Website Privacy Policy

Thinking Notes Pte Ltd (referred to as “we” or “us” in this Privacy Policy) operates the website https://sbo.sg/ (this “Website”). We are committed to respecting and protecting your personal data collected through or in connection with this Website.
 
Introduction
We take our responsibilities under Singapore’s Personal Data Protection Act 2012 (the “PDPA”) seriously. We also recognise the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data.
 
This Privacy Policy is designed to assist you in understanding how we collect, use, disclose and/or process the personal data you have provided to us, as well as to assist you in making an informed decision before providing us with any of your personal data.
 
If you, at any time, have any queries on this policy or any other queries in relation to how we may manage, protect and/or process your personal data, please do not hesitate to contact our Data Protection Officer (the “DPO”) at the contact details below.
 
This Privacy Policy (together with our Website Terms of Use) sets out the basis on which we use and process any personal data we collect from you as a user of this Website. By accessing the Website you hereby agree to be bound by the terms of this Privacy Policy.
 
In addition, this Website may, from time to time, contain links to and from the websites of our partner networks, advertisers, affiliates or other third parties.  If you follow a link to any of these websites, please note that these websites have their own privacy policies. As these websites are not owned or operated by us, we do not accept any responsibility or liability for the contents of these websites and their privacy policies and you access and provide your personal data to these third party websites at your own risk.  Please check these policies before you submit any personal data to any such websites.
 
Personal data we collect
We may collect and process personal data about you such as:
 
  1. Personal data that you may provide when submitting or making available personal data to this Website. This includes but is not limited to any personal data provided when you contact us through our contact page such as your name, email address and contact details.
  2. Personal data that you provide to us when you submit a job application through our Website, which will include your photograph, name, contact details, academic and employment history and the contents of your resume and other documents that you submit to us as part of your job application.
  3. If you contact us for any reason, we may keep a record of that correspondence.
  4. Personal data that may be captured via any error logging and reporting tool that captures error report data and, at your option and with your consent, sends this data to us in order for us to be informed of any software errors or problems that may occur during your use of the Website or the services provided on it.
  5. Details of your visits to our Website, the activities you engage in when accessing the Website and the resources that you access on or via the Website.
Cookies
We use cookies on the Website. A cookie is a text file that a website transfers to your computer's hard disk so that the website can remember who you are. Cookies only record those areas of a website that have been visited by your computer and for how long.
You have the ability to accept or decline cookies by modifying the setting in your browser. If you would like to do this, please see the help menu of your browser. However, you may not be able to use all the interactive features of our Website if cookies are disabled.
 
How we use your personal data
We may use your personal data that we possess for the following purposes:
  1. To contact you through the contact information provided by you in order to provide you with information that you request from us.
  2. To manage and administer your use of the Website and contact you as may from time to time be necessary in connection with your use of the Website.
  3. To collect information relating to your online interactions with us (including, for example, your IP address and the pages you view) so that we can offer you a more consistent and personalised experience in your relationship with us and better serve your needs by customising the content that we share with you.
  4. To determine your suitability for a position with us, contacting you regarding your job application and, if applicable, your terms of employment or engagement (if you have submitted a job application through our Website);
  5. To store, host and/or back up (whether for disaster recovery or otherwise) your personal data, whether within or outside Singapore.
  6. For record-keeping purposes.
  7. To conduct research, analysis and development activities (including but not limited to data analytics, surveys and/or profiling) to improve our Website, services and facilities in order to enhance the services we provide to you, where you have consented to be contacted for such purposes.
  8. To responding to legal process, pursuing legal rights and remedies, defending litigation and managing any complaints or claims.
  9. To respond to requests for information from public and governmental/regulatory authorities, statutory boards, related companies and for audit, compliance, investigation and inspection purposes.
  10. To comply with any applicable law, regulation, legal process or government request.
Disclosure of your information
Your personal data may be used, disclosed, maintained, accessed, processed and/or transferred to the following third parties, whether sited in Singapore or outside of Singapore, for one or more of the purposes set out above:
  1. Our headquarters, subsidiaries and group companies.
  2. Third party service providers which require the processing of your data, for example, third party service providers which have been engaged by us: (i) to provide and maintain any IT equipment used to store and access your personal information; (ii) to host and maintain this Website; (iii) process any job applications made through our Website or (iv) otherwise in connection with the provision of certain services provided to you on or via this Website.
  3. Our auditors and legal advisors.
  4. Public and governmental/regulatory authorities, statutory boards, industry associations.
  5. Courts and other alternative dispute forums.
In certain circumstances, we may provide third parties (whether or not located in Singapore) with aggregate information about this Website's users. This may include information about your computer, including where available your IP address, operating system and browser type, for system administration and to report aggregate information to our advertisers. This is anonymised statistical data about our users' browsing actions and patterns, and does not identify any individual.
Your personal data may also be disclosed if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or in order to enforce or apply our Website Terms of Use; or to protect the rights, property, or safety of any person (including for example for the purposes of fraud detection and prevention).
Please rest assured that we never sell or rent your personal data.
 
Transfer of your personal data outside of Singapore
The personal data that we collect from you may be transferred to, used, processed and stored outside of Singapore for one or more of the purposes set out above. By submitting your personal data and/or using the Website, you agree and consent to such transfer, storing or processing.
We have entered into contractual undertakings to ensure that the personal data which we collect from you and transfer to our service providers (whether or not located in Singapore) is adequately protected.
We will take reasonable steps to maintain appropriate physical, technical and administrative security to help prevent loss, misuse, unauthorised access, disclosure or modification of your personal information.
 
Updating your information
Where you submit your personal data on the Website, you should try to ensure such personal data is accurate, and let us know if such personal data changes so that we are not holding any inaccurate personal data about you.
 
Your rights
You may withdraw your consent for us to collect, use, disclose and/or process your personal data for some or all of the purposes listed in this Privacy Policy.
You may request to access and/or correct the personal data currently in our possession by writing to the Data Protection Officer using the contact details provided below. Please note that we may charge you a reasonable fee for the handling and processing of your requests to access your personal data.
 
Changes to this privacy policy
We reserve the right to amend the terms of this Privacy Policy at our absolute discretion. Any amended Privacy Policy will be posted on our Website. You are expected to check this page from time to time to take notice of any changes we have made as they are binding on you. Your continued use of this Website and/or the services made available on or via the Website following any amendment of this Privacy Policy will signify your assent to and acceptance of its revised terms.
 
Further information about protection of personal data and the Personal Data Protection Act 2012
If you want to contact us with specific queries or concerns in relation to this Privacy Policy, or if you have any questions or complaints as to how your personal data is collected, used, disclosed and/or processed by us, please contact our Data Protection Officer at [email protected].