Agreement – Terms
We want you to understand why and how Starboard SG Pte. Ltd. (“Starboard”, “we”, “us” and/or “our”) collects, uses, discloses and or/processes your Personal Data (as defined below) under Singapore’s Personal Data Protection Act 2012 (the “PDPA”).
This Policy applies to you and all Individuals (as defined below) who provide Starboard with Personal Data or whose Personal Data is otherwise collected, used, processed, stored and/or disclosed by Starboard in connection with and/or for the purposes of its operations.
This Policy supplements but does not supersede or replace any previous consent which you may have provided to Starboard, nor does it affect any legal rights that Starboard may have regarding the collection, use, processing and/or disclosure of any Individual’s Personal Data.
Starboard may from time to time update this Policy to ensure that it is consistent with our business needs or to accommodate amendments to applicable legal or regulatory requirements. All updates to this Policy will be published online at www.starboardhq.com (the “Starboard Website”). Notification of any material revisions will also be published on the Starboard Website. You shall be deemed to have accepted the Policy as amended by continuing your relationship with Starboard (including by accessing the Starboard Website, Dashboard or using any of the Starboard Services (as defined in the Terms)) after any amendments have been published on the Starboard Website.
This Policy forms part of the terms and conditions, if any, governing your specific relationship with Starboard (“Terms and Conditions”) and it should be read in conjunction with the Terms and Conditions. In the event of any conflict or inconsistency between the provisions of this Policy and the Terms and Conditions, the provisions of the Terms and Conditions shall prevail to the fullest extent permissible by law.
There are some information which are mandatory for us to collect in order to provide our services to you as part of being regulated.
A cookie is a small piece of data that is stored on your computer or mobile device.
Our principles of data protection
Our approach to data protection is built around 3 key principles. They’re at the heart of everything we do relating to personal data.
User Sovereignty: You have full control over your data and you have the ability to make changes as required.
Transparency: We take a human approach to how we process personal data by being open, honest and transparent.
Security: We ensure industry-leading approaches to securing the personal data entrusted to us.
1. Definitions: For the purposes of this Policy:
“Individual” (or “you”) means a natural person, whether living or deceased and “Individuals” (and “your”) shall be construed accordingly;
“Personal Data” shall mean data, whether true or not, about an Individual who can be identified (a) from that data; or (b) from that data and other information to which Starboard has or is likely to have access to;
“Personnel” means any Individual engaged under a contract of service with Starboard including permanent or temporary employees as well as trainees and interns engaged by Starboard from time to time; and
“Potential Personnel” means any Individual who has submitted an application to be engaged by Starboard as Personnel.
2. Purposes for collection, use and disclosure of Personal Data
Starboard will only collect, use and disclose Personal Data from/or related to an Individual for the following purposes:
a) Facilitating the provision of Starboard products and services which are used by you and from time to time send you newsletters, marketing or promotional materials and any other information that may be relevant to you;
b) Communicating with you to assist you with your enquiries;
c) Dealing with administrative matters relating to the product and/or services purchased and/or subscribed to by you;
d) Conducting market research and customer satisfaction surveys;
e) Performing audit, risk assessment, fraud and crime prevention, in administering the Company and providing the services;
f) To provide, operate, and maintain the Starboard Website;
g) To improve, personalise, and expand the Starboard Website;
h) Understand and analyse how you use the Starboard Website;
i) To develop new products, services, features, and functionalities;
j) Finding and preventing fraud;
k) Preparing and using log files;
l) other purposes that we notify you of at the time of obtaining your consent to collect, use and/or to disclose your Personal Data
m) verifying and carrying out financial transactions in relation to payments you make online;
n) to improve Starboard’s products and/or services;
o) to resolve any disputes that may arise between Starboard and you; and
p) to comply with applicable laws, (collectively, the “Purposes”).
3. Collection of Personal Data
Generally, Starboard may collect Personal Data from you in one or more of the following ways or circumstances:
a) Information provided directly: You may be asked to provide Personal Data when you visit or use some parts of our websites and/or services. You do not have to provide us with your Personal Data; however, it could mean that you are not able to access some parts of our website or use our services.
b) Information collected automatically: Some information is collected automatically, such as an IP address and device type, when you visit our websites or use our services. This information is useful to us as it provides us with a better understanding of how you are interacting with our websites and services so that we can continue to provide you with the best experience possible.
c) Information from third parties: The majority of information that we collect is collected directly from you. Some data may be collected from other sources, such as information that is available in the public domain or trusted third parties in order to conduct background checks as part of your relationship with us. We use this information to supplement the Personal Data that we have collected from you.
Where your Personal Data is collected from third parties, we will only use such Personal Data where you have provided your consent to the third party which would also cover our processing of your Personal Data.
