Privacy Policy

1 Introduction

This document describes the Privacy Statement of Delaware Consulting Asia Pacific Pte Ltd. In this document you can find more information about the processing of your Personal data. Delaware Consulting Asia Pacific Pte Ltd (“delaware”, “we” or “us”) attaches great importance to your privacy. We seek your Personal Information in a lawful, appropriate and transparent process in accordance with the Singapore Personal Data Protection Act (“PDPA”) and any national legislation adopted on the basis of the PDPA. With this Privacy Statement we want to emphasize this commitment.

Please take the time to review this Privacy Statement and better understand which categories of your Personal Data delaware processes. We also explain on which legal basis delaware processes your Personal Data, for what specific purposes and to whom we transfer this data.

This Privacy Statement also describes your rights to data protection, including the right to raise objections against (certain) processing activities that we carry out, and explains how you can exercise these rights in accordance with the applicable Privacy regulation. To exercise your rights, you can send a request to us by contacting us at dsg_privacy@delaware.pro.

2 What is the scope of the Privacy statement and for whom they intended?

delaware Singapore is a company incorporated under Singapore law, with registered office at 2 Leng Kee Road, #05-05, Thye Hong Centre, Singapore159086, (Company Registration Number: 201128369M).

In all situations described in this Privacy Statement, delaware will process your Personal Data as a Data Controller. That is, we determine the purposes and means of processing this Personal Data ; in other words, we determine the 'how' and the 'why' of it.

This Privacy Statement is intended for all Employees, visitors to the delaware website, job applicants as well as all (potential) service providers and customers of delaware.

For purposes of this Privacy Policy, we are considered as a delaware Affiliate or any other entity that exercises control over, controlled by or under common control as delaware. For the purposes of this definition, "control" means the direct or indirect power to direct the business of an entity through at least 40% of the stock, voting rights, equity or economic interest in that entity.

When you visit the sub-domain of a particular Delaware Affiliate (for example, the delaware Belgium sub-domain), delaware will transfer your Personal Data to the relevant delaware Affiliate, which will also process your Personal Data as the controller responsible for the processing. Such processing will either take place in accordance with what is described in this Privacy Policy or have, if appropriate, in accordance with a separate Privacy Policy that is applicable at the sub-domain in question.

This Privacy Statement is based on the terms of the Personal Data Protection Regulations 2021 on the protection of individuals with regard to the processing of personal data and on the free movement of such data ( the " PDPA "), as well as any other legislation and/or regulation introduced on the basis of the PDPA and the e-Privacy legislation, or which implements, amends, supersedes or consolidates this or any of them and any other applicable legislation regarding the processing of Personal Data and privacy.

Personal data refers to any information about an identified or identifiable natural person. This includes, for example, your name, your photo, your phone number, your email address, your bank account number, etc.

Processing is defined as an operation or set of operations with respect to (a set of) Personal information, whether or not implemented through automated processes, such as collection, recording, organization, structure, store, update, modify, retrieve, consultation, use, provide by transmission, dissemination or otherwise make available, align or combine, shield, erase or destroy data.

3 When and why do we process your Personal Data?

3.1 When you visit the website

When you visit the delaware website, we collect a limited amount of Personal Data that is necessary for the management and functioning of the website. With your permission, we also collect other Personal Information, for example, to optimize the user experience on our website or for analytical and statistical purposes.

We therefore ask you to read our Cookie Statement under “Cookie Settings” at the bottom of our website - www.delaware.pro/en-sg. The Cookie Statement explains what cookies are, which cookies delaware uses and how you can change your cookie preferences.

3.2 For the organization of physical and virtual events

From time to time delaware may organize physical and virtual events, such as physical seminars or workshops and online webinars, where you either can register via a special form on the website, or whether it is by sending an e-mail to DSG_Marketing@delaware.pro or through any other registration method. In this context, we process your Personal Data for the purpose of organizing and managing the event, and to be able to provide you with further necessary information about this.

The table below describes the categories of data we process for these purposes, where your data comes from, the basis for this processing activity and with whom we may share the data.

