Privacy and Personal Data Protection Policy

The Investment Management Association of Singapore (“IMAS”) and our partners, sponsors, service providers, representatives and/or agents, respect the privacy of all our customers and visitors, and are committed to safeguarding the personal information you provide to us. Please read this Personal Data Protection Policy (“Policy”) to learn about how we use and protect your personal information collected from you at the IMAS iLearn website (https://www.imas.org.sg/ilearn)(the “Website”).

1. Application of Policy

   This Policy is based on the Singapore Personal Data Protection Act 2012 and all the associated regulations and guidelines which may from time to time be issued by the Personal Data Protection Commission of Singapore. By providing us with your personal information, whether via registering for our training services and related goods, including but not limited to, any training modules or courses, using the Website, through any other form of interaction or otherwise, you are deemed to have agreed to the terms of this Policy. If you do not wish your information to be collected, used or disclosed in the manners described in this Policy, please do not access the Website or make use of IMAS’ training services and related goods, including but not limited to, any training modules or courses.

2. Collection of Personal Data

   “Personal Data” refers to any data of an individual who can be identified from that data, or in combination with any other information.

   You may be requested to provide your Personal Data in relation to training services and related goods, and depending on the nature of your interaction with us, this may include the following examples (including but not limited to):

   1. Full name;
   2. Business or residential address;
   3. Copy of identity card or passport;
   4. Payment details, including credit card and banking information; and/or
   5. Contact details, including telephone number/s and/or email addresses.
      Where any Personal Data of a third party (e.g. information of your family members, employees, etc.) is provided by you for any particular purpose, you warrant and represent that the appropriate consent(s) have been obtained to provide us with such Personal Data.

   Cookies

   When you visit the Website, we may assign your computer with one or more “cookies”. By accessing the Website, you agree to receive these cookies on your device.

   A cookie is a small text file that contains information that can later be analysed by us to facilitate your access to the Website, gather statistical data, and personalise your online experience. We may employ cookies in order for our server to recognise a return visitor as a unique user including, without limitation, monitoring information relating to how a visitor arrives at the Website, what kind of browser a visitor is on, what operating system a visitor is using, a visitor's IP address, and a visitor's click stream information and time stamp (for example, which pages they have viewed, the time the pages were accessed and the time spent per web page).

   Most browsers automatically accept cookies, but you may choose to modify your browser settings to decline cookies. All web-browsers offer the option to refuse any cookie, and if you refuse our cookie then we do not gather any information on that visitor. If you choose not to accept our cookie(s) when you visit the Website, you may be restricted from some of our interactive features and services, which may be rendered inoperable.

3. Use of Personal Data Collected

   Any Personal Data provided by you to us may be disclosed, shared among ourselves and used for the following purposes (where relevant):

   1. Process and respond to your requests and queries;
   2. Send you information and updatesin relation to our training services and related goods and any of our other products, services and events/activities;
   3. Update our records;
   4. Compile data and conduct statistical or demographic analysis;
   5. Solicit and record your opinion/feedback via surveys and requests for feedback (if you consent to participating);
   6. Send to insurance companies to process claims;
   7. Comply with a court order, other legal processes or other legal requirements of any governmental authority (including detecting, investigating and preventing any crime, offence or breaches);
   8. Facilitate any proposed/actual business assignments or transfers in any of our rights/obligations in relation to your Personal Data;
   9. Compliance with our internal policies/procedures and any applicable laws, rules and regulations, codes of practice, guidelines and any other legal purposes; and
   10. Allow us to use your Personal Data in any other ways for which we have notified you and obtained your consent accordingly.

   IMAS reserves the right to use any affiliated and unaffiliated third party providers for the aforementioned purposes, including but not limited to providing services such as administering of training programmes, delivery of online courses and training modules, credit card processing, and communication regarding IMAS’ services. We will not use, disclose or process your Personal Data for purposes which are not stated above or for which we have not obtained your consent. If we wish to use, disclose or process your Personal Data for another purpose not covered above, we will seek your prior consent.

4. Disclosure of Personal Data

   All Personal Data held by us will be kept confidential, but we may, where such disclosure is necessary to satisfy the purpose, or a directly-related purpose for which the Personal Data was collected, provide such information to the following parties:

   1. Any person or company who is acting for, jointly or on our behalf, in respect of the purpose or a directly- related purpose for which the Personal Data was provided;
   2. Any financial institutions, charge or credit card issuing companies, credit bureau, or collection agencies necessary to establish and support the payment of any services due or requested; and
   3. Any government authority in compliance with any applicable laws, rules and regulations, codes of practices, guidelines, court order, other legal processes or requirements.
   
   
5. Links to Third-Party Websites

   The Website contains or may contain links to other websites. IMAS is not responsible for the privacy practices or content of these other websites. This Policy applies solely to information collected by the Website. IMAS encourages you to be aware when you leave the Website and to read the privacy statements of each and every website that collects Personal Information.

6. Rights of European Economic Area (EEA) residents
   • Access. You have the right to request a copy of the personal information we are processing about you. For your own privacy and security, at our discretion we may require you to prove your identity before providing the requested information.
   • Rectification. You have the right to have incomplete or inaccurate personal information that we process about you rectified.
   • Deletion. You have the right to request that we delete personal information that we process about you, except we are not obliged to do so if we need to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims.
   • Restriction. You have the right to restrict our processing of your personal information where you believe such data to be inaccurate; our processing is unlawful; or that we no longer need to process such data for a particular purpose unless we are not able to delete the data due to a legal or other obligation or because you do not wish for us to delete it.
   • Portability. You have the right to obtain personal information we hold about you, in a structured, electronic format, and to transmit such data to another data controller, where this is (a) personal information which you have provided to us, and (b) if we are processing that data on the basis of your consent or to perform a contract with you.
   • Objection. Where the legal justification for our processing of your personal information is our legitimate interest, you have the right to object to such processing on grounds relating to your particular situation. We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data for the establishment, exercise or defence of a legal claim.
   • Withdrawing Consent. If you have consented to our processing of your personal information, you have the right to withdraw your consent.

7. Withdrawal of Consent

   Should you wish to withdraw your consent from receiving information and/or survey, you may send a request to IMAS Secretariat at ilearn@imas.org.sg.

8. Access and Correction of Personal Data

   If you wish to access, update or otherwise change or remove any information that you have provided to us, please contact the IMAS Secretariat at ilearn@imas.org.sg.

9. Accuracy of Personal Data

   We will keep all Personal Data collected as accurate, complete and up-to-date as necessary, taking into account its intended use and the interests of our customers and visitors. Where possible, we will validate the Personal Data provided by using generally accepted practices and guidelines.

10. Protection of Personal Data

    We will use our best endeavours to protect your Personal Data against loss or theft, as well as any unauthorised access, disclosure, copying, use or modification with security safeguards appropriate to the sensitivity of the Personal Data, regardless of the format in which it is held.

11. Retention of Personal Data

    We will retain your Personal Data only for as long as the purposes for which such data is collected or used (as notified to you) continues, or where necessary, for our legal or business purposes.

12. Changes to Policy

    We reserve the right to modify or change this Policy at any time and will place such amendments on this webpage. Your continued use of our webpage after any modification to this Policy shall constitute your acceptance of the amended Policy.

13. Several Obligation

    Please note that our liability (if any) hereunder is several and each of the above party shall not be liable for the respective privacy breaches of the other party.

14. Contact Us

    For any questions regarding this policy, or to withdraw consent, or to access and/or correct your Personal Data, please contact the IMAS Secretariat at ilearn@imas.org.sg.