Some of the information we collect may include your personal data, such as your full name, contact information, Copy of NRIC, Copy of passport or other identification, telephone number(s), residential address, email address, biometric data and other personal data required by government agencies, product and service selections, and other data that may identify you. We collect personal data about you at several different points, including but not limited to the following:
- when we correspond with you as a customer or prospective customer;
- when you visit the Starboard Website or use the Platform;
- when you use our software or services;
- when you register as an end-user of our services and an account is created for you;
- when you opt-in our newsletter program;
- when you decide to participate in a survey;
- When you voluntarily provide us with your information through our landing pages
As part of our onboarding process, there is some information which we have to collect from you as part of being regulated by the Accounting and Corporate Regulatory Authority (ACRA) and the Monetary Authority of Singapore (MAS), without which we would not be able to provide you our services. In order to do so, we make use of independent providers to help us carry out identity checks on our behalf. When this happens, you will be redirected outside of Starboard platform. The information required might include an image, images of an identity document (e.g a passport or a driver’s license) or a live video. The exact information needed depends on the check that’s being carried out.
Please note that if you choose not to provide us with your Personal Data or choose not to consent to our collection, use and disclosure of your Personal Data, we may not be able to provide some or all of our services to you or respond to your other requests; for job applicants, we would not be able to evaluate your suitability against our employment opportunities.
4. Sharing Information Outside Starboard
Starboard shares information with external parties that are performing tasks on our behalf (including data processors and sub-contractors) and with other companies, organisations, government bodies, and individuals outside Starboard where we have a legitimate legal reason for doing so (for example, in connection with any merger or acquisition or to comply with a court order) or where we have been instructed to share the information on behalf of our clients.
Unless otherwise authorised under the APP, PDPA, PDPO, GDPR or any other applicable law, Starboard will not collect, use or disclose your Personal Data without your knowledge and consent. Starboard will highlight the Purposes relevant to you, by appropriate means, at the point or time of collection of your Personal Data.
Starboard may obtain your consent by any of the following means:
a) via express provisions in a contract, application form and/or registration form to be signed with or submitted to Starboard; or
b) via notifications on the Starboard Website.
In so far as any Purpose(s) are intrinsic to the relationship or provision of services, Starboard reserves the right to decline to engage in the relevant relationship or to provide the relevant services to you if you do not consent to Starboard’s collection, use or disclosure of your Personal Data for such purposes.
a) voluntarily provide Personal Data to Starboard for any specified purpose;
b) use or access Starboard’s computer network;
c) enter Starboard’s premises or use any of the facilities thereon; and/or
d) attend or participate in events or programmes organised by Starboard,
If you provide Starboard with Personal Data relating to a third party Individual (e.g. information of his or her spouse or children) for any particular purpose, you represent and warrant to Starboard that you have: (a) informed such third party Individual that their Personal Data has been or will be disclosed to Starboard by you; (b) informed such third party Individual that their Personal Data will be collected, used, disclosed and/or processed by Starboard in the manner and for the purposes as set out in this Policy; and (c) obtained the consent of the relevant third party Individual for the foregoing in accordance with all applicable laws (including the PDPA).
6. Disclosure of Personal Data
There may be occasions where we may need to share your Personal Data with third parties. Starboard will disclose your Personal Data only in the following circumstances:
a) to Starboard’s third party service providers or agents;
b) to Starboard’s auditors and professional advisors;
c) to regulators, law enforcement bodies, government agencies, courts or any other third party to whom disclosure is permitted or required by any applicable law or regulation;
d) to other parties where we have your consent.
7. Request to Withdraw Consent
You have the right to withdraw your consent to the collection, use and/or disclosure of your Personal Data in the possession of Starboard by submitting your request to firstname.lastname@example.org at any time.
We will process your request for the withdrawal of consent within a reasonable period of time from such a request being made. After that time, we will not collect, use and/or disclose your Personal Data in the manner stated in your request.
Your withdrawal of consent could affect the services that we are able to provide to you. Depending on the extent of your withdrawal of consent for us to process your Personal Data, it may mean that we are not able to continue with our existing business relationship.
9. Security and Transfer of Personal Data
Starboard shall make reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks to Personal Data in its possession.
If Starboard transfers Personal Data outside of Singapore, Starboard will take reasonable steps to ensure that such Personal Data transferred receives a standard of protection comparable to the protection received under the PDPA and PDPO and such transfer shall be subject to this Policy.
Starboard will ensure that third parties who receive Personal Data from Starboard protect such Personal Data in a manner consistent with this Policy and not use such Personal Data for any purposes other than those specified by Starboard, by incorporating appropriate contractual terms in its written agreements with third parties.
Starboard is not responsible in any way for the security and/or management of Personal Data shared by you with third-party websites accessible via links on the Starboard Website.
In the event of a breach of security in respect of any Customer Data, Starboard shall promptly (but as soon as practical from a security perspective) provide notice of such breach to the Customer and any individuals acting on behalf of such Customer, setting out the extent of the breach, the affected Customer Data and any steps taken by Starboard to remedy and limit the consequences of the breach. Notwithstanding the foregoing, where Starboard determines that the PDPA allows Starboard not to provide notification in respect of a breach, Starboard may choose not to inform the Customer of such breach immediately or at all.
