PRIVACY POLICY
In this Privacy Policy (‘Policy”), Bespin Global Singapore Pte. Ltd. (a subsidiary of Bespin Global Inc.) is referred to as “Bespin Global”, “we” or “us” (and the term “our” shall be interpreted accordingly). Bespin Global values your privacy and stands committed to protecting your Personal Data (as defined below).
We have adopted this Policy to safeguard the Personal Data of the users of our website (“User” and as further defined below), to protect their rights and interests and to address User complaints related to Personal Data in accordance with Applicable Laws.
This notice details our Privacy Policy. It tells you how Bespin Global may collect, disclose and use your Personal Data when you visit our website (www.bespinglobal.sg) or whenever you otherwise interact with us. It also explains your privacy rights and how the law protects you. If you wish to make any inquiries regarding this Privacy Policy, you should contact our Data Protection Officer in the manner specified in this Privacy Policy.
Bespin Global is related to other entities. In countries in which we do business, the privacy principles set out in this Privacy Policy are supplemented by more detailed privacy policies that reflect the requirement of those countries. We comply with data protection regulations in jurisdictions where we do business.
By interacting with us, submitting information to us, accessing our website or otherwise engaging in any services offered by us, you agree and consent to Bespin Global collecting, using and disclosing your Personal Data and disclosing such Personal Data to Bespin Global’s authorised service providers and relevant third parties in the manner set forth in this Privacy Policy.
A BRIEF OVERVIEW OF THIS POLICY & YOUR RIGHTS
- What does Bespin Global do with your information? Bespin Global uses your Personal Data to provide you with the most highly individualised services, to respond to your requests for information, to inform you of our products and services, and to carry out other purposes as set out in this Privacy Policy.
- Giving & withdrawing your consent: Where we rely on your consent, such as for marketing our products and services to you, the use of cookies, and the collection and use of your sensitive Personal Data, you may withdraw this consent at any time
- Cookies: Our site uses cookies to track visitors to our site as well as to analyse trends and usage patterns for internal research and marketing purposes. You are not obliged to accept cookies.
- Your rights: You have certain rights to your Personal Data under Applicable Laws, including a right to object to some of the processing which Bespin Global carries out.
KEY DEFINITIONS
- Applicable Data Protection Guidance means applicable data privacy advisory guidelines and codes of conduct issued by the relevant regulatory authorities that do not fall within the scope of Applicable Laws
- Applicable Law(s) means the PDPA and PDPR
- Data Protection Officer is the person within the organisation who is responsible for ensuring the organisation’s compliance with Applicable Laws and can be contacted at sea_legal@bespinglobal.com.
- Data Subject means an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identify of that natural person
- PDPC: Personal Data Protection Commission
- Personal Data means any data, whether true or not, about an individual who can be identified from that data or from that data and other information to which an organisation has or is likely to have access.
- Process means any operation that is carried out in respect of Personal Data, including but not limited to collecting, storing, using, disclosing, transferring or deleting Personal Data and to obtain, record, uses or hold Personal Data and includes organise, adapt or alter, use or consult, disclose by transmission or otherwise make the Personal Data available or destroy the Personal Data within the scope of Applicable Laws and Applicable Data Protection Guidance in respect of data protection.
- PDPA: Personal Data Protection Act 2012
- PDPR: Personal Data Protection Regulations 2021
PERSONAL DATA WE COLLECT FROM YOU AND/OR THIRD PARTIES
Bespin Global collects a variety of Personal Data about our customers and visitors to our website. We do this solely to operate effectively and to optimize your experiences with our services. The specific information collected will depend upon your interactions with Bespin Global’s corporate office, and the specific services you use. Examples of the Personal Data we collect include:
- Identity information (name, date of birth, gender, passport information or data from government-issued identity cards);
- Contact information (email address, mailing address, social media handles and phone number);
- Demographic data (age, gender, country of residence and preferred language);
- Copies of your correspondence if you contact us;
- Technical data about any device you use to interact with us (including the unique device identifier, hardware model, IP address, geolocation,
operating system and version); and - Information related to your use and interaction with our website.
USE OF YOUR PERSONAL DATA
Bespin Global collects your Personal Data to operate effectively and to provide you with the optimal experiences whenever you utilize our services. We use your Personal Data outlined above for a variety of reasons, including the following purposes and type of data:
Purpose/Activity Type of data
To register a User as a new customer
(a) Identity
(b) Contact
To process and deliver an order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
To manage our relationship with a User which will include:
(a) Notification(s) about changes to our terms or privacy policy
(b) Asking a User to leave a review or take a survey
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
To administer and protect our business and our websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
(a) Identity
(b) Contact
(c) Technical
To deliver relevant website content to Users and measure or understand the effectiveness of the content provided
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences
(a) Technical
(b) Usage
To make suggestions and recommendations to Users about goods or services that may be of interest
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications
The legal basis for processing your Personal Data is made up of one or more of the following reasons: (i) your consent, and/or (ii) providing the services you have requested, and/or (iii) compliance with Applicable Laws, regulations, court orders or other legal process.