Categories of processed data

Source of the data

Lawful ground for processing

Data Recipients

First name, Last name, Company name, Phone number, E-mail address, Job title

Directly from you at registration

Necessary for delaware's legitimate interests as an event organizer

- Third parties that provide support to organize events

- IT service providers

3.3 Downloading e-books and other online marketing materials

From time to time, delaware makes online materials, including e-books available for download through its website. When you choose to download this online material, we ask for your explicit consent to process your Personal Data for marketing purposes, including providing you with the material in question, as well as possibly for statistical and analytical purposes.

The table below describes the categories of data we process for these purposes, where your data comes from, the basis for this processing activity and with whom we may share the data.

Categories of processed data

Source of the data

Lawful ground for processing

Data Recipients

First name, Last name, Company name, E-mail address, Phone number

Directly from you via the eBook or other material download form

Your express consent

- IT service providers

3.4 Direct marketing

If you have expressly consented to receive our newsletters or marketing communications, we may, from time to time, contact you with information about our services, products and latest offers and process your Personal Data for this purpose. delaware Affiliates may also contact you for this purpose if you have expressly given permission for this.

If you no longer wish to receive our newsletters or marketing communications, please let us know by emailing to dsg_privacy@delaware.pro. You can also unsubscribe from our marketing emails by clicking the unsubscribe link in the emails sent to you.

Categories of processed data

Source of the data

Lawful ground for processing

Data Recipients

First name, Last name, Company name, Position, E-mail address, Telephone number, Interests

Directly from you via the delaware website or via email

Your express consent

- Marketing service providers

- IT service providers of delaware Affiliates

3.5 When you contact us

The delaware website contains a Contact Us form through which you can contact delaware, for various purposes. The section below shows information about how delaware processes your Personal Data.

3.5.1 Via the general contact form

If you have a specific question or request, or if you want to report something to delaware or respond to something, you can contact us via the general contact form on our website (link here). In this context, we process your Personal Data for the purpose of managing the various requests for information, including to answer your questions, whether or not a particular request is granted and following up on your responses. This processing also takes place for the purpose of planning our activities.

The list below describes the categories of data we process for these purposes, where your data comes from, the basis for this processing activity and with whom we may share the data.

Categories of processed data

Source of the data

Lawful ground for processing

Data Recipients

First name, Last name, Phone number, E-mail address, Country, Company, Position, Request or Questions

Directly from you via the contact form

It is in delaware's legitimate interest as a company to be able to properly respond to the questions, requests, and/or any complaints about which delaware is contacted, given the fact that we always ensure that your interests are protected.

- IT service providers

- delaware Affiliate(s)which your request for contact, directly or indirectly related

3.6 Social media

We may process the Personal Data obtained through social media platforms (including Facebook, Instagram, LinkedIn and Twitter) when something is delaware- related or addressed to delaware in order to (i) provide a first-line response to questions or complaints, (ii) monitor our online reputation, (iii) integrate the testimonials about delaware and our services that you make public into our internal and external communications, and ( iv ) to improve our products and/or services and identify opportunities that delaware can focus on.

Certain of our social media web pages allow users to post their own material. Please remember that all material posted on our social media is accessible to - and thus can be seen by - the public. You should therefore be careful about disclosing certain personal information such as financial information or address details via such platforms. We are not responsible for any action taken by third parties when you post personal information on one of our social media platforms, for example Facebook or Instagram. We also refer to the privacy and cookie statements of the platforms you use.

The list below describes the categories of data we process for these purposes, where your data comes from, the basis for this processing activity and with whom we may share the data.

Categories of processed data

Source of the data

Lawful ground for processing

Data Recipients

First Name, Last Name, User Name, Email address and any other Personal data given which is certainly relevant for the purposes described above and that you share with us if you publish on social media

Directly from you through publicly accessible social media pages

It is in delaware's legitimate interests as a company to process the Personal Data that you have chosen to provide to us or which you have made publicly available through social media platforms for the purpose of improving the services, identifying business opportunities and to strengthen our internal and external communication, given the fact that we always ensure that your interests are also safeguarded in this regard.

- IT service providers

- The recipients of our communication

- delaware Affiliate(s) showing what you share on social media, directly or indirectly related

3.7 When you apply for a job at delaware

When you sent a job application (via the delaware website or a third party website; such as LinkedIn, MyCareersFuture etc.) your Personal Data will be processed for recruitment purposes, administration and management of our (future) employees.

