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Chord X Pte. Ltd. (“the Company”, “we”, “our” or “us”), is committed to safeguarding the privacy of our customers and users (you/your) who visit our website (our Website). This privacy policy (the Privacy Policy) sets out the ways in which we collect your personal data, the purposes for which we use it and the instances where we share it with other individuals and organisations.
If you are an existing customer or vendor of ours, or a representative of an existing customer of ours, further details about how we use your personal data are set out in your/your employer’s customer contract with us. We may provide further notices to you at the point we collect your personal data, which will highlight any further information relating to our use of that personal data and, where applicable, provide you with the ability to opt-in or out of selected uses.
This Privacy Policy is intended to explain our privacy practices and covers the following areas:
If you are based in the European Economic Area during your interactions with us (other than solely for travel purposes), the laws in those countries require us to provide you with additional information about our processing activities. We have included this information in ANNEX A.
We will collect and process all or some of the following personal data about you:
Information you provide to us : personal data that you provide to us, such as when using the contact form on our website, including your name, email address, other contact details;
Information you provide when applying for a role at Chord X: if you apply for a role at Chord X through the Website, we may collect, where permitted by law and appropriate, your CV or résumé and contact details. We may also undertake criminal records or financial probity checks or other independent searches to assess your suitability for the position where permitted by, and in accordance with, applicable laws;
Our correspondence : if you contact us, we will typically keep a record of that correspondence;
Your feedback : we may ask you for feedback from time to time, that we use to help us to improve our service; and
Website and communication usage : details of your visits to our Website and information collected through cookies and other tracking technologies including, but not limited to, your IP address and domain name, your browser version and operating system, information about your device, traffic data, location data, weblogs and other communication data, and the resources that you access.
In this section, we set out the purposes for which we use personal data described above:
To communicate effectively with you and conduct our business : to conduct our business, including to respond to your queries, to otherwise communicate with you, or to carry out our obligations arising from any agreements entered into between you and us;
To assess your application for a role at Chord X : to assess your application prior to entering into an employment contract with us and pursuant to laws to which Chord X is subject (e.g. in relation to equal opportunities). This processing is a necessary pre-condition of entering into any future contract with you and for Chord X to fulfil its employment duties with respect to other employees and you yourself (should you be employed by Chord X). If you are unable to provide us with the information we request for this purpose, we may be unable to assess your appropriateness for the job applied for or to communicate with you.
To provide you with marketing materials : to provide you with updates and offers, where you have chosen to receive these. We may also use your information for marketing our own products and services to you by post, email, and phone and, where required by law, we will ask for your consent at the time we collect your data to conduct any of these types of marketing. We will provide an option to unsubscribe or opt-out of further communication on any electronic marketing communication sent to you or you may opt-out by contacting us as set out in the “Contacting Us” section below.
For research and development purposes: to analyse your personal data in order to better understand your and our other clients’ business and marketing requirements, to better understand our business and develop our products and services;
To monitor certain activities : to monitor queries and transactions to ensure service quality, compliance with procedures and to combat fraud;
To inform you of changes : to notify you about changes to our services and products;
To ensure website content is relevant : to ensure that content from our websites is presented in the most effective manner for you and for your device, which may include passing your data to business partners, suppliers and/or service providers;
To re-organise or make changes to our business : in the event that we: (i) are subject to negotiations for the sale of our business or part thereof to a third party; (ii) are sold to a third party; or (iii) undergo a re-organisation, we may need to transfer some or all of your personal data to the relevant third party (or its advisors) as part of any due diligence process for the purpose of analysing any proposed sale or re-organisation. We may also need to transfer your personal data to that re-organised entity or third party after the sale or re-organisation for them to use for the same purposes as set out in this policy.
In connection with legal or regulatory obligations : We may process your personal data to comply with our regulatory requirements or dialogue with regulators as applicable which may include disclosing your personal data to third parties, the court service and/or regulators or law enforcement agencies in connection with enquiries, proceedings or investigations by such parties anywhere in the world or where compelled to do so. Where permitted, we will generally direct any such request to you or notify you before responding unless to do so would prejudice the prevention or detection of a crime.
Transmission, storage and security of your personal data
We may disclose personal data for the purposes we explain in this notice to service providers, contractors, agents, advisors (e.g. legal, financial, business or other advisors) that perform activities on our behalf and to other third parties in connection with our legal and regulatory obligations (as described above).
Our Website may contain links to other third-party websites. If you follow a link to any of those third-party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your personal data. Please check these policies before you submit any personal data to such third-party websites.
Export to other countries
Your personal data may be accessed by staff or suppliers in, transferred to, and/or stored at, a destination outside the country in which you are located, whose data protection laws may be of a lower standard than those in your country. We will, in all circumstances, safeguard personal data as set out in this Privacy Policy.
