If you are a resident of the European Union (“EU”), please see the below Appendix A for additional information regarding our use of your personal data.
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Personal data that we collect from you includes but is not limited to:
NRIC, passport or other identification number;
contact details (including address, telephone number, e-mail address);
employment, education, and income details; and
other information relating to you which you have provided to us in any forms you may have submitted to us, or in other forms of interaction with you.
Purposes for the Collection, Use and Disclosure of Personal Data
Pangaea collects, uses and/or discloses your personal data, including any additional information you may subsequently provide, for the following purposes (hereinafter collectively referred to as the “Purposes”):
processing of your application to open an account with us;
to contact you and to send statements/notices to you relating to your account and holdings therein;
to carry out your instructions or respond to any enquiry from you;
to deal with any other matters relating to your account and holdings therein;
to form part of the records of the recipient as to the business carried out by it;
communicating with you to inform you of changes and updates to our policies, terms and conditions and other administrative information;
to observe any legal, government or regulatory requirements of Singapore or other relevant jurisdiction including any disclosure or notification requirements to which any recipient of the data is subject;
to satisfy our responsibility relating to 'Know Your Customer' (KYC) requirements; and
other purposes, directly or indirectly relating to any of the above and our activities
Where you have specifically provided us with consents, we may also collect, use and/or disclose for the following purposes: (i) sending you marketing updates on our services and products; (ii) promoting and administering events, contests and competitions; and (iii) developing marketing programmes.
Pangaea does not sell, rent, lease, or release your personal data to third parties. Pangaea may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your unique personal data is not transferred to the third party without your explicit consent. In addition, Pangaea may share personal data with trusted partners to help us perform statistical analysis, send you email or provide customer support. All such third parties are prohibited from using your personal data except to provide these services to Pangaea, and they are required to maintain the confidentiality of your personal data.
Disclosure of Personal Data
Your personal data may be disclosed to our related or associated companies, affiliates, delegates, trustee(s), business partners, and/or service providers, or any third party and/or agents (including outsourcing agents and data processors), any and all governmental and/or quasi-governmental departments and/or agencies, regulatory and/or statutory bodies, any court and/or officer of the court for any of the above Purposes or any other purpose for which your personal data was to be disclosed at the time of its collection or any other purpose directly related to any of the above Purposes.
We may also disclose your personal data to third parties: (a) in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of such business or assets; and (b) if Pangaea or substantially all of its assets are acquired by a third party, in which case personal data held by it about its clients will be one of the transferred assets.
Withdrawal of Consent
Please note that if you withdraw your consent to any or all use or disclosure of your personal data (other than for purposes of direct marketing), we may not be able to process your personal data for all of the Purposes.
Access and correction of your personal data
You are responsible for ensuring that the personal data you provide is accurate, complete, and not misleading and that such personal data is kept up to date.
You may access and request for correction of your personal data by contacting the Personal Data Protection Officer, at our office with any enquiries in respect of your personal data via email at: email@example.com. We reserve the right to refuse to comply with your request for access or correction to your personal data under the PDPA and if we refuse to comply with such request, you will be informed of such refusal and the reason for the same.
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Appendix A: Additional Provisions Applicable to Processing of Personal Data of EU residents
These provisions apply to you if you are a resident of the EU and they are pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the Protection of Natural Persons with Regard to the Processing of Personal Data and on the Free Movement of Such Data (commonly referred to as the “General Data Protection Regulation” (“GDPR”).
1. Rights of Individuals
Access, Correction and Erasure Requests
You have the right to:
ask us to confirm whether we are processing your personal data
receive information on how your personal data is being processed
obtain a copy of your personal data
request that we update or correct your personal data
request that we delete personal data in certain circumstances
Right to Object to Processing
You have the right to request us to cease processing your personal data:
for marketing activities, including profiling
for statistical purposes
where such processing is based on our legitimate business interests, unless we are able to demonstrate a compelling legitimate basis for such processing or we need to process your personal data to establish, exercise or defend a legal claim.
Right to Restrict Processing
You have the right to request that we limit the processing of your personal data:
while we are evaluating or in the process of responding to a request by you to update or correct your personal data
where such processing is unlawful but you do not want us to delete your personal data and would like us simply to store your personal data instead
where we no longer require such data, but you want us to retain the personal data to establish, exercise or defend a legal claim
where you have submitted an objection to processing based on our legitimate business interests, pending our response to such request
Data Portability Requests
You have the right to request that we provide you or a third party that you designate with certain of your personal data in a commonly used, machine-readable format. Please note that data portability rights only apply to personal data that we have obtained directly from you and only where our processing is based on consent or the performance of a contract.
We will only release personal data to your designated third party where it is technically feasible and you agree that we are not responsible for the security of such personal data or its processing once released to such third party.
Right to Withdraw Consent
2. Segmentation (also known as profiling) and Automated Decision Making
We may from time to time use personal data to segment our visitors and customers based on share characteristics such as geography, behaviour or demographics. With your consent, we make from time to time make automated decisions based on such segmentation or your specific personal data to offer you certain benefits based on your characteristics. You may withdraw your consent to such automated decision-making at any time following the withdrawal of consent procedure described above.