General:

1. This document is the privacy policy (“Policy”) of KGP Legal LLC (Company Registration No. 201723916D), a licensed Singapore Law Practice having its registered address at 10 Anson Road, #23-05, International Plaza, Singapore 079903 (hereinafter referred to as “KGP”, “we,” and “us”). 
2. Users (“you”) of our website (“Website”) are to read this Policy carefully and to refer to it as and when required. By accessing and using our Website, you are deemed to have accepted and agreed to KGP’s practices as described in this Policy, and undertaken to comply with the same. 
3. In the course of our business activities, we and our employees will handle the personal data of individuals (“Individuals”) including but not limited to service providers, suppliers, vendors, business associates, clients, enquirers, and users of our Website. 
4. KGP recognizes the privacy of the Individuals and have adopted this Policy which is compliant with the Personal Data Protection Act 2012 (No. 26 of 2012) (“PDPA”) and the European Union General Data Protection Regulation (“GDPR”) to reflect KGP’s commitment to respect and protect the Individuals’ privacy and personal data. 
5. KGP is acting as the data controller for our Website and other services that KGP may offer (collectively referred to as the “Businesses”). 
6. This Policy outlines the personal data that KGP collects, how it may be used, how it is stored and retained, whom it may be transmitted to as well as KGP’s and the Individuals’ responsibilities in relation to such uses and disclosures. 
7. The PDPA recognises the rights of individuals to protect their personal data (including rights of access and correction) and the requirement for organisations to collect, use or disclose personal data for legitimate and reasonable purposes. 

Collection of information:

1. We may collect and process the following information or data (including personal information and information that can be uniquely identified with individual persons) about the Individuals: 
   • Full name, including any aliases; 
   • E-mail address(es) and other contact information that the Individuals may provide to us; 
   • A record of any correspondence between the Individuals and us on the Website and in connection with the Businesses; 
   • A record of the activities of the Individuals on the Website and in connection with the Businesses; and 
   • Information that we may require from clients/users when they report a problem with the Website. 
2. We will collect only the information listed in paragraph above that is reasonable for us to provide the Individuals with our services. 
3. KGP makes a reasonable effort to ensure that the personal data collected is accurate and complete. KGP will not be responsible for relying on inaccurate or incomplete data arising from your failure to notify us of any changes or inaccuracies in your personal data that was initially provided. 
4. KGP only collects such information when the Individuals choose to supply the same to us. They do not have to supply any personal information to us but they may not be able to take advantage of all the services that KGP offers without doing so.

Use of information:

1. By using the Website and contacting KGP, you expressly authorize and consent to KGP gathering, reviewing, retaining and where reasonably required, transmitting your personal data to our intermediary companies and entities for the proper and reasonable purpose of them storing and using the data responsibly and in accordance with the PDPA. When you provide personal information to the Company, the information may be sent to servers located outside of Singapore. 
2. KGP will also take appropriate steps to ascertain that the foreign recipient organization of the personal data is bound by legally enforceable obligations that are in-line with the requirements under the PDPA. 
3. KGP may use this information to: 
   • Ensure that the content on our Website is presented in the most effective manner for the Individuals and for their personal computers, smartphones and other devices and customise the Website to their preferences; understand their activities interests; and optimize our Website’s display of information, and manage our business; 
   • Assist in making general improvements to the Website and our Businesses; 
   • Carry out and administer any obligations arising from any agreements entered into between the Individuals and KGP; 
   • Allow the Individuals to participate in features of the Website and other Businesses; 
   • Communicate with the Individuals by email or other chosen means to send relevant notifications about KGP’s events and services that may be of interest to them; 
   • Contact the Individuals and notify them about changes to the Website or the Businesses that KGP offers (except where they have expressly requested for us not to do so); 
   • Analyse how users are making use of the Website for KGP’s internal marketing and research purposes; 
   • Ensure that the Individuals comply with KGP’s terms and conditions and the applicable law; and 
   • Send the Individuals important notifications that they will require in order to use the Website. 

With whom we share the Individuals’ information:

1. KGP will not share the Individuals’ personal information with others except as indicated in this Privacy Policy or when KGP informs them and gives them an opportunity to opt out of having their personal information shared. KGP may share personal information with: 
   • Service providers: We may share information, including personal information, with third parties that perform certain services on our behalf. These services may include, without limitation, server hosting, marketing and supporting our notification service functionality. These service providers may have access to personal information needed to perform their functions but are not permitted to disclose or use such information for any other purposes.
   • We do not provide any non-anonymized personal information to third parties. We will adhere strictly to the provisions in the PDPA in relation to any disclosure and dissemination of information to any third parties.
2. KGP may disclose your information, including personal information in response to a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement or other government agency, to establish or exercise our legal rights, to defend against legal claims, or as otherwise required by law.
3. KGP will not transfer any of the Individuals’ personal data to a country or territory outside Singapore except to organisations that provide a standard of protection to personal data that is comparable to the protection under the PDPA.

