Privacy Policy

SOFT TRADE SERVICES PTE LTD (“STS”) is committed to protecting its stakeholders’ and customers’ personal data in accordance with the Singapore Personal Data Protection Act (“PDPA”) and other applicable data protection laws.

“Personal data” means any data about an individual who can be identified from that data, as more specifically defined under the PDPA and other applicable data protection laws.

The STS Privacy Policy (“Privacy Policy”) describes how STS collects, uses, stores and protects personal data. The Privacy Policy also describes how you can control the personal data that STS holds on you, and your rights on your personal data, where applicable.

The data protection laws that apply to STS varies depending on where an STS entity operates, where STS’s products and services are provided and/or where STS’s customers are located. Where it is stated in this Privacy Policy that a provision applies “to the extent required by [the applicable law],” such provision will be applicable only to the extent that STS is subject to the relevant law.

STS may from time to time update this Privacy Policy to ensure that it is consistent with future developments, industry trends and/or any changes in legal or regulatory requirements. Please check regularly for updated information.

This Privacy Policy, together with the Cookie Policy (see below), forms part of the General Terms of Use.

1. Information that STS collects

STS collects information about how to contact you and your interest and relationship with STS, including the products and services which are relevant to you.

Personal data that STS may collect (depending on the nature of your interaction with STS) include:

(a) your name, NRIC, passport or other identification number, telephone number, mailing address, email address and any other information relating to you which you have provided STS in your interaction with STS;

(b) your payment related information, such as your bank accounts;

(c) your employment history, education background, and income levels;

(d) information about your use of STS’s website and services, including cookies, IP address, subscription account details and membership details, but only to the extent that STS may identify you from such information.

Such information is collected:

(a) from you or STS’s related corporations, affiliates, partners and/or representatives with your permission and consent, or STS may receive your personal information from third parties who you have given consent to pass this information on to STS;

(b) through contracts or other legal arrangements you have with STS or STS’s related corporations, affiliates, partners and/or representatives on behalf of STS, so that STS may fulfill the contractual/legal obligations thereunder; or

(c) when you browse STS’s websites (please see the Section “Cookies” below for more information),

for example:

(a) when you use some of STS’s services;

(b) when you submit forms relating to any of STS’s products or services;

(c) when you register for or use any of STS’s services on websites owned or operated by STS or when you register as a member of websites owned and/or operated by STS, or use services on such websites;

(d) when you interact with STS’s personnel such as customer service officers, marketing representatives and agents;

(e) when you request that STS contact you;

(f) when you ask to be included in an email or other mailing list;

(g) when you respond to STS’s promotions and other initiatives;

(h) when you enter into agreements with STS;

(i) when STS receive references from business partners and third parties, for example, where you have been referred by them; and

(j) when you submit a job application or a scholarship application to STS;

(k) when you submit your personal data to STS for any other reason.

2. Purposes for the Collection, Use and Disclosure of Personal Data

Generally, STS collects, uses and discloses your personal data for the following purposes:

(a) to provide products and services to you;

(b) to communicate with you on matters relevant to your relationship with or interest in STS;

(c) to assess and improve the products and services that you use or may use;

(d) to selectively send you information about our products, services, activities and/or events that may be relevant to you;

(e) to fulfil the contractual/legal obligations under the contracts or other legal arrangements entered into between STS and you, or entered into between STS’s related corporations, affiliates, partners and/or representatives and you;

(f) to protect and enforce STS’s contractual and legal rights and obligations;

(g) to verify your identity;

(h) to prevent, detect and investigate crime, including fraud and money-laundering, and analyze and manage other commercial risks;

(i) to conduct audits, reviews and analysis of STS’s internal processes, for action planning and managing commercial risks;

(j) to prevent, detect and investigate crime and manage the safety and security of STS’s premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances);

(k) to comply 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

(l) any other purpose relating to any of the above.

STS may share your personal data to third parties with your consent for the purpose for which the information was collected or to be used, and any other reasonable ancillary purposes, for legal reasons, or where permitted under the PDPA and other applicable laws, such as in response to law enforcement agencies.

If STS transfers your personal data to countries outside Singapore, it will be done in accordance with the relevant provisions under Singapore laws and regulations. STS will also comply with the relevant laws and regulations in relation to transfers of personal data outside countries where the personal data is collected.

3. Marketing Communications

It is in STS’s legitimate interests to process your personal data to selectively contact you and/or send you information about STS’s products, services, activities and/or events that may be relevant to you (“Marketing Communications”). To the extent that STS’s processing of your personal data for Marketing Communications is subject to the European General Data Protection Regulation, you have the right to object to such processing by STS. Please email [email protected] if you wish to exercise this right.

4. Cookies

When you browse STS’s websites, STS uses cookies to store information about how you use these websites in order to improve the quality of service provided to you.

5. Retention of your personal data

STS shall retain your personal data for as long as is necessary for the purposes stated in Section 2 above, and take reasonable measures to destroy any personal data that is no longer necessary to meet those purposes.

6. STS security measures

All your personal data is kept confidential and STS takes all reasonable measures to protect it from unauthorized or accidental access, processing or loss, by implementing appropriate physical, electronic and supervisory controls.

7. How you can control your information

If you do not want STS to contact you by telephone or SMS – You may register with the Personal Data Protection Commission’s national Do-Not-Call register. STSX complies with the PDPA’s requirements on screening telephone communications with the Do-Not-Call register.

If you do not want STS to contact you via electronic messaging – You may select the “unsubscribe” option in all STS electronic communications with you. STS also complies with the Singapore Spam Control Act.

If you want to be removed from STS’s customer database – You may email STS at [email protected]

If you believe STS has inaccurate information about you and you want to correct such data – You may  email [email protected]

If you have any questions about this Privacy Policy, or STS’s handling of your personal data – You may email STS at [email protected]

It is important to note that STS uses your personal information to provide you with the products and services you wish to use. STS also complies with various regulatory requirements in doing so, including the requirements for customer due diligence.  Withdrawal of consent for STS to collect, use or disclose personal information means that STS will stop these activities. The absence of certain key personal information, including but not limited to your name, address, email and/or telephone contacts, personal identification numbers or banking information, may cause STS to be unable to continue providing the relevant products and services to you.

8. Your rights regarding your personal data

To the extent that STS’s processing of your personal data is subject to the European General Data Protection Regulation, you may have the following rights:
• access to your personal data
• rectification of your personal data
• erasure of your personal data
• restrict processing of your personal data
• object to  processing (including object to receiving marketing) of your personal data
• data portability
• lodge a complaint with a EU supervisory authority

If you wish to exercise these rights, or have any questions about these rights, you may email STS at [email protected]

9. Contacting us

If you have any questions about this Privacy Policy, or STS’s handling of your personal data, please email our Data Protection Officer at [email protected]