Privacy Policy
Scope of Application
This Privacy Policy (this “Policy”) sets out the basis upon which the Propre Group (defined below, referred to as “we”, “us”, or “our”) may collect, use, disclose, or otherwise process Personal Data (defined below) and Behavioral Data (defined below) of users (both general and registered users, collectively referred to as “Users”) of the services provided by us (the “Services”) and all persons who have applied for any positions with us (the “Job Applicants) in accordance with the Personal Data Protection Act 2012 (the “PDPA”) and the Regulation (EU) 2016/679 (the General Data Protection Regulation (the “GDPR”)). This Policy applies to Personal Data and Behavioral Data in our possession or under our control, including such data in the possession of organizations which we have engaged to collect, use, disclose or process such data for our purposes.
Please note that we may also enter into individual privacy agreements with any Users or Job Applicants (the “Individual Privacy Agreements”). In such cases, where there is a conflict between the terms of this Policy and that of any Individual Privacy Agreement, the terms of the Individual Privacy Agreement shall prevail.
This Policy supplements our Terms of Use which may be found at https://propre.com/term, and your use of the Services is therefore governed by both this Policy and the Terms of Use.
Definitions of Terms
- “Behavioral Data” means non-personally identifiable information which can be used for analyzing your interests and preferences by collecting and storing information such as your service usage history or advertisement browsing history, the history of your actions on our website, search words, the timing of your visits to our website, IP address, cookies (*1) information, location data, usage environment and device unique identifiers.
- Cookies are certain pieces of information which we may send to your computers or mobile devices, which will be stored in the hard drive or memory of such devices. Cookies are used for producing access statistics and otherwise improving our services, and do not invade your privacy or operating environment. Under no circumstances is such information disclosed in a form which specifically identifies an individual who has accessed our website or Services. Please note that third parties (such as analytics software) may also use cookies, over which we have no control.
- “Personal Data” means data, whether true or not, about a Job Applicant who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access to.
- “Propre Group” means Propre Pte. Ltd. and its subsidiaries and affiliates (including those abroad; for details of the Propre Group companies, please visit the website of Propre Pte. Ltd.).
Collection and Handling of Personal Data of Users
We generally collect Personal Data of Users that:
- you knowingly and voluntarily provide in the course of or in connection with your use of the Services and/or our website, or via a third party who has been duly authorized by you to disclose your Personal Data to us;
- you provide us with a consent to the collection and usage of your Personal Data; or
- is permitted or required by the PDPA, the GDPR or other laws.
We will collect the following types of information regarding Users. The following items are listed as non-exhaustive examples of the types of information which may be collected by us. Information which does not identify a certain individual and therefore does not fall within the definition of “Personal Data” may also be included, depending on the specific content of such information.
- Information about Users such as name, address, telephone number, facsimile number, e-mail address, place of work and other contact information, date of birth and gender, etc.;
- Information on the usage history of the Services which is associated with any information that personally identifies a User; and
- IP address used by User’s computers to connect to the Internet, information regarding mobile device identification and any other information which is automatically collected upon accessing the servers operated by us.
We will use the Personal Data of Users collected by us for following non-exhaustive purposes (the “Purposes of Use”):
- Purposes of Use
- Verification of your identity at and after the time of log-in and for automatically displaying the membership information on various screens, in the course of your using any of the Services as its registered member;
- Making phone calls, sending e-mails (including e-mail newsletters), direct mail, short messages (SMS), or any information or questionnaires through apps, etc., with respect to the Services;
- Analyzing, extracting and otherwise handling information with the aim of improving the Services or advertisements provided by us;
- Personalizing the advertisements distributed in the content viewed by you, based on your personal attributes such as gender, age, place of residence, likes or tastes, or your browsing history of websites operated by us or your usage history of the Services offered by us;
- Providing information, including promotions and advertisements, which we consider valuable to you;
- Handling your enquiries regarding your information;
- Statistical data processing in non-personally identifiable form;
- Providing information, including promotions and advertisements, regarding other services;
- Providing services to you or engaging in any other lawful business practice, in addition to those listed in items A through I above;
- Carrying out business entrusted from any third party;
- Investigation into suspected violation of the terms of use of the Services; and
Providing information in accordance with the provisions of (2) below, to any third party who has entrusted us with business, to the extent necessary for carrying out such business.
