INTRODUCTION
MFSG Pte. Ltd., a company incorporated in Singapore with its registered address at 60 Paya Lebar Road, #13-27 Singapore 409051 ("MFSG", "we", "us" or "our"), respects the privacy of visitors to our website at [www.mfsg-tech.com] and its sub-pages (the "Website"), including employees of our customers and suppliers and other third parties ("you"). We are the data controller in respect of the personal data described in this Privacy Policy and are responsible for its use, processing and protection. The collection, use and disclosure of your personal data is subject to the Personal Data Protection Act 2012 of Singapore ("PDPA"), and this Privacy Policy explains what personal data we collect, how and why we collect it, with whom we share it, the period for which we retain it, and the rights you have in relation to it.
If you have any question about this Privacy Policy, or if you wish to exercise any of your rights, please contact us using the details in Section 12.
1. COLLECTION AND USE OF YOUR PERSONAL DATA
1.1 What personal data we collect
We may collect the following categories of personal data about you:
• Contact and identity information: your name, company name, position, title, email address, telephone number and country or region.
• Business and enquiry information: the content of your comments, suggestions or enquiries, records of your appointment requests, and records of your participation in our online and offline activities.
• Technical and usage information: IP address, device and browser type and version, operating system, the pages you visit, the date and time of your visit, the referring URL, and information about how you interact with the content on the Website (see Section 5).
• Investor and marketing information: your subscription to our marketing materials and your communication preferences.
You are not obliged to provide us with personal data. However, if you choose not to provide it in certain cases, we may be unable to provide you with the relevant products or services, respond to your enquiries, or resolve the problems you encounter.
1.2 How we collect your personal data
We collect your personal data in the following ways:
• Directly from you, when you contact us to provide comments, suggestions or enquiries, make an appointment to conduct investor research on MFSG, register for or attend our online and offline activities, or subscribe to our marketing materials.
• Automatically, through cookies and similar technologies when you use the Website (see Section 5).
• Indirectly, from your employer, from our customers, suppliers, business partners or event organisers, or from publicly available sources and professional networking platforms. Where we obtain your personal data indirectly, we will notify you of the purposes for which we intend to collect, use and disclose it, or take such other steps as are required by applicable law.
1.3 Purposes for which we use your personal data
We collect and use your personal data only for the following purposes, and we do not use it for purposes that are incompatible with those set out below.
• To respond to your comments, suggestions and enquiries, and to provide the services or functions you request.
• To improve the user experience and to personalise the Website and our services.
• To evaluate and analyse markets, customers, products and services (including by conducting customer surveys), so that we can improve and develop our products and services.
• To maintain the security of the Website and to provide customer support.
• To send you marketing communications, subject to Section 10.
• To comply with any applicable law, regulation, legal process or enforceable governmental request.
• For any other purpose that we specifically disclose to you at the time of collection and for which we obtain your consent.
1.4 Legal bases for our processing
We process your personal data on the following legal bases, depending on the jurisdiction in which you are located: your consent; performance of a contract; compliance with a legal obligation; our legitimate interests in operating, securing and improving our business (which we will not rely on for sending direct marketing messages); and the other exceptions permitted under applicable law. The legal bases that apply specifically to your jurisdiction are set out in the Annexes below.
2. SHARING AND DISCLOSURE OF PERSONAL DATA
We do not sell your personal data. We may disclose your personal data only in the circumstances set out in this Section 2.
2.1 Our affiliates
We may share your personal data with our affiliates so that they can respond to your request, provide our services, or for the general business purposes described in Section 1.3.
2.2 Service providers
We may disclose your personal data to third-party service providers, contractors and agents that process it on our behalf, including website hosting and backend service providers, analytics providers and email delivery providers.
2.3 Legal and regulatory disclosure
We may disclose your personal data where we have a good-faith belief that such access, use, preservation or disclosure is reasonably necessary to meet any applicable law, regulation, legal process or enforceable governmental request.
2.4 Business transfers
If MFSG is involved in a reorganisation, merger, acquisition, sale of assets or liquidation, we will continue to ensure the confidentiality of your personal data, and we will notify affected users before their personal data is transferred or becomes subject to a different privacy policy.