We may also collect Personal Data about you from third parties and other sources such as:
- your nominated representatives (e.g. spouse or other professional advisors); and
- publicly available sources of information.
If you choose not to provide your Personal Data to us for the purposes set out in this Privacy Policy, we may not be able to provide you with the requested information, products or services or to effectively conduct our relationship with you.
Any marketing to customers can generally only be conducted on an “opt-in” basis by Bespin Global. Bespin Global is not permitted to send “specified messages” (in the form of voice calls, text or fax messages) to Singapore telephone numbers registered with the DNC Registry without the explicit written consent from users who agree to be contacted. For the purposes of this provision, “Specified message” refers to a message if at least one of the purposes of the messages is to sell, advertise or promote goods and services, this is a specified message under the DNC Provisions. Specified messages also include voice calls.
Some exceptions to specified messages include: (1) Informational messages e.g. to confirm or complete a transaction with an individual; (2) Notification messages e.g. notifications regarding a change of terms of a membership or subscription with an individual; and/or (3) Business to business messages. The Personal Data Protection (Exemption From Section 43) Order 2013 provides an exemption from checking the DNC Registry or obtaining clear and unambiguous consent to send a specified message, under certain conditions.
COOKIES AND OTHER DATA
A cookie is a small file of letters and numbers that our website uses to distinguish you from other users of our website. We use cookies and other tracking tools like web beacons and pixel tags to collect information from you as set forth above. If permitted by your device settings, we collect information when you use our website or any apps that we may make available on our website and we may also have third parties collect Personal Data this way as well. Data collected is used to personalize and enhance your online experience and to improve the effectiveness of our website, offers, communications and customer service. We also collect this data, or use third party analytics tools to measure traffic, to analyse usage trends and to better understand the demographics and behaviors of our site visitors.
Linking third party websites to this website is intended to optimise your user experience and does not indicate any association with or endorsement by Bespin Global. We do not assume responsibility or liability of any nature whatsoever for the activities conducted or information contained in the third party websites. To learn about the Personal Data practices of third parties, please visit their respective privacy notices.
DELETING OR DISABLING COOKIES
You may delete or disable cookies through your browser settings. However, you should keep in mind that deleting or disabling cookies may compromise the user experience of our website and erase information saved in your browser, including your account passwords, website preferences, and settings.
On the following links, you’ll find information about how to delete or disable cookies from your browser settings:
- Chrome
- Firefox
- Safari (iOS)
- Opera
- Edge
DOES BESPIN GLOBAL SHARE OR SELL YOUR PERSONAL DATA?
Bespin Global does not share your information without your consent except in accordance with this Privacy Policy, or for the purposes disclosed on any online form where you provide your Personal Data to us. Bespin Global does not engage in the sale of Personal Data.
As a global company that operates in various continents and with the global geographical diversity of our business, it is essential that we share information across multiple jurisdictions in order to provide you with and to maintain the best possible service. The specific kind of information we share depends upon the context of your interactions with Bespin Global, and the services you use. Accordingly, your Personal Data may be shared with the following parties insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy:
- to our trusted business partners to process it for us, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures;
- to our marketing and advertisement partners to provide you with more-relevant ads on our site and to optimise your experience on our site;
- to any third parties to the extent necessary with respect to a sale of all or part of our business operations or assets; or
- third parties that provide products and services to us or through us.
DOES BESPIN GLOBAL TRANSFER YOUR PERSONAL DATA OVERSEAS?
As global company and with the global geographical diversity of our business, it is essential that we share information across multiple jurisdictions in order to provide you with and to maintain the best possible service. By using and/or purchasing our goods and services, we may transfer your Personal Data across multiple jurisdictions. Accordingly, insofar as reasonably necessary for the purposes, and on the legal basis, set out in this policy, we may transfer and store your Personal Data:
- in or to Korea where our corporate office is located;
- in those countries in which we operate sales offices, including (but not confined to) Singapore, Vietnam, the People’s Republic of China, the United Arab Emirates and the United States.
- in such other countries where our third party service providers, advisors and consultants are located, which changes from time to time.
Such transfers may be to a country which may not provide the same level of privacy protection as that provided by the country in which the information was collected. However, we will take reasonable steps (including entering into data transfer agreements based on the European Commission model clauses) to ensure that while your Personal Data is within our control, we will handle your Personal Data using reasonable security and confidentiality procedures to keep your data secure and confidential.
WHAT DOES BESPIN GLOBAL DO TO KEEP YOUR DATA SECURE?
Bespin Global takes the appropriate security measures to keep your Personal Data safe. We implement reasonable administrative, organisational and technical safeguards and security measures to protect all Personal Data within our control from unauthorised access, acquisition, disclosure, destruction or alteration, accidental loss, misuse or damage.
Additionally, we make sure only those people with a genuine business need to know may access your data, including employees, outside contractors and other third parties. They may process your Personal Data only on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. We regularly review and monitor such safeguards and security measures.
No method of transmission over the Internet or 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.
We carry out the following technical, managerial, and physical measures to ensure safety.
