Privacy Policy

Privacy Policy

CommSwift is committed to protecting your privacy and developing technology that gives you the most powerful and safe online experience. This policy how we may collect, use, disclose, process and manage your personal data and applies to all personal data that you provide to us and the personal data we hold about you. By providing us with your personal data, you consent to our collection, use, and disclosure (including transfer) of your personal data in accordance with this Policy. Please DO NOT provide us with any personal data if you do not accept this Policy.

PERSONAL DATA

– Definition of personal data : “Personal data” is data that can be used to identify a natural person. Examples of personal data include name, address, contact details, identification numbers, telephone numbers, email address and photographs. – Scope: This policy applies to all data in any form about an individual who can be identified from that data which are in our possession or under our control for the purposes of and in connection with our contractual duties and provision of our services. – Personal Data Ownership: Personal data of anyone other than yourself should be informed and consented of the purposes we are collecting by the data owner prior to disclosure of data to Commswift.

COLLECTION OF YOUR PERSONAL INFORMATION

A-Generally, we may collect your personal data when you: - Register for any of our product or services; - Use any of our product or services; - Submit any data or document to us for processing; - Report a problem with any of our platform or services; - Contact us whether through email, fax, telephone, or writing; - Attend our webinar ; and/or - Submit your personal data to us for any other reason. B-You have choices regarding our collection, use or disclosure of your personal information. You have the right to object to the processing of your personal information and withdraw your consent in a manner described in this statement. If you choose not to provide us with the personal information described in this statement, we may not be able to fulfil our contractual duties towards you or facilitate your request or provide the service to you.

PURPOSES FOR COLLECTION AND USE OF YOUR PERSONAL DATA

A-Service-related purposes - Generally, CommSwift may collect, use or disclose your personal data for the following service-related purposes: - To provide you with the product and services that you have requested. - To assist with your inquiries. - To keep you updated on our product and services. - To manage the relationship with us. B-Business purposes - Generally, CommSwift may use your personal data for the following business-related purposes: - Complying with our legal obligations and requirements. - Enforcing obligations owed to us. - Research into the development of new products and services or improvement of our existing products and services. - Accounting, risk management, and record keeping. - Carrying out research, planning, and statistical analysis. C-Marketing purposes - Generally, CommSwift uses your personal data for the following marketing-related purposes. - Sending you marketing messages through various modes including but not limited to electronic mail, direct mailers, telephone calls, and any other mobile messaging services. - CommSwift will only send marketing messages to your telephone number via SMS, telephone calls, other mobile messaging services, and numbers that are not registered with the Do not Call registry (DNC). Processing purposes – Generally, CommSwift may collect, use or disclose personal data as a data intermediary on behalf of another organization. In such cases, we will merely be processing the personal data collected from you on behalf of the organization. D-If we process personal data on your behalf and for your purposes as a data intermediary, we shall: - Observe the relevant obligations under the Act in the performance of our services. - Process the personal data we receive from you only to the extent necessary for the purposes specified in the engagement and in accordance with your instructions from time to time given in writing and shall not process the personal data for any other purpose. - Ensure that access to the personal data is limited to employees who need to access to meet our obligations to you. - Use reasonable degree of professional care to prevent unauthorized use, dissemination, or disclosure of personal data, and implement any generally applicable physical, technical and administrative measures to protect the personal data from accidental or unauthorized disclosure, alteration, loss or destruction. - Notify the customer (data controller) without undue delay upon discovering of any accidental or unauthorized disclosure, alteration, destruction or loss of personal data unless prohibited from doing so by law. - Take reasonable action within a reasonable time, investigate the security incident, use its best efforts to mitigate the impact and scope of any security incident, and carry out such recovery or other action we determine necessary in the circumstance to remedy the security incident. - Not hold personal data any longer than required by law for the purpose of performing or having performed the services or for legal or business purposes. E-In the same regard, if we process personal data on your behalf and for your purposes, you will: - Provide us with specific written instructions with regard to the processing of personal data. Oral instructions given by your authorized representatives will be accepted by us in case of emergency only and subject to immediate written confirmation. - Undertake and warrant that you have lawfully obtained personal data and have sufficient legal grounds, including all necessary authorizations, consents, or permissions to provide us with the personal data, and that the same is accurate and provided in any form, to us in a secured way. -Inform us immediately in writing of any change, including any error or omission, with regard to the lawful processing and use of any of the personal data. - Will inform us as soon as reasonably possible of any access request, request for correction or blocking or deletion of personal data, or any objection made related to the processing of the personal data.

