Data Protection Policy
1 Protecting Your Personal Data and Privacy
At NTT Singapore, we take data protection very seriously.
We understand the importance of your privacy and personal data. Therefore, we process all of your personal information in compliance with the Personal Data Protection Act 2012 (‘PDPA’).
Additional measures in the form of our internal data protection policies and security safeguards are also in place when we handle personal information on behalf of our existing clients in our role as a service provider.
While we know that privacy is important to you, it may be inevitable in the course of business that some of your personal data is shared and collected in communications between us, whether these communications are for the purpose of understanding your needs or providing any of our service offerings to you.
This Data Protection Policy provides clarification on how NTT Singapore in general collects, uses and shares your personal information.
2 NTT Singapore’s Data Protection Policy
2.1 What is ‘Personal Information’?
Generally, the term ‘personal information’ refers to any information that identifies or can be used to personally identify an individual. This includes information such as your name, address, telephone number, identification or passport number as well as email address.
2.2 When do we collect personal information?
Personal information may be collected when you/we:-
Contact us with an enquiry or request for assistance
Communicate with our representatives
Respond to your enquiries and requests
Purchase our solutions and services
Use our network and relevant NTT Singapore solutions and services
Obtain your feedback about our solutions and services
Conduct our administrative and business functions
Through your access and use of our websites
Register for our events, workshops, seminars or subscribe to our mailing lists/newsletters
Market our solutions and services to you
In addition to the above, we may also obtain your personal information through third parties from time to time. Where we do so, we will seek confirmation from such third parties that they have obtained your personal information legally and that we have the right to acquire it from them and to use it.
For those seeking a career with us, we may also collect your personal information as part of your application. Where you have voluntarily provided personal information of a third party in the course of submitting your application, kindly ensure that you have obtained the consent of such third party prior to providing such personal information to us.
Kindly note that in all cases where personal information has been voluntarily provided, you will have been deemed to have consented to the collection and use of such personal information unless you inform us otherwise.
2.3 What personal information do we collect?
The type and extent of personal information we generally collect depends on the method and purpose of communication between us.
Typically, we collect the following types of personal information:-
(A) Information as to your identity
Title or Position
Phone / Fax number
(B) Ancillary information
Records of your interaction with us (e.g. note or recording of calls or email/letter)
Information on equipment and their use over our network
Information on use of our solutions and services
Preferential information (e.g. preferred contact methods and solutions/services)
Information from authorized third party organisations (e.g. business directories, credit reference agencies)
NTT Singapore does not collect sensitive personal information relating to your health, religion, race or political beliefs.
For our existing clients, we may also have collected additional personal information about you as part of our business requirements (e.g. for point of contact for billing, invoicing and payment purposes). This is necessary in our continuing pursuit of providing you, our valued client, with consistent solutions and services of a world-class standard.
2.4 Collection and use of personal information
In general, we collect, hold and use your personal information for the purposes of:-
Establishing, managing and maintaining business relationships
Responding to enquiries and requests
Develop, provide and improve our services and solutions
Informing you about our services and solutions
Obtaining feedback about our offerings
Better personalization of services and solutions
Conduct of administrative and business functions
Updating records to keep details current
Process requests for subscriptions to website updates, newsletters and mailing lists
Process requests for registration to NTT Singapore events, seminars and workshops
Process applications for a career at NTT Singapore
Monitor performance of website services and improve accessibility
Respond to privacy complaints
Ensure security and risk management objectives are maintained
Compliance with audit requirements
Compliance with any rule, law, regulation or lawful request or direction of any competent regulator/governmental authority; or as NTT Singapore in good faith believes to be necessary and appropriate
NTT Singapore only keeps personal information for such period as there is a business or legal need.
NTT Singapore does not use any of your personal information other than as described in this policy, or other than as permitted under local laws and regulations.
2.5 Disclosure and sharing of personal information
From time to time, NTT Singapore will disclose or share your personal information with other parties subject to the purposes set out in paragraph 2.4 above. Where recipients of personal information shared by us reside overseas, we will take steps to ensure that such recipients have in place adequate measures and safeguards relating to confidentiality and data protection.
In certain cases, we will also encrypt, aggregate and anonymise personal information before sharing it. This means that the information will only be presented over a range (e.g. by age) and cannot be used to personally identify you.
