Privacy and Data Protection Policy

This Privacy and Data Protection Policy (“Policy”) sets out the basis upon which Sixty Three Law Corporation may collect, use, disclose or otherwise process personal data.

The purpose of this Policy is to inform you of how Sixty Three Law manages Personal Data (as defined below) that is subject to the Personal Data Protection Act 2012 of Singapore (“PDPA”) and any applicable personal data protection principles. Please take a moment to read this document so that you know and understand the purposes for which we collect, use, disclose or otherwise process your personal data in accordance with the PDPA. Capitalised terms used but not defined herein shall have the same meanings given to them in the PDPA, where the context so permits.

This Policy applies to all personal data in our possession or under our control, including personal data in the possession of organisations or persons engaged by us to collect, use, disclose or process for our purposes.

By interacting with us, submitting information to us, or using or engaging any services offered by us, you agree and consent to Sixty Three Law, as well as our respective representatives and/or agents (collectively referred to herein as “Sixty Three Law”, “us”, “we” or “our”), collecting, using, disclosing and sharing amongst themselves your personal data, and disclosing such personal data to our authorised service providers, agents and relevant third parties in the manner set forth in this Policy.

We may, from time to time, update this Policy to ensure that it is consistent with our future developments, industry trends and/or any changes in the legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of this Policy as updated by us from time to time, accessible on our website (https://www.sixtythreelaw.com).

This Policy supplements but does not supersede or replace any other consents you may be previously provided to us in respect of your Personal Data, and your consents herein are additional to any rights which we may have at law to collect, use, disclose or process your Personal Data.
 

In this Policy, “Personal Data” refers to any data, whether true or not, about an individual 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, including data in our records, as may be updated from time to time.

Depending on the nature of your interaction with us, some examples of personal data we may collect from you include your name, telephone number, mailing address, residential address, email address, National Registration Identity Card (NRIC), passport or other identification number, and any other information relating to any individual that you have provided in any forms submitted to us, or via any other forms of interaction with you.

If you provide us with any Personal Data relating to a third party, such as information of your spouse, children, parents and/or employees, by submitting such information to us, you represent and warrant to us that you have obtained the consent of such third party to provide us with their Personal Data for the respective purposes.

You should ensure that all Personal Data submitted to and held by us is complete, accurate, true and correct. Any failure to do so may result in our inability to provide our services to you that you have requested, or delays in processing your application. In such event, we shall not be responsible, accountable or liable for any loss, injury or damage resulting from such failure.

This Policy does not extend to (i) aggregated information that summarises statistical information about groups of individuals, and does not include name, contact information, or any other information that would allow any particular individual to be identified, or (ii) business contact information (“BCI”), as the data protection provisions of the PDPA do not apply to BCI. BCI is defined in the PDPA as an individual’s name, position name or title, business telephone number, business address, business electronic mail address or business fax number and any other similar information about the individual, not provided by the individual solely for his or her personal purposes.
 

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 has 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 in Singapore. We shall seek your consent before collecting any additional personal data or before using your personal data for a purpose that has not been notified to you (except where permitted or required by law).

We may collect Personal Data in the following ways:

• when you interact with us via our website and/or its subdomains (“Website”) or submit a form relating to our services, events or activities;

• when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our services;

• when you interact with our employees, representatives and/or agents via telephone calls, emails, letters, face-to-face meetings or messaging applications or any other form of communications;

• when you use our electronic services, or interact with us via our Website or use services on our Website;

• when you request that we contact you or request that you be included in an email or other mailing list;

• when you respond to our offers, invitations, initiatives or to any request for additional Personal Data;

• when you submit an employment application or when you provide documents or information, such as your resume or curriculum vitae in connection with any appointment as a director, representative, officer or any other position;

• when your images are captured via camera or face recognition system while you are within our premises, or via photographs or videos taken by us or our representatives and/or agents when you attend our events or activities;

• when we receive your referral from business partners and third parties, e.g. where you have been referred by them with your consent;

• when we seek information from third parties about you and receive your Personal Data in connection with your relationship with us, including for our services, events and activities, such as from public agencies, your previous employer, referral intermediaries and/or the relevant authorities; and/or

• when you submit your Personal Data to us for any reason.

When you browse our Website, you generally do so anonymously but please see our Cookie Policy accessible on our Website (https://www.sixtythreelaw.com/cookie-policy). We do not automatically collect Personal Data from our Website unless you provide such information.