2.5 No sale of personal data
We do not sell, rent or trade your personal data to any third party.
3. MANAGING, REVIEWING OR UPDATING YOUR INFORMATION
You may at any time manage, review and update the personal data we hold about you by contacting us using the details in Section 12. We rely on you to keep your information accurate and up to date, and we will take reasonable steps to ensure that the personal data we hold is accurate and complete.
4. EXPORTING, REMOVING OR DELETING YOUR INFORMATION
To the extent required by applicable law, you may request a copy of the personal data you have provided to us, or request that we remove or delete it, by contacting us using the details in Section 12. In some cases we retain personal data for limited periods where it needs to be kept for legitimate business or legal purposes, or to be protected from accidental or malicious deletion; there may therefore be a delay between your deletion request and the deletion of copies from our active and backup systems.
5. COOKIES AND SIMILAR TECHNOLOGIES
A cookie is a small text file that often includes an anonymous unique identifier. When your browser loads a website, the website sends information to the browser, which creates a text file; each time you return to the same website, the browser retrieves and sends that file to the website's server. We use cookies, web beacons and similar technologies to collect information about your use of the Website and to store your online preferences.
Except for cookies that are strictly necessary for the Website to function and to provide basic functions and services, we only set cookies after you have given your consent through our cookie banner, and you may accept, reject or customise non-essential cookies by category at any time. You can also withdraw your consent at any time through the "Cookie Settings" link on the Website, or by clearing cookies through your browser settings.
6. PROTECTING INFORMATION
6.1 Security measures
We have adopted reasonable technical, administrative and physical security measures to ensure the integrity and accuracy of your personal data and to prevent its damage, loss, alteration, destruction or unauthorised use, access or processing. Only personnel authorised by us who are bound by corresponding confidentiality obligations may process your personal data, and they are prohibited from allowing access by unauthorised persons or from using your personal data for purposes other than those described in this Privacy Policy. Those confidentiality obligations subsist even after the termination of their relationship with us. However, no data transmission over the internet is completely secure, and we cannot guarantee that the processing of your personal data will be entirely free from any of the foregoing.
6.2 International transfers of personal data
We will not transfer your personal data outside Singapore except in accordance with the PDPA. Where we do so, we will ensure, by contractual clauses, binding corporate rules, or other legally recognised mechanisms, that the recipient is bound to provide a standard of protection for your personal data that is comparable to that required under the PDPA. Our business processes extend beyond the borders of a single country, and your personal data may therefore be transferred to, and processed in, countries or regions other than the one in which you are located.
6.3 Data breach notification
Where we have credible grounds to believe that a data breach has occurred, we will assess whether it is a notifiable breach within 30 calendar days (or such shorter period as may be required by law). Where the breach is notifiable, we will notify the Personal Data Protection Commission of Singapore within 3 calendar days of making that assessment, and we will notify affected individuals as soon as practicable where the breach is likely to result in significant harm to them or is of a significant scale.
7. CHILDREN’S POLICY
We do not knowingly collect or solicit personal data from children below the age prescribed by applicable law. If you are below that age, you must obtain the prior consent of your parent or guardian before using our services. If we become aware that we have collected personal data from a child without the required consent, we will delete such information from our records without undue delay.
8. THIRD-PARTY WEBSITES AND SERVICES
This Privacy Policy applies to all services provided by MFSG in connection with the Website, and does not apply to products and services that have a separate privacy policy which does not incorporate this Privacy Policy. The Website may contain content, links to, or services provided by third parties (including MFSG’s affiliates). You may choose whether to access such content or links, or to use such third-party products or services. We do not control the products or services provided by third parties, and we cannot control any of your personal data held by them. Any information protection issues arising from your use of third-party products or services are not governed by this Privacy Policy, and this Privacy Policy does not apply to any information you choose to provide to third parties.
9. YOUR RIGHTS RELATING TO YOUR PERSONAL DATA
To the extent provided by applicable law, you have the following rights in relation to your personal data:
• The right of access to your personal data.
• The right to have your personal data corrected where it is incomplete or inaccurate.
