HOME

Privacy Policy

STRATAGILE Pte Ltd (“STRATAGILE” or, as appropriate in the context, “we”, “us” or “our”) is a company registered under the Laws of Singapore.

STRATAGILE respects the protection of your Personal Data and values the relationship we have with you.

This Privacy Policy (“Policy”) describes the types of Personal Data we might collect from you, how we might use that information, and with whom we might share it.

Our Policy also describes the measures we take to protect the security of the information you provide to us, including without limitation through this Website.

We also tell you how you can reach us to update your Personal Data, ask questions you may have about our personal data protection practices and provide feedback on our personal data protection practices.

“Personal Data” in this Policy means data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which the organisation has or is likely to have access.

1. Personal Data – What We Collect

The types of Personal Data we collect about individuals might, but not necessarily, include:

1. personal particulars (e.g., name, date of birth, contact information, residential address, NRIC/FIN/Passport details and/or education details)

2. financial information (e.g., particulars relating to income, expenditure, tax, insurance, risk profile, investments, business interests, assets, financial objectives, knowledge, experience, bank accounts, transactions and/or credit history)

3. specimen signature

4. audio, video and images

5. employment information and associated particulars (e.g. occupation, titles and positions held, duties and responsibilities, employment history, remuneration and/or benefits)

6. personal opinions provided to us (e.g. feedback or survey responses)

You might have provided the Personal Data to us personally or authorised other individuals to provide the Personal Data to us and consent (on your behalf) to our collection of your Personal Data from these individuals.

Where you give us Personal Data about yourself, you confirm that you consent to the use, disclosure, retention and processing of such Personal Data for the purposes described in Section 2 or other purposes for which your consent has been sought and obtained.

Where you give us Personal Data about other individuals, you confirm that you are authorised to disclose and consent, on their behalf, to the use, disclosure, retention and processing of such Personal Data for the purposes described in Section 2 or other purposes for which your authorised consent on their behalf has been sought and obtained.

2. Personal Data – Why We Collect

The Personal Data that we collect might, but not necessarily, be used for the following purposes:

If you are a Vendor / Service Provider / Business Partner

i. To conduct due diligence / background checks mandated by legislation or STRATAGILE’s internal policies, requirements and practices

ii. To facilitate the supply of products and services and support by vendors / service providers / business partners to STRATAGILE

iii. To keep vendors / service providers / business partners updated on changes to STRATAGILE’s policies

iv. To evaluate and to improve STRATAGILE’s products and services

v. To evaluate the products and services provided by vendors / service providers / business partners to STRATAGILE

vi. To facilitate interactions with STRATAGILE

If you are a Customer

i. To conduct due diligence / background checks mandated by legislation or STRATAGILE’s internal policies, requirements and practices

ii. To facilitate the providing of products and services and to communicate with customers as part of providing products and services

iii. To evaluate and to improve STRATAGILE’s products and services

iv. To respond to queries or comments on STRATAGILE’s products and services

Others

i. To evaluate applications for employment / job positions within STRATAGILE

ii. To conduct due diligence/background checks on job applicants

iii. To organise and manage events for community and charitable purposes

iv. For security clearance / entry access into STRATAGILE’s premises

We collect and use Personal Data only for purposes which you have consented to and for which we have been authorised.

If we need to use your Personal Data for any purpose which you have not previously consented to, we will seek your consent prior to using your Personal Data for the new purpose.

3. Personal Data – Disclosure, Sharing & Transfer

STRATAGILE does not sell or rent Personal Data that we collect from individuals, including our website visitors except in the course of or in connection with providing our products and services to our customers. We disclose, share and transfer Personal Data to the following parties for the following purposes:

i. To our agents/vendors/subcontractors/consultants/business partners for the purposes of providing products and services to our customers on our behalf.

ii. To government and non-government authorities, agencies and/or regulators as required under law or under directions or orders from the government and non-government authorities, agencies and/or regulators for security, regulatory approvals or permits.

iii. To other STRATAGILE entities for the purpose of responding to questions, concerns, comments or feedback on our products or services or our business, or to share knowledge on issues such as industry developments, STRATAGILE’s business, market outlook, corporate events and other products and services of STRATAGILE that may be of interest to your company, organisation or business.

iv. To other STRATAGILE entities to facilitate the provision of products and services to our customers where the project or engagement involves other STRATAGILE entities.

v. To event organisers and service providers to facilitate the planning of events / functions that STRATAGILE organises or is involved in.

