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QUANT LEGALTECH PERSONAL DATA POLICY
INTRODUCTION
This Personal Data Policy (referred to herein as the Personal Data Policy, the Privacy Policy or, the Policy) outlines how Quant LegalTech Pte. Ltd. and its subsidiaries and affiliates collect, use, maintain and disclose your Personal Data.
A reference to “Quant LegalTech” in this Policy includes reference to Quant LegalTech Pte. Ltd., Quant LegalTech India Pvt. Ltd. and any other affiliated entities that may be added from time to time.
Quant LegalTech Pte. Ltd. is incorporated in Singapore as a private limited company having a registered address at 20 Bendemeer Road, #03-12 BS Bendemeer Centre, Singapore 339914 (UEN201927299H). In this regard, it safeguards Personal Data in accordance with the Singapore Personal Data Protection Act (No. 26 of 2012) (“the Act”) and in the case of transactions in India and elsewhere, in accordance with the Act and applicable law.
For the avoidance of doubt, this Privacy Policy forms a part of the terms and conditions governing your relationship with us and should be read in conjunction with the Quant LegalTech Terms of Use Agreement and any applicable Subscription Agreement.
TYPES OF PERSONAL DATA
In this Privacy Policy, “Personal Data” refers to any 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 we have or are likely to have access, including data in our records as may be updated from time to time.
Examples of such Personal Data you may provide to us may include (depending on the nature of your interaction with us) your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address and any other information relating to any individuals which you have provided us in any forms you may have submitted to us, or via other forms of interaction with you. You may also provide us with Personal Data of your officers, employees, agents and customers in order for us to provide you with our products and services.
The Personal Data we collect can be either obligatory or voluntary. Obligatory Personal Data are those that we require in order to provide you with our products and services. If you do not provide us with obligatory Personal Data, we would not be able to provide you with our products and services. Voluntary Personal Data are those that are not mandatory in order for us to provide you with our products and services. If you do not provide us with voluntary Personal Data, you can still sign up for our products and services. Obligatory and voluntary Personal Data may differ for each products and service and will be indicated in the application forms.
Apart from Personal Data, we may collect other types of information which is not related to an individual and which is anonymous. For example, the number of website visitors and the number of website users using a particular service. In this way, we hope to improve our customer services.
CONSENT
When you request information or sign up for our products and services, you may be required to provide us with your Personal Data. In doing so, you agree and consent to Quant LegalTech as well as our respective agents, business partners, authorised service providers and relevant third parties collecting, using, disclosing and/or sharing your Personal Data in accordance with this Privacy Policy.
You have the choice, at any time, not to provide your Personal Data or to withdraw your consent to Quant LegalTech processing your Personal Data. However, such actions may impact Quant LegalTech’s ability to provide you with effective products and services.
If you should withdraw your consent to the processing or handling of your Personal Data in respect of any purpose which we may reasonably consider to be essential in order for us to provide you with the products and/or services requested / applied for, we may not be in a position to continue to provide our products or services to you or administer any contractual relationship which may be in place between us. Furthermore, we shall be entitled to treat such withdrawal as your termination of any account / agreement which you may have with us, without prejudice to any rights and remedies which we may have at law against you.
Notwithstanding the above, upon the termination or expiry of your contractual relationship with us we may still continue using or disclosing your Personal Data as may be necessary, required, authorised or permitted for compliance with applicable law or as may be requested by the relevant regulatory bodies, government agencies, statutory boards, administrative bodies, authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes to which we may be subject, whether situated locally or overseas.
In addition, there may be circumstances under applicable laws where we are permitted to collect, process and disclose your Personal Data without your consent.
HOW PERSONAL DATA IS COLLECTED
Generally, we obtain your Personal Data in various ways, such as:
PERSONAL DATA COLLECTED FROM OUR WEBSITE
IP Address
When you visit our website, your IP address is automatically logged in our server. We use your IP address to help diagnose problems with our server, and to administer our website. From your IP address, we may identify the general geographic area from which you are accessing our website however. Generally, we do not link your IP address to anything that can identify you unless it is required by applicable law or if there is a legitimate business purpose.
