Last Updated: 10 June 2020
Collection of Information
As a visitor, you do not have to submit any personal information in order to use the website. This website only collects personal information that is specifically and voluntarily provided by visitors for the purpose the personal information is collected. Personal information may consist of, but is not limited to, your name, current job title, company address, email address and telephone and fax numbers. Do not provide personal information to us, unless you consent to our use of that information for its legitimate business purpose.
How we Collect Information
We use different means to collect your data. These means include the following:
Direct interactions. You may give us your Personal, Qualification, and Contact details by filling in forms or by corresponding with us. This includes personal data you provide when you subscribe to our insights forum; and give us feedback or contact us.
Automated technologies or interactions. When you use the site, we will automatically collect Technical details. This is done by using cookies and other similar technologies. Please see the cookie, analytics and automatic collection of information section* of this Policy for further details.
Cookies, Log In Information, And Other Web Beacons
If you prefer, you can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies via your browser settings.
Use of Information
KCG processes your personal data to manage your requests for information and/or documents, analyse the site’s performance and functioning, as well as personalise and improve its content and related services. We may also use your personal information for marketing purposes, or to send you promotional materials or communications regarding services provided by Kosh Consulting Group that we feel may be of interest to you. We may also contact you to seek feedback on services provided by Kosh Consulting Group or for market or other research purposes.
You may at any time request that we discontinue sending you emails or other communications generated in response to your provision of personal information via this Website (refer to the section on opting out).
Disclosure of Information
We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information, which includes personal details you provide through our contact forms. However, we may do so for trusted third parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others rights, property, or safety. On the other hand, non-personally identifiable information such as your standard internet log-in information (refer to our Cookies, Log-in information, and Other Web Beacons for more details) may be provided to other parties for marketing, advertising, or other uses.
Here is a detailed list of potential outside parties that may obtain and process your data through our information collection:
Employers, customers and partners to whom we provide various services or products in connection with this site or our business or operations, or who have contractual arrangements with us (whether in relation with your transaction or requested service or otherwise).
Service providers, contractors, agents and professionals who provide various services or facilities to us in connection with this site, our business or operations or who have contractual arrangements with us.
Our employees, contractors, agents and advisors.
Financial institutions, third party payors, credit card and payment gateway companies.
Any other person who may be an assignee, transferee or participant in some way in our rights or business (whether actual or proposed). If a change happens to the site, then the new owners may use your personal data in the same way as set out in this Notice.
Other parties authorised or consented to by you.
Regulatory, enforcement and governmental authorities as permitted or any person as required by law or to comply with the directives of the authorities or any order of court or legal process.
Any other person to whom disclosure is required in order to protect or defend our rights and/or property.
Any of our subsidiary, parent, associated or affiliated companies.
Any other person to whom we (and our subsidiary, associated or affiliated companies or representatives) have a duty of disclosure under applicable law, regulations or guidelines.
Data Transfer Outside the European Economic Area (EEA)
Please note that such disclosure or use may involve the transfer of your personal information to places outside of your local country/jurisdiction and by providing us with such information, you consent to such transfer in connection with your dealings with us, the requested services or for the performance of contractual obligations or for other legal or business purposes.
Any such transfer will be pursuant to contractual arrangements and other safeguards to ensure the appropriate levels of protection equivalent to the protection granted under the Personal Data Protection Act 2012 of Singapore and in accordance with this policy and applicable law. This includes ensuring that recipients of such transferred information are in a jurisdiction which has comparable data protection laws or are otherwise bound to protect the personal information, having appropriate security arrangements and processes to protect and manage the information and ensuring that the collection and use of the information is for the purposes(s) set out in this Notice.
We share your personal data within KCG and with some of our third-party suppliers and service providers. This may involve processing and transferring your data outside the European Economic Area (“EEA”).
Whenever we transfer your personal data out of the EEA, we will ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards are in place. In this regard:
Where we use certain service providers or if your Organisation is based in the EEA, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
Where we use third party suppliers or services providers that are based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between Europe and the US.
Please contact us if you would like further information on the specific mechanism used by us when we process or transfer your personal data out of the EEA.
Third Party Links
You may opt-out of receiving emails, marketing communications from us and selected third parties and limiting the distribution of your personal information. You can do so by contacting us via the contact details below, submitting an enquiry form or by clicking on the “unsubscribe” link in certain electronic communications we may send to you through your email.
When we receive your request to opt-out from receiving marketing communication, it may take up to fourteen (14) working days for your opt-out to be updated in our records and systems.
Accordingly, you may still receive marketing communication during this short period of time. Kindly be reminded that even if you opt-out from receiving marketing communication, we may still contact you for other purposes in relation to the transactions between us or the services you have requested from us.
