Privacy Policy

Introduction

This is the Personal Data Protection Policy of Greensafe International Pte Ltd which sets out how we and our affiliated associations (“Organisation”, “us”, “we” or “our”) comply with the provisions of the Personal Data Protection Act of Singapore (“PDPA”). This Personal Data Protection Policy sets out:

our policies on how we manage your Data;
the types of Personal Data we collect, use, disclose, and/or retain;
how we collect, use, disclose, and/or retain your Data; and
the purpose(s) for which we collect, use, disclose, and/or retain your Data.

Each department in Greensafe International Pte Ltd has different channels for collecting personal data, but each is committed to complying with this Policy in its collection, use, and disclosure of personal data, to ensure that there is accountability and uniformity in the way we protect your data. Although this Policy is in common use, each is responsible to you to the extent of its collection, use, and disclosure of your data, and its actions.

You agree and consent to us, the Organisation and our authorized service providers and third parties to collect, use, disclose, and/ or retain your Data in the manner outlined in this Data Protection Policy.
This Data Protection Policy supplements but does not supersede nor replace any other consent which you may have previously provided to us nor does it affect any right that we may have at law in connection with the collection, use, disclosure, and/ or retention of your Data.

From time to time, we may update this Data Protection Policy without your notice to ensure that our Policy is consistent with any regulatory changes. The updated Policy will supersede earlier versions and will apply to data provided to us previously. Should any revision(s) be made to this Data Protection Policy, updates will be published on our website (www.greensafe.com.sg)

This Data Protection Policy forms a part of the Terms and Conditions governing your relationship with us and should be read in conjunction with such Terms and Conditions. In the event of any inconsistency between the provisions of the Data Protection Policy and the Terms and Conditions, the provisions of the Terms and Conditions shall prevail.

Your Data

The data we collect depends on the purposes for which we require the personal data and what you have chosen to provide. In this Data Protection Policy, “Data” refers to any data and/or information about you from which you can be identified by, either (a) from that data; or (b) from that data and other information to which we may have legitimate access to. Examples of such Data include but are not limited to:

Your name, NRIC, passport or other identification numbers, telephone number(s), mailing address, email address, and any other information relating to you that you have provided in any forms you may have submitted to use, or in other forms of interaction with you;
Your photos;
Your employment history, educational background, and income levels;
personal data of Your family members, such as next of kin, spouses, and children;
Information relating to payments, such as your bank account number or credit card information;
Information about your usage of and interaction with our website and/or services including computer and connection information, device capability, bandwidth, statistics on page views, and traffic to and from our website.

Collection of your Personal Data

We generally collect personal data that:

(a) You knowingly and voluntarily provide in connection with your course registration with us, or via a third party who has been duly authorized by you to disclose your data to us (your “authorized representative”), after (i) you (or your authorized representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorized representative) have provided consent to the collection and usage of your data for those purposes, or

(b) Collection and use of personal data without consent is permitted or required by the PDPA or other laws.

We shall seek your consent before collecting any additional data and before using your data for a purpose that has not been notified to you (except where permitted or authorized by law).

Generally, we may collect your Personal Data directly or indirectly through the following ways:

When you access our websites or perform an online registration/transaction
When you interact with any of our employees;
When you submit an application to us for services
When you respond to our request for additional Data;
When you ask to be included in an email or other mailing list;
When you request that we contact you through various communication channels, for example, through social media platforms, messenger platforms, face-to-face meetings, telephone calls, emails, faxes and letters;
Your images are captured via photographs or videos taken by us or our representatives when you are within our premises or attend events organized by us;
From your family members or friends who provide your data to us on your behalf
When you respond to our initiatives or promotions;
We seek information about you and receive your data in connection with your relationship with us, for example, if you are a customer, investor, or shareholder when you submit your Personal Data to us for any other reason.
When you browse our website, you generally do so anonymously, but please see the section below on cookies.
If you provide us with any personal data of a third party (eg: information of spouse, children, relatives, employees, or any other authorized parties), by submitting such information to us, you agree to us that you have obtained their prior permission.
We do check on your sensitive data from time to time to provide you with better service and experience.