Storage limits
Our retention periods for personal data are based on business needs and legal requirements. We retain personal data for as long as is necessary for the processing purpose(s) for which the information was collected, and any other permissible, related purpose. For example, we may retain certain transaction details and correspondence until the time limit for claims arising from the transaction has expired, or to comply with regulatory requirements regarding the retention of such data. When personal data is no longer needed, we either irreversibly anonymise the data (and we may further retain and use the anonymised information) or securely destroy the data.
Marketing
You have the right to ask us not to process your personal data for marketing purposes. We will inform you if we intend to use your information for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by not checking certain boxes on the forms we use to collect your personal data. You can also exercise the right at any time by contacting us as set out in the “Contacting Us” section below.
Updating information
We will use reasonable endeavours to ensure that your personal data is accurate. In order to assist us with this, you may notify us of any changes to the personal data that you have provided to us by contacting us as set out in the “Contacting Us” section below.
Contacting us
If you have any questions in relation to this policy, please contact us at futurewith@chordx.co.
Changes to our Privacy Policy
We may change the content of our Website and how we use your personal data from time to time consequently we may update our Privacy Policy in the future. If we change this Privacy Policy, we will update the date it was last changed below. If these changes are material, we will indicate this clearly on our Website.
This Appendix applies if you are based in the European Economic Area (the EEA) during your interactions with us (other than solely for travel purposes).
It sets out the additional information that we are required to provide you under European data protection law (EU DP Law), including information about rights that you have in relation to your personal information that we handle.
Why we collect your data, and whom we disclose it to
Under EU DP Law, we are required to inform you of the “lawful bases” on which we rely to process your personal information. Below we set out the “lawful bases” that we use as the basis for our use of your personal information for each of the purposes mentioned in section 3 of the main Privacy Policy. You can find an explanation of each of the grounds relied on below:
EU USE BASES TABLE
USE BASE
These are the principal legal grounds that justify our use of your information:
Consent: where you have consented to our use of your information (you will have been presented with consent language in relation to any such use and may withdraw your consent by contacting us as set out in the Contacting Us section of the main Privacy Policy).
Contract performance: where your information is necessary to enter into or perform our contract with you.
Legal obligation: where we need to use your information to comply with our legal obligations.
Legitimate interests: where we use your information to achieve a legitimate interest and our reasons for using it outweigh any prejudice to your data protection rights.
Legal claims: where your information is necessary for us to defend, prosecute or make a claim against you, us or a third party.
Export outside the EEA
Your personal data may be accessed by staff or suppliers in, transferred to, and/or stored at, a destination outside the country in which you are located, whose data protection laws may be of a lower standard than those in your country. We will, in all circumstances, safeguard personal data as set out in this Privacy Policy.
Where we transfer personal data from inside the European Economic Area (the EEA) to outside the EEA, we may be required to take specific additional measures to safeguard the relevant personal data. Certain countries outside the EEA have been approved by the European Commission as providing essentially equivalent protections to EEA data protection laws and therefore no additional safeguards are required to export personal data to these jurisdictions. In countries which have not had these approvals (see the full list here http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm), we will establish legal grounds justifying such transfer, such as EU Commission-approved model contractual clauses, or other legal grounds permitted by applicable legal requirements.
Please contact us as set out in the “Contacting Us” section of the main Privacy Policy below if you would like to see a copy of the specific safeguards applied to the export of your personal data.
Your additional rights
If you have any questions in relation to our use of your personal data, you should first contact us as per the “Contacting Us” section below. Under EU DP Law, you may have the following additional rights in relation to your personal information to those set out in the main Privacy Policy. Under certain conditions, you may have the right to require us to:
provide you with further details on the use we make of your information;
provide you with a copy of information that you have provided to us;
update any inaccuracies in the personal data we hold (please see paragraph 2 of the main Privacy Policy);
delete any personal data we no longer have a lawful ground to use;
where processing is based on consent, to withdraw your consent so that we stop that particular processing (see paragraph 1 of the main Privacy Policy in relation to marketing);
to ask us to transmit the personal data you have provided to us and we still hold about you to a third party electronically;
object to any processing based on the legitimate interests ground unless our reasons for undertaking that processing outweigh any prejudice to your data protection rights; and
restrict how we use your information whilst a complaint is being investigated.
Your exercise of these rights is subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege). If you exercise any of these rights we will check your entitlement and respond in most cases within a month.
If you are not satisfied with our use of your personal information or our response to any exercise of these rights you have the right to complain to the Information Commissioner’s Office or the data protection regulator in your country.
CONTACT US
If you have queries about any part of this EU Appendix, please contact: futurewith@chordx.co
If after contacting us you do not feel that we have adequately addressed your concerns, you may contact the data protection regulator in your country (listed here: http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080).
Last Updated: 3 February 2020
Chord X views seriously any unauthorised access (whether malicious or otherwise), alteration or modification of its website and/or the contents therein and will not hesitate to initiate and pursue appropriate legal action (civil or criminal) under the applicable laws.
If you have any questions or comments about the use of this website or your dealings with this website, you can contact: futurewith@chordx.co
Last Updated: 14 January 2020
