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Privacy Policy

Data Protection Policy

This Privacy Policy sets out the data protection policies and practices of HLS Partnership LLP (“HLS”, “we”, “us” or “our”) with respect to the collection, use, disclosure, processing, storage, access, review, and protection of personal data in accordance with the Singapore Personal Data Protection Act 2012 (Act 26 of 2012) (“PDPA”).

We are aware of, and comply with, the Advisory Guidelines issued by the Personal Data Protection Commission (“PDPC”), including the guidelines relating to the collection and use of NRIC numbers and other National Identification Numbers.

This Policy supplements, and does not limit or replace, any other consents you may have provided to us for the collection, use, or disclosure of your personal data. We reserve the right to update this Policy from time to time to ensure that it reflects our current practices and remains compliant with applicable laws.

Scope of This Policy

This Policy applies to “personal data”, which refers to data, whether true or not, about an individual who can be identified:

  • from that data alone; or

  • from that data and other information to which we have or are likely to have access.

The type of personal data collected will depend on the nature of your interaction with us and may include (but is not limited to):

  • Name

  • Identification numbers (e.g. NRIC or passport number, where permitted by law)

  • Nationality, gender, date of birth

  • Contact details such as telephone numbers, email address, and mailing address

  • Employment and professional information

  • Financial or transactional information

  • Photographs, audio-visual recordings, or correspondence

  • Any other information provided to us through forms, contracts, communications, or interactions

What Is Not Personal Data

Personal data does not include data that has been anonymised, such that the individual is no longer identifiable. Anonymisation techniques may include pseudonymisation, aggregation, data reduction, suppression, shuffling, or masking.

Collection, Use, and Disclosure of Personal Data

By providing your personal data to us (whether directly or through a third party), you consent to HLS Partnership LLP collecting, using, disclosing, and processing your personal data for purposes that include, but are not limited to:

  • Providing services or responding to enquiries

  • Managing and administering our business operations

  • Verifying identity where required

  • Communicating with you, including responding to requests, queries, or feedback

  • Managing contractual or professional relationships

  • Processing payments, invoices, refunds, or other financial transactions

  • Conducting accounting, auditing, tax, and regulatory compliance activities

  • Maintaining internal records and documentation

  • Improving our services and business processes

  • Complying with applicable legal, regulatory, or governmental requirements

We may also use your personal data for any other purposes that are reasonably related to the above or where required or permitted by law.

If you provide us with personal data relating to third parties, you represent that you have obtained the necessary consent from those individuals for us to collect, use, and disclose their personal data in accordance with this Policy.

Consent

a. Requirement for Consent

We will not collect, use, or disclose your personal data unless:

  • you have given or are deemed to have given consent; or

  • such collection, use, or disclosure is permitted or required under the PDPA or other applicable laws.

b. Provision of Consent

We will not obtain consent by providing false or misleading information regarding the purposes for which personal data is collected, used, or disclosed.

c. Withdrawal of Consent

You may withdraw your consent at any time by submitting a written request to our Data Protection Officer using the contact details below.

Please note that:

  • withdrawal of consent may affect our ability to provide services to you;

  • we may require up to ten (10) working days to process the withdrawal;

  • withdrawal does not affect our legal rights or obligations; and

  • personal data may still be retained where required for legal or business purposes under the PDPA.

Data Accuracy

We take reasonable steps to ensure that personal data collected by us is accurate, complete, and up to date. As we generally rely on information provided by you, please notify us promptly of any changes to your personal data.

Data Security and Retention

We implement appropriate administrative, physical, and technical safeguards to protect personal data against unauthorised access, disclosure, alteration, loss, or misuse.

While no system is completely secure, we continuously review and improve our security measures.

We retain personal data only for as long as necessary to fulfil the purposes for which it was collected, or as required or permitted by applicable laws. When no longer required, personal data will be securely disposed of.

Use of Cookies

Our website may use cookies to enhance functionality, improve user experience, and support security measures. Cookies are small text files stored on your device and may be accessed only by our servers.

You may manage cookie preferences through your browser settings.

Access and Correction Requests

You may request:

  • access to your personal data in our possession or control; and

  • information about how your personal data has been used or disclosed within the past year.

You may also request correction of any inaccuracies.

Requests should be submitted in writing to our Data Protection Officer. We may charge a reasonable administrative fee and reserve the right to refuse requests that are frivolous, vexatious, or otherwise exempt under the PDPA.

We will respond as soon as reasonably practicable and within the timeframes prescribed by the PDPA.

Transborder Data Transfers

We generally do not transfer personal data outside Singapore. Where such transfer is necessary, we will take reasonable steps to ensure that the receiving party provides a level of protection comparable to that required under the PDPA.

Enquiries and Complaints

HLS Partnership LLP has appointed a Data Protection Officer to oversee compliance with data protection laws.

Data Protection Officer:
Michael Heng

Email: michael@hlspartnership.com

Address:
61 Robinson Road
#08-01
61 Robinson
Singapore 068893

If your personal data was provided to us by a third party, please contact that party directly for access or correction requests.