We may collect, use, disclose and otherwise process your Personal Data for any or all of the following purposes:

• Operating our Website;

• verifying your identity or matching any Personal Data relating to you;

• contacting or communicating with you, and responding to, processing and handling your applications, requests, queries, feedback and complaints, and providing customer service and support for any services, events or activities offered by us;

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

• managing our administrative and business operations, creating and maintaining your profile in our database or internal records, billing and administering debt recovery and debt management;

• taking photographs and/or videos of you, or otherwise using your image for dissemination within and without Sixty Three Law, and generating digital or print materials for networking, publicity or marketing purposes;

• (i) complying with our internal policies, procedures and protocols, as well as any applicable laws, regulations, rules, codes of practice, or guidelines, (ii) conducting audit checks, due diligence and investigations, (iii) preventing, detecting and investigating crime, and analysing and managing commercial risks, disputes or fraud, and (iv) assisting in law enforcement and inquiries conducted by any governmental and/or regulatory authority;

• requesting feedback or participation in surveys, as well as conducting market research and analysis for statistical, profiling, planning or reporting or other purposes for us to review, develop and improve the quality of our services, events or activities;

• monitoring or recording our phone calls and other interactions with you for identity verification, employee training, performance evaluation and quality assurance;

• hosting, storing or backing up your Personal Data, which may be on third-party servers or data clouds;

• managing our facilities and/or premises, including (but not limited to) maintaining the safety and security of our facilities and/or premises, carrying out camera surveillance or monitoring, and security clearances;

• in connection with any claims, actions or proceedings, including (but not limited to) drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution, and protecting and enforcing our contractual and legal rights and obligations;

• facilitating any business asset transactions involving Sixty Three Law, including (but not limited to) mergers, acquisitions or asset sales;

• any other purposes for which you have provided your personal data; and/or

• any other incidental purposes reasonably related to or in connection with the above.

If you are an existing or prospective participant of our events or activities, in addition to the purposes listed at paragraph 8 above, we may also collect, use, disclose or otherwise process your Personal Data for the following purposes:

• conducting and administering our events and activities, including (but not limited to) budgeting, processing payment, facilitating registration, recording attendance, conducting assessments or examinations, and contacting you for administrative purposes;

• maintaining an alumni network and organising alumni activities, such as mingling events, seminars, talks and sharing sessions;

• registering you on our email or other mailing lists;

• facilitating and providing networking, publicity or marketing opportunities between you and other existing or prospective participants, invited speakers, panelists or guests of our event, seminar, talk or sharing session for which you are registered; and/or

• any other incidental purposes reasonably related to or in connection with the above.

Further, where permitted under the PDPA and/or where you have provided your consent to us separately, we may also collect, use, disclose or otherwise process your Personal Data for the following additional purposes:

• matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision, marketing or offering of our services;

• conducting market research, analytics and surveys to enable us to understand and determine your preferences and profile for us to offer you services that may be relevant to your preferences and profile; and/or

• any other incidental purposes reasonably related to or in connection with the above.

Subject to the provisions of any applicable laws or regulations, we may disclose your Personal Data to the extent necessary, proportionate and legally permissible:

• for the purposes listed above (where applicable) to entities or persons located inside or outside of Singapore;

• if required by law or in the good faith belief that such action is necessary to (i) conform to the edicts of the law or comply  with legal processes served on us or the Website, (ii) protect and defend our rights or property, (iii) act under exigent circumstances to protect the personal safety of users of our Website or (iv) where your consent has been obtained for disclosure;

• to agents, contractors or third party service providers we have engaged to perform any of the functions with reference to the abovementioned purposes, including (but not limited to) (i) our operations, e.g. telecommunications, printing, courier and delivery, information technology, payment, billing, payroll, processing, technical services, training, market research, call centre, security and employee recognition, (ii) events and activities offered by us, e.g. event organisers or coordinators, venue owners and managers, food and beverage caterers, and any other vendors and suppliers in connection with such events and activities;

• to our partners, collaborators and guests of our events and activities;

• to any actual or prospective business partner, investor, assignee or transferee in business asset transactions involving Sixty Three Law, which may include any merger, acquisition or asset sale;

• to our professional advisers such as consultants, auditors and lawyers;

• to relevant government ministries, regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and/or

• to any other party to whom you authorise us to disclose your Personal Data to.
   

Our Website may contain external links, widgets and/or plugins operated or maintained by third parties, over which we have no control. By continuing to browse or use our Website, you acknowledge and accept that certain functions or features, when activated or used by you, will operate to send or display information about yourself, including (but not limited to) your personal data to certain third parties that may be unrelated to us, and you agree to the sharing of such information with these third parties. You further acknowledge, agree and accept that we shall not be held responsible, accountable or liable for any loss, injury or damage resulting from such sharing of information arising out of your activation or use of such features on our Website.

