AGGREGATE CONSULTING SERVICES PRIVACY POLICY (“POLICY”)
This Policy sets out the manner in which AGGREGATE CONSULTING SERVICES Tech Pte. Ltd. (“AGGREGATE CONSULTING SERVICES”) collects, uses, manages and protects Personal Data (as defined below) in compliance with the provisions of the Personal Data Protection Act 2012 (“PDPA”).
This Policy applies to all Individuals (as defined below) who provide AGGREGATE CONSULTING SERVICES with Personal Data or whose Personal Data is otherwise collected, used and/or disclosed by AGGREGATE CONSULTING SERVICES in connection with and/or for the purposes of its operations.
This Policy supplements but does not supersede or replace any previous consent which an Individual may have provided to AGGREGATE CONSULTING SERVICES, nor does it affect any rights that AGGREGATE CONSULTING SERVICES may have at law in connection with the collection, use and/or disclosure of any Individual’s Personal Data. Subject to that, AGGREGATE CONSULTING SERVICES will not collect any Personal Data from an Individual unless the Individual has voluntarily chosen to provide us with the Personal Data or as required for the purposes of providing services to the Individual or by law.
AGGREGATE CONSULTING SERVICES may from time to time update this Policy to ensure it is consistent with its future developments or business purposes or to accommodate future changes to applicable legal or regulatory requirements. All updates to this Policy will be published at http://www.incorporateyour.com (“AGGREGATE CONSULTING SERVICES Website”) and appropriate notifications of any material revisions will be published on the AGGREGATE CONSULTING SERVICES Website and may be issued separately to relevant persons such as may be determined by AGGREGATE CONSULTING SERVICES. Subject to an Individual’s rights at law, the prevailing terms of the Policy from time to time shall apply. By continuing their relationship with AGGREGATE CONSULTING SERVICES after any amendments have been introduced and published on the AGGREGATE CONSULTING SERVICES Website, Individuals shall be deemed to have accepted the Policy as amended.

For the avoidance of doubt, this Policy forms part of the terms and conditions, if any, governing an Individual’s specific relationship with AGGREGATE CONSULTING SERVICES (“Terms and Conditions”) and should be read in conjunction with such Terms and Conditions. In the event of any conflict or inconsistency between the provisions of this Policy and the Terms and Conditions, the provisions of the Terms and Conditions shall prevail to the fullest extent permissible by law.


1.	Definitions:For purposes of this Policy:“Individual” means a natural person, whether living or deceased and “Individuals” shall be construed accordingly;“CCTV” means Closed-circuit Television;Personal Data means data that is capable of identifying an Individual, whether on its own or in conjunction with other data accessible to AGGREGATE CONSULTING SERVICES;“Personnel” means any Individual engaged under a contract of service with AGGREGATE CONSULTING SERVICES, a contract for service with AGGREGATE CONSULTING SERVICES, permanent or temporary employees as well as trainees and interns engaged by AGGREGATE CONSULTING SERVICES from time to time; and“Potential Personnel” means any Individual who has submitted an application to be engaged by AGGREGATE CONSULTING SERVICES as Personnel.

2.	Personal Data collected by AGGREGATE CONSULTING SERVICES AGGREGATE CONSULTING SERVICES will only collect, use or disclose Personal Data about an Individual which it reasonably considers necessary for the relevant purposes underlying such collection, use or disclosure. Depending on the specific nature of an Individual’s interaction with AGGREGATE CONSULTING SERVICES, Personal Data which AGGREGATE CONSULTING SERVICES collects, uses or discloses concerning an Individual may variously include but is not limited to the following:
1.	the Individual’s name, gender and contact particulars, including telephone number(s), residential/mailing address(es) and email address;
2.	details of the Individual’s identification documents (such as, NRIC or passport numbers), and applicable visa or permits (such as employment pass, work permit, permanent residency status);
3.	details of the Individual’s employment history and academic qualifications;
4.	the name and contact particulars of the Individual’s next-of-kin;
5.	the Individual’s network usage data and other information gathered automatically by our computer systems, including the Individual’s computer IP address, links visited and other activities conducted online or using our computer systems;
6.	photographs and video or CCTV recordings of the Individual; and
7.	other information which the Individual may provide to AGGREGATE CONSULTING SERVICES, from time to time, in the course of such Individual’s interaction with AGGREGATE CONSULTING SERVICES.

