Definitions and Interpretation
Applicant means an applicant for employment with the Company.
Apps shall be as defined above.
Company or Ucommune shall be as defined above.
Employee means an employee of the Company.
Membership Agreement means the membership agreement entered into between any of the Company’s members and the Company.
Personal Data means 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 the Company has or is likely to have access (as may be amended from time to time under the Personal Data Protection Act 2012 (“PDPA”).
Policy shall be as defined above.
Services shall be defined above and for the avoidance of doubt includes any services of the Company and services set out in the Membership Agreement.
Website Services shall be as defined above.
References to “you” means anyone who uses the Services, Website Services or Apps which includes any Employee, Applicant and/or member as set out in the Membership Agreement (references to “your” shall be construed accordingly).
Information collected by the Company
The Company may collect information from you including your Personal Data (such as name of individual, phone number, date of birth and address) through its website, by e-mail correspondence, by postal mail or fax, over the telephone, in person or through other documents. The information collected will vary depending on your relationship with the Company but will be limited to that information necessary to record and manage its relationship with you. In accordance with the PDPA, the Company will only collect Personal Data where it is reasonably necessary for its functions or activities.
Use of Personal Data
How the Company uses your Personal Data depends on your relationship with the Company. In general, the Company will use your Personal Data to:
a. provide you with the Services, in order to meet its contractual obligations to you and to request for other materials;
b. contact you about the Services, promotions, events, updates and otherwise communicate with you. The Company generally relies on its legitimate interests in marketing the Services to you, whether on its own websites or on third party websites, and in providing the aforesaid, where permitted by applicable law;
c. comply with its legal obligations including any reporting obligations required under any applicable Singapore law and regulation;
d. monitoring and reviewing the Company’s compliance with relevant regulations and codes of conduct in its dealings with you;
e. for the purposes of market research including but not limited to research for its business and branding;
f. managing recruitment for the Company;
g. automated data collection through interaction with its website;
h. protect against fraud, abuse or harm;
i. provide updates, alerts, information or communicating with you; and
j. purposes directly related or incidental to the above.
Collection of Personal Data
It is the Company’s usual practice to collect Personal Data directly from the individual or their authorised representative. In event of collection of such Personal Data from an authorised representative, it shall be deemed that the authorised representative has obtained the consent of the subject for the disclosure of the Personal Data to the Company.
At times, the Company may collect Personal Data from a third party or a publicly available source, but only if an individual has consented to such collection or would reasonably expect the Company to collect their Personal Data in this way.
Your Personal Data is never shared, sold, rented or otherwise disclosed outside the Company (except as required for any statutory, legal or ethical requirements) in ways different from what is described in this Policy.
Disclosure of Personal Data to third parties
To the extent possible, the Company aims to minimise disclosure of your Personal Data to third parties. However, in order to effectively carry out its business or meet its contractual obligations to you, the Company may disclose Personal Data to its related companies, service providers and advertisers, and other end users, in order to provide its Services.
a. The Company – the Company uses your Personal Data in accordance with this Policy in providing its Services including disclosure to personnel, agents, advisers, auditors, contractors, financial institutions, and service providers in connection with its operations (for example staff engaged in the fulfilment of any obligations, processing of payment and the provision of support services);
b. Community – the Services include online and offline communities, forums and networks that allow you to share information and connect with others. The Company makes this possible by creating profiles for members or permitting members to create their own profiles. Such a profile may contain your name and other information you provide. Depending on the Services you use, this profile might be created automatically and is accessible to others using the forum or network, some of which include the Company’s members. You can supplement your profile by adding additional information about yourself and by posting content and comments. You can share your profile with a broader audience (such as through social media). Please note that the Company cannot control the actions of other users of the Services with whom you share information.
c. Service providers – the Company relies on third-party service providers including event organisers to perform a variety of services on its behalf and it take steps to ensure that they act only in line with the Company’s instructions and on its behalf, or otherwise to use Personal Data as described in this Policy.
d. Third-party advertising partners – the Company shares limited personal information with third parties that serve its advertising online, so that they can display its adverts to individuals who may find them most relevant. The Company shares this information in order to meet its legitimate interests in advertising the Services effectively. The Company makes sure that it only shares limited Personal Data for this purpose, and only to trusted partners that are restricted in how they can use your Personal Data.