This Policy does not apply to your use of third-party websites, and you are advised to read the respective privacy policies or statements of such third-party websites before using them. We are not responsible for the privacy and/or data protection policies or practices of such third-party websites, and once you have left our Website by clicking on an external link, your use of that third-party website shall be governed by the privacy and/or data protection policy of that website.
 

If you have provided us with your Singapore telephone number and have indicated that you consent to receiving marketing or other promotional information via your Singapore telephone number, or where we are permitted to do so under the PDPA, then we may contact you from time to time at such Singapore telephone number (including via voice call, text messaging or other means) with information about our services, events and activities and other marketing or promotional materials or communication even if such telephone number is registered with the DNC Registry.
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The consent that you provide for the collection, use, disclosure and processing of your Personal Data will remain valid until such time it is withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using, disclosing or processing your Personal Data for any or all of the purposes (except where permitted or required by law) mentioned above at any time by submitting a written request.

Any request for (i) withdrawal of consent for our collection, use, disclosure and processing of your Personal Data, (ii) access to a copy of your personal data that is held by us or information about the ways in which we have used or disclosed your personal data, or (iii) correction or updating any of your personal data that is held by us, must be submitted in writing via email or letter to our Data Protection Officer at the contact details provided below.

Upon receipt of your written request, we shall endeavour to process such request within a reasonable time, depending on the complexity of your request and its impact on our relationship with you. We shall notify you in writing after we have processed your request. There is no guarantee that we shall accede to or fulfil your request, and we may not be able or obligated to do so. It may take up to 30 working days for your withdrawal to be reflected in our system.

Please note that there may be legal consequences if you withdraw your consent to any or all use of your Personal Data. Depending on the nature of your request, we may not be in a position to administer any contractual relationships for the time being in force, which may affect your rights and liabilities to us and in turn result in breaches of your contractual obligations or undertakings to us, as well as the termination of any contracts you may have with us. In such event, we shall not be responsible, accountable or liable for any loss, injury or damage resulting from such breach or termination, and all our legal rights and remedies remain expressly reserved.

If you have provided your telephone number and have indicated that you consent to receiving marketing information via that telephone number, then we may, from time to time, continue to contact you at that telephone number via voice calls, text or SMS messages, or messaging applications to provide information about our services, events and activities, unless you have withdrawn your consent.

In relation to particular services or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use, disclose or otherwise process your Personal Data. If so, we may collect, use, disclose or otherwise process your Personal Data for these additional purposes as well, without further notice to you.
 

We have taken reasonable steps to protect the Personal Data in our possession or control against unauthorised access, collection, use, disclosure, copying, modification disposal or similar risks, and shall make reasonable efforts to protect the Personal Data by reviewing and enhancing this Policy and any related preventative security measures from time to time, as may be necessary.

You should be aware that there are no completely secure methods of electronic transmission or electronic storage. There is no guarantee that your Personal Data will be secure in spite of the security measures we have put in place, as the risks associated with using websites, applications and digital services cannot be completely eliminated.

We urge you to take every precaution to protect your Personal Data when you are on the internet or use such information transmission platforms or services.
 

We may retain your Personal Data for as long as it is necessary to fulfil the purposes for which it was provided to us or collected, or as permitted or required by law.

We shall either (i) cease to retain your Personal Data, or (ii) remove the means by which such Personal Data may be associated with you, when it is reasonable for us to assume that doing so no longer serves the purposes for which the Personal Data was collected, or other legal or business purposes.

We may transfer your Personal Data outside of Singapore as may be necessary in order to perform our obligations in the course of or in connection with our provision of services requested by you. You therefore consent for such transfer to be made without further notice to you. We shall take reasonable steps to ensure that your Personal Data remains adequately protected at a similar standard to that afforded by the PDPA.
 

If you have any questions or concerns relating to your Personal Data or this Policy, or if you wish to submit any requests to withdraw your consent to the use of your Personal Data, access or make corrections to your Personal Data records (as set out above), you may write to our Data Protection Officer at the below:

• Email: benson.lim@sixtythreelaw.com

• Address: 
  Sixty Three Law Corporation
  120 Robinson Road, #15-01, Singapore 068913
  Attention: Data Protection Officer

Please note that if your Personal Data has been provided to us by a third party (e.g. a referrer, or your company), you should contact that entity or person to make such queries, complaints, and requests for access or corrections to Sixty Three Law on your behalf.
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This Policy, your browsing of our Website and use of our electronic and/or digital services shall be governed in all respects by the laws of Singapore.
 

This Policy applies in conjunction with any other notices, 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 acknowledgment and acceptance of such revisions.