-Sharing of Personal Data of Non-EEA Users (applicable to Non-EEA Users only)-
We may share the Personal Data of Users who reside outside of the European Economic Area (the “Non-EEA Users”) with third parties outside the Propre Group (in addition to any other scenarios mentioned herein) only if:
- A Non-EEA User has agreed and given his/her explicit consent for us to share his/her Personal Data with third parties;
- the sharing is permitted or required by laws and regulations;
- any business segment of any of the Propre Group has been transferred along with the Personal Data due to merger, company split or business transfer or any other reason;
- handling of all or any part of the Personal Data has been entrusted to any of the Propre Group to the extent necessary for achieving the purpose of use;
- the data containing the Personal Data is disclosed or provided after being processed into a non-personally identifiable form;
-Sharing of Personal Data of EEA Users (applicable to EEA Users only)-
The Propre Group may share the Personal Data of Users who reside in the European Economic Area (the “EEA Users”) with any of the Propre Group and other third parties such as our third-party service providers, to implement the “Purposes of Use” set forth above. Any of the Propre Group and the third parties to whom we may disclose such Personal Data may be located outside the EEA (including, without limitation, Singapore), and the EEA Users agree to the following matters by consenting to this Policy:
- In the case that the country in which any of the Propre Group or a third party is located is outside the EEA, such country does not have the same data protection laws as the EEA, i.e., many of the rights provided to data subjects in the EEA are not given;
- the Personal Data of EEA Users will be provided and processed for the “Purposes of Use” set forth above by any of the Propre Group and third parties outside the EEA; and
- the Personal Data of EEA Users will be provided to third parties located outside the EEA.
We will use the Personal Data of Non-EEA Users jointly with third parties as set forth below only so long as is necessary for achieving the purpose of use:
- The Personal Data subject to the joint use is the same as that provided under the “Collection of Personal Data” set forth above;
- The parties who will jointly use such information are Propre Pte. Ltd. and its designated third parties;
- The purpose for joint use of such data is the same as the “Purposes of Use” set forth above; provided further that the “Propre Group” as stated therein shall be deemed to have been replaced with “each of the joint users”; and
- Propre Pte. Ltd. will be responsible for the joint use.
We may entrust all or any part of the handling of the Personal Data of Non-EEA Users to third parties.
Collection, Use and Disclosure of Personal Data of Job Applicants
We generally collect Personal Data of the Job Applicants that:
- you knowingly and voluntarily provide in the course of or in connection with your job application with us, or via a third party who has been duly authorized by you to disclose your Personal Data to us (which may include your job placement agent);
- you provide us with a consent to the collection and usage of your Personal Data; or
- is permitted or required by the PDPA, the GDPR or other laws.
If you are a Job Applicant, Personal Data which we may collect includes, without limitation, your:
- name or alias, gender, NRIC/FIN or passport number, date of birth, nationality, and country and city of birth;
- mailing address, telephone numbers, email address and other contact details;
- resume, educational qualifications, professional qualifications and certifications and employment references;
- employment and training history;
- work-related health issues and disabilities; and
- photographs.
If you are a Job Applicant, your Personal Data will be collected and used by us for the following purposes and we may disclose your Personal Data to third parties where necessary for the following purposes:
- assessing and evaluating your suitability for employment in any current or prospective position with us;
- sending to you recruitment related information; and
- verifying your identity and accuracy of your personal details and other information provided.
-Sharing of Personal Data of Non-EEA Job Applicants (applicable to Non-EEA Job Applicants only)-
We may also disclose your Personal Data of Job Applicants who reside outside of the European Economic Area (the “Non-EEA Job Applicants”) to other third parties in the following instances:
- when we obtain your consent to do so;
- when such disclosure is permitted or required by any law or regulation; or
- when such disclosure is made to our agents or such organizations which we have engaged to collect, use, disclose, or process personal data for our purposes.
-Sharing of Personal Data of EEA Job Applicants (applicable to EEA Job Applicants only)- The Propre Group may share the Personal Data of Job Applicants who reside in the European Economic Area (the “EEA Job Applicants”) with any of the Propre Group and other third parties such as our third-party service providers, to implement the purposes of use a to c set forth above. Any of the Propre Group and the third parties to whom we may disclose such Personal Data may be located outside the EEA (including, without limitation, Singapore), and the EEA Job Applicants agree to the following matters by consenting to this Policy:
- In the case that the country in which any of the Propre Group or a third party is located is outside the EEA, such country does not have the same data protection laws as the EEA, i.e., many of the rights provided to data subjects in the EEA are not given;
- the Personal Data of EEA Job Applicants will be provided and processed for the purposes of use a to c set forth above by any of the Propre Group and third parties outside the EEA; and
- the Personal Data of EEA Job Applicants will be provided to third parties located outside the EEA.
