At SDCH Pte. Ltd. (hereinafter referred to as "we," "us," or "our") we respect the privacy and confidentiality of the personal data of our clients, associates, and others whom we interact with in the course of providing our services. We are committed to implementing policies, practices, and processes to safeguard the collection, use and disclosure of the personal data you provide us, in compliance with the Singapore Personal Data Protection Act (PDPA) 2012.

We have developed this Data Protection Notice to assist you in understanding how we collect, use, disclose, process, protect and retain your personal data that is in our possession.

Personal data refers to any information that can uniquely identify an individual person (a) on its own, or (b) when combined with other information. Under the PDPA, business contact information (e.g., full name, business address, business telephone number) is not considered as personal data so long as it is used strictly for business-to-business (B2B) transactions or Engagera Technology Platform Users.

We collect your personal data in the following scenarios.

Human Resources (HR)

• When you apply for job positions through our recruitment process, whether as an employee, volunteer, or contractor, 

• Through employer-provided sources, such as when your employer provides your details for insurance, training, or other employee benefits

Sales

• When you make payments, including via credit card, bank transfer, or other payment methods,

• When you request information, quotes, or customer service through our website’s contact forms or digital tools (e.g., chatbots),

• When you make inquiries about our products or services, through website forms, emails, or customer support channels

Marketing

• When you participate in our surveys, polls, or research activities, including any feedback or testimonials you provide,

• When you interact with us through social media platforms, by following our pages, liking our posts, or engaging in direct messages (DMs),

• When you leave reviews or comments about our services, products, or business through third-party review platforms or directly on our website

IT & Data Security

• When you visit our websites or interact with us through social media platforms or online forums

• When you use our mobile apps or digital services, and provide registration and ongoing data such as location, device information, or usage statistics

Legal & Compliance

• During the submission of corporate documents, personal information provided in the process of KYC (Know Your Customer) compliance, due diligence, or regulatory reporting,

• When you submit personal data as part of compliance with legal obligations (e.g., for tax purposes, statutory reporting, or regulatory filing),

• When you submit documents required for legal or regulatory purposes (e.g., copies of identification documents, contracts, or financial information)

Customer Support

• When you provide information to us through customer service or support requests via email, phone, chat, or other communication channels

Administration / Operations

• Stakeholder Engagement, Service Provider inclusive of Contractors

Other Scenarios

• When you provide us your business card at events, meetings, or networking sessions (meant for B2C purposes)

The types of personal data we collect about you include the following.

Employment and HR-Related Activities  

Personal Data collected for managing and administering employment relationships: Full Name, NRIC/FIN/Passport Number (Full or last four characters), Date of Birth, Nationality, Gender, Home Address, Phone Number (Mobile, Home), Job Title, Salary Information, Bank Account Details (for salary disbursement), CPF (Central Provident Fund) Details, Tax Information (e.g., tax residency, income tax records).

Provision and Usage of Our Products and Services  

Personal Data collected for the purpose of providing, improving, and facilitating customer interaction with our products and services: Personal Email Address, Phone Number (Mobile, Work, Home), Payment Information (e.g., credit card, debit card, bank details), Transaction History, Customer Service Requests and Correspondence, Surveys and Feedback Responses, , Cookies and Website Tracking Data, Device Information (e.g., type of device, operating system), Social Media Handles (if voluntarily shared), Membership or Subscription Information, Location Data (via online interactions or app usage), IP Address (for fraud prevention or security) There are other informations that Google Firebase analytics data as per link for analytics purpose only.

Visitor and Communication Management

Personal Data collected for security, communication, and interaction with digital platforms: Visitor Log Information (e.g., time of entry and exit, purpose of visit), Contact Information (e.g., phone number, email), Correspondence via Email, Social Media, or Chat Platforms.

We use the personal data you provide us for one or more of the following purposes.

Service Delivery and Management:

• Executing transactions and managing accounts, including processing payments, billing, subscriptions, and handling account receivables

• Providing customer support and assistance, including handling inquiries, complaints, and feedback

• Managing contracts and agreements between you and our organisation

Business Operations and Development:

• Carrying out surveys and collecting feedback for business improvements

• Performing internal audits, data analysis, and research to enhance our offerings

Marketing and Communications:

• Responding to inquiries, feedback, or requests to maintain high-quality service

Compliance and Legal Obligations:  

• Ensuring compliance with legal, regulatory, and fiscal obligations, which may include auditing and reporting functions

• Supporting law enforcement bodies or regulatory authorities as per the requirements under applicable laws

