This Data Protection Notice (“Notice”) sets out the basis upon which Maxwell Corporate Solutions (“Maxwell Corporate Solutions”) may collect, use, disclose or otherwise process personal data of our customers in accordance with the Personal Data Protection Act (“PDPA”). This Policy will provide you with a notice and overview on how your personal data is collected, intended to be used, transferred to, stored, and accessed. It also covers how we amend and protect your data provided to us.

Here at Maxwell Corporate Solutions, we take just as much pride in providing you with data protection. We will continuously update and review our adherence to changes in the PDPA as well as the steps taken to provide security and protection to your data.

PERSONAL DATA

As used in this Policy:

“customer” means an individual who (a) has contacted us through any means to find out more about any courses or services we provide, or (b) may, or has, entered into a contract with us for the supply of any courses or services by us; and

“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.

Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include name, residential address, email address, telephone number, nationality, gender, date of birth, marital status, employment information, and financial information.

Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context so permits).

COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA

We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall 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).

We may collect and use your personal data for any or all of the following purposes:

  • Performing obligations in the course of or in connection with our provision of the services requested by you;

  • Verifying your identity;

  • Responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;

  • Managing your relationship with us;

  • Processing payment or credit transactions;

  • 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;

  • Any other purposes for which you have provided the information;

  • Transmitting to any unaffiliated third parties including our third-party service providers, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes;

  • Any other incidental business purposes related to or in connection with the above; and

  • Offerings of new services that may continue to provide benefit in relation to the services requested by you or recommended by us;

  • Providing you with regular or ad-hoc updates, information required for your services update, upgrade, enhancement and their respective applications;

  • Processing of insurance applications meant for the coverage and safety during the delivery of our respective services;

  • Submission and application for funding and certification processes to professional bodies;

  • Website visitor traffic and informatics via cookies stored on our website https://stjohn.org.sg/.

We may disclose your personal data:

  • Where such disclosure is required for performing obligations in the course of or in connection with our provision of the courses and services requested by you;

  • To third-party service providers and other organisations we have engaged to perform any of the functions with reference to the above-mentioned purposes; or

  • 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.

The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) 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 a contract with you).

WITHDRAWING YOUR CONSENT

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 collecting, 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 below.

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 fourteen (14) business days of receiving it.

While 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 courses 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 above.

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.

ACCESS TO AND CORRECTION OF PERSONAL DATA

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.

Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.

We will respond to your request as soon as reasonably possible. In general, our response will be within seven (7) business days. Should we not be able to respond to your request within fourteen (14) days after receiving your request, we will inform you in writing within fourteen (14) 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).

PROTECTION OF PERSONAL DATA

To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal, or similar risks, we have introduced appropriate administrative, physical, and technical measures such as authentication and access controls (such as good password practices, need-to-basis for data disclosure, etc.), encryption of data, up-to-date antivirus protection, regular patching of operating systems and other software, securely erasing storage media in devices before disposal, web security measures against risks, usage of one-time password (OTP)/2-factor authentication (2FA)/multi-factor authentication (MFA) to secure access, security review and testing performed regularly, credential exposure checks, and device vulnerability assessments and security hardening.

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.

ACCURACY OF PERSONAL DATA

We generally rely on personal data provided by you (or your authorised representative). 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.

REQUIREMENT OF REASONABLE EFFORT

  • We will make reasonable efforts to ensure that personal data collected is accurate and complete, if such data is likely to be used to make a decision that affects the individual, or is likely to be disclosed to another organization.

  • Reasonable efforts refer to appropriate processes/controls considering the impact on individuals, practicalities, costs and the nature of the data.

ENSURING ACCURACY WHEN PERSONAL DATA IS PROVIDED DIRECTLY BY THE INDIVIDUAL

  • When individuals provide personal data directly to us, we will take reasonable steps to confirm the accuracy at the point of collection. This may include verification calls, documentation checks, etc.

  • We will also provide opportunities for individuals to update their data if there changes through our website

ENSURING ACCURACY WHEN COLLECTING PERSONAL DATA FROM A THIRD-PARTY SOURCE

  • When collecting personal data about individuals from third party sources, reasonable steps will be taken to verify the accuracy of the data.

  • Consent will be obtained from individuals before collecting their personal data from other sources where appropriate.

  • The accuracy of data purchased from external sources will be formally assessed before use.

ACCURACY OF DERIVED PERSONAL DATA

  • Reasonable verification processes will be implemented to ensure accuracy of any personal data derived or calculated from other data through analytical methods.

  • Automated verification checks will be performed for derived data where feasible. Accuracy of derived data will be formally assessed periodically.

  • Individuals have the right to challenge the accuracy of derived data related to them which will be investigated and corrected as appropriate on a case by case basis.

RETENTION OF PERSONAL DATA

We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.
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 and is no longer necessary for legal or business purposes.

TRANSFER OF PERSONAL DATA OUTSIDE OF SINGAPORE

We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and we will 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.

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, in the following manner:

Name of DPO: Josh Lam
Contact No. : 62277175
Email Address: dpo@jplwong.com.sg

EFFECT OF POLICY AND CHANGES TO POLICY

This Policy applies in conjunction with any other Policies, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.

We may revise this Policy from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Policy was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.

WEBSITE

Our websites do contain cookies. These cookies improve the overall experience you have visiting our site and provide us with informatics on how we can better serve you and improve your user experience.

We retain the copyrights to the material including logo, photographs and content found on these sites. No part of these websites may be copied, performed in public, utilized and/or adapted without our written consent.

MARKETING

We may use your Personal Information, such as your name, email address, telephone number, etc. ourselves or by using our third party subcontractors for the purpose of providing you with promotional materials, concerning our services, which we believe may interest you.

Out of respect to your right to privacy we provide you within such marketing materials with means to decline receiving further marketing offers from us. If you unsubscribe we will remove your email address or telephone number from our marketing distribution lists.

Please note that even if you have unsubscribed from receiving marketing emails from us, we may send you other types of important e-mail communications without offering you the opportunity to opt out of receiving them. These may include customer service announcements or administrative notices.

UPDATES OR AMENDMENTS TO THIS PRIVACY POLICY

We reserve the right to periodically amend or revise the Privacy Policy; material changes will be effective immediately upon the display of the revised Privacy policy. The last revision will be reflected in the "Last modified" section. Your continued use of the Platform, following the notification of such amendments on our website, constitutes your acknowledgment and consent of such amendments to the Privacy Policy and your agreement to be bound by the terms of such amendments.

Effective date: 21/01/25

Last updated: 21/01/25

Maxwell Corporate Solutions Privacy Policy