Impart Ltd. (“We” or “Impart”) respects and values the privacy of our clients, partners, donors, volunteers, and potential employees. We are committed to protecting the Personal Data that you provide to us. Please read our Personal Data Protection Privacy Policy (“Policy”) carefully to understand how we collect, use, and disclose your Personal Data. 

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Application of Policy

This Policy is based on the Singapore Personal Data Protection Act 2012 ("PDPA") and the “Proposed Advisory Guideline for the Social Services Sector” (11th September 2014) by the Personal Data Protection Commission (PDPC). By providing your Personal Data to Impart, you agree to the terms of this Policy. 

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Use of Personal Data Collected

Depending on your relationship with Impart (whether as a client, employee, volunteers, employment candidates, etc), we may use your personal data for the following purposes: 
 

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

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

3. Maintaining contact with you; 

4. Managing your relationship with us; 

5. Human Resource and recruitment purposes; 

6. Managing donations, sponsorship & volunteerism; 

7. Complying with any applicable laws, codes of practice, or to assist in law enforcement and investigations conducted by any regulatory authority; 

8. Any reasonable purposes permitted by applicable law; and/or 

9. Any other purposes which Impart may inform you in writing from time to time, but for which Impart will seek your separate consent. 

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Disclosure of Personal Data 

For Non-Clients (partners, donors, volunteers and potential employees) 

Impart will keep your personal data confidential and will not disclose to any related or unrelated third parties, unless otherwise required or permitted by law. 
 

For Clients 

Impart is committed to keeping your personal data confidential. However, depending on the nature of the client engagement, there may be situations in which Impart discloses your personal data to the government, law enforcement authorities or any other related third party (eg. another government agency or VWO) when: 
 

1. It is necessary in the interest of the individual (such as referral for external services or application of schemes administered by public agencies); 

2. Indication and assessment of harm and risk to self or others, where disclosure is necessary to ensure safety and protection of life;  

3. It is used for evaluative purposes (approval of grant for social and financial assistance, the delivery of appropriate health services under any scheme administered by a public agency; 

4. The disclosure is required by law; or is necessary for any investigations or proceedings; and/or 

5. The disclosure is permitted under any of the statutory exemptions under the PDPA. 
    

Impart will keep your personal data confidential and will not disclose to any related or unrelated third parties, unless otherwise required or permitted by law. 

 

Withdrawal of Consent 

If you do not wish for us to use or disclose your Personal Data for any of the above purposes, you may withdraw your consent at any time by contacting us at . 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. Depending on the circumstances and the nature of your withdrawal, the withdrawal of your consent may result in us being unable to provide, or continue to provide our services to you and/or your family member. 
 

Please note that withdrawing consent does not affect our right to continue to collect, use and disclose Personal Data where such collection, use and disclosure without consent is permitted or required by law. 

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Access and Correction of Personal Data 

You should ensure that all Personal Data provided to us is complete, true and accurate. Failure to do so may result in our inability to provide or continue to provide our services to you and/or your family. 
 

If you wish to access, update or otherwise change or remove any information that you have provided to us, please contact us at . We reserve the right to verify your identity before handing over the data or correcting the data as requested. 

 

Protection of Personal Data

Impart has implemented reasonable measures to protect personal data against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. 
 

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. 

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Retention

Impart only retains Personal Data for as long as the retention is required for the purposes for which we collected the Personal Data, the purposes described in this Policy and for our business and legal purposes. In general, we do not retain Personal Data for a period of longer than five years after the original purposes for which the Personal Data was collected have ceased to be applicable, unless otherwise required by law or other mandatory directions by court or government authorities or for purposes of legal proceedings or other similar proceedings or investigations. 

 

Transfer of Personal Data Overseas 

Impart does not generally transfer any personal data of Clients and Non-Clients outside of Singapore, unless otherwise required or permitted by law. 

 

Changes to Policy 

Impart reserves the right to modify or change this Policy at any time. The amended Policy will be uploaded on our website accordingly. Please refer to our website from time to time for any changes and/or updates to our Policy. 

 

Contact Us 

If you have further questions or wish to contact us regarding this Policy, please do not hesitate to contact us at pdpa@impart.sg