However, if your application is unsuccessful (for example, if the vacancy has already been filled), your Personal Data will be retained by delaware for a period of 24 months thereafter. This allows us to keep you posted on other suitable opportunity that might come along. After the expiry of this period, we will remove your data in our database.

3.7.1 Recruitment purposes

delaware shall gather and process your personal data for the purpose of recruitment, administration and management (future) employees.

The table below describes the categories of data we process for these purposes, where your data comes from, the basis for this processing activity and with whom we may share the data

Categories of processed data

Source of the data

Lawful ground for processing

Data Recipients

Full name, Portrait photo, Date of Birth, Nationality, Gender, Marital Status, Dependents details, Residential Address, E-mail, Telephone number, NRIC, FIN, Bank Account, Passport, Emergency Contact details, Education and studies, Professional history,

Any Personal Data you include in the CV you submit to delaware, Any Personal Data you include in the Cover letter you provide to delaware;

Any Personal Data that you additionally voluntarily provide to delaware;

Any Personal Data that you share publicly on social media (e.g. on LinkedIn)

- Directly from you via the application form on the delaware website;

- Directly from you through an application form on LinkedIn;

- Directly from you through phone calls, emails and other communications;

- Directly from you during job interviews;

- Directly from you via social media, such as LinkedIn;

- Indirectly through recruiters and headhunters

- Your explicit consent when submitting your application;

- Necessary to take steps prior to entering into an agreement with delaware;

- Delaware's legitimate interests, including pursuing its commercial activities and objectives, complying with applicable guidelines, standards, and codes of conduct, improving delaware’s business and offerings, protecting its business, shareholders, employees, and customers of delaware, the establishment, exercise or defense of any legal claim; and analysis of market competition.

- Service providers, to enable delaware to provide, develop, monitor and improve its operations and operations;

- Companies or persons that you have provided as a reference as an applicant;

- Certain regulated professions, such as lawyers, notaries and accountants, to ensure compliance with the legal obligations imposed delaware subject and / or for the establishment, exercise or defense of legal claims

3.7.2 Purposes of compliance with legal obligations

Your Personal Information may be processed to meet legal and regulatory obligations that are required under the applicable laws, regulations.

The table below describes the categories of data we process for these purposes, where your data comes from, the basis for this processing activity and with whom we may share the data.

Categories of processed data

Source of the data

Lawful ground for processing

Data Recipients

First name, Last name, E-mail address, Telephone number, Country, Education and studies, Date of birth, Professional history,

All Personal Data you include in the CV you submit to delaware,

All Personal Data you include in the Cover letter you submit to delaware;

All Personal Data that you additionally voluntarily provide to delaware

- Directly from you via the application form on the delaware website;

- Directly from you through an application form on LinkedIn;

- Directly from you through phone calls, emails and other communications;

- Directly from you during interviews;

- Indirectly through recruiters and headhunters

Necessary for compliance with legal obligations required by delaware under applicable laws, regulations or decisions of the competent national authorities and other governmental bodies (such as, for example, obligations under labor and social security legislation)

- Service providers, to enable delaware to provide, develop, monitor and improve its operations and operations;

- Certain regulated professions, such as lawyers, notaries and accountants, to ensure compliance with the legal obligations imposed delaware subject and / or for the establishment, exercise or defense of legal claims;

- Public entities, with a view to compliance with legal obligations to which delaware is subject and / or for the establishment, exercise or defense of legal claims

3.8 When you are a (potential) customer of delaware or an employee thereof

3.8.1 Processing by delaware as data controller for the management and administration of an existing or future customer relationship

delaware processes Personal Data of contact persons and its customers for business and administrative purposes, including in particular (i) managing the relationship with the (potential) customer; (ii) submitting project proposals to the (potential) customer; (iii) the execution of the agreement with the customer or taking measures prior to the conclusion of this agreement ; (iv) protecting delaware's economic interests and ensuring compliance and reporting (such as complying with our applicable policies and legal obligations, managing suspected misconduct or fraud, conducting audits, and exercising or defending legal claims ; (v) managing mergers and acquisitions involving delaware; (vi) archiving and record keeping; (vii) billing purposes.

