ABOUT THIS NOTICE

 

Elevandi Limited (herein be referred as “Elevandi”, “us”, “we” or “our”) is committed to safeguarding your privacy. When you interact with us, you may share information with us that allows identification of you as an individual (“Personal Data”). We may gather such information when reach out to us and/or join any of our certification progammes.

 

This Data Protection and Privacy Notice (“Notice”) describes how we manage Personal Data in this context. This Notice also describes your data protection rights, including a right to object to some of the processing which we carry out. More information about your rights, and how to exercise them, is set out under "How to access and control your Personal Data” below.

 

Elevandi acts in accordance with the Personal Data Protection Act (No. 26 of 2012) of Singapore (“PDPA”), the European Union General Data Protection Regulation (Regulation (EU) 2016/679) (“GDPR”),the UK Data Protection Act of 2018 (“UK GDPR”) and the Personal Information Protection Law of the People’s Republic of China (“PIPL”).

 

The relevant data controller of Personal Data is Elevandi for the purpose of data subjects from the UK and the EU.

 

WHO WE ARE

 

Elevandi (which means to lift up or raise up) is a non-profit organisation set up by the Monetary Authority of Singapore (MAS). Elevandi is running a series of certification programmes in collaboration with universities in Singapore to harness FinTech for growth and development in the new digital economy(together referred to as “Services”).

WHO WE COLLECT PERSONAL DATA FROM

 

In the context of the Services provided by us, we collect Personal Data from:

●       Course participants.

●       Users of our website platforms.

 

The individuals about whom we collect Personal Data shall herein be referred to as “you” in this Notice.

 

HOW WE COLLECT PERSONAL DATA

 

We collect Personal Data from and about you in the following ways:

 

●            Direct Interactions

○        When you engage us for and in relation to any of our Services, whether in writing, orally or through our websites, and/or attend any of our events (e.g. registration forms, subscribe to our mailing list, social media channels, and photographs, videos and/or audio recordings taken by us or our representatives at our events); 

○        When you interact with our staff, service providers and other representatives, for example, via telephone calls, letters, fax, face-to-face meetings and emails and/or other any other means including but not limited to WhatsApp, Telegram, WeChat, Skype and SMS; and/or

○        When you submit Personal Data to us for any other reason.

 

●       Automated Interactions

○        When you interact with us on our websites, we may automatically receive and record information, including Personal Data, on our server logs from your browser (for more details see below under “Cookies and Website”).

 

●       Third Parties

○        Vendors, business partners, regulatory authorities, your employer or other organisations with whom you have dealings in connection with our Services, including Personal Data in publicly available sources.

 

WHAT PERSONAL DATA WE COLLECT

 

Generally, we will seek to reduce the collection of Personal Data to what is needed to complete the respective function or service. We may collect, use, process, store and transfer different kinds of Personal Data about you when you participate in our events or engage us for our Services. The

Personal Data collected includes but is not limited to the following:

 

●       Name, organisation, job title, job function, email or business contact information;

●       Identification information including photographs, videos and audio recordings;

●       Business or employment information;

●       Payment information;

●       Feedback and/or information relating to the usage of our Services and our events; and

●       Identifiable IT information (IP addresses, usage data, cookies data, online navigation data, browser data);

●       Number of log-ins;

●       Webpages visited;

●       Any other information you may choose to provide us.

HOW DO WE USE YOUR PERSONAL DATA

 

We use your Personal Data in the following ways:

 

●       to perform our obligations in the course of providing our Services;

●       to manage our relationship with you and facilitate the provision of our Services;

●       to monitor, analyse and protect our business, including the activities of individuals at our events;

●       to facilitate business operations;

●       to facilitate completion of any requests from you;

●       for the purposes of other events that we may host;

●       to comply with any legal, regulatory or professional obligation; and/or

●       to personalise your customer experience, develop our business and/or improve on our Services.

 

Please note that if you choose not to provide us with your Personal Data or choose not to consent or to object to our processing of your Personal Data, we may not be able to provide some or all our Services to you or respond to your other requests.

 

These purposes may continue to apply even in situations where your relationship with us has been terminated or altered in any way. In such cases, we may still retain Personal Data relating to you and use or disclose such information for legal or business purposes, including for compliance with the PDPA, UK GDPR, GDPR and/or other applicable laws.

 

 

THIRD PARTIES THAT WE MAY SHARE YOUR PERSONAL DATA WITH  

 

Where and when required, your Personal Data may be shared with third parties in certain circumstances. The third parties include:

 

 

●       Our partners

 

We may share Personal Data with our collaboration partners, and any third-party business partners who work with us, whether jointly with us or independently.