• Implementing and maintaining security measures, including monitoring to protect against fraud, unauthorised transactions, claims, and other liabilities

• Handling legal disputes, which may include resolving claims or controversies

Safety and Security:

• Protecting our digital platforms and services against unauthorized access or cyberattacks

Technical and Website Administration:

• Maintaining the integrity of our websites and IT systems, ensuring they operate effectively and efficiently,

• Managing and configuring information technology applications and web services, including system management and setup

Human Resources and Employment:

• Managing employment-related services such as payroll, benefits, and employee performance

• Developing and training employees through internal programs and performance review mechanisms

Product and Service Enhancement:

• Improving and customising our products and services based on user preferences and past interactions

• Developing new offerings, features, or enhancements to meet evolving customer needs

Stakeholder Engagement:  

• Communicating with stakeholders, including investors, partners, and local communities, to ensure transparent and effective engagement

We disclose some of the personal data you provide us to the following entities or organisations in order to fulfil our services to you.

Service Providers and Contractors:

• External Professional Service Providers (e.g., accountants, auditors, bookkeepers, tax advisors)

• Law Firms or Legal Advisors (for legal advice or dispute resolution)

• Consultants (e.g., business consultants, HR consultants, cybersecurity consultants)

IT, Data, and Communication Services:

• Cloud Service Providers (e.g., File Storage, etc)

• Email Service Providers 

• Data Backup and Recovery Services (e.g., third-party storage solutions)

• IT Infrastructure Providers (e.g., web hosting companies, data centers)

• Website, Mobile App, Infrastructure Maintenance and Development Contractors

Educational and Training Institutions:

• Training and Certification Partners (e.g., external trainers, certification bodies)

Financial Institutions and Payment Processors:

• Banks and Financial Institutions (e.g., for transaction processing)

• Payment Gateway Providers

Government Agencies and Regulators:

• Law Enforcement Agencies (for investigations, as required by law)

• Regulatory Bodies (e.g., Personal Data Protection Commission, Singapore Food Agency, etc)

• Tax Authorities (for compliance with tax regulations)

• Statutory Boards (e.g., for reporting requirements or compliance)

Recruitment and Human Resources:

• Background Screening Providers (e.g., for reference checks, criminal record checks)

Security and Risk Management Providers:

• Cybersecurity Service Providers (e.g., penetration testers, security consultants)

Research and Analytics Providers:

• Data Analytics Providers (e.g., for usage data, performance tracking)

Third-Party Platforms and Software:

• Customer Relationship Management (CRM) Systems

• Third-Party Vendors (who provide services related to your account or purchase)

• Advertising Networks (for targeted or programmatic advertising)

Where required to do so by law, we may disclose personal data about you to the relevant authorities or to law enforcement agencies.

6.1       Obtaining Consent

Before we collect, use, or disclose your personal data collected when registering and using the Engagera Technology Platform, we will notify you of the purpose why we are doing so. We will obtain documented confirmation from you on your expressed consent. We will not collect more personal data than is necessary for the stated purpose. We will seek fresh consent from you if the original purpose for the collection, use or disclosure of your personal data has changed.

Under certain circumstances, we may assume deemed consent from you when you voluntarily provide your personal data for the stated purpose, e.g., when you apply for a job with us by sending in your resume/CV containing personal information.

We may rely on exceptions to the need for consent under the PDPA for the collection, use or disclosure of your personal data under the following circumstances (only those relevant to us are included):

• the personal data is publicly available;

• the personal data is disclosed by a public agency or disclosed to a public agency;

• the personal data is necessary for any investigation or proceedings;

• the personal data is necessary for evaluative purposes (e.g., determining the suitability of a job applicant for the job applied for);

• the personal data is necessary for the purpose of managing or terminating an employment relationship; and

• the personal data is necessary for a business asset transaction.

6.2       Withdrawal of Consent

If you wish to withdraw consent, you should give us reasonable advance notice. We will advise you of the likely consequences of your withdrawal of consent, e.g., without your personal contact information we may not be able to inform you of future services offered by us.

Your request for withdrawal of consent can take the form of an email dpo@engagera.co or through the “Delete Account” feature in Engagera Technology Platform.

If you choose to “Unsubscribe via Google or Apple Subscription” your account with Engagera Technology Platform, your access to “Personal Productivity” (eg. Calendar, etc) subscription will be deactivated, it will be achieved but can be reactivated at any time upon subscription payment.