• The right to data portability, that is, to receive your personal data in a structured, commonly used and machine-readable format and to transmit it to another controller.
• The right to the deletion or restriction of the processing of your personal data.
• The right to object to our processing of your personal data, for example where we process it for direct marketing purposes.
Where we have asked for your consent, you may withdraw it at any time with future effect, without affecting the lawfulness of the processing carried out on the basis of that consent before you withdrew it. Please note that, depending on the circumstances, we may not be able to continue to provide you with certain products or services after you withdraw your consent.
The exercise of these rights is free of charge and may be carried out by e-mail or by post using the contact details in Section 12. If a request is manifestly unfounded or excessive, in particular because of its repetitive character, we may charge a reasonable fee or refuse to comply with it. We may request specific information from you to help us confirm your identity before we comply with a request concerning one of your rights.
We will respond to your request without undue delay and in any event within the period prescribed by applicable law. If we are unable to comply with your request, we will inform you of the reasons why, subject to any legal or regulatory restrictions. These rights are not absolute and may be limited in some situations, for example where we are legally required or permitted to retain your personal data, or where making the information available to you would reveal personal data about another person.
10. MARKETING AND DO NOT CALL
We will obtain your consent before sending you marketing communications where such consent is required by law. You may withdraw your consent, or unsubscribe, at any time by using the unsubscribe link in our messages or by contacting us. We will not rely on the legitimate interests exception under the PDPA to send you direct marketing messages.
Where we send marketing messages to Singapore telephone numbers, we will check the Do Not Call Registry before doing so, and our commercial electronic messages will comply with the Spam Control Act 2007, including as to sender identification and the unsubscribe facility.
11. DATA RETENTION
We will retain your personal data for as long as is necessary to carry out the purposes set out in this Privacy Policy, and for such further period as is necessary to comply with legal obligations, settle disputes and enforce agreements. The retention period may vary depending on the scenario, the service and the category of personal data. The criteria we use to determine the retention period are as follows:
• The period required to retain the personal data in order to fulfil business purposes, including the provision of services.
• The period required to maintain corresponding transaction and business records.
• The period required to control and improve the performance and quality of our products and services.
• The period required to ensure the security of our systems, products and services.
• The period required to handle possible user queries or complaints and to locate problems.
• Whether you have agreed to a longer retention period, and whether any law, contract or other equivalent instrument imposes specific requirements as to data retention.
Where we no longer need to retain your personal data for any business or legal purpose, we will delete it or de-identify it.
12. CONTACT US
The data controller for your personal data is MFSG Pte. Ltd.. If you have any question about this Privacy Policy, or if you wish to contact us for any reason in relation to our processing of personal data, please contact us at:
• By e-mail: info@mfsg-tech.com
ANNEX A – EEA / UK SPECIFIC TERMS
A1. Controller and representative. The data controller for your personal data is MFSG Pte. Ltd.. Our representative in the European Union for the purposes of Article 27 of the GDPR is MeetFuture Europe GmbH. Our contact details for privacy matters are set out in Section 12.
A2. Legal bases. We process your personal data on the following legal bases:
• On the basis of our legitimate interests in conducting and improving our business, in particular: to respond to any comments or complaints you send us; to monitor, improve and protect the Website; to personalise the Website and our services for you; to investigate complaints about the Website; and to use your data in connection with legal claims, compliance, regulatory and investigative purposes. Where we rely on our legitimate interests, we have carried out a balancing test and you may object to such processing at any time.
• On the basis of your consent, including to provide you with information about MFSG or promotional details about services that may be of interest to you, and to place cookies and similar technologies in accordance with Section 5.
• Where processing is necessary for compliance with a legal obligation to which we are subject, such as responding to requests by government or law enforcement authorities conducting an investigation, or complying with the requirements of applicable law or any court order.
A3. Your rights. In addition to the rights in Section 9, you have the right to lodge a complaint with a supervisory authority, in particular in the member state of your habitual residence, place of work or place of the alleged infringement, or with the Information Commissioner’s Office in the United Kingdom.