- Performance of regular self-audits: We regularly conduct self-audits to ensure the secure processing of Personal Data.
- Minimization and training of employees that handle Personal Data: We implement measures to manage Personal Data by limiting and designating employees that handle Personal Data only to the extent necessary.
- Establishment and implementation of an internal management plan: We have established and implemented an internal management plan for the secure handling of Personal Data.
- Technical measures against hacking, etc.: We operate a security program, which is subject to regular updates and maintenance, in an externalaccess- controlled-area, technically and physically monitored to prevent leakage and damage of Personal Data by external sources (e.g. hacking, malware, computer virus, etc.)
- Encryption of Personal Data: The Personal Data of the User and passwords are stored and managed after encryption, such that they are only known to the User. Separate security features such as the file and transmission data encryption or use of file lock function may be used for some data.
- Retention and prevention of forgery and alternation of access logs: We maintain the logs of access to the Personal Data processing system for at least one year with a security function to prevent forgery, alteration, theft and loss of access logs.
- Restriction on access to Personal Data: We take necessary measures to control access to Personal Data through granting, modifying, and deleting access rights to the database system that handles Personal Data. We also control unauthorized external access by using a firewall system.
- Use of locks for document security: Documents and supplementary storage media containing Personal Data are kept in a safe place with a lock subject to access control procedures.
- Data Breach Management: When Bespin Global becomes aware of a potential or real data breach, it will make an immediate report to our Data Protection Officer who will in turn carry out an assessment whether any notification should be made to the PDPC and the affected individuals. HOW LONG WILL BESPIN GLOBAL KEEP YOUR INFORMATION?
To the extent permissible by Applicable Law, we will only keep your Personal Data for such period as necessary to satisfy or to fulfill the following
conditions:
- the purposes for which you provided that information,
- an identifiable and ongoing business need, including record keeping,
- a specific legal or regulatory requirement, and/or
- a requirement to retain records that may be relevant to any notified regulatory investigations or active legal proceedings.
Although the PDPA does not prescribe a specific retention period for Personal Data, where there is no longer sufficient justification to retain your Personal Data, such data will be safely and securely deleted, disposed of, anonymised and/or blocked.
In relation to your other Personal Data including registration data, we will not retain your data for longer than required for the purposes indicated above, and will delete Personal Data if they are no longer necessary for the purposes for which they are collected or otherwise processed, unless we are required to keep the data to comply with applicable legal obligations.
HOW CAN YOU OPT OUT OF OUR COMMUNICATIONS?
The choice is always yours. If you do not wish to remain on our database and to receive our personalised mailings (electronic or otherwise) or other communications, please note that you may opt out of our database by using the “Unsubscribe” option at the footer of our email communications, or by sending an email to sea_info@bespinglobal.com.
We will however keep a record of the fact that you have asked us not to send you direct marketing or to process your data.
YOUR RIGHTS
In accordance with other laws, which may be determined by your country, region or state of residency, you may have rights in relation to your Personal Data. Such rights include:
- the right to ask us for a copy of your Personal Data.
- to correct, delete or restrict any active processing of your Personal Data. Each user can request the correction of Personal Data to Bespin Global.
- to obtain the Personal Data you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share this data to another controller
- withdraw consent and request us to stop using your Personal Data for any or all of the purposes listed in this Privacy Policy. Under the PDPA, individuals have the right to withdraw their consent for the collection, use or disclosure of their Personal Data, provided that they first give reasonable advance notice of this withdrawal.
In addition, you may object to the processing of your Personal Data in some circumstances – in particular, where we do not have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing (see above “How Can You Opt Out?”).
Where we have received a request from you withdrawing your consent to the use and/or disclosure of your Personal Data for any or all of the purposes listed above, we will cease to use and/or disclose your Personal Data in accordance with your request within a reasonable time of receiving said request. 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.
These rights may be limited. For example, if fulfilling your request would reveal Personal Data about another person, would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Our legal rights and remedies in such event are expressly reserved. Relevant exemptions are included in applicable data protection laws. We will inform you of relevant exemptions we rely upon when responding to any request you make.
If you wish to exercise any of the rights set out above, please contact Bespin Global at sea_legal@bespinglobal.com. To protect your Personal Data, we may require that you prove your identity to us at the time your request is made. This may involve providing us with information which we hold on file about you (e.g. a home or business address), or we may require you to produce some form of photo or government issued identification.
CONTACT US
If you have any queries or complaints regarding this Privacy Policy or the use of your Personal Data, please contact us at sea_legal@bespinglobal.com and our Data Protection Officer will get in touch with you directly to address your concerns.
AMENDMENTS
This notice will be subject to change from time to time. The effective date of this current Privacy Policy is set out at the end of this document. Your use of this website constitutes your acceptance of the current terms as set out in this Privacy Policy.
OTHERS
Underlying all of the above legal terms and policy talk is our relationship with you, our visitor. To help us deliver the optimal Bespin Global experience to you, we suggest keeping your Personal Data current and accurate. If anything changes, please let us know. Thank you.
EFFECTIVE DATE: 1 November 2021