This section sets out the parties to which your personal information is disclosed or shared and the purposes for doing so (where applicable).
(A) Disclosure and sharing within the NTT Group
Primarily, NTT Singapore may disclose your personal information to our employees and affiliates for business and administrative reasons mentioned in paragraph 2.4 from time to time.
As a global multinational corporation, some of our related entities are based overseas. As such, it may be that your personal information is disclosed to entities not based in Singapore.
For more information on NTT Group and its affiliate companies, you may wish to visit the following link at: http://www.ntt.co.jp/gnavi_e/index.html.
(B) Disclosure and sharing with third parties
Where necessary and to the extent required, NTT Singapore may from time to time disclose your personal information to:-
Contractors, suppliers and other third parties providing business, marketing and other services to us
A third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets or stock
Any organisation for any authorised purpose with your express consent
Regulators, courts/tribunals and governmental authorities of a competent jurisdiction; or such party as NTT Singapore in good faith believes to be necessary and appropriate
In some cases, our website may contain links that allow you to post your enquiries or comments that are accessible by the general public over the internet. When doing so, kindly be reminded that caution should be exercised whenever you are posting personal information online.
Save as aforementioned, NTT Singapore does not provide any personal information to unaffiliated third parties for direct marketing purposes; and, NTT Singapore will only disclose personal information where required by law, an order of court/tribunal or otherwise permitted under the PDPA.
2.6 Security and storage of personal information
Where necessary, we may collect and hold personal information communicated to us, whether the medium of communication is verbal, electronic or written. However, we generally do not store personal information that is sensitive in nature.
If your personal information is held by us, we will take reasonable precautions to protect them from misuse, loss, unauthorised access, modification or disclosure by using a combination of physical, administrative and technical safeguards. Some of the measures put in place to secure and protect your information include:-
Safeguards to prevent security breaches of our network and database systems
Restricted access to information contained in our systems and those of our business partners and vendors
Information security policies and procedures to prevent unauthorised access to personal information
While we take great care in ensuring the security of personal information held by us, we nonetheless wish to highlight that any information which transmitted online remains susceptible to access by unauthorised third parties. This is because of the inherently insecure nature of the internet as a medium of data transmission. As such, we are unable to guarantee with any certainty regarding the security of communications containing personal information transmitted over the internet.
As any communications over the internet are transmitted at your own risk, we once again hope to remind you to exercise caution when using the internet as a medium for data transmission for personal information.
3 Access to and Correcting Personal Information
While we endeavour to ensure that personal information about you held by us remains accurate, up to date and complete, we may not be able to immediately react to changes to your personal information that may occur from time to time.
To that extent, you may wish to request access to personal information about you that is held by us at any time, including to correct such personal information that is inaccurate, incomplete or out of date.
Kindly note that access to your personal information in the manner requested is given subject to exceptions allowed by law or the PDPA and where it is reasonable and practical to do so.
Should you wish to access or correct your personal information, please send a written request to our Data Protection Officer using the contact details set out at the end of this policy. Our Data Protection Officer will respond to your request within thirty (30) days after you have made the request. Note that in some instances, a nominal fee may be charged to you to cover the cost of retrieving the requested personal information.
In certain circumstances, we may nonetheless deny your request for access to or correction of your personal information. For example, where granting such access will interfere with the privacy of others, is unlawful or would result in a breach of confidentiality. In such cases, we will provide you with written reasons for refusing your request and the mechanisms available to you to appeal against our refusal.
3.1 Concerns about breach of privacy
If you have any concerns regarding how your personal data is being handled by NTT Singapore or wish to make a complaint about a breach of the PDPA by NTT Singapore, you may send your complaint in writing to our Data Protection Officer using the contact details set out at the end of this policy.
Our Data Protection Officer will respond to you in writing within thirty (30) days, setting out what action NTT Singapore will take in response to your complaint, or alternatively, where there has been no breach, an appropriate explanation.
