Foremost Consultants Pte Ltd.

Website Privacy Notice

PRIVACY POLICY

1. Important information and who we are

Purpose of this privacy notice

This privacy notice aims to give you information on how Foremost Consultants Pte Ltd collects and processes your personal data through your use of this website, when you receive our services and other interactions with the Foremost Consultants.

It is important that you read this privacy notice together with any other privacy notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

This website is not intended for children and we do not knowingly collect data relating to children.

Controller

This privacy notice is issued on behalf of Foremost Consultants Pte Ltd where Foremost Consultants Pte Ltd is the company responsible for processing your data. Foremost Consultants Pte Ltd (BRN No: 200503037Z) is responsible for this website.

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.

Contact details

Our full details are:

• Full name of legal entity: Foremost Consultants Pte Ltd
• Name or title of DPO: Susan Shuttleworth
• Email address: sue@foremostconsultants.com
• Postal address: 10 Anson Road, #12-01 International Plaza, Singapore 079903
• Telephone number: +65 61001993

Changes to the privacy notice and your duty to inform us of changes

This version was updated in December 2021 and any historic versions can be obtained by contacting us.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We collect personal data from clients, business contacts, partners, personnel, Sub-contractors and other individuals when it is necessary for business purposes.  Such personal data may be provided to us in forms filled out by individuals, face to face meetings, email messages, telephone conversations, through our websites or provided by third parties. If any individuals contact us, we may keep a record of that contact.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Name
• Job title
• Contact information including email address and telephone number
• Geographic information such address and region
• Other information relevant to our services, products, or events that may be of interest
• Marketing and Communications Data, which includes your preferences in receiving marketing from us and your communication preferences.

 

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if Aggregated Data is linked with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

We will only collect, hold, process, use, communicate and/or disclose such personal data, in accordance with this policy.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the service contract we have or are trying to set up with you. In this case, we may have to cancel any contract you have with us but we will notify you if this is the case at the time.

 

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

• Direct interactions. You may give us your Identity and Contact Data by filling in forms, passing us your business card or by corresponding with us by post, phone, email, web forms on our Website or otherwise. This includes personal data you provide when you:
• apply for our services;
• subscribe to our services or request information or publications;
• request marketing information to be sent to you or pass us feedback
• Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookie and other similar technologies. Please see the Cookies section below for further information.
• Third parties or publicly available sources. We may receive personal data about you from various third parties and public sources as set out below:

1. Technical Data from analytics providers such as Google
2. Identity and Contact Data from publicly available sources such as ACRA Bizfile, LinkedIn, Facebook and and other Business Directories.
3. How we use your personal data

Foremost Consultants can hold personal data for its clients, and other contacts within our secured IT systems.

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Internal record keeping.
• We may use the information to improve our services and products.
• We may use the information to customise the website according to your interests.

• From time to time, we may also use your information to contact you by email, telephone or post.

Purposes for which we will use your personal data

We have set out below, a description of all the ways we may make use your personal data,

We may require or store identity and contact data, financial transaction data, technical and website usage data necessary to comply with legal obligations or necessary for our legitimate needs in running our Business for the following reasons;

• To register new Clients for setting up a contract with them
• To process and deliver our services
• Manage fees and payments and to collect money owed to us
• for general management and reporting purposes, such as invoicing and account management
• to maintain contact with clients and other contacts
• to keep clients and other contacts informed of the services we offer, industry developments, service offerings, seminars and other events we may hold, that may be of interest to them
• for recruitment purposes
• for purposes related to the employment of our personnel and providing internal services to our personnel
• to respond to the individual’s request or for the purposes for which it was provided to us as stated at the time of the collection (or as is obvious from the context of collection)
• To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
• To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

 

Marketing

Please note that we may send you other communications in relation to your purchase of services from us or in order to respond to queries you have raised, such communications are service communications and are not a form of marketing.

We do not rely on consent as a legal basis for processing your personal data except in relation to direct marketing communications which we may send to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

Opting out

Individuals may opt-out from receiving marketing communications by contacting us.

Cookies

A cookie is a small file which asks permission to be placed on your computer’s hard drive.

If you provide your consent to the use of analytics cookies, this website uses Google Analytics, a web analytics service provided by Google, Inc. (‘Google’). Google Analytics uses cookies (text files placed on your computer) to help the website operators analyse how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties.where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We do not disclose personal data to third parties except when required by law, when we have the individual’s consent or deemed consent or in cases where we have engaged third parties such as data intermediaries or subcontractors specifically to assist with our firm’s activities.  Any such third parties whom we engage will be bound contractually to keep all information confidential.

We may have to share your personal data with Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy notice.

• External Third Parties as set out in the Glossary. We require all External third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

We share your personal data within the Foremost Consultants Pte Ltd and maybe with service providers or professional advisers located in the countries where Foremost Consultants operates. This occasionally may involve transferring your data outside of Singapore.

We will ensure that any transfers of personal data to a territory outside of Singapore will be in accordance with the PDPA so as to ensure a standard of protection to personal data so transferred that is comparable to the protection under the PDPA.

7. Data security

We have implemented generally accepted standards of technology and operational security to protect the personal data in our possession or under our control and to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks.

In addition, we limit access to your personal data to those employees, agents, Subcontractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8. Data retention

How long will you use my personal data for?

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for five years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see glossary definition of Request erasure below for further information.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9. Your legal rights

Upon request, we will provide the individual with access to their personal data or other appropriate information on their personal data in accordance with the requirements of the PDPA.

Upon request, we will correct an error or omission in the individual’s personal data that is in our possession or control in accordance with the requirements of the PDPA.

We may charge for a request for access in accordance with the requirements of the PDPA.

If you wish to exercise any of the rights set out above, please contact us.

What we may need from you

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. Glossary

LAWFUL BASIS

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and the best and most secure experience. We consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

 

THIRD PARTIES

External Third Parties

• Service providers acting as processors based in Singapore and the United States who provide IT and system administration services.
• Professional advisers, acting as processors or controllers, including lawyers, bankers, auditors and insurers based in Singapore and the countries where Foremost Consultants operates, who provide consultancy, banking, legal, insurance and accounting services.
• Tax and other Government regulators and other authorities acting as processors or joint controllers based in the Singapore and the other countries where Foremost Consultants operate who require reporting of processing activities in certain circumstances.

 

YOUR LEGAL RIGHTS

You have the right to:

Request access to your personal data.  This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.