Last Updated: 23 August 2020.
THIS POLICY DESCRIBES THE PRIVACY PRACTICES OF THE HARBOUR CLUB IN CONNECTION WITH OUR WEBSITE AND ITS SERVICES AND THE RIGHTS AVAILABLE TO OUR USERS WITH RESPECT TO THEIR PERSONAL INFORMATION. PLEASE CAREFULLY READ THIS DOCUMENT BEFORE ACCESSING AND/OR BROWSING AND/OR USING THIS WEBSITE AND/OR ITS SERVICES.
For the purposes of this document, the “Harbour Club” and/o “We“ and/or “Our” and/or “Us means The Harbour Club Pte Ltd. and its affiliates. “You,” “Your” or “User” means any individual accessing and using this Website and its Services.
DATA CONTROLLER INFORMATION
The information about the Data Controller is as follows:
- Business The Harbour Club Pte Ltd
- Phone number: +44 203 397 2948
- Email: [email protected]
PERSONAL AND NON-PERSONAL INFORMATION
WHAT IS NON-PERSONAL INFORMATION AND HOW IS IT COLLECTED AND USED?
Non personal information is information that cannot identify you. If you visit this Website to read information, such as information about one of our services, we may collect certain non-personal information about you from your computer’s web browser. Because non-personal information cannot identify you or be tied to you in any way, there are no restrictions on the ways that we can use or share non-personal information. What is personal information and how is it collected? Personal information is information that identifies you as an individual, such as your name, mailing address, e-mail address, and telephone number. We may collect personal information from you in a variety of ways:
- When you send us an application or other form.
- When you conduct a transaction with us.
- When we collect information about you in support of a transaction, such as credit card information.
- In some places on this Website you have the opportunity to send us personal information about yourself, to elect to receive particular information or to participate in our courses, workshop or events.
HOW WE COLLECT AND USE YOUR INFORMATION
We may collect and store Personal Information or other information that you voluntarily supply to us online while using our Website and its Services (e.g., while on the Website or in responding via email to a feature provided on the Website). We only contact individuals who specifically request that we do so or in the event that they have signed up to receive our messaging or newsletter, attended one of our events, workshops or courses.
We collect Personal Information when you contact us for booking a Training Course or paying a Membership Plan. Generally, this information includes name and e-mail address for registration or opt-in purposes and name, postal address, and credit card information when registering for our events, workshops or courses. All of this information is provided to us by you.
We also collect and store information that is generated automatically as you navigate online through the Website. For example, we may collect information about your computer’s connection to the Internet, which allows us, among other things, to improve the delivery of our web pages to you and to measure traffic on the Website.
We use the information we collect from you while you are using our Website and Services in a variety of ways, including using the information to customize features; advertising that appears on the Website; and, making other offers available to you via email, direct mail, through our newsletter or otherwise.
We reserve the right to use, and to disclose to third parties, all of the information collected from and about you while you are using the Website and Services in any way and for any purpose, such as to enable us or a third party to provide you with information about products and services. If you do not wish your information to be used for these purposes, please read “Your Data Rights” and “Your Requests and our Response Timing” Sections below.
Please keep in mind that whenever you voluntarily make your personal information available for viewing by third parties online – for example on message boards, web logs, through email, or in chat areas – that information can be seen, collected and used by others besides us. We cannot be responsible for any unauthorized third-party use of such information.
The Personal information collected online may be combined with information you provide to us through other sources. We may also remove your personal identifiers (your name, email address, social security number, etc). In this case, you would no longer be identified as a single unique individual. Once we have de-identified information, it is non-personal information and we may treat it like other non-personal information.
Please also note that as our business grows, we may buy or sell various assets. In the unlikely event that we sell some or all of our assets, or one or more of our websites is acquired by another company, information about our Users may be among the transferred assets.
COOKIES AND SIMILAR TECHNOLOGIES
We also may use a standard feature found in browser software called a “Cookie” to enhance your experience with our Website. Cookies are small files that your web browser places on your hard drive for record-keeping purposes. By showing how and when Users use the Website, cookies help us deliver advertisements, identify how many unique Users visit us, and track User trends and patterns. They also prevent you from having to re-enter your preferences on certain areas of the Website where you may have entered preference information before.
Our Website may also use web beacons (single-pixel graphic files also known as “transparent GIFs”) to access cookies and to count users who visit the Website or open HTML-formatted email messages.
To restrict or block any Cookies used on our Website, you will only need to change the browser settings in your device to access our Website. Please be aware that some of our Services will not operate if your browser does not accept our Cookies. For more details about how to restrict or block Cookies, please visit: http://www.allaboutcookies.org.
