on the PROGUIDE Board of Directors:

facilitating appointment to the Board (including but not limited to managing the publication of directors’ statistics on annual reports and circulars);

complying with any applicable rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities (including but not limited to disclosures to regulatory bodies or conducting due diligence);

administrative matters (including but not limited to the maintenance of statutory registers and lodgement of directors’ fee); and/or

any other purpose relating to any of the abov

In addition, where permitted under the Act, PROGUIDE may also collect, use and disclose your Personal Data for the following additional purposes:

providing or marketing services, products and benefits to you, including promotions, loyalty and reward programmes;

administering contests and competitions, and personalising your experience at PROGUIDE’s touchpoints;

sending you details of products, services, special offers and rewards, either to our customers generally, or which we have identified may be of interest to you; and/or

conducting market research, understanding and analysing customer behaviour, location, preferences and demographics for us to offer you products and services as well as special offers and marketing programmes which may be relevant to your preferences and profil

Disclosure of Personal Data

PROGUIDE’s related organisations;

vendors or other third party service providers in connection with promotions and services offered by PROGUIDE;

our professional advisers such as our auditors and lawyers;

relevant government regulators, government ministries, statutory boards or authorities and/or law enforcement agencies, whether local or overseas;

any other party to whom you authorise us to disclose your Personal Data t

Use of Cookies

When you interact with us on our websites, we automatically receive and record information on our server logs from your browser.

Data Security

While we strive to protect your Personal Data, we cannot ensure the security of the information you transmit to us via platforms not managed by ProGui We urge you to take every precaution to protect your Personal Data when you use such platforms.