Please note that if you are offered a job by or commence work with us, your Personal Data may further be retained by us for administrative purposes.
Disclosure, Correction and Deletion of Personal Data of Non-EEA Users and Non-EEA Job Applicants (applicable to Non-EEA Users and Non-EEA Job Applicants only)
If you are a Non-EEA User or Non-EEA Job Applicant, the consent which you provide for the collection, use and disclosure of your Personal Data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop using and/or disclosing your Personal Data for any or all of the purposes listed herein by submitting your request in writing or via email at the contact details provided below.
Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process and effect your request within 30 days of receiving it.
Please also note that depending on the request that is being made, we may only need to provide you with access to the Personal Data contained in the documents requested, and not to the entire document themselves. In those cases, it may be appropriate for us to simply provide you with confirmation of the Personal Data that we have on record, if the record of your Personal Data forms a negligible part of the document.
Please be informed that withdrawing consent does not affect our right to collect, use, and disclose Personal Data where such collection, use and disclosure without consent is permitted or required under any laws/regulations.
If you wish to make an access request to any Personal Data held by us about you or information about the ways in which we use or disclose your Personal data, or to make a request to correct, update, or for us to delete any of your Personal Data which we hold, you may submit your request in writing or via email at the contact details provided above. Please note that a reasonable fee may be charged for such requests, which we will inform you beforehand before processing your request.
EU Rights (applicable to EEA Users and EEA Job Applicants only)
EEA Users and EEA Job Applicants have the right to ask us for a copy of your Persona Data; to correct, delete or restrict (stop any active) processing of your Persona Data; and to obtain the Persona Data you provide to us for a contract or with your consent in a structured, machine readable format.
In addition, you can object to the processing of your Persona Data in some circumstances (in particular, where we are using the information for direct marketing).
These rights may be limited, for example if fulfilling your request would reveal Persona Data about another person, where it would infringe the rights of a third party (including our rights) or if you ask us to delete Persona Data which we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are included in both the GDPR and in any local laws on privacy. We will inform you of relevant exemptions we rely upon when responding to any request you make.
To exercise any of these rights, you can get in touch with us from the contact details provided below. If you have unresolved concerns, you have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred.
Collection and Use of Behavioral Data
We will, directly or in connection with the Services, collect, store and use the Behavioral Data for the following purposes:
- Improving the user-friendliness of the Services;
- Delivering advertisements tailored to your profile;
- Utilization as statistical data;
- Offering content which is deemed valuable to you; and
- Providing consultation for promotional activities of, or for otherwise facilitating the marketing activities of, the partner companies which have entered into an agreement with the Propre Group (the “Partner Companies”) or any other third parties.
For the avoidance of doubt, the Behavioral Data does not, on its own, identify an individual, but may do so when combined and cross-checked with other data. Such Behavioral Data which can be easily combined to ascertain the identity of any particular individual will be treated as Personal Data. We will not actively associate your Behavioral Data with other data to ascertain your identity.
Behavioral Data to be Collected
We collect information, through technology, including but not limited to cookies, JavaScript, web beacons and traffic data, on the timing of when you visit our site and the pages browsed by you throughout our site, URL, action history, type of browser, language, IP address, browser used to visit our site, location data, and device unique identifiers, etc.
Third Party Sharing of Behavioral Data
The Propre Group may share your Behavioral Data and related aggregated data with third parties.
Third parties may also collect your information in connection with your use of the Services and/or website. For example, we may share Behavioral Data and related aggregated data to our Partner Companies about the volume of use of the Services and the specific service which Users are most interested in. As the Behavioral Data does not identify particular Users, these third parties will not be able to contact you solely based on these data.
Provision of Behavioral Data Analysis Results
The Propre Group may be entrusted with certain work by the Partner Companies and may analyze your Behavioral Data to the extent necessary for such work and provide the analysis results to the Partner Companies.
Such analysis results will be used by the Partner Companies for the purpose of providing more personalized interesting contents and/or advertisements to users visiting the websites operated by the Partner Companies.
Use of Cookies, Web Beacons, and similar technologies
When you access, use, or interact with our Services or website, we and/or our authorized service providers may use cookies, web beacons, and other similar tracking technologies for collecting and storing information about you.
Procedures for Opting Out of Behavioral Data Collection
If you do not wish to have your Behavioral Data collected, as performed by us for optimizing the display of content on the Partner Companies’ websites, please contact us using the following enquiry form.
