Data Protection and Privacy Policy

PERSONAL DATA PROTECTION POLICY

This Personal Data Protection Policy (“Policy”) sets out the basis which Magellan Law LLP (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of users in accordance with the Personal Data Protection Act 2012 of Singapore (“PDPA”). This Policy applies to personal data in our possession or under our control. We may revise this Policy from time to time without any prior notice. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.

You have the responsibility to ensure that your personal data is accurate and complete, if your personal data is likely to be used by us to make a decision that affects you or disclosed to another organisation. We will not be responsible for relying on inaccurate or incomplete personal data arising from your failure to update us if any changes in your personal data that you had initially provided us with.

We will take reasonable steps to destroy and/or anonymise your personal data in our possession as soon as it is reasonable to assume that:

the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and
retention is no longer necessary for any other legal or business purposes.

Where you have engaged us to carry out any work in any jurisdictions outside Singapore, the transfer of your personal data records to these jurisdictions may be necessary to give effect to your instructions. Personal data may therefore be exported to, processed and accessed in countries whose laws provide a different level of protection, which may not necessarily be comparable to that provided in Singapore. However, where your personal data is to be transferred out of Singapore, we will comply with the PDPA in doing so.

PERSONAL DATA WE MAY COLLECT

The Personal Data we collection about you depends on your interactions and engagements with us. We may collect the following types of Personal Data:

Direct Identifiers such as name, gender, title, organization, job responsibilities, phone number, mailing address, email address, passports or other identification documents and dates of birth.
Personal Records such as your signature, financial account information and insurance policy numbers (particularly if we are assisting you in a financial matter), payment card information (for example, if you make payments to us directly), and any background information provided by you or collected by us as part of our business analysis, client onboarding, regulatory compliance checks and other related processes.
Commercial Information such as records of personal property, and products or services purchased or obtained.
Client Information such as Personal Data received from clients in respect of employees, customers or other individuals known to clients, invoicing details and payment history, and client feedback, Personal Data contained in documents, correspondence or other materials provided by or relating to transactions, proceedings or other legal matters on which we are advising our clients.
Internet Usage Information such as records of your use of our website, mobile applications or other online services. This may include online identifiers, account names and passwords, Computer Internet Protocol (IP) address, unique device identifier (UDID), cookies and other data linked to a device, and data about usage of our Sites (Usage Data).
Other Personal Data such as Personal Data about individual participation in conferences and in-person seminars, credentials, associations, product interests, and preferences, and contact data, e-mail metadata and other technical data relating to your interactions with us.

COLLECTION OF PERSONAL DATA

Generally, we may collect Personal Data in various ways including:

in the course of your engaging our services, or your providing documentation or information to us;
when you subscribe to any of our online services or communication platforms (including electronic publications, updates, alerts, announcements);
when you communicate or interact with us via telephone, video conferences, letters, fax, face-to-face meetings, our website, email or other modes of contact. Video conference calls may be recorded;
when you attend a seminar or other event organised by us;
when you request that you be included in an email or other mailing list;
when you submit an employment application or provide documents or information such as your resume, from recruitment agencies and employment references;
from public information sources, search services and other third parties; and
when you submit your Personal Data to us for any other reason.

If you provide us with any Personal Data relating to a third party, by submitting such Personal Data to us, you must ensure that you have notified the third party of the terms of this Policy and obtained his consent thereto.

PURPOSES FOR WHICH WE COLLECT PERSONAL DATA

Generally, the purposes for which the Firm collects, uses and discloses Personal Data include:

providing our legal services;
responding to, processing and handling your queries, feedback and suggestions;
verifying your identity, processing payments as well as managing our administrative and business operations (including the processing, storage, monitoring and backup of data);
managing the security of our premises, facilities and technology infrastructure;
providing updates and other communications on developments relating to the law and in respect of our Firm;
to send administrative email notifications e.g. security, support and/or maintenance notices, or updates and/or amendments to our policies, terms and conditions;
to improve our services and communications to you as well as the quality of your interaction with our website;
complying with applicable laws and regulations, codes of practice or guidelines, policies, procedures, regulatory requirements (which may extend to know-your-client and related reviews);
complying with or responding to any requests or directions of directions issued by relevant government authorities or public agencies;
conducting research, analysis and development activities to improve our services and facilities in order to enhance your relationship with is or for your benefit or to improve any of our services for your benefit;
operating our website and/or its subdomains through the use of cookies;
the establishment, exercise or defence of any legal or equitable claim; and
any other purpose relating to any of the above.

