Privacy Policy
This Data Protection Notice (“Notice”) sets out the basis which DocLah
(“we”,
“us”,
or “our”) may collect, use, disclose or otherwise process personal
data of our
customers in accordance with
the
Personal Data Protection Act (“PDPA”). This
Notice applies to personal data in
our possession or under our
control, including personal data in the possession of organisations which we have engaged to
collect, use,
disclose or process personal data for our purposes.
Personal Data
-
As used in this Notice:
“customer” means an individual who (a) has contacted us through any
means to
find
out more about any goods or services we provide, or (b) may, or has, entered into a contract
with us for the
supply of any goods or services by us; and
“personal data” means data, whether true or not, about a customer who can be identified: (a)
from that data;
or (b) from that data and other information to which we have or are likely to have access.
-
Depending on the nature of your interaction with us, some examples of personal data which we may
collect
from you include email address and IP address.
An IP address is a
numerical
label assigned to each device connected to the Internet Protocol for
communication
and required to show you websites, images, files and other information on the Internet. IP
addresses
typically can be used to find out the location of your device, generally down to the city
level. In the
case
of a business IP address, it can be matched with a business name and street address.
-
Other terms used in this Notice shall have the meanings given to them in the PDPA (where the
context so
permits).
Collection, Use, and Disclosure of
Personal
Data
-
We generally do not collect your personal data unless (a) it is provided to us voluntarily by
you directly
or via a third party who has been duly authorised by you to disclose your personal data to us
(your
“authorised representative”) after (i) you (or your authorised representative) have been
notified of the
purposes for which the data is collected, and (ii) you (or your authorised representative) have
provided
written consent to the collection and usage of your personal data for those purposes, or (b)
collection and
use of personal data without consent is permitted or required by the PDPA or other laws. We
shall seek your
consent before collecting any additional personal data and before using your personal data for a
purpose
which has not been notified to you (except where permitted or authorised by law).
The IP address of your networked device is automatically captured whenever a connection is made
over the
Internet regardless of your consent.
-
We may collect and use your personal data for any or all of the following purposes:
-
performing obligations in the course of or in connection with our provision of the goods
and/or services
requested by you;
-
responding to, handling, and processing queries, requests, applications, complaints, and
feedback from
you;
-
complying with any applicable laws, regulations, codes of practice, guidelines, or
rules, or to assist
in law enforcement and investigations conducted by any governmental and/or regulatory
authority; and
-
transmitting to any unaffiliated third parties including our third party service
providers and agents,
and relevant governmental and/or regulatory authorities, whether in Singapore or abroad,
for the
aforementioned purposes.
-
We may disclose your personal data:
-
to third party service providers, agents and other organisations we have engaged to
perform any of the
functions with reference to the above mentioned purposes.
The third parties we may share personal information with are as follows: Amazon
Web Services (AWS),
Cloudflare, Google
Analytics, Hotjar, OneMap and tawk.to.
Reliance on Legitimate Interests
Exception
-
In compliance with the PDPA, we may collect, use or disclose your personal data without your
consent for the
legitimate interests of DocLah or another person. In relying on the legitimate interests
exception of the
PDPA,
DocLah will assess the likely adverse effects on the individual and determine that the
legitimate interests
outweigh any adverse effect.
-
In line with the legitimate interests’ exception, we will collect, use or disclose your personal
data for
the following purposes:
-
Detection and prevention of misuse of services.
The purposes listed in the above clause may continue to apply even in situations where your
relationship with
us
(for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable
period
thereafter.
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 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 shall seek to process your
request within
two (2) 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 goods or services to you
and we
shall, in such circumstances, notify you before completing the processing of your request.
Should you decide
to cancel your withdrawal of consent, please inform us in writing in the manner described in
clause 9 above.
-
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.
Access To and Correction of Personal
Data
-
If you wish to make (a) 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 (b) 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.
-
Please note that a reasonable fee may be charged for an access request. If so, we will inform
you of the fee
before processing your request.
-
We will respond to your request as soon as reasonably possible. In general, our response will be
within two
(2) business days. Should we not be able to respond to your request within thirty (30) days
after receiving
your request, we will inform you in writing within thirty (30) days of the time by which we will
be able to
respond to your request. If we are unable to provide you with any personal data or to make a
correction
requested by you, we shall generally inform you of the reasons why we are unable to do so
(except where we
are not required to do so under the PDPA).
Protection of Personal Data
-
To safeguard your personal data from unauthorised access, collection, use, disclosure, copying,
modification, disposal or similar risks, we have introduced appropriate administrative, physical
and
technical measures such as minimised collection of personal data, authentication and access
controls (such
as good password practices, need-to-basis for data disclosure, etc.), encryption of data, data
anonymisation, up-to-date antivirus protection, regular patching of operating system and other
software,
securely erase storage media in devices before disposal, web security measures against risks,
usage of one
time password (otp)/2 factor authentication (2fa)/multi-factor authentication (mfa) to secure
access, and
security review and testing performed regularly.
-
You should be aware, however, that no method of transmission over the Internet or method of
electronic
storage is completely secure. While security cannot be guaranteed, we strive to protect the
security of your
information and are constantly reviewing and enhancing our information security measures.
Accuracy of Personal Data
-
We generally rely on personal data provided by you (or your authorised representative). In order
to ensure
that your personal data is current, complete and accurate, please update us if there are changes
to your
personal data by informing our Data Protection Officer in writing or via email at the contact
details
provided below.
Retention of Personal Data
-
We may retain your personal data for as long as it is necessary to fulfil the purpose for which
it was
collected, or as required or permitted by applicable laws.
-
We will cease to retain your personal data, or remove the means by which the data can be
associated with
you, as soon as it is reasonable to assume that such retention no longer serves the purpose for
which the
personal data was collected, and is no longer necessary for legal or business purposes.
Transfer or Personal Data Outside of
Singapore
-
We generally do not transfer your personal data to countries outside of Singapore. However, if
we do so, we
will obtain your consent for the transfer to be made and we will take steps to ensure that your
personal
data continues to receive a standard of protection that is at least comparable to that provided
under the
PDPA.
Data Protection Officer
-
You may contact our Data Protection Officer if you have any enquiries or feedback on our
personal data
protection policies and procedures, or if you wish to make any request, at the following email
address: legal@doclah.sg
Effect of Notice and Changes to
Notice
-
This Notice applies in conjunction with any other notices, contractual clauses and consent
clauses that
apply in relation to the collection, use and disclosure of your personal data by us.
-
We may revise this Notice from time to time without any prior notice. You may determine if any
such revision
has taken place by referring to the date on which this Notice was last updated. Your continued
use of our
services constitutes your acknowledgement and acceptance of such changes.
Effective date: 03/11/2024
Last updated: 03/11/2024