Identity of the Data Processor
Spark Commodities Pte Ltd (hereafter “Spark Commodities”, “we” or “us”), a company registered in Singapore with 201909431K as the ACRA registration number (hereinafter “Spark”).
Collection of Personal Data
Spark will receive and/or collect Personal Data of the members, clients, employees or representatives of companies (“Data Subject”). This includes any kind of Personal Data as understood under EU General Data Protection Regulation n°2016/679 (“G DPR”), as for example (a) identification data (name, first name, email address, mailing address, contact number, company details, position within company); (b) information about your connection and device capability in connection and interaction with our Site; (c) electronic identification data (as for example internet protocol address and cookies); (d) your user profile (e) member registration data (including relevant company information). All information of the nature specified in (a) to (e) shall be known as “Personal Data”.
Purpose of the collection of Personal Data
The Personal Data collected will be used in order to enable Spark to fulfil its mission as Service Provider. The legal basis of this processing results from the execution of the contractual documentation applicable to the Services subscribed by the Members.
The purposes for which Spark collect, hold and use Personal Data are :
- To respond to an individual’s request;
- To maintain contact with members;
- For general management and reporting purposes, such as invoicing and account management as necessary; and
If you choose not to provide us with Personal Data, we will be unable to do the above functions.
We collect, hold and use Personal Data about individuals to market our Services, including by email. However, individuals always have the opportunity to elect not to receive further marketing information from us by writing to Spark Commodities at email@example.com.
Recipients of the Personal Data
The Personal Data collected are aimed at operating our services. Spark shall be considered as the main recipient of the collected Personal Data.
Disclosure of Personal Data
You agree that we may disclose your Personal Data to third parties under any of the following circumstances:
- When we have your consent to disclose the Personal Data;
- We need to disclose your Personal Data to provide the Services that you have requested;
- We need to disclose the Personal Data to third parties who on behalf of us provide Services to you or assist us in maintaining the quality and efficiency of our Services and our business operations (we will only provide such third parties the relevant information required for the provision of the Services, and the third parties are prohibited from keeping, using or disclosing such Personal Data for any unauthorised purpose); or
- Such disclosure is otherwise required or permitted by law.
We process your data on servers and IT systems in Singapore. In individual cases, your Personal Data may also be processed in third countries, which may not offer the same level of protection as the places where you first provided the data. However, we will only transfer your personal data to contractors to companies in third countries if we have agreed with the relevant contractors a standard data protection clause adopted by the European Commission as adequate protection for your personal data.
Transfer of Personal Data
You also acknowledge and agree that the information that you provide may be stored or processed in, or transferred to, servers of our affiliates and of our service providers.
While we will take reasonable care in preventing the loss, misuse or alteration of your Personal Data, you acknowledge that the security of data transmitted over the Internet cannot be guaranteed.
We may sell or buy subsidiaries or business units. In such transactions as well as in the event that all or substantially all of our assets are acquired by a third party, your Personal Data will generally be one of the transferred business assets. We reserve the right to include your Personal Data, collected as an asset, in any such transfer to a third party.
Personal Data Management
Spark Commodities takes reasonable steps to protect Personal Data it holds from misuse, interference and loss and from unauthorised access, modification or disclosure.
Personal Data will be stored for as long as the user has access to the Service. It will be retained for an additional 24 months in case it is required by either party, or in accordance to prevailing regulations. Where Personal Information is no longer required for the purpose for which it was collected, reasonable steps will be taken to destroy or permanently de-identify the information, unless we are legally required to retain it. Unsolicited Personal Data received from third parties that does not serve an appropriate purpose will be destroyed.
Any Personal Data breach shall be reported to the supervisory authority within 72 hours.
Any individual has the right to obtain transparent information, to oppose, access, withdraw consent and rectify any data which is relevant. If you wish to exercise any of these rights, please contact Michelle Ma at firstname.lastname@example.org. Any processing of data must be brought to the attention of the individual via email at the time of first communication.
These rights may also be exercised by writing with acknowledgment of receipt to :Spark Commodities
3 Pickering Street #03-53, Nankin Row,
Any complaint may be addressed to the Personal Data Protection Commission of Singapore via their website.
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