Privacy Policy

Vibrant Recycle’s Privacy Policy



1 – Introduction




At Vibrant Recycle, we respect the privacy and
confidentiality of the personal data of our Clients, Associates and others whom
we interact with in the course of providing our services. We are committed to
implementing policies, practices and processes to safeguard the collection, use
and disclosure of the personal data you provide us, in compliance with the Singapore
Personal Data Protection Act (PDPA) 2012.




We have developed this Data Privacy Notice to assist you in
understanding how we collect, use, disclose, process, protect and retain your
personal data that is in our possession.




2 – How We Collect Your Personal Data




Personal data refers to any information that can uniquely
identify an individual person (a) on its own, or (b) when combined with other
information. Under the PDPA, business contact information (e.g. full name,
business address, business telephone number) is not considered as personal data
so long as it is used strictly for business-to-business (B2B) transactions.




We collect your personal data when you:


Enter into an agreement or contract with us to provide you
with our consultancy and advisory services

Register for and enrol in any of the training courses and
certification programmes that we conduct (including processing of your
applications under any government funding programmes that we are under)

Respond to our electronic direct mails (EDMs) sent by us as
part of our marketing or promotion campaigns through an authorised third party
EDM service provider

Are referred to us for our services by one of our clients

Enquire about our range of training courses and services

Visit our website and leave behind your contact information
through our contact form

Communicate with us via emails or written correspondences



3 – Types of Personal Data We Collect About You




The types of personal data we collect about you include:


Your contact information (Name, Email Address)

Your personal details (Name, Gender, Date of Birth,

Your NRIC/Passport last four characters for course attending
taking and verification



4 – How We Use Your Personal Data




We use the personal data you provide us for one or more of
the following purposes:


Enrolling you onto our training programmes

Analyse your visits to our website

Provide our consultancy and advisory services

Conduct training courses and programmes that you have signed
up for

Process account payables/receivables

Process billing, payment and other credit-related activities

Conduct direct marketing and lead generation activities
through analysing and tracking of our sales proposals, advertisements and EDMs
on our events, conferences, seminars and workshops

Conduct joint marketing with other companies and service

Communicate with customers, members and website visitors

Respond to your inquiries and feedback to improve our
quality of service

Analyse the use of our products, services or websites

Carry out our obligations arising from any contracts entered
into between you and us

Comply with or fulfil legal obligations and regulatory



5 – Who We Disclose Your Personal Data To




We disclose some of the personal data you provide us to the
following entities or organisations outside Vibrant Recycle in order to fulfil
our services to you:


External educational regulators (e.g. Skillsfuture

External professional service providers (Book-keepers)

EDM/Email Service Vendors (e.g. Mailchimp)

Cloud Service Providers



Where required to do so by law, we may disclose personal
data about you to the relevant authorities or to law enforcement agencies.




6 – How We Manage the Collection, Use and Disclosure of Your
Personal Data




6.1       Obtaining


Before we collect, use or disclose your personal data, we
will notify you of the purpose why we are doing so. We will obtain written
confirmation from you on your expressed consent. We will not collect more
personal data than is necessary for the stated purpose. We will seek fresh
consent from you if the original purpose for the collection, use or disclosure
of your personal data has changed.


Under certain circumstances, we may assume deemed consent
from you when you voluntarily provide your personal data for the stated
purpose, e.g. when you apply for a job with us by sending in your resume/CV
containing personal information.


We may rely on exceptions to the need for consent under the
PDPA for the collection, use or disclosure of your personal data under the
following circumstances (only those relevant to Vibrant Recycle are included):


The personal data is publicly available

The personal data is disclosed by a public agency or
disclosed to a public agency

The personal data is necessary for any investigation or

The personal data is necessary for evaluative purposes (e.g.
determining the suitability of a job applicant for the job applied for)

The personal data is necessary for the purpose of managing
or terminating an employment relationship

The personal data is necessary for a business asset





6.2       Withdrawal
of Consent


If you wish to withdraw consent, you should give us
reasonable advance notice. We will advise you of the likely consequences of
your withdrawal of consent, e.g. without your personal contact information we
may not be able to inform you of future services offered by us.