3.	How AGGREGATE CONSULTING SERVICES collects Personal DataGenerally, AGGREGATE CONSULTING SERVICES may collect Personal Data from an Individual in one or more of the following ways or circumstances:
1.	when the Individual interacts with AGGREGATE CONSULTING SERVICES’s staff via telephone calls, emails, other correspondence and/or face-to-face meetings;
2.	when the Individual visits AGGREGATE CONSULTING SERVICES’s premises;
3.	when the Individual specifically requests that AGGREGATE CONSULTING SERVICES contact him or her or requests to be included in an email or any mailing list maintained by AGGREGATE CONSULTING SERVICES;
4.	when the Individual responds to any request by AGGREGATE CONSULTING SERVICES for the provision of Personal Data;
5.	when AGGREGATE CONSULTING SERVICES receives references or referrals from its business partners or other third parties;
6.	when the Individual attends or participates in any event organised by AGGREGATE CONSULTING SERVICES;
7.	when the Individual submits his or her Personal Data to AGGREGATE CONSULTING SERVICES pursuant to a job application;
8.	when the Individual subscribes to AGGREGATE CONSULTING SERVICES’s publication(s); and/or
9.	when the Individual submits his or her Personal Data to AGGREGATE CONSULTING SERVICES for any other reason related to AGGREGATE CONSULTING SERVICES’s ordinary course of business operations.


4.	Purposes of collection, use and disclosure of Personal Data Generally, AGGREGATE CONSULTING SERVICES collects, uses and/or discloses Personal Data from Individuals for one or more of the following purposes:

1.	Provision of services
1.	administering and managing the Individual’s relationship with AGGREGATE CONSULTING SERVICES;
2.	providing the Individual with information about AGGREGATE CONSULTING SERVICES’s services and/or the services of any external vendor that is providing services or products in partnership or collaboration with AGGREGATE CONSULTING SERVICES;
3.	responding to the Individual’s complaints, queries and/or requests;
4.	facilitating and/or organising events;
5.	informing the Individual of changes and/or updates to AGGREGATE CONSULTING SERVICES’s policies, terms and conditions and/or other administrative information;
6.	
2.	Security measures 
1.	verifying the Individual’s identity or monitoring the Individual’s activities, including without limitation via CCTV observation and/or recording;
2.	preventing, detecting and investigating fraud, misconduct, any unlawful action, omission or dispute, and whether or not there is any suspicion of the aforementioned;

3.	General business operations of AGGREGATE CONSULTING SERVICES 
1.	staff training, quality assurance and performance evaluation;
2.	record-keeping;
3.	compliance purposes (including but not limited to the Individual obtaining corporate governance advice);
4.	meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines which are binding on AGGREGATE CONSULTING SERVICES (including but not limited to responding to regulatory complaints, disclosure to regulatory bodies and conducting audit checks, due diligence and investigations);
4.	Managing Personnel and Potential Personnel
1.	administering, managing and/or terminating AGGREGATE CONSULTING SERVICES’s relationship with Personnel and Potential Personnel;
2.	evaluating the performance of Personnel;

5.	Marketing
1.	where AGGREGATE CONSULTING SERVICES circulates AGGREGATE CONSULTING SERVICES’s publications or marketing information to an Individual or to any person which may be disseminated to and individual relating to services offered by AGGREGATE CONSULTING SERVICES (whether by AGGREGATE CONSULTING SERVICES or AGGREGATE CONSULTING SERVICES’s business partners) which AGGREGATE CONSULTING SERVICES thinks is or may be of benefit or interest to him/her via postal mail, electronic transmission to his or her or any email address(es), and/or voice call or phone call and/or fax to his or her or any telephone number(s);
2.	for promotional and publicity purposes, including recording or taking photographs of participants at events or functions organised, hosted or participated by AGGREGATE CONSULTING SERVICES;

