TeamSpirit Inc. and its group companies (which means its holding company, its subsidiaries, and any subsidiary of its holding company from time to time) (collectively “TeamSpirit” or “we” or “us”) may need to collect personal data (which means any data, whether true or not, about any person who can be identified from that data) from time to time in the course of its business. This includes the personal data of individuals to whom we provide, whether directly or indirectly, any product and/or service.

This Privacy Policy (“Policy”) contains the details of how TeamSpirit will collect, use, disclose, or otherwise manage your personal data in compliance with the Singapore Personal Data Protection Act (“SGPDPA”). This Policy applies to all persons to whom SGPDPA is applicable and whose personal data comes into
our possession or under our control.

TeamSpirit may amend this Policy from time to time without prior notification to you.

1. How TeamSpirit handles your personal data

Depending on the nature of your interaction with us, some
Examples of personal data which we may collect include your
name, company name, address, job title, department and
billing and contact details such as phone number and email address, billing address.

(1) Collection of Personal Data

We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data
to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by any applicable laws.

(2) Purpose of collecting and using Personal Data

We may collect and use your personal data for any or all of the following purposes (collectively, the “Purposes”):

A. Customer Information

  • To provide our services
  • To send information about ourselves and/or our partners at events
  • To send newsletter or latest information about our service and/or company
  • To collect service fees upon confirmation of financial requirement
  • To improve our service quality and investigate technical issues

B. Marketing/ Prospect Information

  • To provide our services
  • To send information about ourselves and/or our partners at events
  • To send newsletter or latest information about our service and/or company
  • To collect service fees upon confirmation of financial requirement
  • To improve our service quality and investigate technical issues

C. Web Visitor Information

  • To analyse usage of website and/or service, and to improve service quality
  • To promote our services through marketing activities

D. Event Participant Information

  • To send information about ourselves and/or our partners at events
  • To send newsletter or latest information about our service and/or company
  • To provide lead information to those companies who co-organized or sponsored the event (this means we provide personal information to the third party)
  • To achieve the above, collected personal data may be provided to a third party to enable them to contact customers regarding our services or seminars.

E. Customer Information collected via Inquiry

  • To answer customer queries

F. Information received from customers for processing

  • To discharge our contractual obligations to a customer in connection with the supply of any goods or services

(3) Disclosure of Personal Data

  1. The disclosure of your personal data may be made by TeamSpirit to any person (whether located or resident within or outside Singapore) who has a “need to know” such personal data.

Such persons may include:

  • employees, officers, directors and agents of TeamSpirit;
  • TeamSpirit’s professional advisors such as lawyers and auditors;
  • third party vendors engaged to provide services or facilities to TeamSpirit, such as processing of expenses, payrolls and data, data processing, market research and hosting of TeamSpirit’s system on Saleforce.com Co., Ltd.’s cloud servers located in Japan;
  • any regulatory authority, government, dispute resolution or statutory body in any jurisdiction when required by applicable laws in such jurisdiction.
  1. In addition to the above, TeamSpirit may disclose your personal data to a third party without your prior consent:
  • If required or permitted by applicable laws and regulations
  • If required to protect an individual’s life, health or property and it is difficult to obtain a consent from the person who provided the information
  1. The personal data described under clause “1(2) D Event Participant Information” will be disclosed in the following manner:
  • Method of disclosure: Electronically
  • Information disclosed: Company/Organisation Name, Department, Job Title, Name, Address, Postal Code, Telephone Number, Fax Number, Email Address, Number of Employees

If your personal data is transferred to third parties outside of Singapore, we will take appropriate steps to ensure that the recipient is bound by legally enforceable obligations so as to provide to your transferred personal data a standard of protection that is at least comparable to that under the SGPDPA.

  1. We will suspend the disclosure of personal data to third parties in accordance with clauses 3(1) to 3(3) Process of Claim for “Access”, “Correction” and “Withdrawal of Consent”.

(4) Sole Discretion of Provision of Personal Data You (or your authorised representative) have the sole discretion whether or not to provide your personal data to TeamSpirit. However, if any

required information is not  provided, we may not be able to provide any requested information or services.

(5) Use of Cookies

We use cookies in our websites to improve our services by analysing the usage of our websites.

However, there is no information in cookies to identify the person browsing the website.

(6) Protection Obligation

Your personal data may be held and stored by TeamSpirit in either electronic or physical form. TeamSpirit has made reasonable security arrangements to protect your personal data to prevent unauthorised, access, collection, use, disclosure, copying, modification, disposal or similar risks.

