co11ab Privacy Statement

This co11ab Privacy Statement (“Statement”) describes how co11ab Novena, its respective subsidiaries, and affiliates (collectively referred to as “co11ab”, “we”, “us” or “our”) collects, uses and discloses your personal data.

co11ab will collect, use and disclose your personal data in accordance with the Personal Data Protection Act 2012 (“Act“). In general, before we collect any personal data from you, we will notify you of the purposes for which your personal data may be collected, used and disclosed, as well as obtain consent for the intended purposes.

If you have any questions about this Statement or in relation to how co11ab manages, protects and/or processes your personal data, please contact us via email at contact@co11ab.sg.

If you are aware of or suspect a personal data incident, you may report to us.

PURPOSES FOR THE COLLECTION, USE & DISCLOSURE OF PERSONAL DATA

Depending on your relationship with co11ab, the personal data which we collect from you may be used and/or disclosed for the following purposes (“Purposes”):

Invited Guests / Visitors

• Establishing / evaluating (or compiling and preparing) your credentials and verifying your identity;
• Arranging and administering the visit (or any speech, lecture, event or other collaboration) including matters of attendance, accommodation, travel, registration, funding, security, immigration matters, diplomatic matters, and or other governmental or other third party matters relating to the attendance, stay, visit or activity in connection with co11ab as may apply;
• Creating awareness / publicising / promoting your attendance or participation at speeches, lectures, or at collaborative events;
• Vetting underlying publications, documents or other deliverables with referees, peers or third parties required to process, qualify or certify the same;
• Processing honorariums / fees or handling financial payments and expense reimbursements (including handling financial information and addressing financing issues, grant, donor and /or sponsorship);
• (in respect of public facilities and visitor centres) arranging for ticketing or admission, issuance of passes or tokens / subject matter relating to your visit, handling site incidents.

Alumni

• Maintaining a lifelong relationship with co11ab alumni and for professional learning arrangements;
• Creating awareness and promoting alumni relations; this includes informing you of promotions, benefits and services available to alumni, and organising, facilitating and notifying you of alumni events and programmes, courses or other activities, and providing you with co11ab publications that are for alumni;
• Studying the profile of the alumni community for co11ab’s policy making and planning;
• Involving alumni in co11ab’s continual development and progress through the engagement of voluntary services and giving back to their alma mater;
• Tracking or compiling employment statistics to provide insight into alumni affairs and co11ab or educational outcome.

Media Requests / Creation of Collateral

• (where consent has been explicitly obtained beforehand)
• Including your name and/or likeness in materials (including but not limited to print, video, audio or other media) for the purposes of promoting or publicising relevant activities, testimonials, engagement or other interactions for the benefit of co11ab’s interests in co11ab’s activities.

General (For all Data Subjects)

• Carrying out your instructions or responding to any enquiry given by you or on your behalf;
• Contacting you or communicating with you via various modes of communication such as voice call, text message or fax message, email or postal mail for the purposes of administering and managing your relationship with us;
• Dealing with, administering and or managing your use of co11ab facilities including your accommodation or travel needs, provision of IT services and recreation facilities or of campus / co11ab resource;
• Arranging for, administering or executing / attending to health and safety matters (including medical treatment or care as may be applicable and associated referrals or continued / allied care) or assisting differently-abled individuals who attend or interact with co11ab;
• Complying with or as required by any request or direction of any governmental authority; or responding to requests for information from any governmental authority, hospitals, embassies, public agencies, ministries, statutory boards or other similar authorities including their appointed agents, contractors or third party service providers;
• Complying with or as required by any applicable law, governmental or regulatory requirements including but not limited to the compliance with the disclosure requirement;
• Arranging, administering, or executing audits and governance reviews;
• Conducting investigations and making reports into or about: (a) breaches of any laws, rules, regulations, codes, standards or other obligations, (b) in respect of any allegations, claim or proceedings, (c) matters of academic activity or conduct;
• Executing business or service improvement, quality assurance reviews, surveys or research;
• Arranging, administering or executing facilities (including parking, issuance of pass cards, keys or tokens), access management, equipment procurement / issuance and associated maintenance or replacement;
• (wherever CCTV or other surveillance equipment are deployed on campus or other locations in co11ab premises), for detection and prevention of crime and for security purposes and investigations;
• Engaging with third party vendors in respect of procuring goods or services incidental or necessary to the provision of services or engagement in activities with you;
• Engaging with corporate third parties, partners and supporting corporate arrangements or collaborations including but not limited to clearing corporate documents (e.g. appointments, resolutions) and financing or security matters;
• (at co11ab events / lectures / seminars / conferences / workshops / classes / tutorials where pictures or video are recorded and where signage to notify the same has been placed, and unless you explicitly instruct us not to use your image) for promotional, publicity, or event reporting purposes;
• Where you are deemed by law to have consented to various purposes, these purposes will be acted on until such time as such deemed consent is withdrawn in accordance with the arrangements we have in place to assist your doing so;
• Any other purposes which co11ab may inform you in writing from time to time, but for which co11ab will seek your separate consent.

DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES

In order to conduct our operations more smoothly, co11ab may need to disclose your personal data to third parties, whether located within or outside Singapore, for one or more of the Purposes. Such third parties include but not limited to our third party service providers, affiliates or related corporations that would be processing your personal data on co11ab’s behalf.

Except where permitted by law (and not excluding disclosures to third parties for Purposes), co11ab will not disclose your personal data to any third parties without first obtaining your consent permitting us to do so or unless any such disclosure is permitted under any of the statutory exemptions under the Act.

REQUEST FOR ACCESS, CORRECTION AND/OR WITHDRAWAL OF PERSONAL DATA

Subject to certain exceptions in the Act, you may request to review and update your personal data currently in our possession or withdraw your consent for the collection, use and disclosure of your personal data in our possession by submitting your request to us via email at contact@co11ab.sg

REQUEST FOR ACCESS. If you request to access your personal information, we will ask you to verify your identity and specify what information you wish to access. co11ab will provide you with the relevant personal data within a reasonable time after the request has been made.  A fee may be charged for handling the request and you will be notified in advance of this.

REQUEST FOR CORRECTION. For a request to correct your personal data, co11ab will correct your personal data as soon as practicable after verifying your identity. We will send the corrected personal data to every other organisation to which the personal data was disclosed by co11ab within a year before the date the correction was made, unless that other organisation does not need the corrected personal data, or if you so consent, only to specific organisations to which the personal data was disclosed by us.

WITHDRAWAL OF CONSENT. co11ab will similarly process your request within a reasonable time after a request to withdraw consent has been made. In some cases, the request to withdraw consent may adversely impact your relationship with co11ab. We will notify you in advance of any such impact. 

MANAGEMENT AND PROTECTION OF PERSONAL DATA

co11ab will take reasonable and appropriate measures to (i) keep your personal data accurate, complete and updated; and (ii) ensure that your personal data is adequately protected and secured. Appropriate security arrangements will be put in place to prevent any unauthorised access or misuse of your personal data.

We will similarly take reasonable efforts to ensure that the personal data in our possession is destroyed or anonymised as soon as (i) the purpose for which that personal data was collected is no longer being served by the retention of such data; and (ii) retention is no longer necessary for any other legal or business purposes.

GDPR PRIVACY STATEMENT

This GDPR Privacy Statement applies only if a particular circumstance or activity applicable to co11ab requires the application of the GDPR to co11ab and residents of the European Union only.

Generally, we process personal data on the basis of consent. Apart from consent, under the General Data Protection Regulation (“GDPR”), we may also lawfully process your personal data on one or more of the following lawful basis:

• The processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;
• Process your personal data on the basis of a balance of interests to pursue our or a third party’s legitimate interests. This is carried out for one or more of the Purposes set out above. Further, we may process your personal data for the legitimate interests of promoting the good of co11ab and/or alumni community, and maintaining co11ab’s relationship with its alumni to grow the co11ab spirit in its alumni;
• Necessary for compliance with a legal obligation to which co11ab is subject;
• Necessary in order to protect the vital interests of the data subject or of another natural person;
• Necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in co11ab.

