JURONG PORT UNIVERSAL TERMINAL PTE. LTD.
Privacy Policy
We
at Jurong Port Universal Terminal Pte.
Ltd. (“JPUT”) take our
responsibilities under the Personal Data Protection Act 2012 (the “PDPA”) seriously. We also recognise the
importance of the personal data you have entrusted to us and believe that it is
our responsibility to properly manage, protect and process your personal data.
JPUT
operates https://www.jpuniversal.com.sg/
and its subdomains (“Website”) which may be used by you to enquire about
the services offered by JPUT. JPUT also offers services on its portal such as
TankConnect and Vessel Connect. This Privacy Policy sets out how JPUT will
collect, use, and disclose personal data, and the measures that JPUT will have
in place to ensure the security of the personal data in our possession or under
our control. By providing personal data
to us or subscribing/using any of our services, you agree to be bound by the
terms of this Privacy Policy.
1
INTRODUCTION TO THE PDPA
1.1
“Personal data” is
defined under the PDPA to mean data, whether true or not, about an individual
who can be identified from that data, or from that data and other information
to which an organisation has or is likely to have access. Common examples of
personal data could include names, identification numbers, contact information,
financial records, credit card information, photographs and video images.
1.2
We will collect your personal
data in accordance with the PDPA. In general, before we collect any personal
data from you, we will notify you of the purposes for which your personal data
may be collected, used and/or disclosed, as well as obtain your consent for the
collection, use and/or disclosure of your personal data for the intended
purposes.
1.3
Your personal data may
also be collected, used or disclosed if we have assessed that to do so would be
in our legitimate interests and beneficial to the public. Before doing so, we
will take steps to ensure that any adverse effects that might arise for you
have already been identified and eliminated, reduced or mitigated.
2
PURPOSES FOR COLLECTION, USE & DISCLOSURE OF PERSONAL
DATA
2.1
The personal data which
we collect from you may be collected, used and/or disclosed for the following
purposes:
(b)
processing
and/or administering any product-related inquiries, consultations, negotiations,
orders, deliveries, or providing customer support in relation to the purchase
of services;
(c)
processing and/or administering requests for access and/or
correction of your personal data;
(d)
obtaining security clearance from JTC Corporation and/or any other
law enforcement agency, statutory board, government regulator, government
authority for the pass application prior to entry into Jurong Island;
(e)
for administrative, entry access and
security clearance prior to entry into JPUT's premises (and for attending the
in-house Safety Induction Course, if applicable);
(f)
processing
your registration and/or participation for seminars, exhibitions, and other
events organised or co-organised by JPUT;
(g)
carrying out your instructions or responding to any enquiry given
by (or purported to be given by) you or on your behalf;
(h)
conducting customer due diligence or other
screening and
personal identification in accordance with laws, regulations or our risk
management procedures that may be required by law or that may have been put in
place by us;
(i)
to
prevent or investigate any fraud, unlawful activity or omission or misconduct, whether
or not there is any suspicion of the aforementioned;
(j)
complying
with or as required by any applicable law, governmental or regulatory
requirements of any relevant jurisdiction, including meeting the requirements
to make disclosure under the requirements of any law binding on us and/or for
the purposes of any guidelines issued by regulatory or other authorities,
whether in Singapore or elsewhere, with which we are expected to comply;
(k)
complying
with or as required by any request or direction of any governmental authority,
or responding to requests for information from public agencies, ministries,
statutory boards or other similar authorities. For the avoidance of doubt, this
means that we may/will disclose your personal data to the aforementioned
parties upon their request or direction;
(l)
storing,
hosting and backing up (whether for disaster recovery or otherwise) of your
personal data, whether within or outside Singapore;
(m)
administering
security matters and/or arrangements; and
(n)
conducting research, analysis and development activities
(including but not limited to data analytics, surveys and/or profiling) to
improve our products and services in order to enhance your relationship with us
or for your benefit.
2.2
In relation to existing
employees of JPUT, JPUT may collect, use and/or disclose your personal data for
the following purposes:
(a)
administering and
facilitating payment of your salary, claims and/or reimbursements to your bank
account;
(b)
making applications to
the relevant agencies/firms/companies on your behalf for any training courses,
conferences, seminars;
(c)
processing employment
pass applications, visa applications;
(d)
obtaining reference
checks from your ex-employees or providing reference checks to your future
employers and if necessary, governmental and quasi-government bodies, including
but limited to the Inland Revenue Authority of Singapore, Ministry of Manpower and
Central Provident Fund Board;
(e)
tax filing purposes;
(f)
security purposes,
including but not limited to closed-circuit television (CCTV) systems in the
company’s premises which may capture your image and communication; and
(g)
arranging key
installation visits and work-related travel, including the arrangement of
flights, accommodations and visas, when necessary.
2.3
In relation to
prospective employment candidates, JPUT may collect, use and/or disclose your
personal data for the following purposes and by submitting to us your
resume/curriculum vitae, you are deemed to have given consent to us to use,
disclose and/or share your personal data with any of our related companies:
(a)
conducting interviews;
(b)
processing your
application (including pre-recruitment checks involving your qualifications);
(c)
providing or obtaining
employee references and for background screenings;
(d)
processing employment
pass applications. visa applications and letters of appointment;
(e)
evaluating and
assessing your suitability for the position applied for; and
(f)
any other purpose
relating to any of the above.
2.4
The purposes stated in paragraphs
2.1, 2.2 and 2.3 shall collectively be referred to as “Purposes”.
2.5
In order to conduct our
business operations more smoothly, we may also be disclosing the personal data
you have provided to us to our third party service providers, agents and/or our
affiliates or related corporations, which may be sited outside of Singapore,
for one or more of the above-stated Purposes. This is because such third party
service providers, agents and/or affiliates or related corporations would be
processing your personal data on our behalf for one or more of the above-stated
Purposes.