We might transfer, store, process and/or deal with your personal data outside Singapore. If we do so, we will comply with the applicable data protection and privacy laws.

We also disclose and transfer Personal Data to the following parties for the purposes of managing, operating, administering and running our business and for our business and legal purposes:

i. To group companies for security purposes

ii. To group companies for purposes of evaluating our products and services and our business as a group

iii. Financial institutions for purposes of payments and transactions related to STRATAGILE’s provision of products and services or related to products and services provided to STRATAGILE by our vendors / service providers / consultants

iv. To our service providers (who may be located outside Singapore) that have been retained to perform services on our behalf or on behalf of group companies, including:

a. Service providers who provide IT and outsourcing services such as data storage, electronic mail services, deployment of management operations for information technology and HR outsourcing services,

b. Professional, financial and legal advisors, tax advisors, auditors, insurers and insurance brokers,

c. Vendors, service providers and consultants that have been engaged to help manage, operate, administer and run STRATAGILE’s operations and business process or provide services to facilitate our provision of our products and services, and

d. External contractors that provide consultancy and evaluative services to STRATAGILE and for STRATAGILE’s products and services, or organise events for STRATAGILE.

v. For job applicants, your Personal Data may be shared with other entities in the Group companies if STRATAGILE takes the view that you may be suitable or eligible for another job position within the Group, unless you inform us otherwise (please refer to Section 7). The Personal Data will be used in a confidential manner to help STRATAGILE Group monitor recruitment processes. STRATAGILE requires that the parties to whom we transfer Personal Data and our service providers implement adequate levels of protection in order to protect Personal Data. We also require that these parties only process Personal Data strictly for purposes for which we engage them for and consistent with the purposes that we have described in Section 2 or with other purposes for which consent has been sought and obtained.

In addition, we would disclose Personal Data in the following circumstances:

i. we are required to do so by law,

ii. in response to a request from law enforcement authorities or other government officials,

iii. to comply with a court order or direction from a government agency or regulatory authority ordering the disclosure of the Personal Data; and

iv. where the disclosure is necessary for investigations or legal proceedings.

4. Cookies & Internet Technologies

Websites and other online and mobile applications [“app(s)”] that we might own or maintain might place small text files, called cookies, on your computer or mobile device when you visit a website or use an app.

Cookies gather data like Internet Protocol (IP) addresses and other information related to your visit or use of our website or app(s).

We use the cookies and other technologies to facilitate and improve your interaction with our systems and to track the effectiveness of our websites and apps. We might also make use of pixel tags or web beacons, which are invisible tags placed on webpages but not on your computer. Pixel tags are usually used in conjunction with cookies and are used to monitor the behaviour of users visiting the website.

You may set up your web browser to block cookies, which will, in turn, disable the pixel tags from monitoring your website visit. You may also remove cookies stored from your computer or mobile device. However, if you do block cookies and pixel tags, you may not be able to use certain features and functions of our websites.

Our websites might also contain links to other websites not maintained by STRATAGILE. This privacy policy applies only to STRATAGILE’s websites. When visiting others’ websites, you should read their privacy policies regarding your use of their websites.

5. Protection of Personal Data

With reference to Personal Data, we have safeguards to protect against accidental or unauthorised access, collection, use, disclosure, copying, sharing, disposal, deletion, modification and other similar risks.

6. Retention of Personal Data

STRATAGILE retains Personal Data only for as long as the retention is required for the purposes for which we collected the Personal Data, the purposes described in this Policy and for our business and legal purposes. Generally, we do not retain Personal Data for a period longer than 7 years after the original purposes for which the Personal Data was collected have ceased to be applicable, unless otherwise required by law or other mandatory directions by court or government authorities or for purposes of legal proceedings or other similar proceedings or investigations. For unsuccessful job applicants, STRATAGILE will retain your Personal Data for no longer than one year for the purposes of evaluating your suitability for future job openings within STRATAGILE, unless you inform us otherwise (please refer to Section 7).

