We at METROPOLITAN MANAGEMENT SERVICES PTE. LTD. (“MetroCorp”) take our responsibilities under Singapore’s Personal Data Protection Act 2012 (the “PDPA”) seriously. We also recognize the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data.

This Data Protection Policy is designed to assist you in understanding how we collect, use, disclose and/or process the personal data you have provided to us, as well as to assist you in making an informed decision before providing us with any of your personal data.

If you, at any time, have any queries on this policy or any other queries in relation to how we may manage, protect and/or process your personal data, please do not hesitate to contact our Data Protection Officer (the “DPO”) at: dpo@metrocorp.com.sg

1.    INTRODUCTION TO THE PDPA

1.1  “Personal Data” is defined under the PDPA to mean data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organization has or is likely to have access. Common examples of personal data could include names, identification numbers, contact information, medical records, photographs and video images.

1.2  We will collect your personal data in accordance with the PDPA. We will notify you of the purposes for which your personal data may be collected, used, disclosed and/or processed, as well as obtain your consent for the collection, use, disclosure and/or processing of your personal data for the intended purposes, unless an exception under the law permits us to collect and process your personal data without your consent.

2.    PURPOSES FOR COLLECTION, USE, DISCLOSURE AND PROCESSING OF PERSONAL DATA

2.1  The personal data which we collect from you may be collected, used, disclosed and/or processed for various purposes, depending on the circumstances for which we may/will need to process your personal data, including:

1. processing your enquiries and application for new company formation and the provision of secretarial services;
2. administering and/or managing your relationship with MetroCorp;
3. carrying out your instructions or responding to any enquiries by you;
4. complying with obligations under the Companies Act, Variable Capital Companies Act, Limited Liability Partnerships Act, Accounting and Corporate Regulatory Authority (“ACRA”) requirements, Monetary Authority of Singapore (“MAS”) regulations, the Corporate Service Providers Act and Regulations, and other applicable laws and regulations. Conducting ongoing Customer Due Diligence (“CDD”), Know Your Customer (“KYC”), sanctions screening, politically exposed person (“PEP”) screening, beneficial ownership verification, periodic reviews and other compliance monitoring throughout our engagement.
5. dealing in any matters relating to the services which you are entitled to under this Agreement (including the printing and mailing of correspondence, statements, invoices, confirmations, advices, information, reports or notices to you, which could involve disclosure of certain personal data about you to bring about delivery of the same as well as on the external cover of envelopes/mail packages);
6. the recovery of any and all amounts owed to the MetroCorp;
7. the process of reviewing and approving the application, and the conduct of initial and anticipatory background checks and assessments, relevant checks, ongoing assessment and verification of ongoing credit worthiness and standing;
8. preventing, detecting and investigating fraud, misconduct, any unlawful action or omission, whether relating to your application or any other matter relating to your account(s), and whether or not there is any suspicion of the aforementioned;
9. managing MetroCorp’s infrastructure and business operations, and complying with policies and procedures that may be required by law or that may have been put in place by MetroCorp, including those relating to auditing, finance and accounting, billing and collections IT systems, data and website hosting, training, testing, business continuity, and records, document and print management;
10. complying with CDD, KYC, beneficial ownership identification, sanctions screening, PEP screening, periodic reviews, ongoing monitoring and other obligations imposed under applicable anti-money laundering, countering the financing of terrorism and corporate service provider legislation.;
11. any other purposes which we notify you of at the time of obtaining your consent. (collectively, the “Purposes”)

As the purposes for which we may/will collect, use, disclose or process your personal data depend on the circumstances at hand, such purpose may not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of your personal data without your consent is permitted by the PDPA or by law.

2.2  In order to conduct our business operations more smoothly, we may also be disclosing the personal data you have provided to us to our third party service providers, agents and/or our affiliates or related corporations, and/or other third parties whether sited in Singapore or outside of Singapore, for one or more of the above stated Purposes. Such third party service providers, agents and/or affiliates or related corporations and/or other third parties would be processing your personal data either on our behalf or otherwise, for one or more of the above-stated Purposes.

3.    SPECIFIC ISSUES FOR THE DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES

3.1  We respect the confidentiality of the personal data you have provided to us.

3.2  In that regard, we will not disclose your personal data to third parties without first obtaining your consent permitting us to do so. However, please note that we may disclose your personal data to third parties without first obtaining your consent in certain situations, including, without limitation, the following:

1. cases in which the disclosure is required or authorized based on the applicable laws and/or regulations;
2. cases in which the purpose of such disclosure is clearly in your interests, and if consent cannot be obtained in a timely way;
3. cases in which the disclosure is necessary to respond to an emergency that threatens the life, health or safety of yourself or another individual;
4. cases in which the disclosure is necessary for any investigation or proceedings;
5. cases in which the personal data is disclosed to any officer of a prescribed law enforcement agency, upon production of written authorization signed by the head or director of that law enforcement agency or a person of a similar rank, certifying that the personal data is necessary for the purposes of the functions or duties of the officer;
6. cases in which the disclosure is to a public agency and such disclosure is necessary in the public interest; and/or
7. where such disclosure without your consent is permitted by the PDPA or by law.

