The Nanofilm Group (as defined below in Section 1) is committed to safeguarding your Personal Data (as defined further below in Section 2).
Please check back regularly for updated information on the handling of your Personal Data.
Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us):
Please note that the data protection provisions of the PDPA do not apply to business contact information (“BCI”). BCI is defined in the PDPA as an
individual’s name, position name or title, business telephone number, business address, business electronic mail address or business fax number and any other similar information about the individual, not provided by the individual solely for his personal purposes.
Generally, we collect Personal Data in the following ways:
When you browse our website, you generally do so anonymously but please see the section below on cookies.
If you provide us with any Personal Data relating to a third party (e.g., information of your spouse, children, parents, and/or employees), by submitting such information to us, you represent to us that you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes.
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 the Products and Services you have requested, or delays in processing your applications.
Generally, Nanofilm Group is likely to collect, use, process and disclose your Personal Data for the following specific purposes on basis of the consent given (where applicable) for:
When we rely on such a legitimate and/or lawful interest as a basis, we will conduct an assessment and such interests include (but are not limited to):
In addition, Nanofilm Group collects, uses and discloses your Personal Data for the following purposes:
If you are a visitor to our properties or office premises:
Furthermore, where permitted under the PDPA, Nanofilm Group may also collect, use and disclose your Personal Data for the following “Nanofilm Group Additional Purposes”:
In addition, where permitted under the PDPA and subject to the provisions of any applicable law, your Personal Data may be disclosed, for Nanofilm Group Additional Purposes, to the vendors or other third-party service providers in connection with promotions and services offered by Nanofilm Group.
In relation to particular Products and 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/business development materials/communication. You may contact us using the contact details found below in Section 11.
Please be aware that once we receive confirmation that you wish to withdraw your consent for marketing/business development materials/communication, it may take up to 30 working days for your withdrawal to be reflected in our systems.
Therefore, you may still receive marketing/business development materials/communication during this period of time. Please note that even if you withdraw your consent for the receipt of marketing/business development
materials, we may still contact you for other purposes in relation to the Products and Services that you have requested from Nanofilm Group.
Nanofilm Group will take commercially reasonable steps to protect your Personal Data against unauthorised disclosure.
Subject to the provisions of any applicable law, your Personal Data may be disclosed, for the purposes listed above (where applicable), to the following entities or parties, whether they are located overseas or in Singapore:
Please note that the disclosures referred to above may be subject to additional legal requirements under applicable law, if we do disclose your Personal Data, we will only do so to the extent necessary, proportionate and legally permitted.
If you are a European Union (“EU”) resident, we are required, under the EU’s General Data Protection Regulation (EU) 2016/679 of 27 April 2016 (“GDPR”) on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Data Protection Directive 95/46/EC, to disclose the legal basis for processing your data.
We will only process your personal data when we have a legal basis to do so. The following are our legal bases for processing your personal data:
Please be informed that certain categories of personal data (such as information on your health) is considered “sensitive personal data” as defined under the GDPR.
Generally, we try to limit the circumstances where we would collect and process sensitive personal data.
If you are both an EU resident and a job applicant, please note that we may collect sensitive personal data, in particular, your medical details, your marital status and information on your spouse and next-of-kin, when you apply for a job with us.
When you interact with us on our websites, we automatically receive and record information on our server logs from your browser. We may employ cookies in order for our server to recognise a return visitor as a unique user including, without limitation, monitoring information relating to how a visitor arrives at the website, what kind of browser a visitor is on, what operating system a visitor is using, a visitor’s IP address, and a visitor’s click stream information and time stamp (for example, which pages they have viewed, the time the pages were accessed and the time spent per web page).
Cookies are small text files stored in your computing or other electronic devices which allow us to remember you. The cookies placed by our server are readable only by us. Cookies are not programs and therefore cannot access, read or modify any other data on an electronic device. All web-browsers offer the option to refuse any cookie, and if you refuse our cookie then we do not gather any information on that visitor.
Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser. You may also remove cookies stored from your computer or mobile device. However, if you do block cookies, you may not be able to use certain features and functions of our web sites or enter certain part(s) of our website.
If you have provided us with your Singapore telephone number(s) and have indicated that you consent to receiving marketing/business development materials/information via your Singapore telephone number(s), or where we are permitted to do so under the PDPA, then from time to time, we may contact you using such Singapore telephone number(s) (including via voice calls, text, fax or other means) you have provided to us with information about our Products and Services, and other marketing or promotional materials/communication even if these telephone number(s) are registered with the DNC Registry.
Nanofilm Group will take reasonable efforts to protect Personal Data in our possession or our control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. However, we cannot completely guarantee the security of any Personal Data we may have collected from or about you, or that for example no harmful code will enter our website (for example viruses, bugs, trojan horses, spyware or adware). You should be aware of the risks associated with using websites.
While we strive to protect your Personal Data, we cannot ensure the security of the information you transmit to us via the Internet, and we urge you to take every precaution to protect your Personal Data when you are on the internet.
Please inform us as soon as reasonably practicable if you know or suspect that someone else knows your Personal Data or believe the confidentiality of your Personal Data has been lost, stolen or compromised in any way or that actual or possible unauthorised transactions have taken place. We are not liable for any damages resulting from any security breaches, on unauthorised and/or fraudulent use of Personal Data.
If the transfer of your Personal Data within the Nanofilm Group is necessary, we will take reasonable steps to ensure that your Personal Data transmitted outside of your country of residence remains adequately protected to a standard similar to that afforded by the PDPA. In addition, we will ensure that such transfers comply with the requirements of the applicable data protection laws.
All Personal Data is retained for as long as it is necessary for the purposes it has been collected for in accordance with our data retention policy. Any third party who manages our personal data are also required to ensure that the Personal Data is disposed in accordance to the retention period as may be agreed in their respective engagement contract(s).
you can approach our Data Protection Officer (“DPO”) via the following channels:
Data Protection Officer
Email Address: DPO@nti-nanofilm.com
Address: 28 Ayer Rajah Crescent, #02-02/03, Singapore 139959
Please note that if your Personal Data has been provided to us by a third party (e.g., a referrer, or your company), you should contact that organisation or individual to make such queries, complaints, and access and correction requests to Nanofilm Group on your behalf.
If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, Nanofilm Group may not be in a position to continue to provide its Products and Services to you, administer any contractual relationship in place, which in turn may also result in the termination of any agreements with Nanofilm Group, and your being in breach of your contractual
obligations or undertakings. Nanofilm Group’s legal rights and remedies in such event are expressly reserved.
Please also note that while we will use reasonable efforts to provide, correct or delete our records of your Personal Data, we may be prevented by law from complying with your request. We may also decline your request if the law permits us to do so.
Please also be informed that we may charge you a reasonable fee to process an access request and in response to your access request. The purpose of the fee is to allow us to recover the incremental costs of responding to the access request. This may include the time and costs incurred to search for the personal data requested. If so, a written estimate of the fee would be provided to you. Where we intend to charge a fee higher than the original written estimate, we will inform you in writing of the increased fee. We may refuse to process or provide access to your Personal Data until you agree to pay the relevant fee.
The website of our company and its related corporation may contain links to other third-party operated websites operated by third parties over which we have no control over. We are not responsible for the privacy and/or data protection practices of such third-party operated websites that are linked to our websites.
Once you have left our website by clicking a relevant link, your use of that third- party website will be governed by the privacy or data protection policy of that website.
If you send us feedback, comments or suggestions, we may use your Personal Data in order to respond to you.
When we receive a complaint, we may have to disclose the complainant’s identity to whoever the complaint is about. If you are the complainant and you do not want us to disclose your identity to the party you are complaining about, you must let us know immediately. However, it may not always be possible to handle your complaint on the basis of anonymity.
We will retain your personal data for as long as we need to do so for business or legal purposes.