6.	Others
1.	for transfer to third party data intermediaries to facilitate any of the aforesaid purposes;
2.	for any purposes reasonably related to any of the above purposes; and
3.	for any other purposes in relation to which AGGREGATE CONSULTING SERVICES has specifically obtained the Individual’s consent.

7.	ConsentUnless otherwise authorised under the PDPA or any other applicable law, AGGREGATE CONSULTING SERVICES will not collect, use or disclose an Individual’s Personal Data without his or her consent.AGGREGATE CONSULTING SERVICES will take reasonable steps to highlight the purposes relevant to an Individual, by appropriate means, at the point or time of collection of the Personal Data from such Individual, including:
1.	via express provisions in contracts, application forms and/or registration forms to be signed with or submitted to AGGREGATE CONSULTING SERVICES;
2.	via notifications on AGGREGATE CONSULTING SERVICES’s websites;
3.	in the course of verbal communications;

Where feasible, AGGREGATE CONSULTING SERVICES will inform the Individual of purposes that are intrinsic to the relationship between AGGREGATE CONSULTING SERVICES or to the provision of services to such Individual, as well as purposes that are optional.
In so far as any purpose(s) are intrinsic to the relationship or provision of services, AGGREGATE CONSULTING SERVICES reserves the right to decline to engage in the relevant relationship or to provide the relevant services to the Individual if he or she does not consent to AGGREGATE CONSULTING SERVICES’s collection, use or disclosure of his or her Personal Data for such purpose.
Individuals who:
1.	AGGREGATE CONSULTING SERVICES voluntarily provide their Personal Data to AGGREGATE CONSULTING SERVICES for the specified purposes;
2.	use or access AGGREGATE CONSULTING SERVICES’s website(s) or computer network;
3.	enter AGGREGATE CONSULTING SERVICES’s premises or using any of the facilities thereon; and/or
4.	attend or participate in events or programmes organised by AGGREGATE CONSULTING SERVICES.
will be deemed to agree and consent to AGGREGATE CONSULTING SERVICES collecting, using and/or disclosing their Personal Data in the manner and for the purposes set forth in this Privacy Policy.
An Individual who provides AGGREGATE CONSULTING SERVICES with Personal Data relating to a third party (e.g. information of his or her spouse or children) for any particular purpose, represents to AGGREGATE CONSULTING SERVICES that he/she has obtained the consent of the relevant third party to AGGREGATE CONSULTING SERVICES collecting, using or disclosing such Personal Data for the relevant purpose.
In so far as AGGREGATE CONSULTING SERVICES collects Personal Data of an Individual from any third party(ies), AGGREGATE CONSULTING SERVICES will take reasonable steps to inform the relevant third party(ies) of AGGREGATE CONSULTING SERVICES’s purposes for collecting the Personal Data and to verify that consent from the Individual has been obtained by the relevant third party(ies) to such disclosure for the intended purpose.

8.	Disclosure of Personal Data In carrying out one or more of the above Purposes, AGGREGATE CONSULTING SERVICES may need to disclose Individuals’ Personal Data to the following third parties for one or more of the above Purposes:
1.	to AGGREGATE CONSULTING SERVICES’s third party service providers or agents;
2.	any external vendor AGGREGATE CONSULTING SERVICES;
3.	to AGGREGATE CONSULTING SERVICES’s auditors and professional advisors;
4.	any person to whom disclosure is permitted or required by any statutory provision or law;
5.	any permitted assigns; and/or
6.	to any local or foreign regulatory body, government agency, statutory board, ministry, department or other government body and/or its officials.