DISCLOSURE OF YOUR PERSONAL DATA

-CommSwift does not sell, rent or lease its customer lists to third parties. -CommSwift may share data with trusted partners to help us perform statistical analysis, send you email or postal mail, provide customer support, or arrange for deliveries. All such third parties are prohibited from using your personal information except to provide these services to CommSwift, and they are required to maintain the confidentiality of your information. -CommSwift may collect, disclose or use your personal information pursuant to an exception under the Singapore Personal Data Protection Act (PDPA) or other written law such as during the following situations: a- To respond to an emergency that threatens our life, health and safety or of another individual; and b- Necessary in the national interest, for any investigation or proceedings.

PROTECTION AND TRANSFER OF YOUR PERSONAL INFORMATION

-CommSwift will take reasonable measures to secure your personal information from unauthorized access, use, or disclosure. -You have consented to us on transferring your personal data to any location outside of Singapore for the purposes set out above, should there be any. -Personal data that you have provided will be stored in Singapore. In the event data is transferred outside of Singapore the personal data transfer will be in accordance with requirements prescribed under the PDPA or applicable data protection law to ensure that organization provides a standard of protection for personal data. -CommSwift will ensure that the recipient country of your personal data transferred to has comparable protection as under the laws of Singapore.

WITHDRAWAL OF CONSENT

-The consent that you provide for the collection, use and/or disclosure of your personal information will remain valid until such time it is being withdrawn by you. -Should you wish to withdraw your consent, you may send your request through the contact details of our Data Protection Officer provided in this statement. Please understand that your withdrawal of consent for purposes necessary to CommSwift fulfilling our contractual duties towards you or facilitating your request or providing our services to you may carry consequences. We will review and inform you of the consequences of the withdrawal prior to processing your request.

ACCESS AND CORRECTION OF PERSONAL INFORMATION

If you wish to access, update or otherwise change or remove any information that you have provided to us, you may send your request through the contact details of our Data Protection Officer provided in this statement.

ACCURACY OF PERSONAL INFORMATION

-You must ensure that all personal data provided to CommSwift is true, accurate and complete. -We will take reasonable steps to ensure that the personal information we collect about you is accurate, complete, not misleading and kept up-to-date, if necessary, for its intended use. Where possible, we will validate your personal information using general accepted practices and guidelines.

RETENTION OF YOUR PERSONAL INFORMATION

-We will retain your personal information only for as long as the purposes for which such data is collected or used (as notified to you) continues, or where necessary, for our legal or business purposes. -We will dispose of, delete or destroy documents containing your personal information in a secure manner as soon as it is reasonable to assume that the permitted purpose is no longer being served by their retention. -We will not retain any unsolicited personal information received by us. If received by email or through our website, this unsolicited personal information will be deleted right away. If received by telephone, it will not be recorded.

DATA BREACH NOTIFICATION

In the event a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data, we shall promptly assess the impact and if appropriate, report this breach within 3 calendar days to the Personal Data Protection Commission (PDPC). We will notify you when the data breach is likely to result in significant harm to you after our notification to PDPC. We may also notify other relevant regulatory agencies, where required. If we are a Data Intermediary, we shall inform the Data Controller immediately of any data breach so they can promptly assess the impact and comply with their data breach notification obligation. ​

CHANGES TO THIS STATEMENT

CommSwift will occasionally update this Statement of Privacy to reflect company and customer feedback. You shall acknowledge and agree to our privacy policy each time you use our Platforms, or contact, interact or transact with us.

CONTACT INFORMATION

CommSwift welcomes your comments regarding this Statement of Privacy. If you have any questions or concerns regarding any aspect of this policy or the personal data you have provided or wish to make an access request, correct or withdraw your consent given for any or all purposes set out in this Policy, please contact our Data Protection Officer at support@commswift.com Any query should include, at least, your name and contact information. For technical support, also contact our support team at support@commswift.com. If you have any complaints or feedback relating to how we manage your personal data, you may send them to us via the email address above.