(7) Retention Limitation

  1. TeamSpirit will not retain your personal data beyond the period during which:
  1. one or more of the Purposes for which such personal data was collected remains valid, or
  2. retention of such personal data is necessary for legal or business purposes, including but not limited to where:
  1. the personal data is required for an ongoing legal action involving TeamSpirit;
  2. retention of the personal data is necessary in order
    to comply with TeamSpirit’s obligations under any applicable laws, regulations, and international/regional/bilateral standards; or
  3. the personal data is required for TeamSpirit to carry on its business operations, such as to generate annual reports or performance forecasts.
  4. At the end of the relevant period for the retention of your personal data, TeamSpirit will shred all physical copies and delete all electronic copies containing such personal data, or anonymise such personal data, or otherwise destroy or render anonymous documents containing your personal data, as may be appropriate.

2. Information about TeamSpirit

(1) Operating Companies

TeamSpirit Inc.
and its group companies, which (as at the date on which this policy is issued) includes:

  • TeamSpirit Inc.
  • TeamSpirit Singapore Pte. Ltd

(2) Contact Information

If you have any questions about this Policy, or if you have any complaints in relation to TeamSpirit’s collection, use, disclosure, or other dealings with your personal data pursuant to this Policy, please direct them to TeamSpirit Singapore Pte Ltd’s Data Protection Officer who will be able to answer your questions/attend to your complaints:

Corporate Division
(Data Protection Officer)
Email: [email protected]
Address: #16-01, 380 Jalan Besar, Singapore 209000

Please note that we only process your inquiries or requests via email, fax or mail.

3. Process of Claim for “Access”, “Correction” and “Withdrawal of Consent”

TeamSpirit will take appropriate action in response to any claim made by you or your authorised representative with regard to
access, correction and withdrawal of consent of the use of
your personal data

(1) Access

You may request, by way of e-mail to TeamSpirit’s Data Protection Officer, to have access to your personal data and/or to obtain information about the ways in which your personal data may have been used and/or disclosed by TeamSpirit within the period of one year before the date of request. Your e-mail should provide sufficient detail to enable TeamSpirit to respond to your request.

Subject to the above, TeamSpirit will endeavour to respond to your request within [30] days after receiving your request in accordance with all applicable laws. This may include providing you a copy of the personal data and use and/or disclosure information in documentary form (or such other form as may be agreed) or by allowing you a reasonable opportunity to examine the personal data and use and/or disclosure information. If TeamSpirit is unable to respond to your request within [30] days after receiving your request, TeamSpirit will within that time inform you in writing of the time by which it will respond to your request.

(2) Accuracy and Correction

All personal data provided by you to TeamSpirit shall be deemed in all respects to be accurate and complete. TeamSpirit may however require your assistance to verify the accuracy and
completeness of your personal data from time to time. You may also request, by way of e-mail to TeamSpirit’s Data Protection Officer, to correct an error or omission in your personal data in TeamSpirit’s possession or under its control. Your e-mail
should provide sufficient detail to enable TeamSpirit to respond to your request.

TeamSpirit will endeavour to respond to your request within [30] days after receiving your request in accordance with all applicable laws. If TeamSpirit is unable to respond to your request within [30] days after receiving your request, TeamSpirit will within that time inform you in writing of the time by which it will respond to your request.

(3) Withdrawal of Consent

You or your authorised representative may withdraw your consent to the collection, use and/or disclosure of your personal data by TeamSpirit for any purpose by giving reasonable
written notice to TeamSpirit’s Data Protection Officer, delivered by way of e-mail transmission, providing relevant details of the personal data and the purposes for which you are withdrawing consent.

Please note, however, that if you withdraw your consent to the collection, use and/or disclosure of your personal data by TeamSpirit, TeamSpirit may be unable to manage its customer
Relationship with you or may not be able to provide certain services or products to you. TeamSpirit’s Data Protection Officer will notify you of the consequences of the withdrawal of your consent by way of e-mail within  [30] days of your request
to withdraw your consent. Should you confirm your request to withdraw your consent by way of e-mail in reply to such notice, you will be deemed to have accepted the consequences of the withdrawal of your consent as set out in the notice.

(4) Process of Claim

Fill up a request form defined in the clause “(5) Request Form” and send it to us by mail. Please indicate “Request Form for Personal Information” on the envelope in red.

Mailing Address:
#16-01
TeamSpirit Singapore
380 Jalan Besar
Singapore (209000)

(5) Request Form

Please print a request form specified by TeamSpirit and fill up the form and send us by mail together with one of the following documents.

  • Copy of Driver License Card
  • Copy of Passport or any other legal document to prove your identification

(6) Request by authorised representative If a claim is made by an authorised representative, please include the following documents.

  • Letter of authorisation
  • A document to identify the authorised representative (copy of driving license or any other proof documents)

(7) Fee

No fee will be charged.

(8) Method of Reply

We will send a reply by mail.

(9) Purpose of Use of Personal Information Collected During Claim

The personal data collected during the claim will only be used to process the claim.