Your request for withdrawal of consent can take the form of
an email or letter to us, or through the “Unsubscribe” feature in an online




6.3       Use of


We use “cookies” to collect information about your online
activity on our website. A cookie is a small text file created by the website
that is stored in your computer to provide a way for the website to recognise
you and keep track of your preferences. The cookie makes it convenient for you
such that you do not have to retype the same information again when you revisit
the website or in filling electronic forms.




Most cookies we use are “session cookies”, which will be deleted
automatically from the hard disk of your computer at the end of the session.




You may choose not to accept cookies by turning off this
feature in your web browser. Note that by doing so, you may not be able to use
some of the features and functions in our web applications.




6.4       Third-Party


We do not get consent on behalf of another individual. We
only get consent from the individual who will be dealing directly with us.




7 – How We Ensure the Accuracy of Your Personal Data




We will take reasonable steps to ensure that the personal
data we collect about you is accurate, complete, not misleading and kept


From time to time, we may do a data verification exercise
for you to update us on any changes to the personal data we hold about you. If
we are in an ongoing relationship with you, it is important that you update us
of any changes to your personal data (such as a change in your mailing




8 – How We Protect Your Personal Data




We have implemented appropriate information security and
technical measures to protect the personal data we hold about you against loss;
misuse; destruction; unauthorised alteration/modification, access, disclosure;
or similar risks.




We have also put in place reasonable and appropriate
organisational measures to maintain the confidentiality and integrity of your
personal data, and will only share your data with authorised persons on a ‘need
to know’ basis.




When we engage third-party data processors to process
personal data on our behalf, we will ensure that they provide sufficient
guarantees to us to have implemented the necessary organisational and technical
security measures, and have taken reasonable steps to comply with these




9 – How We Retain Your Personal Data




We have a document retention policy that keeps track of the
retention schedules of the personal data you provide us, in paper or electronic
forms. We will not retain any of your personal data when it is no longer needed
for any business or legal purposes.


We will dispose of or destroy such documents containing your
personal data in a proper and secure manner when the retention limit is




10 – How You Can Access and Make Correction to Your Personal




You may write in to us to find out how we have been using or
disclosing your personal data over the past one year. Before we accede to your
request, we may need to verify your identity by checking your NRIC or other
legal identification document. We will respond to your request as soon as
possible, or within 30 days from the date we receive your request. If we are
unable to do so within the 30 days, we will let you know and give you an
estimate of how much longer we require. We may also charge you a reasonable fee
for the cost involved in processing your access request.




If you find that the personal data we hold about you is
inaccurate, incomplete, misleading or not up-to-date you may ask us to correct
the data. Where we are satisfied on reasonable grounds that a correction should
be made, we will correct the data as soon as possible, or within 30 days from
the date we receive your request.




11 – Transfer of Personal Data




Where there is a need to transfer your personal data to
another country outside Singapore, we will ensure that the standard of data
protection in the recipient country is comparable to that of Singapore’s PDPA.
If this is not so, we will enter into a contractual agreement with the
receiving party to accord similar levels of data protection as those in




12 – Mandatory Data Breach Notification




In the unlikely event that we suffer a data breach
pertaining to unauthorised access or disclosure of personal data being stored
or processed by us, we will meet the PDPA’s breach notification timelines and
requirements to perform the needful, including but not limited to informing
relevant authorities and affected individuals, based on the Significant Harm or
Significant Scale definitions as set out by the PDPA.




13 – Contacting Us




If you have any query or feedback regarding this Notice, or
any complaint you have relating to how we manage your personal data, you may
contact our Data Protection Officer (DPO) at:




Any query or complaint should include, at least, the
following details:


Your full name and contact information

Brief description of your query or complaint



We treat such queries and feedback seriously and will deal
with them confidentially and within reasonable time.




14 – Changes to this Data Privacy Notice




We may update this Data Privacy Notice from time to time. We
will notify you of any changes by posting the latest Notice on our website.
Please visit our website periodically to note any changes.


Changes to this Notice take effect when they are posted on
our website.






Last updated: 15 November 2023