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Data Privacy Policy

Hao Ren Hao Shi Limited (“HRHS”)
Data Privacy Policy

This Data Privacy Policy (this “Policy”) sets out the basis which HRHS (“we, “us” or “our”) may collect, use, disclose or otherwise process personal data, including personal data relating to our prospective beneficiaries, beneficiaries, the caregivers for our beneficiaries, donors to us, our volunteers, job applicants, contractors, and online users of our website in accordance with the Singapore Personal Data Protection Act 2012 (“PDPA”). This Policy applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.  


1.    As used in this Policy, “personal data” means data, whether true or not, about an individual (including prospective beneficiaries, beneficiaries, the caregivers for our beneficiaries, donors to us, our volunteers, job applicants, contractors and online users of our website or otherwise) 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. 
2.    Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include your name, identification numbers such as NRIC, FIN, work permit and birth certificate, contact information such as residential address, email address or telephone number, nationality, gender, date of birth, marital status, medical history, photographs and other audio-visual information, employment information and financial information such as credit or debit card numbers or account information. 

3.    Terms used in this Policy shall have the meanings given to them in the PDPA (where the context so permits).  

4.    We generally do not collect, use and/or disclose your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, used and/or disclosed, and (ii) you (or your authorised representative) have provided written consent to the collection, use and/or disclosure of your personal data for those purposes, or (b) otherwise obtained by us, or (c) where the collection, use and/or disclosure of personal data without consent is permitted or required by the PDPA. We shall seek your consent before collecting, using and/or disclosing any additional personal data for a purpose which has not been notified to you (except where permitted or authorised by law). 


5.    Where you disclose personal data of other individuals to us (e.g. referees) to us, you warrant that you have obtained the prior consent of such individuals for us to collect, use, disclose and/or process such personal data for the relevant purpose for which you made the disclosure or as was notified to you at the relevant time and such other purposes as described in this Policy.


6.    We may collect use, and/or disclose your personal data for any or all of the following purposes:  

(a)    establishing or managing your relationship with us. This includes:  

(i)    where you are a beneficiary or prospective beneficiary: 

(A)    processing and evaluating any application for our services;

(B)    providing the services requested by you; 

(C)    monitoring, evaluating and/or auditing of services provided, including but not limited to assessment of the quality of the services provided and the effects of the services provided (both in the short and long term, and after you have stopped using the services); and 

(D)    research related to your personal circumstances or services you used. We will notify you and obtain your written consent before using your personal data for any specific research project, unless otherwise permitted under the PDPA or other legislation; 

(ii)    where you are a beneficiary’s authorised representative, processing and evaluating the beneficiary’s application for our services;
(iii)    where you are a donor:

(A)    processing, administering and finalising your donations (including processing and facilitating payment and any applicable tax-deduction claims), if any;

(B)    including your name and/or contact details and profile for further donor engagement; 

(C)    gift processing, handling financial, quality, feedback and security issues in relation to your contributions;

(D)    conducting know-your-client checks and donor due diligence; 

(E)    providing reports, documents, collaterals, brochures, programmes, promotional materials and other information regarding HRHS as well as other third parties with whom it may collaborate with from time to time;


(iv)    where you are a volunteer:


(A)    processing and evaluating your suitability to volunteer (including conducting background checks); and 

(B)    monitoring, evaluating and/or auditing of services you participated in; 

(v)    where you are a job applicant, a contractor or an employee: 


(A)    evaluating your application and suitability for employment in any current or prospective position with us;

(B)    contacting or communicating with you for the purposes of processing your employment application and other opportunities;

(C)    carrying out due diligence or screening activities including but not limited to reference checks in accordance with legal or regulatory obligations or risk management procedures that may be required by law or put in place by us; and

(D)    for security clearances, conducting background checks and issuing permits and access to HRHS resources or work arrangements;

(b)    providing you with information on our upcoming events or activities, where you have specifically requested to receive such information; 

(c)    creating event publications, and informational and communications materials, including publications on the HRHS’s website, social media and/or any internal publications;


(d)    verifying your identity; 


(e)    responding to, handling, and processing queries, requests, applications, complaints and feedback from you; 


(f)    contacting you or communicating with you via various modes of communication such as voice call, text message/Whatsapp or fax message, email or postal mail for the purposes of administering and managing your relationship with us;


(g)    dealing with, administering and or managing your use of HRHS facilities or resources;


(h)    compiling and analysing feedback for internal use; 


(i)    enhancing the individual’s experience on the HRHS website; 


(j)    arranging, administering, or executing audits and governance reviews;


(k)    executing goods and/or service improvement, quality assurance reviews, surveys or research;


(l)    arranging, administering or executing facilities (including parking, issuance of pass cards, keys or tokens), access management, equipment procurement / issuance and associated maintenance or replacement;