In addition, if you are seeking employment or any other appointment with us, the purposes for which we collect and use your personal data include:

processing and assessing your application;
performing background checks, verifying your credentials and qualifications as well as obtaining employment references; and
any other purpose relating to any of the above.

The purposes for which we may collect and use your personal data is specific to the circumstances on hand and the purposes listed above are non-exhaustive. Should there be other purpose(s) for which we require your personal data, we will notify you at the time of obtaining your consent.

DISCLOSURE OF PERSONAL DATA

We may disclose your personal data:

With your consent. We may disclose your Personal Data to any party for whom your consent has been provided.
To our vendors. We may disclose your Personal Data to technical consultants, experts and other law firms assisting with your matters, third party vendors, agents and other organisations we have engaged to perform any functions including, but not limited to, internet service providers, technology solutions, data analytics providers, external consultants, advertising networks, support, operational or administrative services, such as for our online services, courier services, telecommunications, information technology, payment, payroll processing, training, market research, storage, archival, client support services.
In relation to services provided. We may disclose and transfer your Personal Data if we are involved in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy or other change of ownership or control (whether in whole or in part), including negotiation and diligence of such transaction, or where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods and services requested by you.
To other services providers. We may disclose and transfer your Personal Data in connection with professional indemnity policies, and to our professional advisers including auditors.
As we believe to be necessary and appropriate. We may also disclose your Personal Data: (i) as permitted by law; (ii) if we determine that the disclosure of specific information is necessary to comply with the request of a law enforcement or regulatory agency or other legal process; (iii) to protect the legitimate rights, privacy, property, interests or safety of our company or our affiliated entities, customers, business partners, employees or the general public; (iv) to pursue available remedies or limit damages; (v) to enforce our Terms of Use; and (vi) to respond to an emergency.

USE OF WEBSITE

Where your use of our website is concerned, certain functions, when activated or used by you, will operate to send or display information about yourself, including but not limited to, your personal data to certain third parties, and you agree to the sharing of such information with these third parties. We will not be responsible or accountable for any loss, injury or damage sustained by you for sharing the aforesaid information arising out of your activation or use of such features on our website.

IP Address

An IP address is a number that is automatically assigned to your computer when you are connected to the Internet. When you visit our website, your IP address is automatically logged in our server. We use your IP address to help diagnose problems with our server, and to administer our website. From your IP address, we may identify the general geographic area from which you are accessing our website; however, we will not be able to pinpoint the exact geographic location from which you are accessing our website. Generally, we do not link your IP address to anything that will enable us to identify you unless it is required by applicable laws and regulations.

Cookies

Our website may place and access certain cookies on your computer and/or any other electronic device used to access the website. We use cookies to improve your experience using the website and to improve the efficacy of our services through gathering information about your usage patterns when you navigate our website in order to enhance your personalized experience.

You can adjust settings on your browser so that you will be notified when you receive a cookie. Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser. However, your ability to use our website or the functionality thereof may be affected.

WITHDRAWING YOUR CONSENT

The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent, or deemed consent, and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.

Upon receipt of your written 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 will seek to process your request within 30 days of receiving it.

Whilst we respect your decision to withdraw your consent, please be aware that depending on the nature and scope of your request, we may not be in a position to continue providing our goods and/or services to you and we will, in such circumstances, inform you before completing the processing of your request.

Please note that withdrawing consent does not affect:

our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws;
any liability, debt or obligation accrued by you prior to the date of such withdrawal; or
the terms and conditions of any contract agreed between us (unless it relates to our collection, use or disclosure of your personal data with your consent).

ACCESS TO AND CORRECTION OF PERSONAL DATA

If you wish to make:

an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or
a correction request to correct or update any of your personal data which we hold about you,

you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.

We will respond to your request as soon as reasonably possible. In general, we will respond within 30 days. Should we not be able to respond to your request within 30 days after receiving your request, we will inform you ahead of that time in writing. If we are unable to provide you with any Personal Information or to make a correction requested by you, we will inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

DATA PROTECTION OFFICER

You may contact our Data Protection Officer at alextoh@magellanlawllp.com if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request.

Last updated on: 23 August 2024