Privacy and Data Protection Policy
ACT Management Services Pte. Ltd. (“ACT”) 1 is dedicated to protecting the confidentiality and privacy of information entrusted to it. As part of this fundamental obligation, ACT is committed to the appropriate protection and use of personal information (sometimes referred to as “personally identifiable information” or “PII”) that has been collected through its web sites.
Generally, our intent is to collect only the personal information that is provided voluntarily by visitors to our web sites so that we can offer information and/or services to those individuals or offer information about employment opportunities. Please review this Online Privacy Statement (“Online Privacy Statement” or “Privacy Statement”) to learn more about how we collect, use, share and protect the PII that we have obtained.
Collection and use of PII
We obtain personal information about you if you choose to provide it — for example, to contact mailboxes or to register for certain services. In some cases, you may have previously provided your PII to ACT (if, for example, you are a former employee). By registering and/or submitting personal information on our web sites, you are also agreeing to the use of this information in accordance with this Privacy Statement. Your personal information is not used for other purposes, unless we obtain your permission, or unless otherwise required or permitted by law or professional standards. For example, if you send us an email message requesting information about ACT, we will use your email address and other information you supply to respond to your request. If you send us a resume or curriculum vitae (CV) to apply online for a position with ACT, we will use the information that you provide to match you with available ACT job opportunities.
ACT generally collects only the personal information necessary to fulfill the visitor’s request. Where additional, optional information is sought, you will be notified of this at the point of collection.
ACT only collects “sensitive” personal information when the relevant individuals voluntarily provide us with this information or where such information is required or permitted to be collected by law or professional standards. Sensitive information includes personal information regarding a person’s race, ethnicity, political beliefs, trade union membership, religious or similar beliefs, physical or mental health, sexual life or criminal record. Please use your discretion when providing sensitive information to ACT, and under any circumstances, do not provide sensitive information to ACT, unless you thereby consent to ACT’s use of that information for its legitimate business purposes and consent to the transfer and storage of such information to and in ACT databases. If you have any questions about whether the provision of sensitive information to ACT is, or may be, necessary or appropriate for particular purposes, please contact ACT at the address indicated below.
Automatic collection of PII
In some instances, ACT automatically collects certain types of information when you visit our web sites and through emails that we may exchange. Automated technologies may include the use of web server logs to collect IP addresses, “cookies”, and web beacons. The collection of this information will allow us to better understand and improve the performance, usability and effectiveness of ACT web sites and to measure effectiveness of our marketing activities.
An IP address is a number assigned to your computer whenever you access the internet. It allows computers and servers to recognise and communicate with one another. IP addresses from which visitors appear to originate may be recorded for IT security and system diagnostic purposes. This information may also be used in aggregate form to conduct web site trend and performance analysis.
If you subsequently register with a ACT web site, this information may be linked to a cookie in order to enhance and personalize your online experience (e.g., by welcoming you back when you return or providing you access to your registration information).
You have the choice of deciding whether to accept cookies or not. You can set your browser to notify you when you receive a cookie or to reject cookies. However, please be aware that if you do not accept cookies, you may not be able to fully experience some of our Web site features.
A web beacon is a small image file on a web page that can be used to collect certain information from your computer, such as an IP address, the time the content was viewed, a browser type, and the existence of cookies previously set by the same server. ACT only uses web beacons in accordance with applicable laws.
ACT or its service providers may use web beacons to track the effectiveness of third party web sites that provide us with recruiting or marketing services or to gather aggregate visitor statistics and manage cookies.
You have the option to render some web beacons unusable by rejecting their associated cookies. The web beacon may still record an anonymous visit from your IP address but cookie information will not be recorded.
In some of our other communications, we may confirm a recipient’s email address through embedded links within the messages. We collect this information to gauge user interest and to enhance future user experiences.
Sharing and transfer of PII
We do not share personal information with unaffiliated third parties, except as necessary for our legitimate professional and business needs, to carry out your requests, and/or as required or permitted by law or professional standards.
In some instances, ACT may also share PII about you with various outside companies or service providers or vendors working on our behalf to help fulfill your requests.
In addition, ACT may transfer certain PII across geographical borders to other ACT member firms or outside companies working with us or on our behalf. ACT may also store PII in a jurisdiction other than where you are based. By providing PII on ACT’s web sites, visitors are consenting to this transfer and/or storage of their data across borders.
ACT may also disclose PII in connection with the sale, assignment, or other transfer of the business of the site to which the data relates, in order to respond to requests of government or law enforcement agencies or where this is required by applicable laws, court orders, or government regulations. These disclosures may also be needed for data privacy or security audits and/or to investigate or respond to a complaint or security threat. ACT does not sell PII to any third parties. Also, ACT will not transfer the PII you provide to any third parties for their own direct marketing use.
ACT understands the importance of protecting children’s privacy, especially in an online environment. In particular, our sites are not intentionally designed for or directed at children under the age of 13. It is our policy never to knowingly collect or maintain information about anyone under the age of 13, except as part of an engagement to provide professional services.
You have several choices regarding your use of our sites. In general, you are not required to submit any PII when you visit our web sites, but ACT may require you to provide certain PII in order for you to receive additional information about our services and events. Certain web sites may also ask for your permission for certain uses of your PII, and you can agree to or decline those uses. If you opt-in for particular services or communications, such as an e-newsletter, you will be able to unsubscribe at any time by following the instructions included in each communication. If you decide to unsubscribe from a service or communication, we will try to remove your information promptly, although we may require additional information before we can process your request.
If you have submitted personal information to ACT, under most circumstances you have the right to reasonable access to that data to correct any inaccuracies. You can also make a request to update or remove information about you by contacting the Data Protection Officer at firstname.lastname@example.org, and we will make all reasonable and practical efforts to comply with your request, so long as it is consistent with applicable law and professional standards.
Data security and integrity
ACT has reasonable security policies and procedures in place to protect personal information from unauthorized loss, misuse, alteration, or destruction. Despite ACT’s best efforts, however, security cannot be absolutely guaranteed against all threats. To the best of our ability, access to your personal information is limited to those who have a need to know. Those individuals who have access to the data are required to maintain the confidentiality of such information. We also make reasonable efforts to retain personal information only for so long as the information is necessary to comply with an individual’s request or until that person asks that the information be deleted.
Links to other sites
Changes to this policy
ACT may modify this Privacy Statement from time to time to reflect our current privacy practices. When we make changes to this statement, we will revise the “updated” date at the top of this page. We encourage you to periodically review this Privacy Statement to be informed about how ACT is protecting your information.
Policy questions and enforcement
ACT is committed to protecting the online privacy of your personal information. If you have questions or comments about our administration of your personally identifiable information, please contact us at email@example.com. You may also use this address to communicate any concerns you may have regarding compliance with our Online Privacy Statement.
1Throughout this web site, “ACT,” “we,” “our,” and “us” refers to ACT Management Services Pte. Ltd. (“ACT”).