A4. International transfers. Where we transfer your personal data outside the EEA or the United Kingdom to a country that is not subject to an adequacy decision by the European Commission, or that is not considered adequate under applicable data protection laws, we rely on the European Commission approved Standard Contractual Clauses. For transfers out of the United Kingdom, we rely on the United Kingdom International Data Transfer Agreement or the United Kingdom Addendum to the EU Standard Contractual Clauses. We will also implement such further organisational, contractual and technical supplementary measures as may be necessary. The same mechanisms apply to transfers to other entities in our group, including in China. You may request a copy of the relevant safeguards by contacting us using the details in Section 12.
ANNEX B– CALIFORNIA SPECIFIC TERMS
B1. Application. This Annex applies to you if you are a California resident and we are a business to which the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (together, the "CCPA"), applies. If the CCPA does not apply to us, this Annex is provided for information only.
B2. Categories of personal information we collect. We may have collected the following categories of personal information from users within the last twelve (12) months:
• A. Identifiers: real name, online identifier, IP address, email address, telephone number, or other similar identifiers.
• B. Personal information categories listed in the California Customer Records statute.
• C. Professional or employment-related information, including work email, company name and type, job role and industry.
• D. Commercial information, including your browsing history.
• E. Internet or other electronic network activity information, including your interactions within the Website, and information about the devices and computers you use to access the Website.
• F. Inferences drawn from any of the above categories.
B3. Sources of personal information. We obtain the categories of personal information listed above from the following categories of sources:
• Information and data directly provided by you on the Website.
• Information automatically collected through cookies and similar technologies, including from analytics providers.
• Information received from our affiliates, service providers, business partners and publicly available sources.
B4. Disclosure, sale and sharing of personal information. In the preceding twelve (12) months, we have disclosed the following categories of personal information to the following categories of third parties for business purposes. We have not sold or shared personal information, and we do not sell or share the personal information of consumers we know to be under 16 years of age.
Category of personal information | Category of recipients | Business purpose for disclosure | Sold or shared |
Identifiers; Internet or other electronic network activity information; Geolocation data | Data analytics providers; website hosting and IT service providers | Website traffic analysis; security monitoring; responding to enquiries | No |
Identifiers; Professional or employment-related information | Email delivery providers; our affiliates | Sending marketing communications; responding to enquiries | No |
B5. Your California privacy rights. You have the following rights:
• The right to know the categories and specific pieces of personal information we have collected about you, the categories of sources, our business or commercial purposes, and the categories of third parties to whom we disclose it.
• The right to delete the personal information we have collected from you, subject to certain exceptions.
• The right not to be discriminated against for exercising any of your rights under the CCPA.
B6. How to exercise your rights. You may exercise your rights to know, delete or correct by e-mailing info@mfsg-tech.com . You may only submit a request to know twice within a 12-month period. Your request must provide sufficient information to allow us to reasonably verify your identity or authority, and must describe your request with sufficient detail. We confirm receipt within ten (10) business days and respond substantively within forty-five (45) days, which we may extend by a further forty-five (45) days where necessary. We do not charge a fee unless a request is excessive, repetitive or manifestly unfounded.
B7. Shine the Light. California’s "Shine the Light" law (Civil Code section 1798.83) permits users who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please e-mail info@mfsg-tech.com.
ANNEX C – CHINA SPECIFIC TERMS
C1. Application. This Annex applies where we process the personal information of individuals in the People’s Republic of China for the purpose of providing products or services to, or analysing the activities of, individuals in the PRC. If this does not apply to us, this Annex is provided for information only.
C2. Legal bases and separate consent. We process personal information on the bases permitted under the Personal Information Protection Law of the PRC, and we will obtain your separate consent where required, including for the transfer of your personal information outside the PRC, and for the processing of sensitive personal information.
C3. Cross-border transfer. Where we transfer personal information out of the PRC, we will rely on the relevant mechanism under Article 38 of the Personal Information Protection Law, which may include filing of the standard contract with the competent authority, personal information protection certification, or a security assessment, and we will rely on an applicable exemption where the Provisions on Promoting and Regulating Cross-Border Data Flows permit us to do so.
C4. Your rights and contact. You may exercise your rights of access, copying, correction, deletion, and the transfer of your personal information, and withdraw your consent, by contacting us using the details in Section.