The table below describes the categories of data we process for these purposes, where your data comes from, the basis for this processing activity and with whom we may share the data.

Categories of processed data

Source of the data

Lawful ground for processing

Data Recipients

First name, Last name, Phone number, E-mail address, Country, Company, Position; Any other Personal Data that you voluntarily provide to us

- Directly from you via email, telephone, the delaware website or in other communications;

- Indirectly via the customer you are an employee of

It is in the legitimate interest of Delaware as a company in a proper manner to customer acquisition , customer administration to do and customer management, as well as a proper way to give effect to the agreements it has concluded with its customers

- IT Service Providers

- delaware Affiliate(s)with whom you or the company you work for, as (potential) customer is a business or administrative relationship

3.8.2 Processing by delaware as data controller for marketing purposes

delaware processes Personal Data of contacts and its existing customers, provided that such Personal Data was obtained directly from those contacts, to provide delaware products and services similar to those previously purchased by the customer from delaware.

You have the right, without charge and without giving any reason, to inform us that you no longer wish to receive marketing communications. If you no longer wish to receive our newsletters or marketing communications, please let us know by emailing dsg_privacy@delaware.pro. You can also unsubscribe from our marketing emails by clicking the unsubscribe link in the emails sent to you.

The table below describes the categories of Personal Data we process for these purposes, where your data comes from, the basis for this processing activity and with whom we may share the data.

Categories of processed data

Source of the data

Lawful ground for processing

Data Recipients

First name, Last name, Phone number, E-mail address, Country, Company, Position; Any other Personal Data that you voluntarily provide to us

- Directly from you in the context of the sale of a product or service

It is in delaware's legitimate interests as a company to market to its existing customers.

- IT Service Providers

- Marketing service providers

- delaware Affiliate(s)with whom you or the company you work for, as (potential) customer is a business or administrative relationship

3.9 When you are a supplier of delaware or an employee thereof

delaware processes Personal Data of contact persons and its suppliers for business and administrative purposes, including in particular (i) managing the relationship with the (potential) supplier; (ii) the performance of the agreement with the supplier or taking steps prior to the conclusion of this agreement; (iii) protecting delaware's economic interests and ensuring compliance and reporting (such as complying with our applicable policies and legal obligations, managing suspected misconduct or fraud, conducting audits, and exercising or defending legal claims, (iv) the management of mergers and acquisitions which delaware is in question; (v) the archiving and tracking of data; (vi) aims of invoicing.

The table below describes the categories of Personal Data we process for these purposes, where your data comes from, the basis for this processing activity and with whom we may share the data.

Categories of processed data

Source of the data

Lawful ground for processing

Data Recipients

First name, Last name, Phone number, E-mail address, Country, Company, Position; Any other Personal Data that you voluntarily provide to us

- Directly from you via email, telephone, the delaware website or in other communications;

- Indirectly via the customer you are an employee of

It is in the legitimate interest of delaware as a company in a proper way to do customer acquisition, customer administration and customer management, as well as a proper way to give effect to the agreements it has concluded with its customers

- IT Service Providers

- delaware Affiliate(s)with whom you or the company you work for, as (potential) customer is a business or administrative relationship

4 How is your Personal Data shared with third parties?

We only share information and make information known only, - as described in this Policy.

Your Personal Data will also be shared with government authorities and/or police officers when this is necessary for the purposes described above, when this is required by law or when this is necessary for the legal protection of the legitimate interests of the Controller in accordance with applicable law.

5 Are your Personal Data transferred outside Singapore?

For the purposes described in this Privacy Statement, your data will typically be held within Singapore or will only be transferred outside Singapore to a country or countries that the Singapore Government has recognized as providing an appropriate level of data protection. In the event that your data should nevertheless be transferred to or stored in a country outside Singapore that is not recognized as providing an adequate level of protection, delaware will take appropriate security measures to ensure that the transfer complies with the requirements of the Data Protection Legislation.

If you would like more information about how delaware applies the above in relation to your Personal Data, please contact us at dsg_privacy@delaware.pro.

6 How long will we keep your Personal Data ?

We will retain your Personal Data for as long as necessary to fulfill the processing activities listed in this Privacy Statement, as long as you have been otherwise notified or as long as permitted by applicable law.