Third Party Sites:

There are a number of places on our Website where users may click on a link to access other websites that do not operate under this Privacy Policy. These third-party websites may independently solicit and collect information, including personal information, from the users and, in some instances, provide us with information about the users’ activities on those websites. You should consult the privacy statements of all third-party websites that they visit.

How we protect personal information:

1. KGP will take security measures to help safeguard your personal information from unauthorised access, collection, use, copying, modification, disposal and disclosure. However, no system can be completely secure. Therefore, although KGP takes steps to secure the Individuals’ information, we cannot guarantee that the Individuals’ personal information, activities on the Website, or other communications in relation to the Businesses will always remain secure.
2. If you wish to delete all of their personal data in our possession, you may email us at enquiry@kgplegal.com.sg. Your personal data in our possession will be deleted within 24 hours.

Children’s privacy:

Although the Website is for a general audience, KGP restricts the use of the Website to individuals age 18 and above. KGP does not knowingly collect, maintain, or use personal information of children under the age of 18. It is your sole responsibility to provide your correct birth date.

No Third-party Rights:

This Policy does not create rights enforceable by third parties or require disclosure of any personal information relating to the Individuals.

Notification of changes to our Privacy Policy:

1. As part of KGP’s efforts to ensure that we properly manage, protect and process your personal data, we will review our policies, procedures and processes from time to time.
2. KGP reserves the right to amend the terms set forth under this Policy at our sole and absolute discretion.
3. KGP will post details of any changes to this Policy on the Website to help ensure that the Individuals are always aware of the information that we collect, how we use it, and in what circumstances, if any, that we share it with other parties.
4. You are encouraged to visit the Website from time to time to ensure that you are well informed of our latest policies in relation to personal data protection.

Specific provisions related to the European Union General Data Protection Regulation (GDPR):

1. KGP acknowledges that the GDPR will apply if we process or hold any personal data of individuals residing in the EU or if we offer goods or services to individuals in the EU.
2. KGP understands that we may lawfully process personal data if consent is provided by the Individual for the processing for specific purposes, if it is necessary for the performance of a contract of if it is necessary for our compliance with a legal obligation.
3. KGP understands that personal data must be processed lawfully, fairly and transparently, be collected and applied only for specified, explicit and legitimate purposes, must be limited to only what is required, must be accurate, not be kept in personally identifiable form for longer than is necessary and must be secured and protected pursuant to the GDPR.
4. KGP acknowledges and agrees that the GDPR affords Individuals with rights such as:
   • Right to access and obtain a copy of the Individuals’ personal data, including the purposes of processing and who the personal data has been disclosed to;
   • Right to rectify inaccurate personal data concerning the Individual;
   • Right to erasure of personal data concerning the Individual in certain circumstances;
   • Right to restriction of processing of personal data in certain circumstances, such as where the accuracy of the personal data is contested, or the processing is unlawful;
   • Right to data portability by receiving personal data concerning the Individual or data which has been provided to us, in a structured, commonly used and machine-readable format, and the right to transmit that data to another organisation;
   • Right to object to the processing of personal data in certain circumstances, including for the purposes of direct marketing; and
   • Right not to be subject to automated decision-making (including profiling) where this has a legal effect on the Individual or significantly affects him.
5. We agree that we will act on a request from an Individual without undue delay (within one month). We will maintain records of how we process personal data, acknowledge the need to conduct data protection impact assessments and the need to apply careful consideration in the adoption and engagement of our data processors.

Contact & Data Protection Officer:

If at any time you would like to contact KGP with your views about KGP’s privacy practices, or with any enquiry or request relating to your Personal Data, including but not limited to, the following:

• Any request to provide you with your personal data that is in KGP’s possession or control;
• Any request to withdraw your consent for the collection, use and/or disclosure of your personal data;
• Any enquiry on the ways in which your personal data has been or may have been used or disclosed by KGP within one year prior to the date of the enquiry; and
• Any request to correct an error or omission in your personal data, you should use one of the following means:
  • Kenneth G Pereire is the DPO of KGP Legal LLC. He can be reached at: kenneth@kgplegal.com.sg or at his office at: +65 6916 1298. ; or
  • Post to: KGP Legal LLC Anson Road, #23-05, International Plaza, Singapore 079903 KGP will process your request within ten (10) working days from the date on which the request for withdrawal of consent was made, and will thereafter not collect, use and/or disclose your personal data. However, your withdrawal of consent could result in certain legal consequences arising from such withdrawal. Depending on the extent of the withdrawal of consent, it may mean that KGP will not be able to continue with the existing relationship with you and the contract that you have with us will have to be terminated.