7. How to Contact Us

If you have any questions or comments about this Policy and our policies and practices on our collection, use, disclosure or retention of Personal Data, you may contact our Data Protection Officer.

Email address:     dpo@stratagile.com

If you are a job applicant and wish to inform us that:

  • you do not wish for STRATAGILE to share your personal data with other entities in the STRATAGILE Group for evaluating your suitability or eligibility for another job position within the Group companies other than the one you are applying for; or
  • you do not wish for STRATAGILE to retain your personal data for the purposes of evaluating your suitability for future job openings within the STRATAGILE Group, please contact our Data Protection Officer.

Email address:     dpo@stratagile.com

8. Updating or Correcting your Personal Data

STRATAGILE takes reasonable measures to ensure that the Personal Data we collect about individuals is accurate and complete.  For this reason, if there is any change or update in Personal Data, we would like to know about these changes or updates.

If there is a change or an update in your Personal Data or if there is a need to correct any Personal Data of yours that we have, please write to us and provide us with the following details:

  • Your name
  • An address to contact you
  • The nature of our relationship with you
  • The Personal Data to be changed, updated or corrected

You may send your requests to our Data Protection Officer at the contact details listed in Section 7 above. We will endeavour to acknowledge the receipt of your request within seven working days after the date of receipt of your request.

As it is important to us that the Personal Data that we have about you is accurate and complete, it may be necessary for us to request for supporting documentation from you. We will contact you if we require supporting documentation from you.

There may be circumstances where we will not update or correct Personal Data, including:

  1. The Personal Data is opinion data that is kept solely for an evaluative purpose; and
  2. The Personal Data is in documents related to a prosecution if all proceedings relating to the prosecution have not been completed.

9. Requests & Feedback on Personal Data

You may request for information from STRATAGILE on what Personal Data of yours we have and how we have used and shared your Personal Data during the last one year before the date of your request. To learn how you can request for information from STRATAGILE, please see our Request for Information Notice.You may also choose to withdraw your consent to STRATAGILE’s use, collection, sharing or processing of your Personal Data at any time. To learn how you can withdraw your consent, please see our Withdrawal of Consent Notice.

Please note that your withdrawal of your consent to our use of your Personal Data may affect our provision of products and services to you or our business dealings with you, depending on the nature of your relationship with us.

If you have any concerns, feedback or complaints about the use and/or sharing of your Personal Data, we are open to receiving your feedback or complaint. To learn how you may submit a complaint about our use and/or sharing of your Personal Data, please see our Feedback and Complaint Notice. 

10. Updates to Policy

We may change or update portions of this Policy at any time and without prior notice to you. Please review this Policy from time to time so you are aware of any changes or updates to the notice. The effective date of this Policy is provided at the end of this document.

If you do not agree with any of the changes or updates to the Policy, you have the option of withdrawing your consent to our collection, use, disclosure and processing of your Personal Data (please refer to Section 9 above).

Effective Date: 01 January 2021

Accordion Content

STRATAGILE Pte Ltd is a company registered under the Laws of Singapore. STRATAGILE Pte Ltd (“STRATAGILE” or, as appropriate in the context, “we”, “us” or “our”) respects the protection of your Personal Data and values the relationship we have with you.

Personal Data means data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which the organisation has or is likely to have access.

This Request for Information Notice describes how you can submit a request to us to request for information on what Personal Data of yours STRATAGILE has and how STRATAGILE has used and disclosed your Personal Data within the last one year before the date of your request.

Submitting a Request for Information

To submit a request for information on what Personal Data of yours STRATAGILE has and how STRATAGILE has used and shared your Personal Data within the last one year before the date of your request, please complete the form and send it to our Data Protection Officer by e-mail to:

Email address:     dpo@stratagile.com

STRATAGILE may charge a fee to cover the administrative costs of responding to your request for information, such as any printing or postage costs and any reasonable costs that STRATAGILE incurs specifically in order to retrieve the relevant information to respond to your requests.

STRATAGILE will inform you about the fee to be paid upon our receipt of your request for information.