Protection & Retention of Personal Data
We take the necessary security and technical measures to protect the security and confidentiality of personal data in compliance with applicable law, and protect personal data from loss, misuse, alteration, or destruction. Only authorized Kosh Consulting Group personnel and third party service providers are provided access to personal data, and these employees and service providers are required to treat this information as confidential. However, as no means of Internet or mobile transmission or mode or digital transfer or storage is entirely secure, we cannot guarantee its absolute security.
When you provide your personal data to us via this website, we will only retain your personal data for as long as reasonably necessary in order to fulfil the purposes that you provided it for and have consented to, including for the purposes of satisfying any legal, regulatory, accounting tax and reporting requirements. In the unlikely event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you, we may retain your personal data for a longer period.
Singapore Personal Data Protection Act
KCG is a Singapore-based consulting firm and as such, we are in compliance with the requirements of the Singapore Data Protection Act (PDPA). We adhere to the following guidelines of the PDPA, by which we are obligated to:
Receive your consent before we collect, use, or disclose your personal data. You may withdraw any consent given at any time and be informed of the likely consequences of withdrawing your consent.
Collect, use, or disclose your personal data for the limited purposes of fulfilling our business obligations to address your requests. You may request and find out more details about our use of your personal data from our business representative by submitting a general enquiry.
Inform you of the purposes for the collection, use, or disclosure on or before the collection of your personal data.
Upon your request, provide you details about your personal data that is in our possession, and how it have been or may be used or disclosed by us within a year before the date of your request. You may request to correct an error or omission in your personal data that is in our possession, and we will correct it so long as it is on reasonable grounds that a correction should be made.
Make a reasonable effort to ensure that we collect your personal data accurately and completely, such that we make optimal decisions when we fulfil your requests; or if your data is disclosed to another organisation.
Protect your personal data by making reasonable security arrangements to prevent unauthorised access.
Cease to retain documents relating to your personal data or remove our means to link personal data back to your profile as soon as we have our legal or business purposes have been served.
Refrain from transferring any personal data to a country or territory outside Singapore, with the exception that it is in accordance with the requirements prescribed under this Act.
Rendering power to the Commission to review, give or enforce directions, should there be any complaints by an individual against KCG, whereby the Commission is of the opinion that the complaint may be more appropriately resolved by mediation.
General Data Protection Regulation
We strive to be compliant with the requirements of the General Data Protection Act (GDPR), which gives you the right:
To request correction of your personal data if it is incorrect or out of date. If the data we hold about you is out of date, incomplete or incorrect you can inform us and your data will be updated.
To request access to the personal data we hold about you, without charge (certain exceptions apply and can be explained by submitting us a request through the general enquiry form in more detail as needed).
To request to withdraw consent for processing your data if that process relies on consent.
The right to object to processing of your data. You may request that we stop processing information about you. Upon receiving your request, we will contact you and let you know if we are able to comply or if we have legitimate grounds to continue to process your data. Please note that even after you exercise your right to object, we may continue to hold your data to comply with your other rights or bring or defend legal claims.
The right to data portability. You may request that we transfer your data to another controller if the data is processed by automated means (i.e. excluding paper files).
The right to request restriction of processing of your personal data.
To request that we delete your data and the right to erasure (the “right to be forgotten”). If you feel we should no longer be using your data, you can request that we erase the data that we hold.
In order for you to exercise your rights, we may request specific information from you to assist us in confirming your identity. This is a security measure to prevent personal data from being disclosed to unauthorised persons. Generally, we will respond to all legitimate requests within one month. There may be times when it takes us longer than a month e.g. your request is particularly complex or you have made numerous requests. In these situations, we will notify you and keep you updated.
Updating Your Details
If you wish to access, verify or correct your personal data or obtain information about how your personal data may have been used or disclosed in the past year, you may do so by contacting us via the contact details below. Please note that depending on the request, we may charge a small fee. Please also note that in certain circumstances, we may be prevented by law from complying with your request and we may also decline the request if allowed to do so by applicable law or if the relevant records are no longer retained by us.
Our security procedures mean that we may request proof of identity before we reveal information or carry out the requests. This proof of identity may take the form of your e-mail address and other personal information submitted through our contact forms.
Changes to Our Privacy Statement
We may modify or amend this Privacy Statement from time to time at our discretion. When we make changes to this Statement, we will amend the revision date at the top of this page, and such modified or amended Privacy Statement shall be effective as to you and your information as of that revision date. We encourage you to periodically review this Privacy Statement to be informed about how we are protecting your information.