In addition to the aforementioned tools, we also use “Google Analytics”. The advertising features of Google Analytics implemented by us are as follows:
- Remarketing with Google Analytics;
- Impression reports with regard to Google display network;
- DoubleClick-platform integration; and
- “Demographics Report” and “Interest Report” of Google Analytics.
Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. If you choose to decline cookies, you may not be able to access all or parts of the website or to fully experience the interactive features of the website.
We and our contracted third parties may use the Behavioral Data associated with cookies and IDs, in combination, for the following purposes:
- Displaying, on the Services, any information which seems to match your interests; and
- Displaying, on third party operated websites, any advertisement which seems to match your interests.
If you continue to use the Services without taking the procedures to opt out of the collection of Behavioral Data, you are deemed to have agreed to this Policy. Please make sure you have read and fully understood this Policy.
Processing of Behavioral Data of EEA Users and EEA Job Applicants
Under the GDPR, Behavioral Data, such as Cookies, Web Beacons and other similar online identifiers, are considered Personal Data. Therefore, you hereby agree to that we process Behavioral Data of EEA Users and EEA Job Applicants as follows:
-Sharing of Behavioral Data-
The Propre Group may share the Behavioral Data of EEA Users and EEA Job Applicants with any of the Propre Group and other third parties such as our third-party service providers, to implement the purposes of use (1) to (5) set forth in “Collection and Use of Behavioral Data” above. Any of the Propre Group and the third parties to whom we may disclose such Behavioral Data may be located outside the EEA (including, without limitation, Singapore), and the EEA Users and EEA Job Applicants agree to the following matters by consenting to this Policy:
- In the case that the country in which any of the Propre Group or a third party is located is outside the EEA, such country does not have the same data protection laws as the EEA, i.e., many of the rights provided to data subjects in the EEA are not given;
- the Behavioral Data of EEA Users and EEA Job Applicants will be provided and processed for the purposes of use (1) to (5) set forth in “Collection and Use of Behavioral Data” above by any of the Propre Group and third parties outside the EEA; and
- the Behavioral Data of EEA Users will be provided to third parties located outside the EEA.
In addition, EEA Users and EEA Job Applicants have the relative rights as defined in “EU Rights (applicable to EEA Users and EEA Job Applicants only)” above as to your Behavioral Data.
Period of Retention of Personal Data and Behavioral Data
We will retain your Personal Data and Behavioral Data for as long as it is necessary to fulfil the purposes for which they were collected, or as required or permitted by applicable laws.
Legal Basis for our Use of Personal Data and Behavioral Data of EEA Users and EEA Job Applicants, etc.
We will process the Personal Data and Behavioral Data of EEA Users and Job Applicants based on your consent to this Policy. Some Personal Data or Behavioral Data are mandatory and indicated as such at the time we ask you to provide them. Where provision of your Personal Data or Behavioral Data is mandatory and you choose not to provide such data, then we will not be able to provide you with the Services or you will not be able to be involved in the recruitment activities. You may withdraw your consent from the contact details provided below. The consent which you provide for the collection, use and disclosure of your Personal Data and Behavioral Data will remain valid until such time it is being withdrawn by you.
Security Measures
In order to prevent any unauthorized access to, leakage or loss of, or damage to (including, without limitation, missing, destruction and alteration of) the Personal Data and the Behavioral Data, we have in place appropriate security measures to safeguard your Personal Data and Behavioral Data, and minimize the risk of unauthorized access to, or loss, alteration or leakage of the Personal Data and the Behavioral Data collected from you.
However, you should be aware that no method of transmission over the internet or method of electronic storage is completely secure. While security cannot be guaranteed, we will strive to protect the security of your information and Personal Data as much as possible.
Contact for Enquiries
For enquiries regarding this Policy or the management of Personal Data or the Behavioral Data, or requests for notice regarding purpose of use, disclosure, correction, deletion, suspension of use or opting out of third party sharing, please contact:
Data Protection Officer of Propre Pte. Ltd.
Address: 133 Cecil Street, #05-01A Keck Seng Tower, Singapore, 069535
E-mail: info@propre.com
Changes to Details of this Policy
This Policy applies in conjunction with any other policies, notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your Personal Data by us.
We may revise this Policy from time to time without any prior notice. You may determine if such revision has taken place by referring to the date on which this policy was last updated. Your continued usage of our Services constitute your acknowledgement and acceptance of such changes.