3.3  The instances listed above at paragraph 3.2 are not intended to be exhaustive. For more information on the exceptions, you are encouraged to peruse the Second Schedule of the PDPA, which is publicly available at https://sso.agc.gov.sg/Act/PDPA2012.

3.4  Where we disclose your personal data to third parties with your consent, we will employ our best efforts to require such third parties to protect your personal data.

4.    REQUEST FOR ACCESS AND/OR CORRECTION OF PERSONAL DATA

4.1  You may request to access and/or correct the personal data currently in our possession by submitting your request to dpo@metrocorp.com.sg. For a request to access personal data, we will provide you with the relevant personal data within a reasonable time from such a request being made.

4.2  For a request to correct personal data, we will:

1. correct your personal data as soon as practicable after the request has been made unless we have reasonable grounds not to do so; and
2. subject to paragraph 4.3, we will send the corrected personal data to every other organization to which the personal data was disclosed by MetroCorp within a year before the date the correction was made, unless that other organization does not need the corrected personal data for any legal or business purpose.

4.3  Notwithstanding paragraph 4.2(b), we may, if you so consent, send the corrected personal data only to specific organizations to which the personal data was disclosed by us within a year before the date the correction was made.

4.4  We may charge a reasonable fee for processing your request to access your personal data. Where a fee is applicable, we will provide you with a written estimate of the fee before processing your request. We are not required to respond to or process your access request until you have agreed to pay the applicable fee.

5.    REQUEST TO WITHDRAW CONSENT

5.1  You may withdraw your consent for the collection, use and/or disclosure of your personal data in our possession or under our control by submitting your request to dpo@metrocorp.com.sg

5.2  We will process your request from such a request for withdrawal of consent being made, and will thereafter not collect, use and/or disclose your personal data in the manner stated in your request.

5.3  However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal. In this regard, depending on the extent of your withdrawal of consent for us to process your personal data, it may mean that we will not be able to continue with your existing relationship with us.

6.    ADMINISTRATION AND MANAGEMENT OF PERSONAL DATA

6.1  We will take reasonable efforts to ensure that your personal data is accurate and complete, if your personal data is likely to be used by MetroCorp to make a decision that affects you, or disclosed to another organization. However, this means that you must also update us of any changes in your personal data that you had initially provided us with. We will not be responsible for relying on inaccurate or incomplete personal data arising from you not updating us of any changes in your personal data that you had initially provided us with.

6.2  We will also put in place reasonable security arrangements to ensure that your personal data is adequately protected and secured. Appropriate security arrangements will be taken to prevent any unauthorized access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data. However, we cannot assume responsibility for any unauthorized use of your personal data by third parties which are wholly attributable to factors beyond our control.

6.3  Personal data will be retained for as long as necessary to fulfil the purposes for which it was collected or as required under applicable laws and regulatory requirements, after which it will be securely destroyed or anonymised.

6.4  Where your personal data is to be transferred out of Singapore, we will comply with the PDPA in doing so. In this regard, this includes us obtaining your consent unless an exception under the PDPA or law applies, and taking appropriate steps to ascertain that the foreign recipient organization of the personal data is bound by legally enforceable obligations to provide to the transferred personal data a standard of protection that is at least comparable to the protection under the Act. This may include us entering into an appropriate contract with the foreign recipient organization dealing with the personal data transfer or permitting the personal data transfer without such a contract if the PDPA or law permits us to. This may include transfers to our overseas affiliates, professional advisers, service providers, regulators and counterparties where necessary for the provision of our services or compliance with applicable laws.

7.    COMPLAINT PROCESS 

7.1  If you have any complaint or grievance regarding about how we are handling your personal data or about how we are complying with the PDPA, we welcome you to contact us with your complaint or grievance.

7.2  Please contact us through one of the following methods with your complaint or grievance:

(a)   Singapore telephone number:  +65 6309 3800

(b)  E-mail: dpo@metrocorp.com.sg
            Attention it to the ‘Data Protection Officer’

(c)   Office address: METROPOLITAN MANAGEMENT SERVICES PTE. LTD.
                                     1 North Bridge Road #19-09 High Street Centre Singapore 179094
                                     Attention it to the ‘Data Protection Officer’

7.3  Where it is an email or a letter through which you are submitting a complaint, your indication at the subject header that it is a PDPA complaint would assist us in attending to your complaint speedily by passing it on to the relevant staff in our organization to handle. For example, you could insert the subject header as “PDPA Complaint”.

7.4  We will certainly strive to deal with any complaint or grievance that you may have speedily and fairly.

8.    UPDATES ON DATA PROTECTION POLICY 

8.1  As part of our efforts to ensure that we properly manage, protect and process your personal data, we will be reviewing our policies, procedures and processes from time to time.

8.2  We reserve the right to amend the terms of this Data Protection Policy at our absolute discretion. Any amended Data Protection Policy will be posted on our website and can be viewed at https://metrocorp.com.sg/terms-&-policies.

8.3  You are encouraged to visit the above website from time to time to ensure that you are well informed of our latest policies in relation to personal data protection.