Definitions
“Client Contact” refers to a existing, past, or prospective direct customer of Attunemen or its Partners.
“Data Processor” refers to any natural or legal person that Processes Personal Data under the instructions of Attunemen.
“Partner” refers to any natural or legal person with whom Attunemen may be engaged in commercial relationships.
“Personal Data” is any information that is recorded in any form relating to an identifiable natural person.
“Personnel” refers to any employee, former employee, representative consultant, job applicant, director of Attunemen.
“Process (-ing, -es, -ed)” means to perform any operation or set of operations which is performed upon Personal Data, whether or not by automatic means, such as collection, recording, organization, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, erasure or destruction.
“Third Party” is any natural or legal person, or any other body other than the said person, Attunemen, Data Processor or Vendor.
“Vendor” refers to any natural or legal person who is not an employee, and under contract to provide services to Attunemen.
Introduction
As a global provider of translation and other commercial services, Attunemen Pte. Ltd. (“Attunemen”) is trusted by customers, employees, vendors and partners to safeguard the confidentiality and integrity of their content. Attunemen has deployed a variety of measures to ensure that this content is protected appropriately and is transferred securely. When content consists of “personally identifiable information” or “Personal Data”, Attunemen has implemented special procedures for processing, storage and transfer of Personal Data. These procedures are detailed in this Privacy Policy, and applies to all Personal Data that Attunemen processes, transfers or stores, whether from Personnel, Vendors, Partners or Client Contacts.
Scope
This Policy applies to all Personal Data received by Attunemen in any format. Attunemen will ensure all data handled by our offices conform to this Policy.
Cookies and Online Privacy
Attunemen corporate website and online portals use cookies, tracking pixels and related technologies. Cookies are small data files that are served by our platform and stored on your device, for a variety of purposes including to operate and personalize the website. Attunemen vendor portals store and processes Personal Data for the purposes of providing e-invoicing services, and fulfilling our payment obligations. Personal Data may be shared with payment Vendors to facilitate bank compliance checks and fulfilment of remittance transactions.
Notice
Attunemen treats all Personal Data received as confidential, in accordance with current confidentiality undertakings which have been provisioned as part of all of our contracts with all Personnel, Clients, Vendors and Partners. Attunemen notifies all identified persons regarding the types of Personal Data collected and its intended uses. Attunemen does not use Personal Data for purposes beyond its intended uses.
Attunemen works with a global network of Vendors to assist in the process of translation and other activities. These Vendors may be exposed to Personal Data in performance of these services. However, they are at all times subject to confidentiality agreements and are authorized only to use such information within the scope of performance of the services.
Any Vendor has the right to terminate its working relationship with Attunemen, and upon which, to request the deletion of Personal Data pertaining to them in accordance with applicable law. However, Attunemen will continue to maintain Personal Data in accordance with its Privacy Notices and in accordance with Attunemen records retention policies and local laws and regulations. This practice is in the best interests of both parties so that identifying information relating to a particular matter is accessible but sufficiently discrete so that Personnel will no longer have access to their Personal Data, and Attunemen does not accidentally contact them for projects in the future.
Attunemen may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet bank compliance, national security or law enforcement requirements.
Choice
Attunemen’s Personnel, Vendors, Partners and Client Contacts have the opportunity to opt out from allowing Attunemen to process Personal Data for any purpose other than its original purpose. Attunemen will not disclose Personal Data to any Third Party for the purposes of marketing of any products or services without seeking and receiving permission, or providing an opportunity to opt out of receiving the direct marketing.
In order to better serve our Client’s needs, Attunemen may from time-to-time, send information on additional services we provide. Should any Client Contact decide that this information is not desirable, the Client Contact may opt-out of receiving this information.
Personnel, Vendors, Partners and Client Contacts can ask questions and exercise his or her rights with respect to Personal Data by contacting Attunemen at privacy@attunemen.com. However, Attunemen will continue to maintain Personal Data in accordance with its Privacy Notices and in accordance with Attunemen records retention policies and local laws and regulations.
With regard to Personal Data that Attunemen receives in connection with the employment or business relationship, Attunemen will use such Personal Data only for the purpose for which it was originally collected. If Attunemen intends to disclose Personnel Personal Data to a Third Party for any purpose other than its original purpose, Attunemen will provide the Personnel or Client Contact with an opportunity to opt-out of such uses.
Onward Transfer
Attunemen will obtain assurances from Data Processors, Partners, Third Parties and Vendors that they will safeguard Personal Data consistent with this Policy. Attunemen will take all precautions with respect to this Policy to prevent, contain, or stop disclosure contrary to such entity’s confidentiality obligations.
Access and Correction
Attunemen will provide individuals with reasonable access to the Personal Data they have provided to Attunemen and will allow them to review and correct this Personal Data. Access to review this Personal Data will be granted in accordance with applicable law, and except where the expense of providing access would be disproportionate to the risks to the Personnel’s privacy or in any situation where the rights of others would be violated.
Attunemen conducts annual assessment to verify that this Policy is published, accurate, comprehensive, prominently displayed, implemented, accessible and conforms to the principles of Singapore PDPA. Attunemen has implemented and maintains procedures for training Personnel in the implementation of the Policy.
Data Integrity
Attunemen ensures that all applicable Personal Data is accurate, complete, current and reliable for its intended use. However, it is highly recommended that Personnel, Vendors, Partners and Client Contacts continue to monitor the information provided to Attunemen and remain proactive with advising Attunemen of the need for updates and corrections as and when needed.
Data Security
Attunemen undertakes to protect Personal Data using reasonable organisational, technical and administrative procedures to protect against unauthorized or unlawful access, processing, disclosure, alteration, destruction or accidental loss of your Personal Data. These precautions include password protections for online information systems and restricted access to Personal Data. Attunemen may assign different types of data different access rights, with appropriate corresponding security precautions. Attunemen also restricts access to Personal Data to those Personnel or Data Processors of Attunemen that have a legitimate business need for such access.
Independent Resources for Privacy Complaints
Attunemen commits to resolve complaints about our collection and use of your personal information. To exercise all relevant rights, queries or complaints, or any other issues arising under this Policy, please send an email to privacy@attunemen.com.
Enforcement
Attunemen verifies adherence to this Policy once per year as part of its annual review and internal compliance measures. Attunemen will use its best efforts to ensure compliance with this policy, and that the Policy remains accurate, comprehensive, and continues to conform to applicable law. We encourage any issues or concerns with Attunemen’s Policy to be raised immediately to privacy@attunemen.com. All issues will be officially documented and addressed as per our internal framework.
Effective May 2019