AAL is committed to maintaining your personal data in compliance with the relevant data protection legislations which includes, but is not limited to, the European Union General Data Protection Regulation (GDPR) and the Personal Data Protection Act 2012 (PDPA) of Singapore.
The use of the word “processing” in this Policy is intended to include such actions as collecting, recording, handling, using, storing, transferring, and disclosing of your personal data.
Personal Data Collected
Personal data may refer to any online or offline information, whether true or not, that identifies a person or makes a person identifiable. This includes, but is not limited to names, addresses, usernames and passwords, photographs, social security numbers, personal identification numbers, financial data, and employment-related information.
Employees: In order to consider you for employment, or employ you, we need to process certain information about you. We only collect details that help us provide what is required as part of your application process or employment. For example, we need information such as your name, age, contact details, education details, employment history, emergency contacts, next of kin, immigration status, passport size photos, passport copies, bank account details and other relevant information required for the purposes of your employment or that you may choose to share with us. Where appropriate, and in accordance with local laws and requirements, we may also collect information of a more sensitive nature, such as diversity information, information related to your health, or details of any criminal convictions.
If you are providing AAL with your personal data for the purposes of a job application and/or job enquiries, the personal data that you provide may also be used for the purposes listed in the Personal Data Notice and Consent.
Customers: To enable us to communicate with you and to ensure that we meet certain legal requirements such as KYC (know your customer) and AML (anti-money-laundering), we need to have certain details of yours or details of individual contacts at your organisation (such as their names, telephone numbers and email-addresses). We may also need to have certain personal data in order to meet our contractual obligations with you, as well as to send you services-related and other marketing materials if you have given us your consent to do so.
Website users: We do not collect personal data that can identify anonymous users on our website. We collect a limited amount of information to help improve your experience when using our website. This includes anonymous information such as the frequency with which you access our website, and the times that our website is most visited, we will not be able to identify you from these data.
AAL will ask our website users for their personal data only if they wish to stay in touch, provide feedback about any of our products or services, or seek employment opportunities with us (see above for more information on employees). For these users, AAL may process your personal data for the following purposes:
- Personal identification and verification,
- To allow AAL to respond to your requests and provide feedback,
- To allow AAL to contact you for the service(s) or opportunities, including employment opportunities, as requested by you,
- To conduct research, analysis or development activities to enhance products or services offered on this website, and/or for AAL business operations and purposes,
- To facilitate or manage any business transaction(s) with you,
- To inform you of events, industry updates or market developments, or other information that AAL considers to be relevant and of interest to you according to your requests/feedback/services
- To carry out due diligence and other screening activities, or to prevent or investigate any fraud or breach of contract, or unlawful activity,
- For any other additional purposes that is consistent with the original purpose for which the personal data was given.
If you do not provide the information requested, this may limit our ability to respond to your request(s) or feedback may be limited.
AAL will first seek your permission if we wish to process your personal data for any other purposes.
Suppliers of goods and services: We collect a small amount of information from our suppliers to ensure that operations work properly. We need contact details of relevant individuals at your organisation so that we can communicate with you. We also need other information such as your bank details so that we can pay for the services you provide (if this is part of the contractual agreements between us).
Office visitors: When visiting our office premises, we collect the necessary personal data required for security and notification purposes. For security purposes, we also operate a Closed Circuit Television system (CCTV). The CCTV cameras only operate in common areas of our premises and are positioned so as not to intrude on privacy.
Disclosure of Personal Data to Third Parties
AAL’s objective is to use the information you provide to better understand your requirements and provide information to you on products and services that are most relevant to you.
In order to achieve this objective, as well as other legal, regulatory, and contractual obligations, we may need to share some personal data we process with third parties. These third parties may be located within or outside your country. They will be required to keep your information confidential and use it only for the purposes for which we are permitted to use it.