If you choose to “Delete Account” your account with Engagera Technology Platform, “Community Collaboration” User Content will be retained on the Site and App. “Personal Productivity” (eg. Calendar, etc) User Content will be deleted post a retention period of 30days to allow you to resubscribe with all the data intact. Profile email will be deleted post retention period. Please refer to User Contents for more details.

6.3       Use of Cookies

We use “cookies” to collect information about your online activity on our website. A cookie is a small text file created by the website that is stored in your computer to provide a way for the website to recognise you and keep track of your preferences.

The cookie makes it convenient for you such that you do not have to retype the same information again when you revisit the website or in filling electronic forms.

Most cookies we use are “session cookies”, which will be deleted automatically from the hard disk of your computer at the end of the session.

You may choose not to accept cookies by turning off this feature in your web browser. Note that by doing so, you may not be able to use some of the features and functions in our web applications.

Learn more about Cookies.

6.4       Third-Party Consent

We do not get consent on behalf of another individual. We only get consent from the individual who will be dealing directly with us.

We will take reasonable steps to ensure that the personal data we collect about you is accurate, complete, not misleading and kept up-to-date.

From time to time, we may do a data verification exercise for you to update us on any changes to the personal data we hold about you. If we are in an ongoing relationship with you, it is important that you update us of any changes to your personal data (such as a change in your mailing address).

We have implemented appropriate information security and technical measures to protect the personal data we hold about you against loss, misuse, destruction, unauthorised alteration/modification, access, disclosure, or similar risks.

We have also put in place reasonable and appropriate organisational measures to maintain the confidentiality and integrity of your personal data, and will only share your data with authorised persons on a ‘need to know’ basis.

When we engage third-party data processors to process personal data on our behalf, we will ensure that they provide sufficient guarantees to us to have implemented the necessary organisational and technical security measures, and have taken reasonable steps to comply with these measures.

We have a document retention policy that keeps track of the retention schedules of the personal data you provide us, in paper or electronic forms. We will not retain any of your personal data when it is no longer needed for any business or legal purposes.

We will dispose of or destroy such documents containing your personal data in a proper and secure manner when the retention limit is reached.

You may write to us (dpo@engagera.co) to find out how we have been using or disclosing your personal data over the past year. Before we accede to your request, we may need to complete an Access Request and Acknowledgement Form to verify your identity by checking your Engagera Technology Platform details and for sight validation purposes only we require your NRIC or other legal identification document. If you are authorising someone else to collect on your behalf, an Authorization Letter is required. We will respond to your request as soon as possible, or within 30 days from the date we receive your request. If we are unable to do so within 30 days, we will let you know and give you an estimate of how much longer we require. We may also charge you a reasonable fee for the cost involved in processing your access request.

All User registration to join the Engagera Technology Platform, will be able to access and maintain their personal data within their profile page. If you find that the personal data we hold about you is inaccurate, incomplete, misleading or not up-to-date, you may directly update or correct the data. Where certain personal data are not editable, you may write to us via email. Where we are satisfied on reasonable grounds that a correction should be made, we will correct the data as soon as possible, or within 30 days from the date we receive your request.

• Engagera Platform Digital Data Anonymization and Storage Notice: Due to the security built into our system. Your data has been anonymized and stored in a manner that prevents re-identification, thereby limiting our ability to retrieve your personal information. We will not be able to access your data, you will have to login to Engagera to access your personal data.

Where there is a need to transfer your personal data to another country outside Singapore, we will ensure that the standard of data protection in the recipient country is comparable to that of Singapore’s PDPA. If this is not so, we will enter into a contractual agreement with the receiving party to accord similar levels of data protection as those in Singapore.

In the unlikely event that we suffer a data breach pertaining to unauthorised access or disclosure of personal data being stored or processed by us, we will meet the PDPA's breach notification timelines and requirements to perform the needful, including but not limited to informing relevant authorities and affected individuals, based on the Significant Harm or Significant Scale definitions as set out by the PDPA.

If you have any query or feedback regarding this Notice, or any complaint you have relating to how we manage your personal data, you may contact our Data Protection Officer (DPO) at: dpo@engagera.co

Any query or complaint should include, at least, the following details:

• your full name and contact information; and

• A brief description of your query or complaint.

We treat such queries and feedback seriously and will deal with them confidentially and within a reasonable time.

We may update this Data Protection Notice from time to time. We will notify you of any changes by posting the latest Notice on our website. Please visit our website periodically to note any changes.

Changes to this Notice take effect when they are posted on our website.

DRAFT : Receive from DPO, review, and undergoing finalisation. (Start Date: 09 Sep 2024)

VERSION 1: Initial Release (Last Updated : 19 Nov 2024)