PDPA Policy

Last updated on 9 November 2020.
We, Covenant Chambers LLC, take your personal data and our legal obligations in respect of the same seriously. This privacy policy sets out the manner in which we collect, use, manage and protect the data that is capable of identifying you as an individual whether on its own or in conjunction with other data accessible by us (Personal Data) in compliance with the Personal Data Protection Act 2012 of Singapore as may be amended from time to time (PDPA).
Please note that capitalised words and expressions shall, unless otherwise specified or the context otherwise requires, have the corresponding meaning assigned to them in the Terms and Conditions of the use of our Website.

1.

Collection of information

1.1 In order for us to provide our services, it is necessary for us to collect and use certain Personal Data.
1.2 While the specific types of Personal Data you provide to us may vary depending on the context in which you provide to us, there are a few broad categories of Personal Data which we may collect from you:
(a) Name and identity Data, which includes your country of residence, job title, age, marital status, gender, and national identification number (only where necessary and relevant).
(b) Matter Data, including any information about you in relation to matters on which you instruct us or in which you are involved.
(c) Contact Data, which includes your email address, fax and/or telephone number.
(d) Likeness Data, including photographs, and audio or video recordings.
(e) Usage Data, which includes information about how you use our Website (including the time you visit our Website, the duration of your visit, the types of services you are searching for and/or how you are searching for such services).
(f) Marketing and Communications Data, which includes your interests, feedback, survey responses, preferences in receiving marketing materials from us and your communication preferences, as well as your preferences for particular services.
(g) Technical Data, which includes your Internet Protocol (IP) address, the internet device identity or media access control address of your device, information regarding the manufacturer, model or operating system of the device that you use and/or information about the web browser that you use to access our Website.
1.3 How we collect your Personal Data:
We collect your Personal Data:
(a) Directly from you. You may give us your Personal Data when you do any of the following (whether on your own behalf or on behalf of your organisation):
(i) visit or use our Website;
(ii) enter into a contract with us;
(iii) enquire about our services;
(iv) in the ordinary course of our relationship;
(v) participate in a survey, event or other marketing campaign organised by us;
(vi) subscribe to our newsletters or alerts;
(vii) contact us – for example, if you get in touch to give us some feedback.
(b) From your authorised representatives. We may also collect your Personal Data from your authorised representatives. These include persons whom you have authorised and persons who have been validly identified as acting on your behalf pursuant to our security procedures.
(c) When you interact with our Website. As you interact with our Website, we may automatically collect your Technical Data. We may collect such personal data by using website cookies
(d) Third parties or publicly available sources. We may receive your Personal Data from third parties which are located in various countries. These include:
(i) Technical Data from analytics providers such as Google, advertising networks and social media platforms such as LinkedIn, Twitter and Facebook; and
(ii) Contact and Transaction Data from providers of technical, payment and delivery services.
1.4 We presume that any Personal Data you provide to us is accurate, complete and up to date.

2.

Use of information

2.1 We may use your Personal Data for the following purposes:
(a) To process you and/or your organisation as a new client (including conducting Know Your Client (KYC) due diligence).
(b) To provide legal advice and services to you and/or your organisation.
(c) To manage your account, including managing payments, fees and charges and collecting and recovering money owed to us.
(d) To manage our relationship with you and/or your organisation.
(e) To administer, operate, provide, maintain and protect our business and our Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data, as well as ensuring that unauthorised users do not access the information on our Website).
(f) To deliver relevant information to you.
(g) To make suggestions and recommendations to you about services that may be of interest to you.
(h) To organise seminars, webinars and events.
(i) To send you relevant information about our events, news announcements, and legal updates.
(j) To enable you to complete a survey or participate in a survey, event or other marketing campaign organised by us.
(k) To respond to your questions, requests or complaints.
(l) Any other purpose for which we notify you and obtain your consent prior to processing.
(m) To contact you in relation to any of the above.
(n) Where we have to use your Personal Data for another purpose as required by law or regulation — for example, to respond to administrative, judicial or law enforcement requests or to comply with applicable laws and regulations.
2.2 If you provide us with any Personal Data of third parties, you represent and warrant that you have obtained all necessary consents to do so, and that we may process such Personal Data for the purposes set out above, in accordance with the PDPA.
2.3 Cookies
We use cookies to provide visitors with a personalised experience on our Website. Cookies are pieces of information that a website transfers to the memory or hard drive of a visitor’s computer for record-keeping purposes. We use cookies to allow access without re-entering the visitor’s User ID, to make improvements, and to better tailor our Website to our visitors’ needs. We also use this information to verify that visitors meet the criteria required to process their requests. Most browsers used by visitors have options that allow the visitor to control whether the browser will accept cookies, reject cookies, or notify the visitor each time a cookie is sent. However, if you disable or refuse cookies, please note that some parts of our Website may become inaccessible or not function properly. In addition, you can delete Covenant Chambers LLC cookies from your browser program at any time.