Minor: If you are a child, minor, or not of legal age, please inform and seek the consent of your parent or guardian, before you provide your data to us. If you are a parent or guardian and you have reason to believe your child or ward has provided us with their data without your consent, please contact us to request for erasure of their data.

Note: Unsolicited personal data will be deleted immediately if received in physical copy or email or returned to the data subject.

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

Generally, we may collect, use, disclose, and/ or retain your Data for the following purposes:

To provide you with services/training/funding purposes;
To assist you with your inquiries, requests, and feedback.
To process payment for your services rendered or any other purchases;
To improve customer services, such as resolving complaints and handling requests and inquiries; for security and safety purposes,
protecting our platforms from unauthorized access or usage and monitoring for security threats, and your image may be captured by security cameras;
To conduct research, surveys, and interviews;
To keep you updated on our events; and
To comply with applicable laws and regulations.
Job application and related matters; engaging you as an associate trainer or matters relating to training;
preventing, detecting, and investigating crime, including fraud and money laundering
conducting any promotions, offers, contests, etc.
To comply with our legal or regulatory obligations (eg Skillsfuture Singapore, Ministry of Manpower, etc)
for our legitimate business interests, provided that this does not override your interests or rights.

Note: As an individual, your consent is deemed under the PDPA to cover these circumstances:

Where the collection, use, or disclosure of personal data is reasonably necessary to conclude or perform a contract or transaction.
Where individuals have been notified of the purpose of the intended collection, use, or disclosure of their data and are given a reasonable opportunity to opt out (and have not opted out).
OR you allow us to collect, use, or disclose personal data without having to obtain consent from the individuals in these circumstances:
- Where it is in the legitimate interests of the organization and the benefit to the public is greater than any adverse effect on the individual.
- Where it is for business improvement purposes. As a business organization, we are committed to safeguarding any such data that may be used.

Marketing/ Optional Purposes

From time to time, we may contact you via mail, electronic mail, telephone (call or SMS-Text), facsimile, or social media platforms, to inform you about our courses/services and events that we think may be of interest to you.
Analyzing and/or profiling your purchases, transactions, and/or likes or dislikes to be better able to send you relevant or targeted news (including events and product launches), promotion, and marketing information from us (and/or our affiliates or related entities) and on our group products.
Videos and photos will be taken during the classes and events to be used for marketing and related purposes.
You can let us know at any time if you no longer wish to receive marketing materials (by informing us through our email to salesadmin@greensafe.com.sg) and we will remove your details from our direct marketing database. Please note that we may still send you non-marketing messages such as surveys, customer-service notices, and other service-related

Disclosure of your Data

We may disclose your Personal Data to the following groups of external organizations for the purposes mentioned above, subject to the requirements of applicable laws:

Our professional advisers such as our auditors;
relevant government regulators, statutory boards or authorities, or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any government authority;
third parties who are appointed to provide services to us, e.g. IT vendors, marketing companies, and event organizers;
business partners that provide any membership services and benefits; and
any other person in connection with the purposes set forth above.

Use of Cookies

We may collect or analyze anonymized information from which individuals cannot be identified (“Aggregate Information”), such as several users and their frequency of use, the number of page views (or page impressions) that occur on our websites, and common entry and exit points into our websites.
We make use of “cookies” to store and track Aggregate Information about you when you enter our website(s). Such cookies are used to track information such as the number of users and their frequency of use, profiles of users, and their online preferences.
Such aggregate information collected may be used to assist us in analyzing the usage of our website(s) to improve your online experience with us.
Should you wish to disable the cookies associated with these technologies you may do so by changing the settings on your browser. However, please note that this may affect the functionality of the website(s).

Third-Party Sites

Our website(s) may contain links to other websites operated by third parties independent of the Organisation. We are not responsible for the privacy practices of such website(s) operated by third parties even though it is linked to our website(s).
We encourage you to learn about the privacy policies of such third-party website(s) by checking the policy of each site you visit and contacting its owner or operator if you have any concerns or questions.