Cookies
We use cookies in some of our pages to store visitors’ preferences and record session information. The information that we collect is then used to ensure a more personalised service level for our users. You can adjust the settings on your browser so that you will be notified when you receive a cookie, or to disable the cookies associated with our website. Please note however that you may not be able to enter certain part(s) of our website, and some of the functions and services may not be able to function without cookies. This may also impact your user experience while on our website.
THE PURPOSE OF PROCESSING YOUR PERSONAL DATA
Generally, Quant LegalTech collects, uses and discloses your Personal Data for the following purposes:
In addition, where permitted under the terms of the agreement which you have entered into with us and as part of the services which we provide to you, we may from time to time and at our discretion also use your contact particulars (including your phone number and email address) to contact you in order to provide you with information and/or updates which you are entitled to receive in accordance with the terms and conditions of our agreement with you on products and services.
If you are an employee of an external service provider Quant LegalTech may also collect, use and discloses your Personal Data for the following purposes:
If you submit an application to us as a candidate for an employment or representative position, Quant LegalTech also collects, uses and discloses your Personal Data for the following purposes:
Where permitted under applicable law, Quant LegalTech may also collect, use and disclose your Personal Data as follows:
If you have provided your telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your Singapore telephone number(s), then from time to time, Quant LegalTech may contact you using such Singapore telephone number(s) (including via voice calls, text, WhatsApp, fax or other means) with information about our products and services (including discounts and special offers).
In relation to particular products or services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.
You have a choice to withdraw your consent for receiving marketing or promotional materials/communication.
Please be aware that once we receive confirmation that you wish to withdraw your consent for marketing or promotional materials/communication, we will require some time to process your withdrawal request. During this period of time you may still receive marketing or promotional materials/communication. Please note that even if you withdraw your consent for the receipt of marketing or promotional materials, we may still contact you for other purposes in relation to the accounts, facilities or services that you hold or have subscribed to with Quant LegalTech.
YOUR RIGHTS IN RELATION TO YOUR PERSONAL DATA
If you are not a resident in the EU, you may have certain rights in relation to the Personal Data we hold about you, which we detail below.
Access
You have the right to know whether we process Personal Data about you, and if we do, to access Personal Data we hold about you and certain information about how we use it and who we share it with.
In exceptional circumstances, Quant LegalTech reserves the right to deny you access to your Personal Data and may provide an explanation as required by applicable laws.
Exceptional circumstances include (to the extent allowable under applicable law) where:
Correction
You have the right to correct any Personal Data held about you that is inaccurate.
Feedback and Complaints
If you have any concerns, feedback or complaints about the use and/or sharing of your Personal Data, please feel free to contact us with your concerns.
Exercise of Rights
To exercise any of your rights, please contact us at info@quantlegaltech.com.
EU SUBJECTS’ RIGHTS IN RELATION TO PERSONAL DATA
If you are a resident in the EU or Switzerland, you may have certain rights in relation to the Personal Data we hold about you, which we detail below. Some of these only apply in certain circumstances as set out in more detail below. We also set out how to exercise those rights.
These rights include:
Please note that we will require you to provide us with proof of identity before responding to any requests to exercise your rights. We shall endeavour to respond to a request by you to exercise those rights without undue delay and at least within one month (although this may be extended by a further two months in certain circumstances). To exercise any of your rights, please contact us at info@quantlegaltech.com.
Complaints
If you wish to make a complaint about how we process your Personal Data, please contact us and we will endeavour to deal with your request as soon as possible. This is without prejudice to your right to launch a claim with your data protection authority.
Access
You have the right to know whether we process Personal Data about you, and if we do, to access Personal Data we hold about you and certain information about how we use it and who we share it with.
If you require more than one copy of the Personal Data we hold about you, we may charge an administration fee.
