Privacy Policy
EFFECTIVE AS OF 3 FEBRUARY 2022.
This Privacy Policy sets out the basis which Contour Ptd. Ltd. (“Contour”, “we”, “us ”, or “our”) collects, uses, discloses and otherwise processes the Personal Data of our customers in accordance with the PDPA. This Privacy Policy applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.
1. INTERPRETATION
1.1. In this Privacy Policy, the terms below have the following meaning:
1.1.1. “customer”, "you" or "your" means an individual or entity who: (a) has entered into a contract with us for the supply of goods or services by us, including existing Members of the Contour Network; (b) has contacted us through any means or accessed our Website to find out more about any goods or services we provide; or (c) been contacted directly or indirectly by us in relation to any sales, marketing or commercial opportunities;
1.1.2. “Data Intermediary” means a third party organisation which processes personal data on behalf of Contour but does not include an employee of Contour;
1.1.3. “PDPA” means the Personal Data Protection Act 2012 of Singapore;
1.1.4. “Personal Data” means data, whether true or not, about a customer 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; and
1.1.5. “Website” means Contour’s website, accessible at https://contour.network.
1.2. Other capitalised terms used in this Privacy Policy shall have the meanings given to them in the Membership Agreement and the PDPA (where the context so permits).
2. Compliance with PDPA
Contour shall comply with all of its obligations under the PDPA at its own cost.
3. COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
3.1. We may collect Personal Data from you through: (a) your use of the Contour Application and/or Licensed Software; (b) the contact forms on our Website; and (c) when you communicate with us (either by email, telephone, in writing, via our Website, or in person), provided that you have been notified of the purposes for which the data is collected and provided consent to such collection and usage for those purposes. In certain circumstances, we may also collect and use your Personal Data without consent where permitted or required by the PDPA or other laws. The types of Personal Data we collect may include your name, email address, company name, and role.
3.2. We will seek your consent before collecting any additional Personal Data and before using your Personal Data for a purpose which has not been notified to you (except where permitted or authorised by law).
3.3. We may collect, process, and use your Personal Data for any or all of the following purposes:
3.3.1. performing obligations in the course of, or in connection with, our provision of the goods and/or services requested by you, including Members who have signed up to the Membership Agreement;
3.3.2. verifying your identity;
3.3.3. responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
3.3.4. managing your relationship with us, including in relation to any potential or future sales, marketing and commercial opportunities with you;
3.3.5. sending you marketing information about our goods or services including notifying you of our marketing events, referral arrangements, initiatives and promotions, and membership schemes;
3.3.6. if you provide us with your contacts’ information, we may process this information to facilitate invitations to our referral programs on your behalf;
3.3.7. complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
3.3.8. any other purposes for which you have provided the information;
3.3.9. transmitting to any unaffiliated third parties including our third party service providers, data intermediaries and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
3.3.10. any other incidental business purposes related to or in connection with the above.
3.4. We may disclose your Personal Data:
3.4.1. where such disclosure is required for performing obligations in the course of, or in connection with, our provision of the goods or services requested by you, including Members who have signed up to the Membership Agreement;
3.4.1. with your prior written consent; or
3.4.2. to third party service providers, data intermediaries, agents and other organisations we have engaged to perform any of the functions listed in clause 3.3 for us.
3.5. The purposes listed in clauses 3.3 and 3.4 may continue to apply even in situations where your relationship with us has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under any contract with you).
4. WITHDRAWING YOUR CONSENT
4.1. The consent that you provide for the collection, use and disclosure of your Personal Data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop using and/or disclosing your Personal Data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided in clause 11.
4.2. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.
4.3. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing in the manner described in clause 4.1 above.
4.4. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.
5. ACCESS TO AND CORRECTION OF PERSONAL DATA
5.1. If you wish to make: (a) an access request for access to a copy of the Personal Data which we hold about you or information about the ways in which we use or disclose your Personal Data; or (b) a correction request to correct or update any of your Personal Data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.
5.2. We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).
6. PROTECTION OF PERSONAL DATA
6.1. To safeguard your Personal Data from unauthorised or accidental access, collection, use, disclosure, copying, modification, disposal or similar risks, we have implemented various technical and organisational measures (including, where appropriate, physical, administrative, procedural and information & communications technology measures) such as: (a) up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of Personal Data by us; and (b) disclosing Personal Data both internally and to our authorised third party service providers and agents only on a need-to-know basis. For current Members of the Contour Network, a more detailed description of these technical and organisational measures is set out in the Support Handbook.
6.2. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.
7. ACCURACY OF PERSONAL DATA
Before you provide any Personal Data to Contour, you shall make a reasonable effort to ensure that such Personal Data is accurate and complete. We shall put in place adequate measures to ensure that Personal Data in our possession or control remains or is otherwise accurate and complete. In order to ensure that your Personal Data is current, complete and accurate, please update us if there are changes to your Personal Data by informing our Data Protection Officer in writing or via email at the contact details provided below.
8. RETENTION OF PERSONAL DATA
8.1. We may retain your Personal Data for as long as it is necessary to fulfil the purpose for which it was collected (e.g. to provide the services to you under our Membership Agreement), or as required or permitted by applicable laws.
8.2. We will cease to retain your Personal Data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the Personal Data was collected (e.g. to provide the services to you under our Membership Agreement), and is no longer necessary for legal or business purposes.
9. TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
9.1. In some circumstances, we may transfer your Personal Data to Data Intermediaries located outside of Singapore in order to process Personal Data on your behalf.
9.2. With the primary exception of clause 9.1, we generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will:
9.2.1. take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA; and
9.2.2. remain responsible for such Data Intermediary's compliance with the obligations of this Privacy Policy and for any acts or omissions of such Data Intermediary that causes Contour to breach any of its obligations under this Privacy Policy.
9.3. A full list of the Data Intermediaries currently engaged by Contour and their locations are available here.
10. Notification of breach
We will as soon as reasonably practicable notify you if Contour becomes aware of any breach of our obligations in clauses 3 to 9 of this Privacy Policy.
11. DATA PROTECTION OFFICER
You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, at the following email address: legal@contour.network
12. CHANGES TO NOTICE
We may revise and update this Privacy Policy from time to time, in our sole discretion, without any prior notice to you. All such changes to the Privacy Policy are effective immediately when posted to the Website and apply immediately to our customers thereafter. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.