 

●       Our service providers

 

We use other companies, agents or contractors to perform services on our behalf or to assist us with the provision of our Services, we may share your Personal Data with the following categories of service provider(s):

 

○        website builders / website hosting platforms, infrastructure and IT service providers, including for email archiving;

○        marketing, advertising and communications agencies;

○        accounting and corporate services providers;

○        contractors, venue providers, transport providers, logistics providers, virtual platform providers, business matchmaking providers; and/or

○        security providers.

 

●       Our sponsors and exhibitors

 

We may, where you consent, share some of your Personal Data with the sponsors and exhibitors so that they can send you information about products, content and services that might interest you and for internal analytical and business development purposes. You can withdraw this consent at any time. Please note that the sponsors and exhibitors have their own privacy policies, you should check their privacy policies or opt-out from their communications directly with the respective organisations.

 

●       Third parties permitted by law

 

In certain circumstances, we may be required to disclose or share Personal Data in order to comply with legal obligations from regulatory or supervisory authorities (e.g. police, regulators, government agencies or to judicial or administrative authorities). We may also disclose Personal Data to third parties where disclosure is both legally permissible and necessary to protect or defend our rights, matters of national security, law enforcement, to enforce our contracts or protect your rights or those of the public.

 

●       Third parties connected with business transfers

 

We may transfer Personal Data to third parties in connection with a reorganisation, restructuring, merger, acquisition or transfer of assets, provided that the receiving party agrees to treat your Personal Data in a manner consistent with this Notice.

 

Please note that our websites may, from time to time, contain links to and from the websites of our partners or affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we have no control over how they may use your Personal Data. You should check the privacy policies of these third-party websites before you submit any Personal Data to them.

 

 

THE LEGAL BASIS FOR INDIVIDUAL PROCESSING

 

We process your Personal Data for the following purposes:

To fulfil a contract, or take steps linked to a contract: this is relevant where you agree to attend an event we run. This includes:

·        verifying your identity, this also includes collecting your age or storing an image of you;

·        taking payments;

·        communicating with you; and

·        providing customer services and arranging the provision of Services.

 

To conduct our business and pursue our legitimate interests, in particular:

·        we monitor and analyse use of our websites and online services, and use your information to help us monitor, improve and protect our Services and websites;

·        we use information you provide to personalise our websites or Services for you;

·        if you provide a credit or debit card as payment, we also use third parties to process that payment and check the validity of the card number you submit in order to prevent fraud (see data sharing below);

·        we use information you provide to investigate any complaints received from you or from others, about our websites or our Services;

·        Images and audio and video recordings may be used for marketing future events, this especially applies to you if you are a speaker or member of a panel; and

·        we will use data in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation).

 

We have carried out balancing tests for all the data processing we carry out based on our legitimate interests, which we have described above.

 

Where you give us consent:

·        we may send you direct marketing in relation to our Services;

·        where we provide our sponsors or exhibitors with some of your Personal Data so they can contact you before or after an event in order to provide you with further information that you may be interested in;

·        we place Cookies and use similar technologies in accordance with our Cookies Policy and the information provided to you when those technologies are used; and

·        on other occasions where we ask you for consent, we will use the data for the purpose which we explain at that time;

 

Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above.

 

For purposes which are required by law:

·        we will process information in order to comply with portability requirements under (UK) GDPR; and

·        we will provide data in response to requests by government or law enforcement authorities conducting an investigation.

 

 

DATA RETENTION

 

●       Protection and Security

We implement appropriate technical and organisation measures to protect your Personal Data against accidental, unauthorized or unlawful use, disclosure, access, destruction, loss, change or damage. Access to your Personal Data is strictly limited to persons on a “need-to-know” basis.

However, we cannot completely guarantee the security of any Personal Data we may have collected from or about you, or that, for example, no harmful code (e.g. viruses, bugs, trojan horses, spyware or adware) will enter our websites. You should be aware of the risks associated with using websites.

While we strive to protect your Personal Data, we cannot ensure the security of the information you transmitted to us via the Internet.

 

●       Retention

We will only retain your Personal Data for as long as necessary for the purpose for which that data was collected and to the extent permitted by applicable law.

 

Where we process registration data or otherwise in connection with performing a contract, we do this for as long as at least 6 years after your participation.

 

Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). Where you have not opened an email from us in two years, we will take you off our mailing lists. We also keep a record of the fact that you have asked us not to process your data indefinitely so that we can respect your request in the future.

