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This Policy sets out the manner in which   MINDGEN PTE. LTD collects, uses, manages and protects Personal Data (as defined below) in compliance with the provisions of the Personal Data Protection Act 2012 (“PDPA”).


This Policy applies to all Individuals (as defined below) who provide MINDGEN PTE. LTD. with Personal Data or whose Personal Data is otherwise collected, used and/or disclosed by MINDGEN PTE. LTD. in connection with and/or for the purposes of its operations.


MINDGEN PTE. LTD. may from time to time update this Policy to ensure it is consistent with its future developments or business purposes or to accommodate future changes to applicable legal or regulatory requirements. All updates to this Policy will be published at (“MINDGEN PTE. LTD. Website”) and appropriate notifications of any material revisions will be published on the MINDGEN PTE. LTD. Website and may be issued separately to relevant persons such as may be determined by MINDGEN PTE. LTD.Subject to an Individual’s rights at law, the prevailing terms of the Policy from time to time shall apply. By continuing their relationship with MINDGEN PTE. LTD. after any amendments have been introduced and published on the MINDGEN PTE. LTD. Website, Individuals shall be deemed to have accepted the Policy as amended.


For the avoidance of doubt, this Policy forms part of the terms and conditions, if any, governing an Individual’s specific relationship with MINDGEN PTE. LTD. (“Terms and Conditions”) and should be read in conjunction with such Terms and Conditions. In the event of any conflict or inconsistency between the provisions of this Policy and the Terms and Conditions, the provisions of the Terms and Conditions shall prevail to the fullest extent permissible by law.


Definitions: For purposes of this Policy:“Individual” means a natural person, whether living or deceased and “Individuals” shall be construed accordingly ;“CCTV” means Closed-circuit Television;Personal Data means data that is capable of identifying an Individual, whether on its own or in conjunction with other data accessible to MINDGEN PTE. LTD.;“Personnel” means any Individual engaged under a contract of service with MINDGEN PTE. LTD., a contract for service with MINDGEN PTE. LTD., permanent or temporary employees as well as trainees and interns engaged by MINDGEN PTE. LTD. from time to time; and“Potential Personnel” means any Individual who has submitted an application to be engaged by MINDGEN PTE. LTD. as Personnel.


Personal Data collected by MINDGEN PTE. LTD.

MINDGEN PTE. LTD. will only collect, use or disclose Personal Data about an Individual which it reasonably considers necessary for the relevant purposes underlying such collection, use or disclosure. Depending on the specific nature of an Individual’s interaction with MINDGEN PTE. LTD., Personal Data which MINDGEN PTE. LTD. collects, uses or discloses concerning an Individual may variously include but is not limited to the following:

  1. the Individual’s name, gender and contact particulars, including telephone number(s), residential/mailing address(es) and email address;

  2. details of the Individual’s identification documents (such as, NRIC or passport numbers), and applicable visa or permits (such as employment pass, work permit, permanent residency status);

  3. details of the Individual’s employment history and academic qualifications;

  4. the name and contact particulars of the Individual’s next-of-kin;

  5. the Individual’s network usage data and other information gathered automatically by our computer systems, including the Individual’s computer IP address, links visited and other activities conducted online or using our computer systems;

  6. photographs and video or CCTV recordings of the Individual; and

  7. other information which the Individual may provide to MINDGEN PTE. LTD., from time to time, in the course of such Individual’s interaction with MINDGEN PTE. LTD..


How MINDGEN PTE. LTD. collects Personal Data

Generally, MINDGEN PTE. LTD. may collect Personal Data from an Individual in one or more of the following ways or circumstances:

  1. when the Individual interacts with MINDGEN PTE. LTD.’s staff via telephone calls, emails, other correspondence and/or face-to-face meetings;

  2. when the Individual visits MINDGEN PTE. LTD.’s premises;

  3. when the Individual specifically requests that MINDGEN PTE. LTD. contact him or her or requests to be included in an email or any mailing list maintained by MINDGEN PTE. LTD.;

  4. when the Individual responds to any request by MINDGEN PTE. LTD. for the provision of Personal Data;

  5. when MINDGEN PTE. LTD. receives references or referrals from its business partners or other third parties;

  6. when the Individual attends or participates in any event organised by MINDGEN PTE. LTD.;

  7. when the Individual submits his or her Personal Data to MINDGEN PTE. LTD. pursuant to a job application;

  8. when the Individual subscribes to MINDGEN PTE. LTD.’s publication(s); and/or

  9. when the Individual submits his or her Personal Data to MINDGEN PTE. LTD. for any other reason related to MINDGEN PTE. LTD.’s ordinary course of business operations.