2.6
By providing any
personal data relating to a third party (e.g., information of your dependents,
spouse, children and/or parents) to us, you represent and warrant that the
consent of that third party has been obtained for the collection, use and
disclosure of their personal data for any and all of the Purposes listed above.
You should also ensure that all personal data (whether that of your own or of a
third party) submitted to us is complete, accurate, true and correct. You
should update us in a timely manner of any changes to the personal data
provided to us.
3
SPECIFIC ISSUES FOR THE DISCLOSURE OF PERSONAL DATA TO
THIRD PARTIES
3.1
Please note that we may
disclose your personal data to third parties without first obtaining your
consent in certain situations, including, without limitation, the following:
(a)
cases in which the
disclosure is required based on the applicable laws and/or regulations;
(b)
cases in which the
purpose of such disclosure is clearly in your interests, and if consent cannot
be obtained in a timely way, provided that we shall, as soon as may be
practicable, notify you of the disclosure and the purposes of the disclosure;
(c)
cases in which the
disclosure is necessary to respond to an emergency that threatens the life,
health or safety of yourself or another individual;
(d)
cases in which there
are reasonable grounds to believe that the health or safety of yourself or
another individual will be seriously affected and consent for the disclosure of
the data cannot be obtained in a timely way, provided that we shall, as soon as
may be practicable, notify you of the disclosure and the purposes of the
disclosure;
(e)
cases in which the
disclosure is necessary for any investigation or proceedings;
(f)
cases in which the
personal data is disclosed to any officer of a prescribed law enforcement
agency, upon production of written authorisation signed by the head or director
of that law enforcement agency or a person of a similar rank, certifying that
the personal data is necessary for the purposes of the functions or duties of the
officer; and/or
(g)
cases in which the disclosure is to a public agency
and such disclosure is necessary in the public interest.
3.2
The instances listed
above at paragraph 3.1 are not intended to be exhaustive. For an exhaustive
list of exceptions, you are encouraged to peruse the First and Second Schedules
of the PDPA which are publicly available at https://sso.agc.gov.sg/.
3.3
In all other instances
of disclosure of personal data to third parties, we will only do so if you have
provided your consent. We will endeavor to provide adequate supervision over
the handling and administration of your personal data by such third parties, as
well as to provide for adequate forms of protection over such personal data.
3.4
Where personal data is transferred by us to any third
parties outside of Singapore, we will ensure that such transfers are compliant
with the requirements under the PDPA. In this regard, we will take such
necessary measures to ensure that such overseas recipients are bound by legally
enforceable obligations to ensure that these overseas recipients provide a
standard of protection to the personal data so transferred that is comparable
to the protection under the PDPA.
4
REQUEST FOR ACCESS AND/OR CORRECTION OF PERSONAL DATA
You may request for access and/or to correct the personal
data currently in our possession at any time by submitting your request to the
contact details listed at paragraph 7.2.
5
REQUEST TO WITHDRAW
CONSENT
5.1
You may withdraw your
consent for the collection, use and/or disclosure of your personal data in our
possession or under our control at any time by submitting your request to the
contact details listed below at paragraph 7.2.
5.2
We will process your
request within a reasonable time from such a request for withdrawal of consent
being made, and will thereafter refrain from collecting, using and/or
disclosing your personal data in the manner stated in your request.
6
ADMINISTRATION AND MANAGEMENT OF PERSONAL DATA
6.1
We will take
appropriate measures to keep your personal data accurate, complete and updated.
6.2
We will also take
commercially reasonable efforts to take appropriate precautions and preventive
measures to ensure that your personal data is adequately protected and secured.
Appropriate security arrangements will be taken to prevent any unauthorized
access, collection, use, disclosure, copying, modification, leakage, loss,
damage and/or alteration of your personal data. However, we cannot assume
responsibility for any unauthorized use of your personal data by third parties
which are wholly attributable to factors beyond our control.
6.3
We will also take
commercially reasonable efforts to ensure that the personal data in our
possession or under our control is destroyed and/or anonymized as soon as it is
reasonable to assume that (a) the purpose for which that personal data was
collected is no longer being served by the retention of such personal data; and
(b) retention is no longer necessary for any other legal or business purposes.
7
COMPLAINT PROCESS
7.1
If you have any
complaint or grievance regarding how we are handling your personal data or
about how we are complying with the PDPA, we welcome you to contact us with
your complaint or grievance.
7.2
Please contact us
through one of the following methods with your complaint or grievance:
(a)
E-mail: [email protected].
Attention it to the “Data Protection Officer”.
(b)
Office address: 61
Meranti Crescent, Singapore 627807. Attention it to the “Data Protection
Officer”.
7.3
Where it is an email or
a letter through which you are submitting a complaint, your indication at the
subject header that it is a PDPA complaint would assist us in attending to your
complaint speedily by passing it on to the relevant staff in JPUT to handle.
For example, you could insert the subject header as “PDPA Complaint”.
7.4
We will certainly
strive to deal with any complaint or grievance that you may have speedily and
fairly.
8
UPDATES ON PRIVACY POLICY
8.1
As part of our efforts
to ensure that we properly manage, protect and process your personal data, we
will be reviewing our policies, procedures and processes from time to time.
8.2
We reserve the right to
amend the terms of this Privacy Policy at our absolute discretion. Any amended Privacy
Policy will be posted on our Website and can be viewed at https://www.jpuniversal.com.sg/en/PDPA.html.
8.3
You are encouraged to
visit the above website from time to time to ensure that you are well informed
of our latest policies in relation to personal data protection.
Last Updated on 14 August 2023