This statement outlines SPRUCE on compliance with the Singapore’s Personal Data Protection Act 2012 (“PDPA“). This policy applies and issues to all divisions, subsidiaries, associated, related and affiliated companies of SPRUCE, where applicable (collectively, “SPRUCE“, “we” or “us“) and SPRUCE immediate and/or prospective customers, suppliers or agents or service provider unless we have notified you otherwise in writing.
Collection and Purpose of Personal Data
In the course of your dealings with SPRUCE, we may request that you provide data and information about yourself (“Personal Data“) which may include, but not limited, to your name, company industry, postal address, e-mail address, photograph or video image of an individual, mobile telephone number and any other corporate/personal information related to you for the purpose to:-
- provide notices, services or products or corporate information, newsletters and the promotion and marketing material of our products and services whether present or future, to you;
- communicate with you;
- process your request and/or application;
- perform research, assessment/statistical and analysis exercise;
- customer relationship management procedures, for example to deal with customer’s feedback; or
- comply with legal obligations.
and you agree and consent to SPRUCE using and processing your Personal Data in the manner as identified in this statement.
Depending on the product or service concerned, your Personal Data may also be disclosed to:-
- SPRUCE, including those established in the futures;
- SPRUCE holding company and its related companies;
- SPRUCE external advisors, service providers, agents, consultants and insurers;
- SPRUCE business associates that provide related services and products in connection with SPRUCE business; and
- courts, arbitrations, tribunals and regulatory authorities in accordance to law.
Safety of Personal Data
Reasonable efforts will be made to ensure that any Personal Data held by SPRUCE is stored securely.
We require that organisations outside SPRUCE which handle or obtain Personal Data as service providers and/or business associates of SPRUCE under strict confidentiality undertakings or agreements to protect the confidentiality and Personal Data.
Your Rights of Access and Correction
Subject to any exceptions under applicable laws, you have the right to request access to or correction or rectification of your Personal Data or limit the processing of your Personal Data, or seek further information from us, and in this respect, you may:-
- check whether we hold or use your Personal Data and request access to such data;
- request that we correct any of your Personal Data that is inaccurate, incomplete or out-of-date;
- register your telephone number with Do Not Call (“DNC”) Registry, we will not send you promotional and marketing messages; and
- withdraw your Personal Data, in full or in part, your consent given previously from us.
In respect of your right to access and/or correct your Personal Data, we have the right to refuse your requests to access and/or make any correction to your Personal Data for the reasons permitted under law.
SPRUCE reserves its sole discretion to change, modify, add, amend, vary and/or remove any terms, in full or in part of this statement at any time and you should check this page periodically for changes. You acknowledge and agree that by using this website and provide your Personal Data to us, you shall be deemed to be bound by terms and conditions set forth herein.