This Data Protection Notice (“Notice”) sets out the basis which STRYNEX Pte. Ltd. (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of our customers in accordance with the Personal Data Protection Act (“PDPA”). This Notice 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.
PERSONAL DATA
As used in this Notice:
“customer” means an individual who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us; and
“personal data” means data, whether true or not, about a customer 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.
Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include name, email address and telephone number.
Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).
COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
We generally do not collect 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, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal 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 personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).
We may collect and use your personal data for any or all of the following purposes:
(a) performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
(b) responding to, handling, and processing queries, requests, applications, complaints, and feedback from you; and
(c) any other incidental business purposes related to or in connection with the above.
We may disclose your personal data:
(a) where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods and services requested by you.
WITHDRAWING YOUR CONSENT
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 in writing. You 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 in writing or via email to our Data Protection Officer at the contact details provided below.
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. In general, we shall seek to process your request within seven (7) business days of receiving it.
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 in the manner described in clause 7 above.
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.
ACCESS TO AND CORRECTION OF PERSONAL DATA
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 in writing or via email to our Data Protection Officer at the contact details provided below.
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.
We will respond to your request as soon as reasonably possible. In general, our response will be within seven (7) business days. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).
PROTECTION OF PERSONAL DATA
To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as minimised collection of personal data, encryption of data, up-to-date antivirus protection, regular patching of operating system and other software, and web security measures against risks.
You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
ACCURACY OF PERSONAL DATA
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 in writing or via email at the contact details provided below.
RETENTION OF PERSONAL DATA
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.
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.
TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.
DATA PROTECTION OFFICER
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: contact@strynex.sg
EFFECT OF NOTICE AND CHANGES TO NOTICE
This Notice 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.
We may revise this Notice 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 Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.
EU/EEA CONTACTS AND PERSONAL DATA RECEIVED FROM COOPERATION PARTNERS
Where you submit a private label or product development enquiry through a website, contact form or other communication channel operated by one of our cooperation partners, STRYNEX may receive your personal data from the operator of that website or communication channel. The categories of personal data received may include your name, business contact details, company name, professional position, the content of your enquiry, product and project requirements, expected quantities and timelines, attachments provided by you, and related communication data. STRYNEX processes this information as an independent data controller for the purpose of assessing, responding to and managing your enquiry, preparing proposals, communicating with manufacturers and other service providers where necessary, conducting requested pre-contractual measures and, where applicable, entering into and performing a contract with you or the organisation you represent. Where you act in your own name, the legal basis under the GDPR is Article 6(1)(b). Where you act on behalf of a company or other organisation, the processing is based on Article 6(1)(f). Our legitimate interest and that of the organisation you represent is the efficient assessment, communication and performance of the requested private label project. The source of the personal data is the operator of the website, contact form or communication channel through which you submitted your enquiry. We will identify the specific source in our first communication with you. Where personal data is transferred from the European Economic Area to STRYNEX in Singapore, appropriate safeguards are implemented in accordance with Chapter V of the GDPR. Where applicable, the transfer is governed by the Standard Contractual Clauses adopted by the European Commission and additional technical and organisational safeguards. You may request further information or a copy of the applicable safeguards by contacting us. Enquiry data which does not result in a contractual relationship will generally be deleted no later than 24 months after the last relevant communication, unless continued retention is necessary for the establishment, exercise or defence of legal claims. Where a contract is concluded, personal data and business records may be retained for the applicable statutory retention periods. Where the GDPR applies, you have the right to request access, rectification, erasure, restriction of processing and, where applicable, data portability. You also have the right to object to processing based on Article 6(1)(f) GDPR and to lodge a complaint with a competent data protection supervisory authority. Information and the first copy of your personal data will generally be provided free of charge in accordance with the GDPR.