Please pay the fee by cheque made payable to “STRATAGILE Pte Ltd” and send it to the above mailing address. Please enclose a copy of your form with the cheque so that we will know that the cheque is payment for your request for information.

Please note that cash is not an acceptable mode of payment of the administrative fee.

Once we receive payment of the administrative fee, we will respond to your request for information within 30 days from the date of our receipt of payment of the administrative fee.

In certain circumstances, we might require more time to respond to your request for information. If this is so, we will contact you within 30 days from the date of our receipt of payment of the administrative fee and inform you of our estimated time of our response.

If we require more information from you in order to respond to your request, we will contact you within 30 days from the date of our receipt of payment of the administrative fee to obtain the necessary information from you.

Please note that there are some circumstances under which STRATAGILE will not accede to your request for information. These circumstances include:

  1. You have requested for opinion data that is kept solely for an evaluative purpose
  1. You have requested for documents related to a prosecution when all proceedings relating to the prosecution have not been completed
  1. You have requested for Personal Data which is subject to legal privilege
  1. You have requested for Personal Data the disclosure of which would reveal confidential commercial information that could harm the competitive position of STRATAGILE
  1. Your request relates to Personal Data that is collected, use or disclosed for the purposes of an investigation where the investigation and associated proceedings and appeals have not been completed
  1. In STRATAGILE’s discretion:

(a)     your request would unreasonably interfere with the operations of STRATAGILE because it is repetitious or systematic

(b)     the burden or expense of responding to your request would be unreasonable to STRATAGILE or disproportionate to your interests

(c)     your request is for information that does not exist or cannot be found

(d)     your request is for information that is trivial, or

(e)     your request is otherwise frivolous or vexatious.

The full list of exceptions and circumstances is available in the Fifth Schedule of the Personal Data Protection Act 2012 (see the Legislation Division of the Attorney General’s Chambers’ website at Singapore Statutes Online https://sso.agc.gov.sg/).

In the event that any of the above circumstances apply to your request for information, we will contact you within 30 days from the date of receipt of payment of the administrative fee and inform you of the reason for STRATAGILE not being able to respond to your request for information.

If you have any queries concerning our Request for Information Notice, please contact the Data Protection Officer whose contact details are set out above.

Form for Request for Information

Date of Request:                                 _______________ (DD/MM/YYYY)

Personal Particulars

Full Name :                                               ————

NRIC/FIN/Passport Number:                 ————

Contact Number:                                                          

(Mobile):                                                   ————

(Office):                                                    ————

Email:                                                        ————

Address:                                                   ————

Mailing Address:                                     ————

Scope of Request

Please indicate the scope of your request for information:

  • I would like to know what Personal Data of mine STRATAGILE has. (To facilitate our response, please provide details of the Personal Data requested, including further information, if any, such as the associated incident or transaction, the circumstances under which the Personal Data was collected or held, etc.).

Details:

  • I would like to know how STRATAGILE has used and disclosed my Personal Data in the last one year before the date of my request.

To assist us in our response, please let us have the following information:

  • Date around which or period within which the requested Personal Data was collected (if known): _______________________________
  • The name/email of the STRATAGILE Pte Ltd staff member who collected the requested Personal Data (if known): ______________________

Please indicate your relationship with STRATAGILE:

  • I am an employee, representative, agent or officer of one of STRATAGILE’s vendors / service providers / business partners / customers. My company is ________________________________ (name of company).
  • I had applied for employment with STRATAGILE in ______________ (please state the year/month, if possible) / I was employed by STRATAGILE from _____________________ to __________________ (please state the time period of employment).
  • Others: _______________________________________

Preferred Mode of Response

Please indicate your preferred mode of communication of our response to you:

  • By registered mail/ordinary mail at my mailing address given above
  • By email at my email address given above

STRATAGILE Pte Ltd is a company registered under the Laws of Singapore.

STRATAGILE Pte Ltd (“STRATAGILE” or, as appropriate in the context, “we”, “us” or “our”) respects the protection of your Personal Data and we at STRATAGILE Pte Ltd value our relationship with you.

STRATAGILE agrees that you have the right under the Personal Data Protection Act (2012) to withdraw consent to us using, disclosing and processing your Personal Data.

