Privacy Policy

Last updated: 16 December 2020

Data Protection and Privacy Policy

1. Protecting your Personal Data and Privacy

Trinax understands the importance of your personal data and privacy and therefore takes the protection of them very seriously. As such, we process all of your personal information in compliance with the Personal Data Protection Act 2012 (‘PDPA’).

We have further put in place additional measures in the form of our internal data protection policies and other security safeguards whenever we handle personal information on your behalf or on that of our clients at all times.

While we understand that your privacy is of your paramount importance, it may be inevitable in the course of business that some of your personal data is shared and collected in communications between us, whether these communications are for the purposes of understanding your needs or in the course of providing any of our service offerings to you.
This Data Protection and Privacy Policy (“Privacy Policy”) provides clarification on how Trinax in general collects, uses and shares your personal information.

2. Our Privacy Policy

2.1 Your Personal Information

Generally, the term ‘personal information’ refers to any information that identifies or can be used to personally identify an individual. This includes information such as your name, address, telephone number, identification or passport number as well as email address.

2.2 Collection of Personal Information

Your personal information may be collected by Trinax whenever you/we:

Contact us with an enquiry or request for assistance
Communicate with our representatives
Respond to your enquiries and requests
Engage us to provide services/solutions
Use our services/solutions
Obtain your feedback about our services/solutions
Conduct our administrative and business functions
Through your access and use of our website
Register for our events, workshops, seminars or subscribe to our mailing lists/newsletters
Market our services/solutions to you
Contact us for a career job opportunity with us for prospective job applicants

In addition to the above, we may also obtain your personal information through third parties from time to time. Where we do so, we will seek confirmation from such third parties that they have obtained your personal information legally and that we have the right to acquire it from them and to use it.

2.3 Consent to use and Careers with Trinax

In all cases that you have voluntarily provided your personal information to us, you will have been deemed to have consented to the collection and use of such personal information by Trinax unless you inform us otherwise.

For those seeking a career with us, we may also collect your personal information as part of your application. Where you have voluntarily provided personal information of a third party in the course of submitting your application, kindly ensure that you have obtained the consent of such third party prior to providing such personal information to us.

Providing us with your Personal Data is voluntary. However, if you choose not to provide us with the Personal Data described in this Policy, we may not be able to fulfil our contractual duties towards you or facilitate your request or provide the service to you, or the company you may be representing

2.4 Types of Personal Information collected

The type and extent of personal information we generally collect depends on the method and purpose of communication between us.

Typically, we collect the following types of personal information:-

Information as to your identity, e.g.:
– Name
– Gender
– Date of birth
– NRIC/FIN/Passport number
– Title or Position
– Business address
– Phone / Fax number
– Email address
– Photo or video footages when using our interactive machines
Other ancillary information, e.g.:
– Records of your interaction with us (e.g. note or recording of calls or email/letter)
– Information on devices and their use over our services/solutions
– Information on use of our services/solutions
– Preferential information (e.g. preferred contact methods and services/solutions)
– Information from authorized third party organisations (e.g. business directories, credit reference agencies)
Trinax may collect personal data pursuant to an exception under the Personal Data Protection Act or other written law
Providing us with your personal data is voluntary. However, if you choose not to provide us with the Personal Data described in this Policy, we may not be able to fulfil our contractual duties towards you or facilitate your request or provide the service to you, or the company you may be representing.
You may withdraw consent (including marketing consents) and request us to stop using and/or disclosing your personal data for any or all of the purposes listed in section 2.2 by submitting your request to our Data Protection Officer at the contact details provided in section 8.
Upon receipt of your request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within 30 business days of receiving it.
Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our services to you and we shall, in such circumstances, notify you before completing the processing of your request.
Please note that withdrawing your consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclosure without consent is permitted or required under applicable laws.

Trinax does not collect sensitive personal information relating to your health, religion, race or political beliefs.

As for our clients, we may also collect additional personal information about you as part of our business requirements (e.g. for point of contact for billing, invoicing and payment purposes). This is necessary in our continuing pursuit of providing you, our valued client, with the best-in-class services and solutions that you have come to expect from the Trinax name.

2.5 Using Personal Information

Trinax will only keep your personal information for such period as there is a business or legal need.