7 What are your rights and how can you exercise them?

In principle, you can exercise these free of charge, subject to legal exceptions. These rights may be limited, for example where complying with a request would reveal Personal Data of another person, or where you ask us to delete information that we are required by law to keep or that we keep based on our legitimate interests. To exercise your rights, please contact us at dsg_privacy@delaware.pro or by post at the following address: delaware Consulting Asia Pacific Pte Ltd, for the attention of the Privacy Coordinator, 2 Leng Kee Road, Thye Hong Centre, #05-05, Singapore 159086.

If you contact us to exercise your rights, we will reply within 1 month. Exceptionally this can take longer (up to a maximum of 3 months in total ), but then we will let you know within 1 month why this is so. Whether or not you can exercise your rights depends on the processing and the legal basis.

We ask you to ensure that it is always clear which law you want exactly to exercise and how (e.g. E-mail, postal mail, verbal, ...) you want to get the information. Keep in mind that in certain cases we may need more information. We want to make sure we help the right person.

If you still have unanswered concerns, you always have the right to submit a complaint to the supervisory authority. Of course we encourage you to first come to us but to the extent that this right applies to you is you are entitled to direct the supervisory authority complain.

7.1 Right to access and correct your Personal Data

You have the right to access, evaluate and rectify your Personal Data. You are entitled to ask us for a copy of your information, to evaluate and/or improve it. If you want to straighten information such as your name, email address, address and / or any other information or preferences, you can easily do so by contacting us via dsg_privacy@delaware.pro You may also ask us for a copy of the Personal Data that we process, as described in this Privacy Statement.

7.2 Right to object

Under certain circumstances described in the privacy regulation, you may object to the processing of your Personal Data, including where your personal data are processed, purposes of direct marketing, and possibly because of your specific situation related reasons when delaware processed your personal data under the legitimate interests of delaware or of a third party .

7.3 Right to withdraw your consent

At any time and at your own initiative you may choose to contact us to withdraw permission via dsg_privacy@delaware.pro. Withdrawing your consent will not affect the lawfulness of processing based on your consent prior to such withdrawal.

7.4 Right to Restrict Processing

Under certain circumstances described in the privacy regulation, you may ask us to limit the processing of your personal data. This is the case, for example, when you dispute the accuracy of your Personal Data. In such case, we will restrict the processing until we are able to verify the accuracy of your data.

7.5 Right to erasure

In accordance with the privacy regulation you have the right to remove your personal data processed by us as described in this Statement, in case they are no longer necessary for the purposes for which the data was initially collected and processed, or in the event that you have withdrawn your consent or objected to a processing described in this Privacy Statement and there is no other basis for processing. If you wish to have your Personal Information erased, you can submit a request via dsg_privacy@delaware.pro.

7.6 Right to portability of Personal data

When processing your Personal Information made via automated processes and is based on your consent or in the performance of a contract between you and us, you have the right to receive the processed personal data in a structured, standard and by a machine-readable form and to transfer it to another service provider.

8 Does this Privacy Statement apply to third-party websites?

When you click on a link from a third party website, you will be taken to a website over which we have no control and our Privacy Statement will no longer apply. Your browsing and interaction on any other website is subject to the terms of use and privacy and other statements of such third party websites. We recommend that you carefully read the privacy statements of other websites. delaware is not responsible or liable for the information on or the content of the websites of third parties.

9 What happens if delaware changes this Privacy Statement?

delaware reserves the right to amend this Privacy Statement as and when needed. Where this entails a fundamental change to the processing or where the changes are relevant to the nature of the processing or are relevant to you and affect your data protection rights, we will draw your attention to this. The latest version of this Privacy Statement can always be found in our website under “Privacy Policy” (link here).

10 How to contact delaware ?

If you have questions, comments, requests or complaints about this Privacy Policy or the processing of your Personal Information by delaware, you can also contact the Privacy Coordinator delaware :

- or by post to the following address:

delaware Consulting Asia Pacific Pte Ltd
to the attention of the Privacy Coordinator
2 Leng Kee Road, #05-05
Singapore 159086

- or by e-mail to the following address: dsg_privacy@delaware.pro