We practise data minimisation and strive to collect only what is necessary in relation to the purposes for which such personal data is processed and to maintain the relevant relationship between us. The consequence of not providing such requested personal data may result in our inability to start or maintain that relationship with you or to provide you with our products or services.

Where your personal data is transferred to a country for which the European Data Protection Board has not made an adequacy decision, we will take appropriate steps to ensure that the foreign recipient organisation of the personal data is bound by legally enforceable obligations to protect the transferred personal data. This may include us entering into an appropriate contract with the foreign recipient organisation dealing with the personal data transfer.

Where the GDPR is applicable, you have the following rights (subject to any exceptions under the GDPR):

• ACCESS. You have the right to request confirmation of whether we process your personal data, a copy of the personal data we are processing about you, and other information relating to your personal data as provided for in the GDPR.
• RECTIFICATION. You have the right to have incomplete or inaccurate personal data that we process about you rectified.
• ERASURE. You have the right to request that we delete personal data that we process about you if one of the grounds for erasure under the GDPR applies.
• RESTRICTION OF PROCESSING. You have the right to restrict our processing of your personal data if one of the grounds for such restriction under the GDPR applies, such as where you believe such data to be inaccurate; our processing is unlawful; or that we no longer need to process such data for a particular purpose, pursuant to the full terms of the grounds as provided in the GDPR.
• DATA PORTABILITY. You have the right to obtain personal data we hold about you, in a structured, commonly used, electronic format, and to transmit such data to another data controller, if certain conditions under the GDPR are satisfied.
• OBJECTION TO PROCESSING. You have the right to object to our processing of your personal data where such personal data is being processed by us for the performance of a task carried out in the public interest, or in the exercise of official authority vested in us, or for the purposes of the legitimate interests pursued by us. Additionally, you have the right at any time to object to our processing of your personal data for direct marketing. Further, you have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes, subject to condition(s) in the GDPR.
• WITHDRAWING CONSENT. If you have consented to our processing of your personal data, you have the right to withdraw your consent at any time, free of charge.

WHEN YOU VISIT OUR WEBSITE

This section describes the information practices (and how we process your personal data when you interact with us) in connection with co11ab’s websites and apps, including mobile websites and applications that are accessed and, on the site (collectively, the “Site”).

• If you are only browsing this Site or using the Search function, we do not capture data that allows us to identify you individually. While user sessions will be tracked, the users will remain anonymous.
• If you choose to submit your request via our form or send an email that contains personally identifiable data, for co11ab to process or to render you a service, we may share that relevant data within co11ab, or if necessary, with other Government agencies or universities, so as to serve you efficiently and effectively.
• For your convenience, when you are carrying out a transaction on our Site, we may also display to you the data that you previously supplied to co11ab, other Government agencies or private organisations that have been authorised to carry out specific services on our behalf. This is intended to save you time and effort in re-keying the same data. If the pre-displayed data is out-of-date, please enter the latest data. co11ab will retain your personal data only as necessary for business and legal purposes.
• To safeguard your personal data, we have put in place appropriate security technologies, policies and procedures to secure all electronic storage and transmission of personal data. Although we make every effort to secure our networks, please understand that the transmission of information via the internet is not completely secure and we cannot guarantee the security of your personal data transmitted through any online means. Therefore, you are strongly advised to take safety precautions and any transmission remains at your own risk.
• This Site may contain links to other independently managed websites within the co11ab network and sites outside of “co11ab.sg” domain whose privacy practices may be different from ours. We are not responsible for the content and privacy practices of these other websites and encourage you to examine the privacy notices of those sites.

USE OF COOKIES

• To help us optimise your browsing experience and ensure the website works properly, we use cookies when you use our websites.
• If you would like to disable our cookies, you may deactivate it by adjusting your internal browser setting.

UPDATES ON THIS CO11AB PRIVACY STATEMENT

As part of our effort to ensure that we properly manage, protect and process your personal data, we may update this Statement from time to time at our absolute discretion.

We encourage you to periodically check this Statement so that you will remain updated on any changes. This Statement was last updated in May 2023.