This Data Protection Notice (“Notice”) sets out the basis which Green Nudge Strategies Pte Ltd (“we”, “us”, or “our”) maycollect, use, disclose or otherwise process personal data of our customers inaccordance 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 forour purposes.
1. 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 acontract 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.
2. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include name, residential address, email address, telephone number, nationality, gender and the last 4 digits of your National Identification Registration Card (“NRIC”) number.
3. Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).
4. 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).
5. We may collect and use your personal data for any or all of the following purposes:
We may disclose your personal data:
6. We collect and use cookies on our website for to gather statistics and gain insights into how you navigate on our website so that improvements can be made.
7. Cookies are small text files that can be used by websites to make a user's experience more efficient. You can find out more about cookies at www.allaboutcookies.org.
8. The cookie is used to track information such as the number of users and their frequency of use, profiles of users and their preferred digital services. While this cookie can tell us when you enter our digital services and which pages you visit, it cannot read data off your hard disk.
9. This site uses different types of cookies. Some cookies are placed by third party services that appear on our pages.
10. The law states that we can store cookies on your device if they are strictly necessary for the operation of this site. For all other types of cookies we need your permission. You can at any time change or withdraw your consent from the Cookie Declaration on our website.
11. To safeguard your Personal Data, all electronic storage and transmission of Personal Data is secured with appropriate security technologies.
12. Preference cookies enable a website to remember information that changes the way the website behave or looks, like your preferred language or the region that you’re in.
13. Statistic cookie help website owners to understand how visitors interact with websites by collecting and reporting information anonymously.
14. You may refuse to accept cookies by changing the settings of your Internet browser. If you do not want cookies to be placed on your device, you can control this through your browser’s settings. Refer to the links below for each browser’s guide on how to turn off or delete cookies.
15. Please note that if you delete your cookies, we won’t be able to know that you’ve opted out of behavioural on our website; recognise that you’ve agreed to our Terms and Conditions, Privacy Policy and Cookie Policy. This means that the cookies consent banners will appear. You’ll need to accept the use of cookies and provide other cookie-related information again.
16. You may opt out by visiting Hotjar, following the instructions to install Do Not Track header to prevent Hotjar from collecting your users’ behaviour data.
17. A Chrome browser add-on is available to opt out to prevent your data being used by Google Analytics.
18. . 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.
19. . 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 ten (10) business days of receiving it.
20. 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 7 above.
21. 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.
22. 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.
23. 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.
24. We will respond to your request as soon as reasonably possible. In general, our response will be within thirty (30) 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).
25. 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, and authentication and access controls (such as good password practices, need-to-know basis for data disclosure, etc.).
26. 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.
27. 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.
28. 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.
29. 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.
30. 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.
31. 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.
32. 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.
33. If you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, you may contact us at:
Heng Li Seng, Founder
liseng@greennudge.sg
Effective date : 22/07/2021
Last updated : 06/06/2022