The list below contains a description of the types of organisation with which we may need to share some of the personal data we process:
- Agents and brokers
- Business associates, other professional bodies, and advisors
- Central and local government
- Courts and tribunals
- Credit reference, debt colleation, and tracing agencies
- Current, past, and prospective employers
- Employment and recruitment agencies
- Education and examining bodies
- Law enforcement and prosecuting authorities
- Ombudsman and other regulatory authorities
- Suppliers and services providers
AAL will not sell, rent or trade your personal information.
AAL has put in place reasonable measures to ensure that any necessary transfer of personal data cross border is protected and compiles with the applicable data protection laws.
Retention of Personal Data
AAL will retain your personal data for a reasonable period for the purposes for which it was obtained, or until you request for AAL to delete your personal data (if the circumstances allow)or as required by law, whichever arrives first.
Retention of specific records may be necessary for one or more of the following reasons:
- Fulfilling statutory or other regulatory requirements
- Evidencing events/agreements in case of disputes
- Operational needs
- Historical and statistical purposes
Withdrawal of Consent
In situations where we request and receive your consent to process your personal data, you can exercise your right to withdraw your consent at any time by writing to the Privacy Officer. Withdrawal of consent to allow us to send you marketing material can also be made by clicking on the unsubscribe option at the bottom of each marketing email sent to you. Please note that if you have subscribed to more than one list (i.e., Liner List – AUP), unsubscribing from that list will not automatically unsubscribe you from another list (I.e., Tramp List) if you are also subscribed to it.
Withdrawal of consent cannot be back-dated so it has no effect on processing already performed during the period of consent. Please note that withdrawal of consent might affect AAL’s ability to either respond to your request(s) or provide important service notifications in the future.
To ensure that the personal data held by AAL is accurate and up to date, it is important that you inform AAL, in writing, of any changes to your personal data. If you would like to update or modify your personal data, please write to the Privacy Officer.
When you submit your contact details to AAL, you represent and warrant that you are the authorised user and/or subscriber of the email and/or telephone number.
AAL has put in place robust policies and security arrangements to protect the personal data it processes from misuse, loss and unauthorised access. AAL ensures that only authorised employees and necessary third parties have access to personal data held by AAL.
However, no electronic system can be entirely secured from unauthorised invasion. Accordingly, AAL cannot guarantee the absolute security of any personal data held in our electronic storage system, or that no harmful code will enter AAL’s website. You will be informed promptly once we become aware that your Personal Data held by us have been accessed in an unauthorized manner. You are advised to take note of the risks and exercise any necessary precautions.
AAL is not responsible for the content or privacy practices used by websites that are linked to or from this website.
Under certain circumstances you have rights regarding your personal data. These are:
- Access to a copy of your personal data
- Withdraw consent to our processing of your personal data for particular purpose(s)
- Stop receiving marketing material
- Have inaccurate or outdated personal data rectified, blocked, erase or destroyed
- Have your personal data removed from our records, if the circumstances allow
- Lodge a complaint with the relevant data protection authority
- Claim compensation for damages caused by a breach of the applicable data protection legislation based on the territory on the breach
If you wish to exercise any of these rights, weather you are an employee or non-employee of AAL, please email the Privacy Officer. Please note that the rights you have in relation to your personal data may differ based on the applicable data protection laws of the country.
Cookies are small text files that are placed onto internet enabled devices when you visit a website in order to recognise a device upon recurring visits, and in turn enable a website’s features and functionalities.
When you use our website, our Internet Service Provider (“ISP”) will record and log information about your visit including:
- your IP address, server address and top level domain name (eg. .com, .gov, etc),
- the date and time of your visit, or when entering from another website, the address of that website,
- the pages and documents you access during your visit, and
- the type of browser, plug-ins and other technologies you are using.
For further information on Cookies such as deleting, disabling or blocking cookies, please visit AboutCookies.org. For more specific information on how to adjust cookies configurations, please refer to your specific browser.
Changes to The Policy
AAL may make changes to this Policy from time to time for any reason and will publish an amended version of this Policy on this website. You are encouraged to check back here for any updates.
Telephone: +65 6248 3600
Fax: +65 6334 2422
Address: 9 Temasek Boulevard
#20-01 Suntect Tower 2
Last updated 17 May 2018