We may not provide you with certain Personal Data if providing it would interfere with another’s rights (e.g. where providing the Personal Data we hold about you would reveal information about another person) or where another exemption applies.
Portability
You have the right to receive a subset of the Personal Data we collect from you in a structured, commonly used and machine-readable format and a right to request that we transfer such Personal Data to another party.
The relevant subset of Personal Data is data that you provide us with your consent or for the purposes of performing our contract with you.
If you wish for us to transfer the Personal Data to another party, please ensure you provide details of that party and note that we can only do so where it is technically feasible. We are not responsible for the security of the Personal Data or its processing once received by the third party. We also may not provide you with certain Personal Data if providing it would interfere with another’s rights (e.g. where providing the Personal Data we hold about you would reveal information about another person).
Correction
You have the right to correct any Personal Data held about you that is inaccurate. Please note that while we assess whether the Personal Data we hold about you is inaccurate or incomplete, you may exercise your right to restrict our processing of the applicable data as described below.
To exercise any of your rights, please contact us at info@quantlegaltech.com.
Erasure
You may request that we erase the Personal Data we hold about you in the following circumstances:
Please also note that you may exercise your right to restrict our processing of the Personal Data whilst we consider your request as described below.
Please provide as much detail as possible on your reasons for the request to assist us in determining whether you have a valid basis for erasure. However, we may retain the Personal Data if there are valid grounds under law for us to do so (e.g., to comply with regulatory obligations in respect of anti-money laundering, counter terrorism financing and customer due diligence legislation and procedures, for the defence of legal claims or freedom of expression) but we will let you know if this is the case. Please note that after deleting the Personal Data, we may not be able to provide the same level of servicing to you as we will not be aware of your preferences.
To exercise any of your rights, please contact us at info@quantlegaltech.com.
Restriction of Processing to Storage Only
You have a right to require us to stop processing the Personal Data we hold about you other than for storage purposes in certain circumstances. Please note, however, that if we stop processing the Personal Data, we may use it again if there are valid grounds under data protection law for us to do so (e.g. to comply with regulatory obligations in respect of anti-money laundering, counter terrorism financing and customer due diligence legislation and procedures, for the defence of legal claims or for another’s protection).
You may request we stop processing and just store the Personal Data we hold about you where:
Objection
At any time, you have the right to object to our processing of Personal Data about you in order to send you promotions, special offers, marketing messages, including where we build profiles for such purposes and we will stop processing the Personal Data for that purpose.
You also have the right to object to our processing of Personal Data about you and we will consider your request in other circumstances as detailed below.
You may object where we are processing the Personal Data we hold about you (including where the processing is profiling) on the basis of our legitimate interest and you object to such processing.
Please provide us with a full explanation of your objection so that we can assess whether there is a compelling overriding interest in us continuing to process such data or we need to process it in relation to legal claims. Also note that you may exercise your right to request that we stop processing the Personal Data whilst we make the assessment on an overriding interest by indicating this when you contact us at info@quantlegaltech.com.
WHERE WE PROCESS AND STORE PERSONAL DATA
Personal Data will be transmitted to data storage facilities where Quant LegalTech keeps its central records. Personal Data will be transferred to Quant LegalTech’s offices and appointed agents, where appropriate, in Singapore, India and other locations around the world in connection with Quant LegalTech’s performance of the contract with you.
This means that Personal Data will be transferred to, and stored at, a destination outside of your country and outside the European Economic Area (“EEA”), and Switzerland, and in particular to Singapore, India and other locations where we have our own or third party data centers. This is premised on the basis that it is necessary for the performance of the contract of service between you and Quant LegalTech.
If you are an EU or Swiss resident, where we transfer Personal Data outside the EEA and Switzerland, this is done primarily on the basis that it is necessary for the performance of the contract of services between you and Quant LegalTech.