 

TRANSFER TO OTHER COUNTRIES

 

In the provision of our Services, the Personal Data we collect may be transferred to and processed by us or third parties in countries outside the EU, the UK or the People’s Republic of China. In all such instances, we shall ensure that the transfer of your Personal Data is carried out in accordance with any applicable laws and that appropriate safeguards (e.g. contractual, technical and organisational measures) are put in place before such transfer takes place.

 

COOKIES AND WEBSITE

 

●       Cookies

For the purpose of this notice, “Cookies” are used on our server to allow us to keep track of your activity on the internet, collect and record Personal Data from the browser and facilitate your experience when browsing our websites and accessing any of our online pages (e.g. site traffic and volume, site usage statistics, operating system, referral source or device information). We use Cookies which are necessary for the functioning and operation of our websites. The Cookies placed by our server are readable only by us, and Cookies cannot access, read or modify any other data on an electronic device. All web-browsers offer the option to refuse any Cookies, and if you choose to refuse our Cookies, no information will be collected.

If you wish to disable any Cookies associated with these technologies, you may do so by changing the settings on your browser or manually select “Decline” when first visiting our websites. However, please note that once Cookies has been disabled, you may still continue to use our websites but with limited functionality. 

 

●       Website

On our websites, we may, from time to time, display advertisements from third parties or provide links to third party websites. In these instances, kindly note that we cannot be held responsible or liable for the privacy practices and policies of the third party. Please read the privacy policies of such third parties to find out how they process and collect your Personal Data.

 

●       The websites run by us are https://www.elevandi.io/ and https://education.elevandi.io/ (referred to as “our websites”).

 

HOW TO ACCESS AND CONTROL YOUR PERSONAL DATA

 

You have the following rights where applicable:

 

●       Access

You may request a copy of the Personal Data we are processing about you. For your own privacy and security, at our discretion, we may require you to prove your identity before providing the requested information.

 

●       Rectification

You may request to update and rectify any incomplete or inaccurate Personal Data that we process about you. To help us ensure accuracy please provide us with updated information where possible.

 

●       Deletion

You may request that we delete Personal Data that we process about you, except we are not obliged to do so if we need to retain such data in order to comply with a legal obligation or to establish, exercise or defend legal claims.

 

●       Restriction

You may restrict our processing of your Personal Data where you believe such data to be inaccurate; our processing is unlawful; or that we no longer need to process such data for a particular purpose unless we are not able to delete the data due to a legal or other obligation or because you do not wish for us to delete it.

 

●       Portability

You may request to obtain Personal Data we hold about you, in a structured, electronic format, and to transmit such data to another data controller, where this is (i) Personal Data which you have provided to us, and (ii) if we are processing that data with your consent or to perform a contract with you.

 

●       Objection

You may object to our processing of your Personal Data. We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data for the establishment, exercise or defence of a legal claim.

 

Withdrawing Consent. You may withdraw your consent for us to process your Personal Data at any time, free of charge. This includes cases where you wish to opt-out from marketing messages that you receive from us. Individuals are given rights in relation to their Personal Data pursuant to the applicable law.

 

If you are based in the EU or the UK, you may have the right to complain to your competent data protection supervisory authority (e.g. the Information Commissioner’s Office for data subjects in the UK).

 

●       Right not to be subject to Automated Decision-making

You have the right to not be subject to a decision based solely on automated decision-making where the decision would have a legal effect on you or produce a similarly significant effect. If we send you electronic marketing messages based on your consent or as otherwise permitted by applicable law, you may, at any time, respectively withdraw such consent or declare your objection at no cost. The electronic marketing messages you receive from us will also include an “unsubscribe” option within the message itself to enable you to manage your Personal Data. Please note that if you opt-out of receiving direct marketing materials, we may still send you non-promotional messages, such as receipts or information about the Services we are providing to you.

 

In order to enable you to exercise these rights with ease and to record your preferences in relation to how we use your Personal Data, you may manage your privacy preferences at any time by contacting Elevandi at dpo@elevandi.io.

 

CHANGES TO THIS NOTICE

 

We reserve the right to change this Notice from time to time.

 

CONTACT US

 

If you have any questions about your privacy, your privacy rights, or how to exercise them, please feel free to contact Elevandi at dpo@elevandi.io. We will respond to your request within 5 days upon verification of your identity, if applicable.

 

 

This Notice was updated on 15 Mar 2023 and is effective as of that date.