Privacy


Your personal data is important to AnaVantage.

Your personal data is important to AnaVantage (collectively, “we”, “us” or “our”) and it is our policy to respect the confidentiality of information and the privacy of individuals. This Policy outlines how we manage the personal data we hold in compliance with the Personal Data Protection Act in Singapore (the “Act”) and applies to all divisions in AnaVantage.


What types of personal data do we collect?

We may collect and hold personal data of persons/entities including but not limited to:
  • customers;
  • job applicants and employees;
  • shareholders;
  • service providers; and
  • other people who we may come into contact.

Examples of such personal data include biodata, contact details, account information and your preferences, queries, requests and feedback.


How do we collect your personal data?

The ways in which we may collect your personal data include (but are not limited to) collecting directly or indirectly from you or your authorised representatives in the course of:
  • you signing up for alerts or newsletters;
  • you visiting our websites;
  • you attending our courses, training workshops, seminars, etc;
  • you applying for a job with us;
  • you participating in our marketing or promotional events;
  • you using our products or services;
  • you contacting us with your queries, requests or feedback;
  • our conducting or completing of transactions;
  • our conducting of market research or surveys;
  • our conducting of interviews.

 
What kind of purposes do we collect your personal data for?

In general, we may use your personal data for the following purposes:
  • conducting and completing transactions (e.g. processing orders and payments; providing products or services that have been requested);
  • providing customer service (e.g. responding to queries and requests; informing you about service status and product updates; sending you alerts and newsletters);
  • conducting market research and improving customer service (e.g. conducting market research or surveys; performing market analysis; managing and enhancing our products and services; developing new products);
  • conducting marketing promotions (e.g. sending of alerts, newsletters, marketing materials and invitations from us wholly or through affiliation with third parties; offering promotions and loyalty programs);
  • complying with applicable laws, regulations and other requirements (e.g. providing assistance to law enforcement agencies, regulatory authorities and other governmental agencies; performing internal audits);
  • performing evaluations (e.g. assessing suitability of employees).

AnaVantage may decide to buy or sell assets which form part of or relate to its business within AnaVantage. In any such transaction, personal data will usually be one of the transferred assets and will be disclosed to the purchaser. In most cases, if you do not provide information about yourself which AnaVantage has requested, AnaVantage may not be able to provide you with the relevant product or service.


How do we use and/or disclose your personal data?

We will only use, disclose and/or transfer your personal data for the purposes you have been notified of and consented to or which are permitted under applicable laws and regulations.

We will not sell, rent or give away personal data to third parties for commercial purposes without your consent.


Who do we share your personal data with?

Depending on the product or service concerned, personal data may be disclosed or transferred to:
  • other divisions within AnaVantage;
  • our joint venture/ alliance partners;
  • our service providers and specialist advisers/institutions who have been contracted to provide administrative, financial, legal, accounting, information technology, research or other services;
  • other insurers, credit providers, courts, tribunals, law enforcement agencies, regulatory authorities and other governmental agencies as agreed or authorized by law;
  • credit reporting or reference agencies or insurance investigators;
  • anyone authorized by an individual, as specified by that individual or the contract.

Where personal data is disclosed or transferred to organizations outside of AnaVantage who handle or obtain personal data as service providers to AnaVantage, we require such organizations to acknowledge the confidentiality of such personal data, undertake to respect any individual's right to privacy and comply with the Act and this Policy and use such personal data only for our purposes and otherwise follow our reasonable directions with respect to this data.

In addition, where personal data is transferred overseas and we may need to process or deal with your personal data outside Singapore, we will ensure that such transfer is in compliance with the Act and this Policy or is permitted under applicable data protection and privacy laws and regulations.


How do we manage, protect and store your personal data?

AnaVantage has appointed a Data Protection Officer (“DPO”) to oversee our management of personal data in accordance with the Act.

We regard breaches of your privacy very seriously and we have implemented measures to secure and protect your information, such as training our employees who handle your personal data to respect the confidentiality of such personal data and your privacy, storing personal data in a combination of secure computer storage facilities and paper based files and other records, taking steps to protect the personal data we hold from misuse, loss, unauthorised access, modification or disclosure.

However, you will appreciate that it is not for us to perfectly secure your personal data from cyber attacks, such as hacking, spyware and viruses. Accordingly, you will not hold us liable for any unauthorized disclosure, loss or destruction of your personal data arising from such risks.

The Act also requires us not to store personal data longer than necessary. We will cease to retain your personal data when we no longer require such personal data for the purposes we originally notified you of or for any business or legal needs.


How do we keep personal data accurate and up-to-date and how to exercise your right to correct the personal data we hold of you?

We endeavour to ensure that the personal data we hold about you is accurate and up-to-date. We realise that such personal data changes frequently with changes of address and other personal circumstances. We encourage you to contact us as soon as possible in order to update any personal data it holds about you. Our contact details are set out below. We may require you to verify your identity.


How to exercise your right to access the personal data we hold of you?

To make a request to access the personal data we hold about you, please contact us and we will require you to verify your identity and to specify what data you require. We may charge a fee to cover the cost of verifying the application and locating, retrieving, reviewing and copying any material requested. If the data sought is extensive, we will advise the likely cost in advance and can help to refine your request if required.

 
How to exercise your right to withdraw your consent?

To make a request to withdraw your consent previously given, please contact the DPO of AnaVantage in writing. We do not accept any other form of communication. To ensure your request(s) has/have been attended to, you should receive a reply from us within 2 - 3 business working days upon receiving your request, failure of which, please contact us again to rectify the issue.


What if you have a complaint?

If you consider that any action of AnaVantage breaches the Act or this Policy, you can make a complaint to the DPO by contacting us directly at [email protected]. AnaVantage will endeavour to act promptly in response to a complaint.

 
How to contact us?

You can contact the Data Protection Officer (DPO) of AnaVantage Management Consultancy LLP at [email protected]. You may also write in to us at our Corporate Office at 1 Scotts Road, Shaw Centre, #24-10, Singapore 228208. You may attention the letter to: "AnaVantage Management Consultancy LLP, Data Protection Officer (DPO)".


Updates to this Policy

This Policy will be reviewed from time to time to take account of new laws and technology, changes to our operations and practices and the changing business environment. This Policy was last updated on 4 November 2014. If you are unsure whether you are reading the most current version, please contact us at [email protected].