e. Other third party partners with your consent – the Company may request your consent to share Personal Data about you with certain third parties so that they can provide you with special offers, promotional materials, and other materials that may be of interest to you. With your consent, the Company also uses and publicises your name, likeness and other personal characteristics and private information for advertising, promotion and other commercial and business purposes.
f. Research or surveys – from time to time, the Company will provide your Personal Data to its service providers to perform research (online and offline) through surveys on its behalf. Participation is voluntary, and the Company will use the information that it collects for research and reporting purposes, and to help it to improve the quality of its Services. The Company uses the survey responses to determine the effectiveness of its Services, including the quality of its communications and its advertising and/or promotional activities. If you participate in a survey, your responses will be used along with other participants’ responses.
The Company may also disclose Personal Data to other third parties, who may be located overseas, including:
a. third parties engaged by the Company to perform functions or provide products and services on its behalf, such as:
– distributors of its Services;
– event organisers;
– hosting, data storage or archiving service providers, payment processing and debt collection services;
– marketing, research and advertising agencies;
b. third parties authorised by you to receive information held by the Company.
The Company may impose obligations on any third party with which it shares your Personal Data to maintain the integrity and security of that Personal Data.
Personal Data Transfer Abroad
The Company is headquartered in Singapore but may also provide Services outside of Singapore. Therefore your Personal Data will likely be collected in your country and subsequently transferred or stored in another country, including countries that may have privacy protections less stringent than your jurisdiction. In accordance with applicable law, the Company implements measures, such as standard data protection clauses, to ensure that any transferred Personal Data remains protected and secure.
Some organisations to which the Company discloses Personal Data may be located outside Singapore. The Company will not disclose your Personal Data to an overseas recipient without taking appropriate steps to ensure that the overseas recipient will provide a standard of protection to Personal Data so transferred that is comparable to protection under the PDPA. Such a disclosure could include use of an overseas data processing facility like an email server overseas.
Third Parties that provide content or functionality on the Services
The Company partners with certain third parties to collect, analyse and use some of the Personal Data described in this Policy, for example:
a. Third-parties – that provide features and functionality on the Services by means of plug-ins. Even if you do not click on or interact with social networking services or other plug-ins, they collect information about you, such as your IP address and the pages that you view.
b. Advertising providers – who help the Company and its advertisers provide advertisements on the Services or elsewhere, including advertisements that are targets based on your online behaviour, and analytics companies help the Company measure and evaluate the usage of the Services.
c. Other content providers – who offer products and services on the Services and operate contests, or surveys on the Services.
e. Public forums – the Company’s websites may make member networks, chat rooms, forums, and/or other groups available to the users. Remember that anyone can read, collect or use your postings on a network or forum or in a chat room or group and, the Company cannot be responsible for unauthorised third party’s use of information that you disclose online.
f. Social media – the Company is active on social media and shares information, images, and videos with the public through unaffiliated external social media sites. The Company encourages you to read their policies. Remember that the social media sites are public, which means that anyone can see your posts, and your posts may even show up in search engine results. Whilst the Company will not edit comments, it may delete a comment from the page on the social media site if it, for example does not relate to the post, promotes a commercial product or service, uses obscene, threatening, or harassing language or violates copyright laws.
Cookies are text files created on your computer when your web browser loads a website or web application. The Cookies the Company sets helps it to improve its website and to deliver a better and more personalised service, remembering your preferences, and generally improving the user experience.
You may refuse to accept Cookies by activating the setting on your browser which allows you to refuse the setting of Cookie. Please be aware that if you elect to refuse or restrict Cookies you may be unable to access certain parts of the Company’s website.
Anonymity and Pseudonymity
Unless the Company is required by any applicable Singapore law and regulation, or it is otherwise impractical to deal with individuals who have not identified themselves, all individuals have the option of not identifying themselves, or using a pseudonym, when dealing with the Company in relation to a particular matter.
Notification of the Collection of Personal Data
If the Company collects Personal Data about you, it will take reasonable steps to notify you of:
a. the identity and contact details;
b. the fact and circumstances of collection;
c. whether the collection is required or authorised by law;
d. the purposes of the collection;
e. the consequences if Personal Data is not collected;
f. its usual disclosures of Personal Data of that kind;
g. information about the Policy; and,
h. whether it is likely to disclose the information to overseas recipients.