In general, we may collect, hold and use your personal information for one or more of the following purposes:

Sending communications
Establishing, managing and maintaining business relationships
Responding to enquiries and requests
Develop, provide and improve our services/solutions
Informing you about our services/solutions
Obtaining feedback about our offerings
Better personalization of services/solutions
Conduct of administrative and business functions
Updating records to keep details current
Process requests for subscriptions to website updates, newsletters and mailing lists
Process requests for registration to events, seminars and workshops affiliated with us
Process applications for a career at Trinax
Monitor performance of website services and improve accessibility
Respond to privacy complaints
Ensure security and risk management objectives are maintained
Complying with audit requirements
Assessing and evaluating your suitability for employment in any current or prospective position within our organisation for prospective job applicants

We do not use any of your personal information other than as described in this Privacy Policy, or other than as permitted under local laws and regulations.

2.6 Disclosure and sharing of Personal Information

From time to time, we may be required to disclose and/or share personal information with other parties for the purposes set out in paragraph 2.5 above.

Whenever we share personal information to other parties, we will take steps to ensure that these recipients have in place adequate measures and safeguards relating to confidentiality and data protection.

In certain cases, we will also encrypt, aggregate and anonymise personal information before sharing it. This means that the information will only be presented over a range (e.g. by age) and cannot be used to personally identify you.

In this section, we provide some of the instances in which we disclose or share personal information with third parties and our purposes for doing so (where applicable).

2.6.1 Internal sharing

Primarily, Trinax may disclose personal information to our employees and representatives for business and administrative reasons mentioned in paragraph 2.5 from time to time. For these purposes, it may be that some of our employees and representatives are based overseas. As such, it may be that your personal information is transferred outside of Singapore although we will try to limit the instances in which such transfer occurs.

2.6.2 Sharing with third-parties

Where necessary and to the extent required, Trinax may from time to time disclose your personal information to:

Contractors, suppliers and other third parties providing business, marketing and other services to you/us
A relevant third party involved in any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our
business, assets or stock
With your express consent, another organisation for any authorised purpose
Any governmental authority, regulatory body, court or other tribunal

From time to time, our website may display links that allow you to post your enquiries or comments accessible by the general public over the internet. When doing so, kindly be reminded that caution should be exercised whenever you are posting personal information online.
Apart from the foregoing, Trinax does not provide any personal information to unaffiliated third parties for direct marketing purposes unless you have given your consent to do so. We will only disclose personal information without first seeking your consent where required by law, an order of court/tribunal or otherwise permitted under the PDPA.

2.7 Security and storage of Personal Information

Personal information collected and held by us comes in a variety of mediums e.g. verbal, electronic or written. However, we generally do not keep any personal information that is sensitive in nature.

During the time we hold your personal information, we will take reasonable precautions to protect them from misuse, loss, unauthorised access, modification or disclosure by using a combination of physical, administrative and technical safeguards. Some of the measures we’ve put in place to secure and protect personal information include:

Safeguards to prevent security breaches of our network and database systems
Restricted access to information contained in our systems and those of our business partners and vendors
Information security policies and procedures to prevent unauthorised access to personal information

While we take great care in ensuring the security of personal information held by us, we nonetheless wish to highlight that information which is transmitted online remains susceptible to access by unauthorised third parties. This is due to the inherently insecure nature of the internet as a medium of data transmission. As such, we are unable to guarantee with any certainty, the security of communications containing personal information transmitted over the internet.

As any communications submitted over the internet are done so at your own risk, we would like to remind you to exercise caution when using the internet as a medium for data transmission for personal information.

3. Accessing and Correcting Personal Information

While we endeavour to ensure that personal information about you held by us remains accurate, up to date and complete, we may not be able to immediately react to changes to your personal information that may occur from time to time.

To that extent, you may wish to request access to personal information about you that is held by us at any time, including to correct such personal information that is inaccurate, incomplete or out of date. Kindly note that access to your personal information in the manner requested is given subject to exceptions allowed by law or the PDPA and where it is reasonable and practical to do so.

Should you wish to access or correct your personal information, please send a written request to our Data Protection Officer using the contact details set out at the end of this policy. Our Data Protection Officer will respond to your request within thirty (30) days after you have made the request. Note that in some instances, a nominal fee may be charged to you to cover the cost of retrieving the requested personal information.

