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Data Protection Policy

Your privacy is important to us. The purpose of this Data Protection Policy is to inform you of how Joy Management Services Pte Ltd (“JMS”) manages personal data in accordance with the Personal Data Protection Act 2012 (“the Act”).

By interacting with us, submitting information to us or signing up for any services offered by us, you agree and consent to JMS amassing and using your Personal Data, and disclosing such Personal Data to  authorised third party service providers in the manner set forth in this Privacy Policy.

JMS may from time to time update this Data Protection Policy to ensure that this Data Protection Policy is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements.

1. Your Personal Data
1.1 In this Data Protection Policy, “Personal Data” refers to any data or information about you from which you can be identified either (a) from that data; or (b) from that data and other information to which we have or are likely to have access.

Examples of such Personal Data which you may provide to us include:

(a) your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address and any other information relating to you which you have provided us in any forms you may have submitted to us, or in other forms of interaction with you;
(b) your employment history, education background, and income levels; and
(c) your payment-related information, such as your credit card details or bank account, and your credit history.
2 Collection of Personal Data
2.1 GenerallyJMS collects your Personal Data in the following manners:
(a) when you submit forms in respect of Know Your Client customer due diligence forms;
(b) when you leave your contact details via the JMS website for us to get in touch with you;
(c) when you interact with our staff;
(d) when you request that we contact you;
(e) when you respond to our request for additional Personal Data
(f) when we receive references from business partners/asosciates and third parties, for example, where you have been referred by them; and
(g) when you submit your Personal Data to us for any other reason other than those mentioned above.
2.2  If you provide us with any Personal Data relating to a third party (e.g. information of spouse, children, parents, employees and/or authorised representatives), by submitting such information to us, you represent to us that you have obtained the consent of the third party to you providing us with their Personal Data for the respective purposes.
2.3 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 services you have requested.
3 Purposes for the Collection, Use and Disclosure of Your Personal Data
3.1 Generally, JMS collects, uses and discloses your Personal Data for the following purposes:
(a) responding to your queries and requests and responding to complaints;
(b) business operations of JMS and complying with internal policies and procedures;
(c) matching any Personal Data held which relates to you for any of the purposes listed herein;
(d) verifying your identity as part of “Know Your Client” due diligence procedures;
(e) preventing, detecting and investigating crime, including fraud and money-laundering and terrorism financing, and analyzing and managing and mitigating other commercial risks;
(f) protecting and enforcing our contractual and legal obligations and rights;
(g) conducting audits, reviews and analysis of our internal processes, and managing commercial risks;
(h) preventing, detecting and investigating crime and managing the safety and security of our premises and services;
(i) compliance with any relevant rules, laws and regulations, codes of practice or guidelines or to assist in law enforcement and investigations by relevant authorities; and/or
(j) any other purpose relating to any of the above.
3.2 In addition, JMS may collect, use and disclose your Personal Data for the following purposes, depending on the nature of our relationship with you:
(a) If you submit an application to us as a candidate for employment or an internship:
(i) processing your application including pre-recruitment checks;
(ii) providing or obtaining employee references or other references where relevant for background screening/vetting;
(iii) collecting information about your suitability for the position applied for;
(iv) organising training and staff development programs;
(v) assessing your performance;
(vi) administrating benefits and payroll processing;
(vii) providing you with tools to facilitate or as required for you to do your job;
(ix) any other purposes relating to the aforesaid.
 3.3 In addition, where permitted under the Act, JMS may also collect, use and disclose your Personal Data for the following purposes:
(a) providing services;
(d) sending you details of services or special offers and rewards which may be of interest to you; and
(e) conducting market research
4 Disclosure of Personal Data
4.1  JMS will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, this Personal Data may be disclosed, for the purposes listed above (where applicable), to the following third parties, whether they are located overseas or in Singapore:
(a)  agents, contractors or third party service providers who provide operational services to JMS, such as accounting, tax, corporate secretarial , audit, training, market research and/or advisory;
(b)  anyone to whom we transfer or may transfer our rights and duties;
(c)  relevant government regulators or authority or law enforcement agency to comply with any laws or  rules and regulations imposed by any governmental authority; and
(d)  any other party to whom you authorise us to disclose your personal data
5 Third-Party Sites
5.1 Our website may contain links to other websites operated by third parties, such as our business partners and associates. We are not responsible for the privacy practices of websites operated by third parties that are linked to our website. We encourage you to learn about the privacy policies of such third party websites. Once you have left our website, you should check the applicable terms, conditions and policies of the third party website to determine how they will handle any information they collect from you.
6 Withdrawal, Access and Correction of your Personal Data
6.1 Should you wish to withdraw consent to use of your Personal Data or obtain access to or make amendments to your Personal Data records, please contact the Personal Data Protection Officer, contact details of which are found in the Personal Data Protection Statement or similar document elsewhere on the JMS website.
6.2 Please note that if your Personal Data has been provided to us by a third party, you should contact such party directly to make any queries, feedback, and access and correction requests to JMS on your behalf.
6.3 Please note that if you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, JMS may not be in a position to continue to provide its services to you or administer any contractual relationship in place, and this may also result in the termination of any agreements with JMS and your being in breach of your contractual obligations or undertakings, and JMS’s legal rights and remedies in such event are expressly reserved.
7 Governing Law
7.1 This Privacy Policy shall be governed in all respects by the laws of Singapore.