Data Privacy and Control Policy

Effective Date: 2nd January 2025

1. Introduction

Emergent.works (“we,” “us,” or “our”) is committed to respecting and protecting the privacy of individuals whose personal data we collect and process (“you” or “your”). This Policy explains how we handle your personal data in compliance with the Singapore Personal Data Protection Act (“PDPA”) and the European Union’s General Data Protection Regulation (“GDPR”).

2. Scope and Applicability

This Policy applies to:

• Personal data collected through our website at emergent.works (the “Website”);
• Personal data collected during our leadership and culture development programs;
• Data obtained via our professional or coaching services, which may involve psychometric tools such as Gallup CliftonStrengths (or other recognized providers).

By using our Website, participating in our services, or otherwise providing us with your personal data, you acknowledge that you understand and agree to the practices described in this Policy.

3. Definitions

• Personal Data: Any information that can identify or be used to identify an individual directly or indirectly (e.g., name, contact information, identification numbers, IP addresses).
• Processing: Any operation or set of operations performed on personal data, whether or not by automated means (e.g., collection, recording, organization, structuring, storage, adaptation, retrieval, consultation, use, disclosure, combination, restriction, erasure, or destruction).
• Data Controller: The party responsible for determining the purposes and means of processing personal data. Under this Policy, Emergent.works is the Data Controller.
• Data Processor: Any third party that processes personal data on behalf of the Data Controller.

4. What Personal Data We Collect

Depending on the nature of your interactions with us, we may collect the following types of personal data:

1. Contact Information: Name, address, email address, phone number, job title, and organization details.
2. Professional or Psychometric Data: Results or interpretations from tools such as Gallup CliftonStrengths (or other recognized psychometric tools), leadership assessments, feedback surveys, or coaching exercises.
3. Technical Data: IP addresses, browser type, operating system, and browsing history on our Website.
4. Communication Data: Correspondence and other information you share when communicating with us (e.g., emails or phone calls).

We will only collect personal data that is necessary for the purposes described in this Policy, or as otherwise required by applicable laws and regulations.

5. How We Collect Personal Data

• Directly from You: When you register for our events, sign up for newsletters, complete forms, participate in coaching sessions, or use psychometric tools under our facilitation.
• Automatically: Via cookies and similar technologies on our Website, which collect Technical Data.
• Third Parties: From partners or service providers who have obtained your consent or have a legal basis to share your data with us.

6. Purposes and Legal Bases for Processing

We process your personal data for the following purposes and rely on one or more of the following legal bases under the PDPA and GDPR:

1. Service Delivery
   • Purpose: To provide leadership development, coaching, and related services, which may include using Gallup CliftonStrengths or similar tools.
   • Legal Basis: Fulfillment of a contract or legitimate interests (where necessary to provide requested services).
2. Communications
   • Purpose: To respond to inquiries, provide requested information, or send updates about our services.
   • Legal Basis: Your consent, fulfillment of a contract, or our legitimate interests in maintaining communication.
3. Marketing and Events
   • Purpose: To send newsletters or marketing materials (where permitted by law), and to manage event registrations.
   • Legal Basis: Your explicit consent or our legitimate interests in marketing to existing or prospective clients, subject to applicable laws.
4. Website Functionality and Analytics
   • Purpose: To analyze traffic, enhance user experience, and maintain Website security.
   • Legal Basis: Our legitimate interests in ensuring our Website runs smoothly, or consent where required.
5. Legal and Regulatory Compliance
   • Purpose: To comply with legal obligations (e.g., tax and accounting requirements) or respond to lawful requests from authorities.
   • Legal Basis: Compliance with legal obligations, legitimate interests, or exercise of legal claims.

7. How We Share Your Personal Data

We may share your personal data with:

• Service Providers: For hosting, analytics, marketing, or psychometric testing (e.g., Gallup CliftonStrengths). Such providers are bound by confidentiality obligations.
• Professional Advisors: Including lawyers, auditors, and insurers, where necessary for the conduct of our business and compliance with legal obligations.
• Regulatory and Government Authorities: Where required by law or to protect legal rights.

We do not sell, rent, or trade your personal data to third parties for their own marketing use.

8. International Transfers

If we transfer your personal data outside of Singapore or the European Economic Area (EEA), we will ensure the recipient provides an adequate level of protection or that appropriate safeguards are in place. These may include:

• Contracts approved by relevant authorities (e.g., EU Standard Contractual Clauses);
• Transfer mechanisms recognized by the European Commission or by PDPC guidelines in Singapore;
• Your explicit consent to the transfer, where required.

9. Data Retention

We store personal data for as long as necessary to fulfill the purposes outlined in this Policy, unless a longer retention period is required or permitted by law. Once it is no longer needed, we will securely destroy or anonymize the data.

10. Your Rights

10.1 Under the GDPR

If you are located in the EEA, you have certain rights regarding your personal data, including:

• Right of Access: Obtain a copy of your personal data.
• Right to Rectification: Request corrections to inaccurate or incomplete data.
• Right to Erasure (“Right to Be Forgotten”): Request deletion of your data under certain conditions.
• Right to Restrict Processing: Ask us to limit how we use your data.
• Right to Data Portability: Receive your data in a structured, commonly used format.
• Right to Object: Object to processing of your data for direct marketing or under certain legitimate interests.
• Right to Withdraw Consent: Revoke consent at any time (without affecting the lawfulness of processing based on consent before its withdrawal).

10.2 Under the PDPA

If you are located in Singapore, you are entitled to:

• Right to Access: Request access to your personal data we hold.
• Right to Correction: Request corrections to ensure your data is accurate.
• Right to Withdraw Consent: Withdraw consent for the collection, use, or disclosure of your personal data.

To exercise these rights, please contact us at the details provided in Section 12. We may request additional information to verify your identity.

11. Data Security

We implement technical and organizational measures to protect your personal data from unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit (e.g., SSL/TLS).
• Access Controls to limit data access to authorized personnel.
• Regular Monitoring and security assessments to detect and prevent threats.

However, no internet transmission or storage system can be guaranteed to be 100% secure. You are responsible for keeping your account and login information confidential.

12. Contact Us

If you have any questions about this Policy, wish to exercise your rights, or have concerns about our data protection practices, please contact us at:

Emergent.works
Email: legal@emergent.works
Address:

152 Beach Road #02-08
Mypostebox [3058]
Singapore 189721

13. Updates to This Policy

We may update this Policy from time to time to reflect changes in our practices, technologies, or legal requirements. When we post changes, we will revise the “Effective Date” at the top. We encourage you to review this Policy periodically for any updates.

Disclaimer: This Data Privacy and Control Policy is for informational purposes only and does not constitute legal advice. Organisations should consult qualified legal counsel to ensure compliance with all applicable laws and regulations.

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