4 Information about using NTT Singapore’s Website
4.1 Cookies and third-party addons
As with most other websites on the internet accessible by the general public, NTT Singapore’s website utilizes ‘cookies’ – a small file stored on a user’s computer designed to hold a modest amount of data specific to an incoming user and the website assessed. Using cookies allows NTT Singapore to engage you in a more meaningful way by allowing us to recall information you have previously entered via our website without having you re-enter them and to tailor our website’s content to be more relevant to you.
While NTT Singapore’s website does not utilize tracking cookies – cookies which have a potential to track a user’s browsing habits, we nonetheless recognize that you may not wish to receive cookies on your computer. If that is the case, you may wish to visit the options menu for your browser to prevent cookies from being accepted.
In addition to general cookies described above, NTT Singapore’s website also utilizes Macromedia Flash (a widely used third party addon by Adobe) to present information in a more visual way to enhance user experience. In order for the addon to display content correctly, Macromedia Flash may store Flash Local Shared Objects (LSOs), commonly referred to as Flash cookies, on your computer.
Flash cookies are a form of local storage which can store data regarding a user’s preference and retrieve them whenever a user accesses a page containing Flash content. NTT Singapore’s website uses Macromedia Flash to help us display dynamic content in order to enhance your experience of our website. If you do not wish to have LSOs stored on your computer, you can adjust the settings of your Flash Player. More information on how to do so may be found at http://www.macromedia.com/support/documentation/en/flashplayer/help/settings_manager.html. Do be reminded that restricting or limiting LSOs on your computer may reduce or interfere with the functionality of Flash content which are dependent on LSOs to display properly (including Flash content found on NTT Singapore’s website).
Kindly take note that from time to time, we may monitor user activity or log IP addresses on our website in order to administer the website, analyse demographic access trends and improve accessibility.
4.2 Third-party websites
In using NTT Singapore’s website, you may come across links to other websites whether of entities within the NTT Group or of third parties. Please note that the contents of this policy do not extend to such third party websites. Should you visit any third party websites through links made available on our website, kindly be reminded that NTT Singapore make no representations or warranties in relation to the privacy practices of any third party website and are not responsible for the privacy policies or content of any third party website.
5 Direct Marketing
From time to time, we may send you communications and information about our services and solutions that we consider may be of interest to you. These communications may come in various forms e.g. mail, SMS, fax or email.
If you do not wish to receive such direct marketing communications from us, you can opt-out of receiving them by submitting your request using the contact details using the contact details set out at the end of this policy or using the opt-out mechanisms provided in the communications.
Do note that if you do opt-out of receiving marketing related communications from us, we may still send you important administrative messages, and you cannot opt-out from receiving administrative messages.
6 Contacting Us
If you have any enquiries regarding NTT Singapore’s Data Protection Policy or would like to contact us regarding how your personal information is being handled by NTT Singapore, please contact us via our contact details as provided below:-
NTT Singapore Pte Ltd
20 West Pasir Panjang Road
Mapletree Business City
Attention to: Data Protection Officer
Email to: firstname.lastname@example.org
Attention to: Data Protection Officer
Fax: +65 6438-3102
NTT Singapore may revise this Data Protection Policy from time to time. Any such revisions will be announced on this Web Site. Kindly take note to review this policy as well as any updates on a regular basis.
8 General Information
8.1 Guarantees and Limitation of Liability
NTT Singapore assumes no responsibility whatsoever for any and all claims, damages, losses, expenses, costs or liabilities (including without limitation, any direct, indirect, punitive, special, incidental or consequential damages or loss of profits) arising from the use of information taken from this website or from that of other companies that have placed links to their site on this website.
All contents contained in or accessed through NTT Singapore’s website are provided on an "as is" and "as available" basis and user agrees to use them at their sole risk. NTT Singapore expressly disclaim all warranties of any kind, whether express or implied, including implied warranties of merchantability, satisfactory quality, fitness for a particular purpose and non-infringement, to the fullest extent allowed by law.
Without prejudice to the foregoing, NTT Singapore make no warranty as to the accuracy, reliability or quality of any content or service obtained through this website or any defects therein will be corrected and that such content and access to them are error free and uninterrupted or available at all times.
8.3 Applicable Law
By accessing NTT Singapore’s website and online services, user agrees that such access and/or use, as well as this policy are construed in accordance with, and governed by the laws of the Republic of Singapore and hereby submits to the exclusive jurisdiction of the Singapore courts.