INFORMATION SHARED WITH THIRD PARTIES
We do not use or share any of your Personal Information with third parties for any purposes without your express consent. In the ordinary course of business, we may share some personal information with companies that we hire to perform services or functions on our behalf as our service providers and/or third parties (“Data Processors”). In all cases in which we share your personal information with a third party for the purpose of providing a service to us, we will not authorize them to keep, disclose or use your information with others except for the purpose of providing the services we asked them to provide.
We will not sell, exchange or publish your personal information, except in conjunction with a corporate sale, merger, dissolution, or acquisition. For some sorts of transactions, in addition to our direct collection of information, our Data Processors (such as credit card companies, clearinghouses and banks) may collect Personal Information directly from you to assist you with your transaction.
We do not control how these third parties use such information, but we do ask them to disclose how they use your Personal Information before they collect it. If you submit a review for a third party (person or business) using our Facebook Fan Review Application, during the submission process we ask your permission to gather your basic Personal Information (such as name and email address) which we then share with the third party for whom you are submitting the review.
INTERNATIONAL DATA TRANSFER
We are a company legally incorporated and domiciled in the Republic of Singapore and provide our Services globally. We process and store your information in the Republic of Singapore and/or United States of America, however, our service providers (Data Processors) may process and store it in such countries and/or any place else.
If you are located outside the Republic of Singapore and/or United States of America and choose to provide us with your Personal Information, we will transfer your Personal Information to the Republic of Singapore and/or United States of America for due processing, and our Data Processors may process your Personal Information in the Republic of Singapore and/or United States of America and/or any place else. You expressly accept and acknowledge that such countries may not have the same data protection laws as your country or the country in which you initially provided your Personal Information. Notwithstanding, we will ensure that our Data Processors apply at least the basic data security standards so that your Personal Information remains undisclosed and secure.
We may be legally compelled to release your personal information in response to a court order, subpoena, search warrant, law or regulation.
We may disclose your Personal Information to third parties if we feel that the disclosure is necessary to protect our rights or property, protect someone’s health, safety or welfare, or to comply with a law or regulation, court order or other legal process.
We should cooperate with law enforcement authorities in investigating and prosecuting Website Users who violate our rules or engage in behavior, which is harmful to other User (or illegal), as well as other third parties to enforce laws, such as: intellectual property rights and other rights, to help protect you and all our Users of any crime or fraud. For this reason, and in response to a verified request by law enforcement or other government officials relating to a criminal investigation or alleged illegal or fraudulent activity, we may (and you expressly authorize us to) disclose your Personal Information, user history, fraud complaints, and similar information without a subpoena. However, in an effort to respect your privacy, we will not otherwise disclose your Personal Information to law enforcement or other government officials without a subpoena, court order or substantially similar legal procedure, except when we believe in good faith that the disclosure of information is necessary to prevent imminent physical harm, fraud or financial loss; or report suspected illegal or fraudulent activities.
HOW WE SECURE PERSONAL INFORMATION
We guarantee the privacy and confidentiality of your Personal Information and also guarantee that we have implemented physical and electronic security measures, as well as other appropriate administrative procedures to prevent unauthorized or illegal access by third parties to your Personal Information. Only authorized personnel and our Data Processors have access to your personal information, and these employees and services providers are required to treat this Information as confidential.
We will continually review and update our security policies and controls as technology changes to ensure ongoing information security.
We implement and maintain reasonable and appropriate technical and organizational security measures to protect the Personal Information we process, from unauthorized access, alteration, disclosure, loss or destruction.
We regularly audit the application of our security measures and we ask third party experts to review our security controls against international standards. These audits help us to further improve our security level. Should in despite of the security measures, a security breach occur that is likely to result in a risk to your Personal Information, we will inform our Users about the security breach as soon as reasonably possible.
We protect your Information safely in a high security data center, adhering to stringent security controls, measures and protocols to safeguard the privacy of your information. While we shall use our best efforts to ensure that the privacy of all Information is kept secure, please note that it is an accepted fact that no data transmission conducted over the Internet and/or through other electronic channels can be guaranteed to be completely secure. As such, please ensure that your information is not accessible or disclosed to anyone. Further, we shall neither be held responsible nor liable for any damages or losses which you may suffer, whether directly or indirectly, as a result of the said Information being stolen, tampered with, copied, abused, misused or otherwise violated.
DATA STORAGE AND RETENTION
We may store and retain your Personal Information until necessary but for a limited period of time that may not exceed one (1) year, since the last time you use our Services.
We may also retain data for such a longer period as may be in our legitimate interests, when such data cannot directly be identified with a specific User. We use this kind of data for research purposes only and to help us develop and improve our services, and we take appropriate measures to ensure you can not be re-identified from this data.
YOUR DATA RIGHTS
a) Right of Access and Data Portability
You may issue queries or ask questions about your Personal Information by email at any time, and we will provide you with such information.
You have the right to ask us to provide you with any Personal Information that you have registered with us and is stored in our records, at any time, in any usable format by other service providers or third parties.