The Personal Data will also be processed by staff operating outside the EEA and Switzerland who work for us, for our suppliers or our business partners. Such staff are engaged in, among other things, the fulfilment of your order, the processing of your payment details and the provision of support services.
It should also be noted that where Quant LegalTech processes and stores Personal Data using blockchain technology and relevant distributed or decentralised storage facilities, it should be noted that Quant LegalTech will endeavour to protect your Personal Data in a similarly secure manner as that of a conventional storage facility.
DISCLOSURE OF YOUR PERSONAL DATA
Your Personal Data held by us shall be kept confidential. However, in order to provide you with effective and continuous products and services, and for the purposes listed above (where applicable), your Personal Data may be disclosed to the following parties:
In addition, to the extent that we may need to transfer Personal Data outside of Singapore or India, whether to our affiliates, related companies, business partners, authorized agents or third party service providers or simply to data storage facilities, we endeavour to do so in accordance with the Act and applicable law to ensure that we provide a standard of protection to personal data so transferred that is comparable to the protection under the Act.
HOW YOUR DATA IS PROTECTED
The security of your Personal Data is our priority. Quant LegalTech takes all physical, technical and organisational measures needed to safeguard Personal Data. We will use all reasonable efforts to protect your information in a highly secure data centre, adhering to strict computer security standards. However, you should be aware that the use of the Internet is not entirely secure and for this reason we cannot guarantee the security or integrity of any Personal Data which is transferred from you or to you via the Internet.
Access to Personal Data is only limited to authorised personnel of Quant LegalTech who are trained in handling your information. These authorised personnel are required to ensure the confidentiality of your information and to respect your privacy at all times and relevant employment/engagement contracts reflect this obligation.
Personnel who have access to your information will be subjected to disciplinary action should they fail to observe this Privacy Policy and other guidelines, codes or policies which we may issue to them from time to time.
If we disclose any of your Personal Data to our business partners, authorised agents or service providers, we will require them to appropriately safeguard the Personal Data provided to them.
RETENTION OF YOUR PERSONAL DATA
We will only retain your Personal Data for as long as necessary to fulfil the purpose(s) for which it was collected or to comply with legal, regulatory and internal requirements.
CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time to ensure that this Privacy Policy is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements. If there are material changes to this Privacy Policy, we will notify you by posting a notice of such changes on our website or by sending you a notification directly. Please periodically review this Privacy Policy to stay informed on how we are protecting and managing your information.
Subject to your rights at law, you agree to be bound by the prevailing terms of the Privacy Policy.
ACCURACY, ACCESS AND CORRECTION OF PERSONAL DATA
You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with products and services you have requested / applied for.
If there are any changes to your Personal Data or if you believe that the Personal Data we have about you is inaccurate, incomplete, misleading or not up-to-date, please contact us so that we may take steps to update your Personal Data.
You have the right to access your Personal Data. If you would like to request access to your Personal Data, please contact us. Please note that depending on the information requested we may charge a small fee. We may also take steps to verify your identity before fulfilling your request for access to your Personal Data. However, in exceptional circumstances, we reserve the right to deny you access to your Personal Data and may provide an explanation as required or unless permissible by applicable laws.
GOVERNING LAW
This Privacy Policy shall be interpreted and construed in accordance with Singapore law. However, we have also endeavoured to set out and comply with the main principles of EU GDPR. We do not otherwise represent or warrant that this Privacy Policy complies with the privacy laws of all other jurisdictions.
CONTACT
If you need to contact us or have any questions on this Privacy Policy, you may contact us at the address below referencing ‘Privacy Policy’: info@quantlegaltech.com.
GRIEVANCE OFFICER
In accordance with India’s Information Technology Act 2000 and rules made there under, the name and contact details of our Grievance Officer are provided below:
NAME | Quant LegalTech Pvt ltd |
ADDRESS | 25/2, 8th Floor, SN Towers MG Road BANGALORE Bangalore KA 560001 IN |
TEL | NA |
EMAIL: | sales@quantlegaltech.com |