Purposes of collection, use and disclosure of Personal Data

Generally, MINDGEN PTE. LTD. collects, uses and/or discloses Personal Data from Individuals for one or more of the following purposes:

Provision of services

  1. administering and managing the Individual’s relationship with MINDGEN PTE. LTD.;

  2. providing the Individual with information about MINDGEN PTE. LTD.’s services and/or the services of any external vendor that is providing services or products in partnership or collaboration with MINDGEN PTE. LTD.;

  3. responding to the Individual’s complaints, queries and/or requests;

  4. facilitating and/or organising events;

  5. informing the Individual of changes and/or updates to MINDGEN PTE. LTD.’s policies, terms and conditions and/or other administrative information;


Third-party sites

Our Site or our communication with you may from time to time contain links to third-party websites over which we have no control. If you follow a link to any of these websites, please note that they have their own practices and policies. We encourage you to read the privacy policies or statements of these websites understand your rights. We accept no responsibility or liability for any practices of third-party websites.


Security measures

  1. verifying the Individual’s identity or monitoring the Individual’s activities, including without limitation via CCTV observation and/or recording;

  2. preventing, detecting and investigating fraud, misconduct, any unlawful action, omission or dispute, and whether or not there is any suspicion of the aforementioned;

General business operations of MINDGEN PTE. LTD.

  1. staff training, quality assurance and performance evaluation;

  2. record-keeping;

  3. compliance purposes (including but not limited to the Individual obtaining corporate governance advice);

  4. meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines which are binding on MINDGEN PTE. LTD. (including but not limited to responding to regulatory complaints, disclosure to regulatory bodies and conducting audit checks, due diligence and investigations);

Managing Personnel and Potential Personnel

  1. administering, managing and/or terminating MINDGEN PTE. LTD.’s relationship with Personnel and Potential Personnel;

  2. evaluating the performance of Personnel;



where MINDGEN PTE. LTD. circulates MINDGEN PTE. LTD.’s publications or marketing information to an Individual or to any person which may be disseminated to and individual relating to services offered by MINDGEN PTE. LTD. (whether by MINDGEN PTE. LTD. or MINDGEN PTE. LTD.’s business partners) which MINDGEN PTE. LTD. thinks is or may be of benefit or interest to him/her via postal mail, electronic transmission to his or her or any email address(es), and/or voice call or phone call and/or fax to his or her or any telephone number(s);

for promotional and publicity purposes, including recording or taking photographs of participants at events or functions organised, hosted or participated by MINDGEN PTE. LTD.;


  1. for transfer to third party data intermediaries to facilitate any of the aforesaid purposes;

  2. for any purposes reasonably related to any of the above purposes; and

  3. for any other purposes in relation to which MINDGEN PTE. LTD. has specifically obtained the Individual’s consent.



 Unless otherwise authorised under the PDPA or any other applicable law, MINDGEN PTE. LTD. will not collect, use or disclose an Individual’s Personal Data without his or her consent .MINDGEN PTE. LTD. will take reasonable steps to highlight the purposes relevant to an Individual, by appropriate means, at the point or time of collection of the Personal Data from such Individual, including:

via express provisions in contracts, application forms and/or registration forms to be signed with or submitted to MINDGEN PTE. LTD.;

via notifications on MINDGEN PTE. LTD.’s websites;

in the course of verbal communications;


Where feasible, MINDGEN PTE. LTD. will inform the Individual of purposes that are intrinsic to the relationship between MINDGEN PTE. LTD. or to the provision of services to such Individual, as well as purposes that are optional.


In so far as any purpose(s) are intrinsic to the relationship or provision of services, MINDGEN PTE. LTD. reserves the right to decline to engage in the relevant relationship or to provide the relevant services to the Individual if he or she does not consent to MINDGEN PTE. LTD.’s collection, use or disclosure of his or her Personal Data for such purpose.


Individuals who:


MINDGEN PTE. LTD. voluntarily provide their Personal Data to MINDGEN PTE. LTD. for the specified purposes;

use or access MINDGEN PTE. LTD.’s website(s) or computer network;

enter MINDGEN PTE. LTD.’s premises or using any of the facilities thereon; and/or

attend or participate in events or programmes organised by MINDGEN PTE. LTD.

will be deemed to agree and consent to MINDGEN PTE. LTD. collecting, using and/or disclosing their Personal Data in the manner and for the purposes set forth in this Privacy Policy.


An Individual who provides MINDGEN PTE. LTD. with Personal Data relating to a third party (e.g. information of his or her spouse or children) for any particular purpose, represents to MINDGEN PTE. LTD. that he/she has obtained the consent of the relevant third party to MINDGEN PTE. LTD. collecting, using or disclosing such Personal Data for the relevant purpose.