We will provide you such Personal Information in a structured, commonly used, machine-readable format, or (where technically feasible) to have it ported directly to another data controller, provided this does not adversely affect the rights and freedoms of others.
a) Right to Data Rectification
You have the right to ask us to update and/or rectify and/or complete your inaccurate or incomplete Personal Information.
Please note that although all reasonable efforts will be made to keep your Personal Information updated, you are kindly requested to inform us promptly of any change, error or inaccuracy in your Personal Information.
a) Right to Be Forgotten
You have the right to ask us to delete your Personal Information when it is not relevant to the purpose for which we collect it, once the period established in “Data Store and Retention” Section above has elapsed. We may delete your Personal Information before the expiration of that period, when such information is not necessary, at our sole discretion.
However, please keep in mind, there may be legal obligations which may prohibit us from deleting all or part of the Personal Information held about you immediately at the time of the request, however we will process your request at the earliest opportunity whenever the data retention period expires in accordance with “Data Store and Retention” Section above.
a) Right to Object or Restrict the Data Processing
You have the right to object or request us to suspend the processing of your Personal Information when you have a legitimate interest (or those of a third party) and there is something about your particular situation that causes you to object to the processing because it makes you feel it impacts your fundamental rights and freedoms.
You also have the right to object the processing of your Personal Information for direct marketing purposes on grounds of legitimate interest. You may also object us for showing your targeted ads on our Website, in which case you will not see any less ads but you will see ads that are less relevant to your interests.
a) Right to Withdraw Consent
YOUR REQUESTS AND OUR RESPONSE TIMING
You may exercise, at any time, your rights as described in Section above by contacting us at [email protected].
All communications with us must be through the e-mail address that you have provided to us when using our Services. Please note that we will verify your identity prior to responding to any request.
We try to respond to all legitimate requests within one month. Please keep in mind that occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
We also use Google Analytics Advertiser Features to optimize our business. Advertiser features include:
- Remarketing with Google Analytics.
- Google Display Network Impression Reporting.
- DoubleClick Platform integrations.
- Google Analytics Demographics and Interest Reporting.
By enabling these Google Analytics Display features, we are required to notify our Users by disclosing the use of these features and that we and third-party vendors use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to gather data about your activities on our Website. Among other uses, this allows us to contact you if you begin to fill out our check-out form but abandon it before completion with an email reminding you to complete your order. The “Remarketing” feature allows us to reach people who previously visited our Website, and match the right audience with the right advertising message.
We abide by Facebook’s Data Use Restrictions.
- Any ad data collected, received or derived from our Facebook ad (“Facebook advertising data”) is only shared with someone acting on our behalf, such as our service provider. We are responsible for ensuring that our service providers protect any Facebook advertising data or any other information obtained from us, limit our use of all of that information, and keep it confidential and secure.
- We do not use Facebook advertising data for any purpose (including retargeting, commingling data across multiple advertisers’ campaigns, or allowing piggybacking or redirecting with tags), except on an aggregate and anonymous basis (unless authorized by Facebook) and only to assess the performance and effectiveness of our Facebook advertising campaigns.
- We do not use Facebook advertising data, including the targeting criteria for a Facebook ad, to build, append to, edit, influence, or augment user profiles, including profiles associated with any mobile device identifier or other unique identifier that identifies any particular user, browser, computer or device.
- We do not transfer any Facebook advertising data (including anonymous, aggregate, or derived data) to any ad network, ad exchange, data broker or other advertising or monetization related service.
This Website contains links to other websites that provide information that we consider to be interesting. We are not responsible for the privacy practices or the content of such websites.
This Website may provide public discussions on various business valuation topics. Please note that any information you post in these discussions will become public, so please do not post sensitive information in the public discussions. Whenever you publicly disclose information online, that information could be collected and used by others. We are not responsible for any action or policies of any third parties who collect information that Users disclose in any such forums on the Website. We do not agree or disagree with anything posted on the discussion board. Also remember that you must comply with our other published policies regarding postings on our public forums.
.This Website is not directed to individuals who are below legal age as prescribed by applicable laws (“Minors”). For this reason, we will not intentionally collect any Personal Information from a Minor (such as a minor’s name or email address).
We screen Users who wish to provide Personal Information in order to prevent Minors from providing such information. If we become aware that we have inadvertently received personally identifiable information from a Minor through our Website, we will delete such information from our records. If we change our practices in the future, we will obtain prior, verifiable parental consent before collecting any personally identifiable information from Minors to provide our Services.
We do not collect any personally identifiable information from Minors and we also do not knowingly distribute such information to third parties.
We do not knowingly allow Minors to publicly post or otherwise distribute personally identifiable contact information through the Website. Because we do not collect any personally identifiable information from Minors, we also do not condition the participation of a Minor in our Website’s online activities on providing personally identifiable information.
If you think that we have collected Personal Information from a Minor, please contact us immediately.