10. Third-party websites
The Starboard Website may, from time to time, contain links to and from the websites of our partner networks and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility for them. Please check these policies before you submit any personal data to these websites.
11. Accuracy of Personal Data
Information voluntarily provided by you to Starboard shall be deemed complete and accurate.
Starboard will take reasonable steps to verify the accuracy of Personal Data received at the point of collection, but you will remain primarily responsible and liable to ensure that all Personal Data submitted by you to Starboard is complete and accurate.
Starboard will also take reasonable steps to periodically verify the Personal Data in its possession, taking into account the scope of its operations. However, you remain responsible for notifying Starboard, from time to time, of any applicable changes to your Personal Data. You can amend your Personal Data on the Starboard Platform or you may notify your assigned associate at any time.
Starboard shall not be held liable for any inability on its part to provide services to you if you fail to ensure that your Personal Data submitted to Starboard is complete and accurate.
12. Access to and correction of Personal Data
In general, the rights afforded to individuals are:
a) Right to Access
The right to request access to be provided with: (i) your Personal Data that we have in our posession or control; and (ii) and information about the ways in which the personal data mentioned in paragraph (i) has been or may have been used or disclosed by Starboard within a year before the date of the request.
b) Right of Correction/Rectification
The right to request that we amend or update your Personal Data where it is inaccurate or incomplete. Kindly note that while we shall make a reasonable effort to ensure that the Personal Data we collect is accurate and complete, you are responsible for ensuring the accuracy of the Personal Data that you provide to us directly.
c) Right to Withdraw Consent
You have right to withdraw your consent at any time, where consent is the legal basis of the processing of your Personal Data. Kindly note that depending on the nature and scope of your request, we may not be in a position to continue performing our obligations in the course of or in connection with the Event to you.
For individuals covered by the GDPR, they also have the following rights (as available and subject to any applicable law):
d) Right to Erasure
The right to request that we temporarily or permanently stop processing all or some of your Personal Data.
e) Right to Object
The right to object to your Personal Data being processed by us for direct marketing purposes, or to, at any time, object to us processing your Personal Data on grounds relating to your particular situation
f) Right to Data Portability
The right to request a copy of your Personal Data in electronic format and the right to transmit that Personal Data for use in another party’s service.
g) Right not to be subject to Automated Decision-making
The right to not be subject to a decision based solely on automated decision-making where the decision would have a legal effect on you or produce a similarly significant effect.
If we send you electronic marketing messages (i.e newsletters) based on your consent or as otherwise permitted by applicable law, you may, at any time, respectively withdraw such consent or declare your objection at no cost. The electronic marketing messages you receive from Starboard will also include an “unsubscribe” option within the message itself to enable you to manage your Personal Data. Please note that if you opt-out of receiving direct marketing materials, we may still send you non-promotional messages, such as receipts or information about the Services we are providing to you.
Additionally, you have the right at any time to lodge a complaint with your local Data Protection Authority if you are unhappy with the way in which we are using your Personal Data.
13. Retention of Data
The length of time that we keep your Personal Data depends on what it is and whether we have an ongoing business need to retain it. For example, we may retain your Personal Data for five to seven years to comply with applicable laws.
We will only retain your data for as long as necessary to fulfill the purposes for the collection of such Personal Data unless we have other legal or business or purposes.
Upon the expiry of time relating to any business needs or legal requirements to retain your Personal Data, we will ensure that your Personal Data is deleted or anonymised.
14. Making a complaint
You are welcome to contact our Data Protection Officer if you have any complaint or grievance about how we are handling any Personal Data in our control or possession by contacting your assigned associate.
If any provision of this Policy shall be held to be illegal, void, invalid or unenforceable under the laws of any jurisdiction, the legality, validity and enforceability of the remainder of this Policy in that jurisdiction shall not be affected, and the legality, validity and enforceability of the whole of this Policy in any other jurisdiction shall not be affected.
Nothing in this Policy shall be construed as Starboard providing an indemnity to any Customer in relation to any Customer Data or use thereof. Starboard expressly excludes liability or any losses which the Customer may suffer on account of Starboard’s collection, storage or use of Customer Data in accordance with this Policy. In any event, Starboard expressly excludes any liability to the Customer which are in the nature of indirect or consequential losses, special losses, loss of profits, loss of contracts, loss of reputation or goodwill, or other tangential or intangible losses that a Customer may suffer on account of a breach of this Policy by Starboard or any of its agents or service providers.
16. Minors’ Information
We also prioritise the protection of minors. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity.
Starboard does not knowingly collect any personal data from minors under the age of 18. If you think that a minor provided this kind of information on the Starboard Website, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.
17. Contacting our Data Protection Officer