Protection of Your Data

We maintain appropriate security safeguards and practices to protect your Data from unauthorized access, collection, use, disclosure, copying, modification disposal, or similar risks, by applicable laws.

Period of Retention. We keep your data only for so long as we need the data to fulfill the purposes we collected it for and to satisfy our business and legal purposes, including audit, accounting, g, or reporting requirements. How long we keep your data depends on the nature of the data, e.g. we keep personal data for at least the duration of the limitation period for bringing claims if the personal data may be required to commence or defend legal proceedings. Certain information may also be retained for longer, e.g. where we are required to do so by law or to maintain a record of the certification you have obtained with us. Typically, our data retention period is from 5 years upwards, depending on the limitation period.
Anonymized Data. In some circumstances, we may anonymize your data so that it no longer identifies you, in which case we are entitled to retain and use such anonymized data without restriction, including for data analytics.
Unauthorized Access and Vulnerabilities. While we take reasonable precautions to safeguard your data in our possession or under our control, we cannot be held responsible for unauthorized or unintended access that is beyond our control, including hacking or cybercrimes. We also do not guarantee that our websites and applications are invulnerable to security breaches, or that your use of our websites and applications is safe and protected from viruses, worms, Trojan horses, and other vulnerabilities.

Accuracy of your Data

You must ensure that all personal data that you provide is true, accurate, and complete. We take all reasonable measures to ensure that your data remains accurate, complete, and up-to-date.
You may also keep us informed when there are any updates to your data by contacting us directly.
Any incorrect data provided will not hold us liable for any related consequences.

Withdrawal of Consent

If you wish to withdraw your consent to any use or disclosure of your Personal Data as set out in this Personal Data Protection Policy, you may contact us via www.greensafe.com.sg. Depending on the complexity of the request and its impact on our relationship with you, we will cease (and instruct any of our data intermediaries and agents to cease) collecting, using, or disclosing the personal data within thirty (30) days of our receipt of your request, unless required or authorized under applicable laws.
Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing to our data protection officers at the contact details provided below.

Access and Correction of your Personal Data

You may request access to or make corrections to your Personal Data records, but Greensafe International Pte Ltd has the right to charge a reasonable fee for processing your request. We may require that you submit certain forms or provide certain information to process your request. Upon receipt of your written request, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of our acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we will seek to process and effect your request within 30 days of receipt of your request.
Please submit your request to our Data Protection Officer: salesadmin@greensafe.com.sg
We may be permitted under applicable laws to refuse your request to exercise your rights, for example, we may refuse (a) a request for erasure where the personal data is required in connection with claims; or (b) an objection request and continue processing your data based on compelling legitimate grounds for the processing.

Retention Limitation

The Commission shall cease the retention of data or remove how personal data can be associated with particular individuals when it is no longer necessary for any business or legal purposes.

Notification of Breach

Our Organisation is committed to notifying the PDPC and affected individuals if any data breach is detected and results in, or is likely to result in, significant harm to the affected individuals (e.g., compromised NRIC numbers, etc). Where the organization has reason to believe that a data breach has occurred, we will conduct, reasonably and expeditiously, an assessment as to whether it is a notifiable data breach. If the notification criteria are met, we will notify the PDPC as soon as practicable and also the affected individuals.

Portability Obligation

As a responsible organization we will, at the request of an individual, transmit his or her data that is in the organization’s possession or under our control to another organization in a commonly used machine-readable format. However, our obligation only applies to data that is provided by the individual or is data about the individual created in the course of the individual’s use of our relevant product or service. Data that is derived by the organization in the course of business from other personal data will not be covered. The individual exercising the right must also have an existing, direct relationship with our organization, where the data is in electronic form, and the receiving organization must have a presence in Singapore.

Contacting Us

If you have any questions or complaints relating to the use or disclosure of your Personal Data, or if you wish to know more about our data protection policies and practices, please contact our Data Protection Officers: salesadmin@greensafe.com.sg