This Data Protection and Privacy Notice (“Notice”) sets out how Will Field Family Office Pte. Ltd. (“we”, “us” or “our”) may collect, use, disclose or otherwise process personal data in accordance with the Personal Data Protection Act 2012 of Singapore (“PDPA”).
This Notice applies to customers and prospective customers, individuals who contact us with enquiries or in connection with our goods or services, and persons who apply for employment with us (“job applicants”). It applies to personal data in our possession or under our control, including personal data held by organisations engaged to process personal data on our behalf.
In this Notice, “personal data” means data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which we have or are likely to have access. Other terms have the meanings given to them in the PDPA, where the context permits.
Depending on the nature of your interaction with us, we may collect your name, email address and other contact details that you provide, together with information you provide in connection with an enquiry, request or transaction.
Depending on the nature of your application, we may collect:
We generally collect personal data that you knowingly and voluntarily provide to us directly, or through a third party duly authorised by you to disclose it to us (“authorised representative”), which may include a job placement agent. We will notify you or your authorised representative of the purposes of collection, use and disclosure and obtain your consent, unless consent is deemed to have been given, or collection, use or disclosure without consent is permitted or required under the PDPA or other applicable laws.
Before collecting additional personal data or using or disclosing your personal data for a new purpose that has not been notified to you, we will notify you of that purpose and obtain consent where required by applicable law.
We may collect, use and, where necessary, disclose your personal data for the following purposes:
We may collect, use and, where necessary, disclose your personal data for the following purposes:
We may disclose your personal data to third parties where necessary for the purposes set out in Section 4, including service providers engaged to support our operations or recruitment process, and parties involved in verifying information provided by job applicants. We may also disclose personal data where required or permitted under the PDPA or other applicable laws.
Where we engage an organisation to process personal data on our behalf, we will take reasonable steps to ensure that it protects the personal data and processes it for the purposes for which it has been engaged.
You may withdraw your consent to our collection, use or disclosure of your personal data for any or all purposes by giving reasonable notice in writing or by email to our Data Protection Officer at the contact details in Section 12.
We may require a reasonable period to process and give effect to your request, depending on its complexity and impact on your relationship with us. We aim to process and give effect to your request within five (5) business days of receiving it. If more time is required, we will inform you.
We will inform you of the likely consequences of withdrawing your consent. Depending on the nature and scope of your request, we may be unable to continue providing the goods or services requested by you or processing your job application. We will notify you of these consequences before giving effect to your withdrawal. If you wish to cancel your withdrawal request, please inform our Data Protection Officer in writing or by email.
Withdrawal of consent does not affect our right to collect, use or disclose personal data without consent where this is permitted or required by applicable law. Where your consent is withdrawn, we will cease, and cause our data intermediaries and agents to cease, the relevant collection, use or disclosure unless it is otherwise permitted or required by applicable law.
You may request access to personal data we hold about you, information about how we have used or disclosed that personal data within the year preceding your request, or correction of an error or omission in your personal data. Please submit your request in writing or by email to our Data Protection Officer.
We may take reasonable steps to verify your identity before processing your request. A reasonable fee may be charged for an access request; we will inform you of the fee before processing your request.
We will respond as soon as reasonably possible and aim to respond within five (5) business days. If we cannot respond to an access request within thirty (30) days of receiving it, we will inform you in writing within that period of the time by which we will respond. We will make corrections as soon as practicable in accordance with the PDPA.
Access and correction are subject to the exceptions and requirements in the PDPA. If we are unable to provide access or make a requested correction, we will generally inform you of the reasons, except where we are not required to do so under the PDPA. An access request does not necessarily entitle you to the entire document containing your personal data; we may provide the relevant personal data separately where appropriate.
We will make reasonable security arrangements to protect personal data in our possession or under our control from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, and the loss of any storage medium or device on which personal data is stored. These arrangements include appropriate administrative, physical and technical measures suited to the nature of the personal data and the risks involved.
No method of transmission over the Internet or electronic storage is completely secure. We review our information security measures and seek to improve them as appropriate.
We generally rely on personal data provided by you or your authorised representative. We will make reasonable efforts to ensure its accuracy and completeness where it is likely to be used to make a decision affecting you or disclosed to another organisation. Please inform our Data Protection Officer if your personal data changes or requires correction.
We may retain your personal data for as long as necessary to fulfil the purposes for which it was collected, or where retention is necessary for legal or business purposes. This applies to customer records and recruitment records, including records of unsuccessful applications.
We will cease to retain your personal data, or remove the means by which it can be associated with you, as soon as it is reasonable to assume that retention no longer serves the purpose for which it was collected and is no longer necessary for legal or business purposes.
Your personal data may be transferred to or processed in countries outside Singapore where necessary for the purposes described in this Notice, including through service providers or cloud-based systems used to support our operations or recruitment process.
Where we transfer personal data outside Singapore, we will comply with the applicable requirements of the PDPA and take appropriate steps to ensure that the transferred personal data receives a standard of protection at least comparable to that provided under the PDPA. These steps may include appropriate contractual obligations or other safeguards recognised under applicable law. We will obtain your consent where required.
For enquiries, feedback or complaints concerning our personal data protection policies and procedures, or to make a consent withdrawal, access or correction request, please contact:
This Notice applies together with any other notices, contractual clauses and consent clauses that apply to our collection, use and disclosure of your personal data. It covers the recruitment process; any employment-related processing following appointment may be addressed in separate employment notices or policies.
We may revise this Notice from time to time. The date at the beginning of this Notice indicates when it was last updated. We will make the updated Notice available and notify you of new purposes and obtain any additional consent where required by applicable law. Changes to this Notice do not, by themselves, constitute your consent to a new purpose for collecting, using or disclosing personal data.