In certain circumstances, we may nonetheless deny your request for access to or correction of your personal information. For example, where granting such access will interfere with the privacy of others, is unlawful or would result in a breach of confidentiality. In such cases, we will provide you with written reasons for refusing your request and the mechanisms available to you to appeal against our refusal.

4. Breach of Privacy concerns

If you have any concerns regarding how your personal data is being handled by Trinax or wish to make a complaint about a breach of the PDPA by us, you may send your complaint in writing to our Data Protection Officer using the contact details set out at the end of this policy.

Our Data Protection Officer will respond to you in writing within thirty (30) days, setting out what action Trinax will take in response to your complaint, or alternatively, where there has been no breach, an appropriate explanation.

Alternatively, you may also wish to submit your complaint directly to the Personal Data Protection Commission of Singapore (PDPC) which is the regulator tasked to administer and enforce the PDPA at https://www.pdpc.gov.sg/Individuals/Complaints-and-Reviews.

5. Cookies, Addons and Third-party websites

5.1 Cookies and Addons

Trinax’s website features cookies and functions requiring third-party addons to display correctly.

Please visit our cookies policy for more information on how we use cookies and how you can adjust your preferences.

5.2 Third-party websites

While browsing our website, you may come across links to other websites hosted or belonging to other third parties. Please note that the contents of this Privacy Policy do not extend to such third party websites. Should you visit any external websites via links on our website, kindly be reminded that Trinax make no representations or warranties in relation to the privacy practices of such third party website and are not responsible for the privacy policies or content of any third party website.

6. RETENTION OF PERSONAL DATA

We will not retain any of your Personal Data when it is no longer needed for any business or legal purposes. We will dispose of or destroy such documents containing your Personal Data in a secure manner as soon as it is reasonable to assume that the permitted purpose is no longer being served by their retention. Any unsolicited personal data received by us will be returned to the sender immediately. If received by email or through our website, these unsolicited personal data will be deleted right away. If received by telephone, these will not be recorded

7. Direct Marketing

From time to time, we may send you communications and information about our services and solutions that we consider may be of interest to you. These communications may come in various forms e.g. mail, SMS, fax or email.

If you do not wish to receive such direct marketing communications from us, you can opt-out of receiving them by informing us using the contact details set out at the end of this policy or using the opt-out mechanisms provided in the marketing communication itself.

Do note that even if you opt-out of receiving marketing related communications from us, we may still send you important administrative messages, and you cannot opt-out from receiving administrative messages.

8. Contacting Us

If you require any clarification regarding this Privacy Policy or would like to contact us to find out more about how your personal information is being handled by us, please contact us via our contact details as provided below:

Mailing Address
68 Kallang Pudding Road
#01-01 SYH Logistics Building
Singapore 349327

Attention to: Data Protection Officer

Alternative Methods (Email)
dpo@trinax.sg

Attention to: Data Protection Officer

9. Changes to our Privacy Policy

Trinax may revise its Privacy Policy from time to time. Any such revisions will be announced on this website. Kindly take note to review this Privacy Policy as well as any updates on a regular basis.

10. Other General Information

10.1 Access and Use

All contents contained in or accessed through Trinax’s website are provided on an “as is” and “as available” basis and user agrees to use them at their sole risk. Trinax expressly disclaim all warranties of any kind, whether express or implied, including implied warranties of merchantability, satisfactory quality, fitness for a particular purpose and non-infringement, to the fullest extent allowed by law.

Without prejudice to the foregoing, Trinax make no warranty as to the accuracy, reliability or quality of any content or service obtained through this website or any defects therein will be corrected and that such content and access to them are error free and uninterrupted or available at all times.

10.2 Limitation of Liability

Trinax assumes no responsibility whatsoever for any and all claims, damages, losses, expenses, costs or liabilities (including without limitation, any direct, indirect, punitive, special, incidental or consequential damages or loss of profits) arising from the use of information taken from this website or from that of other companies that have placed links to their site on this website.

10.3 Applicable Law

By accessing Trinax’s website and online services, user agrees that such access and/or use, as well as this policy are construed in accordance with, and governed by the laws of the Republic of Singapore and hereby submits to the exclusive jurisdiction of the Singapore courts.