3.

Disclosure of information

3.1 We may disclose your Personal Data to our affiliated entities and third parties in limited circumstances as set out below:
(a) We may share your Personal Data with our service providers, suppliers, agents or contractors in connection with services they perform for us or pursuant to agreements with them.
(b) We may share your Personal Data with other professional advisors and consultants with whom we are dealing on your behalf, and other third parties including any counterparty or opposing party and/or their lawyers.
(c) We may share your Personal Data with third parties to comply with a legal obligation, when we believe in good faith that an applicable law requires it, at the request of government authorities conducting an investigation, to verify or enforce our contractual rights or other applicable policies, to detect and protect against fraud or any technical or security vulnerabilities, to respond to an emergency, or otherwise to protect the rights, property, safety or security of third parties and visitors to our website or the public.
(d) As we continue to develop our business, we may sell or purchase assets. If another entity merges with us, your Personal Data will be disclosed to such entity.
(e) Also, if any bankruptcy or reorganisation proceeding is brought by or against us, all such information will be considered an asset of ours and as such it is possible they will be sold or transferred to third parties.
(f) We may disclose your Personal Data to third parties without your prior consent under certain circumstances which are permitted by the PDPA.
3.2 We do not disclose your Personal Data to unaffiliated third parties for their independent use unless we have obtained your express consent to do so and pursuant to executing confidentiality agreements with such unaffiliated third parties. We also require all third parties to respect the security of your Personal Data and to treat it in accordance with the law.

4.

Retention of information

4.1 We only retain your Personal Data for as long as is necessary for us to use your Personal Data as described above. However, please be advised that we may retain some of your Personal Data after you cease to use our services, for instance if the data is necessary to meet our legal obligations, such as retaining the information for litigation, tax and accounting purposes.
4.2 In some circumstances we may anonymise your Personal Data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

5.

International transfers of information

Where our service providers, suppliers, agents, contractors, or affiliates who help us in the administration or operation of our organisation are based in other locations, your Personal Data may be transferred outside of Singapore. When we send your Personal Data outside Singapore, we will make sure that your Personal Data is protected to at least the same standard as that in Singapore. For example, we will always ensure that there is a proper legal agreement that covers the data transfer.

6.

Security

Our management and their teams take commercially reasonable precautions to keep Personal Data secure against unauthorised access or use, and we periodically review our security measures. Although there is no way that any website or organisation can absolutely guarantee the security of your Personal Data, Covenant Chambers LLC is committed to employing reasonable security measures, regularly reviewing our security practices (security risk assessments / audits), and providing regular awareness training. You are responsible for keeping your online information and passwords confidential. Covenant Chambers LLC uses security certificates and/or tools for its Website and email security certificates. However, we cannot assume responsibility for any unauthorised access or use of your Personal Data by third parties which are due to factors beyond our reasonable control.

7.

Collection of information from children

7.1 Covenant Chambers LLC does not knowingly collect personal data from children under the age of 13. If you are under the age of 13, please do not provide personal data of any kind whatsoever.
7.2 If a child under the age of 13 provides us with personal data, a parent or guardian of that child may have this information deleted from our records by contacting us at +65 6635 8885 or via email to the Data Protection Officer: [email protected].

8.

Access and making changes to your Personal Data

You may request to access, update, correct or withdraw consent to use or disclose any of the Personal Data that you have provided by contacting us at +65 6635 8885 or via email to the Data Protection Officer: [email protected]. We may fulfil or reject your request in accordance with the PDPA. We may charge an administration fee to process any such request. We will require a reasonable time to respond to and/or process any such request.

9.

Links to others sites

Our Website may contain links to other sites. These sites are not covered by this privacy policy, and we are not responsible for the privacy practices or the content of those other sites.

10.

Changes to privacy policy

We reserve the right to modify this privacy policy and related business practices at any time by posting updated text on this page. Please check this page periodically for updates.

11.

Contact us

If you have any comments, questions or complaints about our privacy policy, please contact us at +65 6635 8885 or via email to the Data Protection Officer: [email protected].