Personal Data means data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which the organisation has or is likely to have access.

This Withdrawal of Consent Notice describes how you can inform us of your withdrawal of consent to us using, disclosing and processing your Personal Data.

Observing the steps and using the prescribed form as described in this Notice will greatly facilitate and assist us in responding to your request expediently.

Withdrawing Your Consent

You may withdraw your consent to STRATAGILE using, disclosing and processing your Personal Data for a particular purpose(s) at any time.

The purposes for which STRATAGILE uses, discloses and processes your Personal Data are set out in our Privacy Policy.

Some purposes for which STRATAGILE uses and shares your information are necessary to STRATAGILE providing services to you (or, where applicable, to your employer or to your business).

Other purposes are optional to STRATAGILE providing services to you. You may withdraw your consent to optional purposes without withdrawing consent for necessary purposes.

STRATAGILE will respect your decision to withdraw consent. Should you choose to withdraw consent to STRATAGILE using, disclosing and processing your Personal Data for purposes necessary to STRATAGILE providing services to you, STRATAGILE will respect your decision and will stop using, disclosing and processing your Personal Data.

However, please understand that your withdrawal of consent for purposes necessary to STRATAGILE providing services to you may carry legal or practical consequences, which will continue to apply.

To notify us that you wish to withdraw your consent to STRATAGILE using and sharing your Personal Data for a particular purpose(s), please complete the form and send it to our Data Protection Officer by email:

Email address:     dpo@stratagile.com

Once we receive your notice that you wish to withdraw consent, we will contact you within seven days to acknowledge receipt of your withdrawal notice and within 30 days to inform you of the likely consequences of your withdrawal of your consent to STRATAGILE using and sharing your Personal Data.

STRATAGILE will cease to use and share your Personal Data within 30 days after our acknowledgement of receipt of your withdrawal notice.

STRATAGILE will also inform STRATAGILE’s agents and data intermediaries (organisations who process Personal Data for and on behalf of STRATAGILE under agreement) to stop using and sharing your Personal Data.

If we require more information from you to respond to your request for withdrawal of consent, we will contact you at the contact address you have provided within 30 days after our acknowledgement of receipt of your withdrawal notice to obtain the necessary information from you.

Please understand that after your withdrawal of consent, STRATAGILE will continue to retain your Personal Data for STRATAGILE’s business and legal purposes in accordance with applicable legislation, including the Personal Data Protection Act 2012.

If you have any queries concerning our Withdrawal of Consent Notice, please contact the Data Protection Officer.

Form for Withdrawal of Consent

STRATAGILE respects the protection of the Personal Data of individuals. STRATAGILE appreciates that individuals may have reasons for wanting to withdraw consent that they earlier provided to us to use, disclose and process their Personal Data.

If you wish to withdraw your consent to STRATAGILE using and sharing your Personal Data for a particular purpose(s), please fill in this Notice and send it to the Data Protection Officer by email:

Email address:     dpo@stratagile.com

STRATAGILE will send you an acknowledgement of receipt of your Notice within seven days.

If we require more information from you in order to respond to your request for withdrawal of consent, we will contact you within 30 days after our acknowledgement of receipt of your withdrawal notice to obtain the necessary information from you.

STRATAGILE will respect your decision to withdraw your consent to our use and sharing of your Personal Data for purposes specified by you.

However, please understand that should you choose to withdraw consent to STRATAGILE using and sharing your Personal Data for purposes necessary to STRATAGILE providing services to you, your withdrawal may carry legal or practical consequences, which will continue to apply.

Full Name :                                               ————

NRIC/FIN/Passport Number:                 ————

Contact Number:                                                          

(Mobile):                                                   ————

(Office):                                                    ————

Email:                                                        ————

Address:                                                   ————

Mailing Address:                                     ————

 

Name of the organisation you work for (if applicable, for STRATAGILE’s vendors, service providers, business partners and customers): ______________________________

I wish to give notice of my withdrawal of my consent to STRATAGILE’s use, disclosing and processing of my Personal Data for the following purpose(s)*:

  • To communicate with me about STRATAGILE’s business, products and services
  • To communicate with me concerning any changes or updates to STRATAGILE’s policies
  • To communicate with me concerning events organised by STRATAGILE
  • Others: __________________________________________

*Please select the relevant purpose(s). If you select ‘Others’, please state the purpose(s) to assist us to respond to your request expediently.