9.	Disclosure of Personal Data In carrying out one or more of the above Purposes, AGGREGATE CONSULTING SERVICES may need to disclose Individuals’ Personal Data to the following third parties for one or more of the above Purposes:
1.	to AGGREGATE CONSULTING SERVICES’s third party service providers or agents;
2.	any external vendor AGGREGATE CONSULTING SERVICES;
3.	to AGGREGATE CONSULTING SERVICES’s auditors and professional advisors;
4.	any person to whom disclosure is permitted or required by any statutory provision or law;
5.	any permitted assigns; and/or
6.	to any local or foreign regulatory body, government agency, statutory board, ministry, department or other government body and/or its officials.

10.	Verification of Personal Data & Notification of ChangesWhere feasible, AGGREGATE CONSULTING SERVICES will take reasonable steps to verify the accuracy of Personal Data received at the point of collection but Individuals remain primarily responsible and liable to ensure that all Personal Data submitted by them to AGGREGATE CONSULTING SERVICES is complete and accurate. Information voluntarily provided by an Individual to AGGREGATE CONSULTING SERVICES shall prima facie be deemed complete and accurate.AGGREGATE CONSULTING SERVICES will also take reasonable steps to periodically verify Personal Data in its possession, taking into account the exigencies of its operations, but Individuals are nonetheless responsible for notifying AGGREGATE CONSULTING SERVICES, from time to time, of any applicable changes to such Personal Data.AGGREGATE CONSULTING SERVICES shall not be held liable for any inability on its part to provide services to an Individual who fails to ensure that his or her Personal Data submitted to AGGREGATE CONSULTING SERVICES is complete and accurate or who fails to notify AGGREGATE CONSULTING SERVICES of any relevant changes to such Personal Data.

11.	Protection of Personal Data AGGREGATE CONSULTING SERVICES shall make reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks to Personal Data in its possession.

If AGGREGATE CONSULTING SERVICES transfers Personal Data outside Singapore, AGGREGATE CONSULTING SERVICES will take reasonable steps to ensure that such Personal Data transferred receives a standard of protection comparable to the protection received under the PDPA and such transfer shall be subject to this Policy.AGGREGATE CONSULTING SERVICES will ensure that third parties who receive Personal Data from AGGREGATE CONSULTING SERVICES protect such Personal Data in a manner consistent with this Policy and not use such Personal Data for any purposes other than those specified by AGGREGATE CONSULTING SERVICES, by incorporating appropriate contractual terms in its written agreements with these third parties.AGGREGATE CONSULTING SERVICES is not responsible in any way for the security and/or management of Personal Data shared by Individuals with third party websites accessible via links on AGGREGATE CONSULTING SERVICES’s website.

12.	Contacting AGGREGATE CONSULTING SERVICES-Access and Correction of Personal Data Any Individual who:
1.	has questions or feedback relating to this Policy;
2.	would like to obtain access to his or her Personal Data held by AGGREGATE CONSULTING SERVICES;
3.	would like to obtain information about the ways in which his or her Personal Data held by AGGREGATE CONSULTING SERVICES has been or may have been used or disclosed by AGGREGATE CONSULTING SERVICES in the year preceding the request; and/or
4.	would like to update or make corrections to his or her Personal Data held by AGGREGATE CONSULTING SERVICES,
should contact AGGREGATE CONSULTING SERVICES’s Data Protection Officer at dpo@incoporateyour.com.
Individuals should note that AGGREGATE CONSULTING SERVICES is not required, under the PDPA, to provide access and correction to Personal Data in certain exempted situations as set out in the PDPA.
The PDPA allows and AGGREGATE CONSULTING SERVICES reserves the right to charge a reasonable fee for the handling and/or processing of access requests by an Individual pursuant to paragraphs (b) or (c) above.

13.	Governing Law This Policy shall be governed by and construed in accordance with the laws of Singapore. Any dispute arising out of or in connection with this Policy including any question regarding its existence, validity or termination, shall be referred to and finally resolved by the Courts of Singapore.