In so far as MINDGEN PTE. LTD. collects Personal Data of an Individual from any third party(ies), MINDGEN PTE. LTD. will take reasonable steps to inform the relevant third party(ies) of MINDGEN PTE. LTD.’s purposes for collecting the Personal Data and to verify that consent from the Individual has been obtained by the relevant third party(ies) to such disclosure for the intended purpose.



Disclosure of Personal Data

 In carrying out one or more of the above Purposes, MINDGEN PTE. LTD. may need to disclose Individuals’ Personal Data to the following third parties for one or more of the above Purposes:

to MINDGEN PTE. LTD.’s third party service providers or agents;

any external vendor MINDGEN PTE. LTD.;

to MINDGEN PTE. LTD.’s auditors and professional advisors;

any person to whom disclosure is permitted or required by any statutory provision or law;

any permitted assigns; and/or

to any local or foreign regulatory body, government agency, statutory board, ministry, department or other government body and/or its officials.


Withdrawal of Consent

 Any Individual who wishes to withdraw his or her consent to any use or disclosure of his or her Personal Data by MINDGEN PTE. LTD. as set out in this Policy may do so by contacting MINDGEN PTE. LTD.’s Data Protection Officer at .Depending on the extent to which an Individual withdraws consent to the use or disclosure of his or her Personal Data by MINDGEN PTE. LTD., such withdrawal of consent may result in MINDGEN PTE. LTD.’s inability to provide services to the Individual and may be considered as a termination by the Individual of any agreement between MINDGEN PTE. LTD. and the Individual. MINDGEN PTE. LTD.’s legal rights and remedies are expressly reserved in such event. In so far as an Individual’s data is being collected by cookies, the Individual may disable the use of cookies on his or her internet browser when accessing MINDGEN PTE. LTD.’s Website. However, this may result in the loss of functionality, restrict the Individual’s use of the website and/or delay or affect the way in which MINDGEN PTE. LTD.’s website operates.


Verification of Personal Data & Notification of Changes

Where feasible, MINDGEN PTE. LTD. will take reasonable steps to verify the accuracy of Personal Data received at the point of collection but Individuals remain primarily responsible and liable to ensure that all Personal Data submitted by them to MINDGEN PTE. LTD. is complete and accurate. Information voluntarily provided by an Individual to MINDGEN PTE. LTD. shall prima facie be deemed complete and accurate. MINDGEN PTE. LTD. will also take reasonable steps to periodically verify Personal Data in its possession, taking into account the exigencies of its operations, but Individuals are nonetheless responsible for notifying MINDGEN PTE. LTD., from time to time, of any applicable changes to such Personal Data. MINDGEN PTE. LTD. shall not be held liable for any inability on its part to provide services to an Individual who fails to ensure that his or her Personal Data submitted to MINDGEN PTE. LTD. is complete and accurate or who fails to notify MINDGEN PTE. LTD. of any relevant changes to such Personal Data.


Protection of Personal Data.

MINDGEN PTE. LTD. shall make reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks to Personal Data in its possession.


If MINDGEN PTE. LTD. transfers Personal Data outside Singapore, MINDGEN PTE. LTD. will take reasonable steps to ensure that such Personal Data transferred receives a standard of protection comparable to the protection received under the PDPA and such transfer shall be subject to this Policy.MINDGEN PTE. LTD. will ensure that third parties who receive Personal Data from MINDGEN PTE. LTD. protect such Personal Data in a manner consistent with this Policy and not use such Personal Data for any purposes other than those specified by MINDGEN PTE. LTD., by incorporating appropriate contractual terms in its written agreements with these third parties.MINDGEN PTE. LTD. is not responsible in any way for the security and/or management of Personal Data shared by Individuals with third party websites accessible via links on MINDGEN PTE. LTD.’s website.


Contacting MINDGEN PTE. LTD.-Access and Correction of Personal Data

Any Individual who:


has questions or feedback relating to this Policy;

would like to obtain access to his or her Personal Data held by MINDGEN PTE. LTD.;

would like to obtain information about the ways in which his or her Personal Data held by MINDGEN PTE. LTD. has been or may have been used or disclosed by MINDGEN PTE. LTD. in the year preceding the request; and/or

would like to update or make corrections to his or her Personal Data held by MINDGEN PTE. LTD.,

should contact MINDGEN PTE. LTD.’s Data Protection Officer at


Individuals should note that MINDGEN PTE. LTD. is not required, under the PDPA, to provide access and correction to Personal Data in certain exempted situations as set out in the PDPA.


The PDPA allows and MINDGEN PTE. LTD. reserves the right to charge a reasonable fee for the handling and/or processing of access requests by an Individual pursuant to paragraphs (b) or (c) above.



Governing Law

This Policy shall be governed by and construed in accordance with the laws of Singapore. Any dispute arising out of or in connection with this Policy including any question regarding its existence, validity or termination, shall be referred to and finally resolved by the Courts of Singapore.

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