Commited to You

At Easy Touch Pte. Ltd. (“PouchNATION”) we respect the privacy and confidentiality of the personal data of our Clients, Associates and others with whom we interact in the course of providing our services. We are committed to implementing policies, practices and processes to safeguard the collection, use and disclosure of the personal data you provide us, in compliance with the Singapore Personal Data Protection Act (PDPA) 2012.

We have developed this Data Privacy Notice to assist you in understanding how we collect, use, disclose, process, protect and retain your personal data that is in our possession.

Personal data refers to any information that can uniquely identify an individual person (a) on its own, or (b) when combined with other information. Under the PDPA, business contact information (e.g. full name, business address, business telephone number) is not considered personal data so long as it is used strictly for business-to-business (B2B) transactions.

We collect your personal data when you:

• Enter into an agreement or contract with us to provide you with our consultancy and advisory services.

• Register for and enrol in any of the training courses and certification programmes that we conduct (including processing of your applications under any government funding programmes that we are under).

• Respond to our electronic direct mails (EDMs) sent by us as part of our marketing or promotion campaigns through an authorised third-party EDM service provider.

• Are referred to us for our services by one of our clients.

• Visit our website and leave behind your contact information through our contact form.

• Communicate with us via emails or written correspondence.

The types of personal data we collect about you include:

• Your contact information (Name, Email Address, Postal Address).

• Your personal details (Name, Gender, Date of Birth, Nationality; Next-of-Kin name, relationship, contact number).

We use the personal data you provide us for one or more of the following purposes:

• Analyse your visits to our website.

• Provide our consultancy and advisory services.

• Process account payables/receivables.

• Process billing, payment and other credit-related activities.

• Conduct direct marketing and lead generation activities through analysing and tracking of our sales proposals, advertisements and EDMs on our events, conferences, seminars and workshops.

• Conduct joint marketing with other companies and service providers.

• Communicate with customers, members and website visitors.

• Respond to your enquiries and feedback to improve our quality of service.

• Analyse the use of our products, services or websites.

• Carry out our obligations arising from any contracts entered into between you and us.

• Comply with or fulfil legal obligations and regulatory requirements.

We disclose some of the personal data you provide us to the following entities or organisations outside PouchNATION in order to fulfil our services to you:

• External professional service providers (Book-keepers).

• EDM/Email Service Vendors (e.g. Mailchimp).

• Cloud Service Providers.

Where required to do so by law, we may disclose personal data about you to the relevant authorities or to law enforcement agencies.

6.1 Obtaining Consent

Before we collect, use or disclose your personal data, we will notify you of the purpose why we are doing so. We will obtain written confirmation from you on your expressed consent. We will not collect more personal data than is necessary for the stated purpose. We will seek fresh consent from you if the original purpose for the collection, use or disclosure of your personal data has changed.

Under certain circumstances, we may assume deemed consent from you when you voluntarily provide your personal data for the stated purpose, e.g. when you apply for a job with us by sending in your CV containing personal information.

We may rely on exceptions to the need for consent under the PDPA for the collection, use or disclosure of your personal data under the following circumstances (only those relevant to PouchNATION are included):

• The personal data is publicly available.

• The personal data is disclosed by a public agency or disclosed to a public agency.

• The personal data is necessary for any investigation or proceedings.

• The personal data is necessary for evaluative purposes (e.g. determining the suitability of a job applicant for the job applied for).

• The personal data is necessary for the purpose of managing or terminating an employment relationship.

• The personal data is necessary for a business asset transaction.

6.2 Withdrawal of Consent

If you wish to withdraw consent, you should give us reasonable advance notice. We will advise you of the likely consequences of your withdrawal of consent, e.g. without your personal contact information we may not be able to inform you of future services offered by us.

Your request for withdrawal of consent can take the form of an email or letter to us, or through the “Unsubscribe” feature in an online service.

6.3 Use of Cookies

We use “cookies” to collect information about your online activity on our website. A cookie is a small text file created by the website that is stored in your computer to provide a way for the website to recognise you and keep track of your preferences.

Most cookies we use are “session cookies”, which will be deleted automatically from the hard disk of your computer at the end of the session. You may choose not to accept cookies by turning off this feature in your web browser. Note that by doing so, you may not be able to use some of the features and functions in our web applications.

We will take reasonable steps to ensure that the personal data we collect about you is accurate, complete, not misleading and kept up to date.

We have implemented appropriate information security and technical measures (such as data encryption, firewalls and secure network protocols) to protect the personal data we hold about you against loss, misuse, destruction, unauthorised alteration/modification, access, disclosure, or similar risks.

We will not retain any of your personal data when it is no longer needed for any business or legal purposes.

You may write to us to find out how we have been using or disclosing your personal data over the past one year. Before we accede to your request, we may need to verify your identity.

Where there is a need to transfer your personal data to another country outside Singapore, we will ensure that the standard of data protection in the recipient country is comparable to that of Singapore’s PDPA.

If you have any query or feedback, you may contact our Data Protection Officer (DPO) at: [email protected]

We may update this Data Privacy Notice from time to time. Please visit our website periodically to note any changes.