(m)    (wherever CCTV or other surveillance equipment are deployed on locations in HRHS premises or other locations), for detection and prevention of crime and for security purposes and investigations;


(n)    engaging with third party vendors in respect of procuring goods or services incidental or necessary to the provision of services or engagement in activities with you;


(o)    (at HRHS events where pictures or video are recorded and where signage to notify the same has been placed, and unless you explicitly instruct us not to use your image) for promotional, publicity, or event reporting purposes;


(p)    where you are deemed by law to have consented to various purposes, these purposes will be acted on until such time as such deemed consent is withdrawn in accordance with the arrangements we have in place to assist your doing so;


(q)    complying with any applicable laws, regulations, regulatory policies, codes of practice, guidelines, rules, judgments, orders, directions or requests issued by any court, legal or regulatory bodies, including but not limited to rules and regulations relating to anti-money laundering and countering the financing of terrorism and the carrying out of internal and external audits and investigations, or requests to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority; 


(r)    any other purposes for which you have provided the information;


(s)    for transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and 


(t)    any other incidental purposes related to or in connection with the above. 

7.    We may disclose your personal data:  

(a)    to third party service providers, agents, affiliates, related corporations and other organisations we have engaged to perform any of the purposes listed in clause 6 above for us;  

(b)    to comply with any applicable laws, regulations, regulatory policies, codes of practice, guidelines, rules or requests by to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority; and  

(c)    any other party to whom you authorised us to disclose your personal data to, or where necessary to undertake any action requested by you. 

8.    The purposes listed in the above clauses may continue to apply even in situations where your relationship with us has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under a contract with you).  
9.    Your failure to supply certain personal data to us (or if we are not permitted by you to process your personal data), may/would result in us being unable to process, administer and/or manage your relationship with us. Depending on the extent by which you do not permit us to process your personal data or the extent of personal data which you do not provide to us, it may mean that we will not be able to continue the relationship with you, as we will be unable to administer the relationship.
10.    In compliance with the PDPA, we may collect, use or disclose your personal data without your consent for the legitimate interests of HRHS or another person. In relying on the legitimate interests exception of the PDPA, HRHS will assess the likely adverse effects on the individual and determine that the legitimate interests outweigh any adverse effect.  
11.    In line with the legitimate interests’ exception, we will collect, use or disclose your personal data for the following purposes: 

(a)    fraud detection and prevention; 
(b)    detection and prevention of misuse of services; and 
(c)    collection and use of personal data on company-issued devices to prevent data loss. 

The purposes listed in the above clause may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter. 


12.    The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you or your authorised representative in writing. You or your authorised representative may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request via email to our Data Protection Officer at the contact details provided below. 
13.    Upon receipt of your written request to withdraw your consent, 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 us acceding to the same, including any legal consequences which may affect your rights and liabilities to us.  
14.    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 the manner described in clause 12 above.  
15.    Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.  

16.    If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request via email to our Data Protection Officer at the contact details provided below. 
17.    Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.  

18.    HRHS will take reasonable and appropriate measures to (i) keep your personal data accurate, complete and updated; and (ii) ensure that your personal data is adequately protected and secured. Appropriate security arrangements will be put in place to prevent unauthorised collection, use, disclosure, access, copying, modification, disposal or misuse of your personal data. 
19.    You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While your security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.  

20.    We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer at the contact details provided below.  
21.    We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws. 
22.    We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.  



23.    We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will take steps to ensure that such personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA. 



24.    This section further describes the information practices (and how we process your personal data when you interact with us) in connection with HRHS’ website(s), including mobile websites and applications that are accessed and, on the site (collectively, the “Site”). 


25.    If you are only browsing this Site or using the Search function, we do not capture data that allows us to identify you individually. While user sessions will be tracked, the users will remain anonymous.


26.    If you choose to submit your request via our form or send an email that contains personally identifiable data, for HRHS to process or to render you a service, we may share that relevant data within HRHS, or if necessary, with other Government agencies, so as to serve you efficiently and effectively.


27.    For your convenience, when you are carrying out a transaction on our Site, we may also display to you the data that you previously supplied to HRHS or private organisations that have been authorised to carry out specific services on our behalf. This is intended to save you time and effort in re-keying the same data. If the pre-displayed data is out-of-date, please enter the latest data. HRHS will retain your personal data only as necessary for business and legal purposes.


28.    To help us optimise your browsing experience and ensure the website works properly, we use cookies when you use our websites.


29.    If you would like to disable our cookies, you may deactivate it by adjusting your internal browser setting.


30.    You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:  
Email Address: 

31.    This Policy applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.  
32.    We may revise this Policy from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Policy was last updated. By continuing your relationship with us and/or accessing any part of the Site, you acknowledge that you have read and understood the terms of this Policy and agreed or shall be deemed to agree to be bound by this Policy including any updates or amendments.

Effective date :      19 December 2023
Last updated :      19 December 2023

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