I acknowledge that depending on the purpose(s) for which I am withdrawing my consent to STRATAGILE’s use, disclosure and processing of my Personal Data, my withdrawal may affect STRATAGILE’s provision of services to me or the organisation I am working for (as applicable) in future and may carry legal or practical consequences, which will continue to apply.

I also acknowledge that the withdrawal of my consent will not take effect immediately and there will be a period of 30 days from the date of STRATAGILE’s acknowledgement of receipt of this Notice before STRATAGILE will stop the use and sharing of my Personal Data.

Signature:              _______________

Date:                      _______________ (DD/MM/YYYY)

STRATAGILE Pte Ltd (“STRATAGILE” or, as appropriate in the context, “we”, “us” or “our”) is a company registered under the Laws of Singapore. STRATAGILE respects the protection of your Personal Data and values the relationship we have with you.

Personal Data means data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which the organisation has or is likely to have access.

This Feedback and Complaint Notice describes how you can provide your feedback and/or complaints to us on STRATAGILE’s Personal Data protection policies and practices or on how STRATAGILE has used and shared your Personal Data.

Submitting Feedback on Personal Data Protection Policies & Practices

If you have any feedback concerning our Personal Data protection policies and practices, please send your feedback by e-mail to:

Email address: dpo@stratagile.com

Submitting a Complaint on Use and/or Sharing of Personal Data

If you have a complaint on how STRATAGILE has used and/or shared your Personal Data, you may submit your complaint to the Data Protection Officer by completing the Form and sending it by e-mail to the contact details provided above.

STRATAGILE takes all complaints that it receives on STRATAGILE’s use and sharing of your Personal Data seriously and we will look into and investigate your complaint.

We might need to contact you to request for more information or documentation in order to assist us or to facilitate us looking into or investigating your complaint. For this reason, we would need you to provide us with your contact details when you fill in the Form so that we can contact you for this purpose and to respond to your complaint once we have finished looking into and/or investigating your complaint.

We will use reasonable endeavours to respond to your complaints in writing within 45 days from the date of our acknowledgement to you of our receipt of your complaint. If we are unable to respond to your complaint within 45 days, we will inform you of the estimated time when we would be able to respond to your complaint.

At any time, you may contact our Data Protection Officer to enquire about the status of your complaint, or if you have any queries whatsoever about our Personal Data protection policies and practices.

 Complaint Form

Personal Particulars

Full Name :                                               ————

NRIC/FIN/Passport Number:                 ————

Contact Number:                                                          

(Mobile):                                                   ————

(Office):                                                    ————

Email:                                                        ————

Address:                                                   ————

Mailing Address:                                     ————

*Please provide a valid mailing address or email address for receiving our response on your complaint.

 Relationship with STRATAGILE

Please indicate your relationship with STRATAGILE:

  • I am a customer / employee, representative or agent of STRATAGILE’s customer/ vendor / service provider / business partner. I work for _______________ (name of company).
  • I previously applied for employment with STRATAGILE in ___________ (please specify year and month, if possible) / I was employed by STRATAGILE from ____________ to ____________ (please specify time period of employment).
  • Others: _______________________

Complaint

Please describe your complaint on STRATAGILE’s use and/or sharing of your Personal Data.

(If you can identify the relevant person(s) or department(s) within STRATAGILE that dealt with your Personal Data, please include the details.)

(Please also attach all relevant documentation to this Form.)

 Preferred Mode of Response

Please indicate your preferred mode of communication of our response to you:

  • By registered mail/ordinary mail at my mailing address given above
  • By email at my email address given above

 Declaration

I confirm that all statements I made on this Form are true, accurate and complete to the best of my knowledge and belief. I understand and agree that I may be requested to provide documentation or further details to assist or facilitate STRATAGILE in looking into, investigating and responding to my complaint. I agree to provide such documentation or further details as requested for by STRATAGILE.

Signature:                ____________

Date:                        ____________ (DD/MM/YYY)