The Company will only use or disclose Personal Data to communicate directly with you to promote a good or service:
a. if the Company collected the information directly from you, and you have consented that the information is to be used in this way; or
b. if it is permitted under the applicable Singapore laws and regulations to do so.
You will generally be given the opportunity to determine that you do not wish to receive marketing or promotional communications from the Company. Instructions for the aforesaid will typically be included within the communication.
Data Quality and Security
The Company takes steps to ensure that the Personal Data it collects is accurate, up to date and complete. These steps include maintaining and updating Personal Data when the Company is advised by individuals that their Personal Data has changed, and at other times when necessary.
The Company will take all reasonable steps to maintain the security and integrity of your Personal Data including the use of computer access passwords, policies, procedures and firewalls.
Links and Third Party Platforms
Websites operated by the Company may contain links to other sites operated by third parties. The Company makes no representations or warranties as to the privacy practices of any third- party site and is not responsible for the privacy policies of other sites.
Information collected through Employment Applications
In processing applications for employment, the Company collects resumes, references, certificates of graduation and qualification and other Personal Data about candidates. All applications for employment that the Company receives are stored in its Human Resources department. A member of the Human Resources department will review your application. Alternatively, the Company may provide your application to a recruitment agency or contractor who assists in reviewing applications that it receives.
Resumes sent to the Company as part of an application for an advertised position, or sent generally to ascertain whether any positions are available, will be used to match Applicants with available opportunities. If the Company considers that your application may be suitable to its current requirements, it, or a party acting on its behalf, will contact you to request that you attend an interview. The Company may also ask you to provide it with contact information for individuals who will act as professional and personal referees. The Company may contact these individuals and ask them questions it feels are relevant to your possible employment with it. The Company may contact you again to request that you attend further interviews or to inform you of whether it is able to offer you a position.
If your application is not suitable to the Company’s current requirements, but it feels that there may be a position in the future for you with it, the Company will a keep a record of your application and may contact you again if a suitable position becomes available.
How you can access and/or correct your Personal Data
You can always, by written request, seek access to your Personal Data and/or ask the Company to correct or delete any inaccurate, incomplete or out of date information or information about the way in which the Personal Data is used or disclosed within a year of such request (or such period as may be required in the PDPA from time to time). Any request for access, correction or deletion of information, or complaint must be addressed to the Company’s Data Protection Officer using the following contact details:
Upon receipt of your request, the Company may request for additional information from you (including proof of identity) in order to process your request. The Company may also charge a reasonable fee to cover administration costs when dealing with any requests for access, which the Company will inform you of in advance.
The Company will endeavour to disclose and/or correct such Personal Data in accordance with its legal obligations, and where it refuses to do so, it will, where possible, provide you with the reasons for the refusal.
The Company will retain your Personal Data for as long as you have a relationship with it, and for a period after your relationship with it has ended. When determining how long this retention period will last, the Company takes into account the length of time Personal Data is required to, among other things:
a. continue to develop, tailor, upgrade and improve the Services;
b. maintain business records for analysis and/or audit purposes;
c. comply with record retention requirements under the law;
d. defend or bring any existing or potential legal claims; or
e. address any complaints regarding the Services.
The security of all Personal Data provided to the Company is important. The Company takes reasonable steps to use appropriate measures to protect your Personal Data, including against unauthorised or unlawful processing and accidental loss, destruction or damage. Unfortunately, no data transmission over the internet or storage of information can be guaranteed to be completely secure. As a result, while the Company strives to protect your Personal Data, it cannot ensure or warrant the security of any information that you transmit to the Company, and you do so at your own risk. As such, you should help by implementing your own security controls, such as a strong password, not sharing your personal information with others, logging out when you leave your desk, and other best practices.
Complaints and Queries
If you wish to make a complaint about the handling of your Personal Data, or if you have any queries in relation to this Policy, please contact the Data Protection Officer using the contact details set out above.
Upon receipt of any complaints, the Company will carry out an investigation and may contact you for further information.
What if the Policy changes?
The Company may review, amend or revise its Policy and the way it handles Personal Data from time to time. The Company will post the updated Policy on its website and its terms will take effect from the date of posting. Please check the Policy periodically to inform yourself of any changes.