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privacy policy

i. In The Present Pte. Ltd. (“In The Present” or as appropriate in the context, “we”; “us”; or “our”) is a company that offers training and consultancy services to organizations such as leadership/team development and organizational culture building; coaching services to individuals such as life/career/executive/grief/trauma/relationship/peer coaching; mindfulness programs and activities such as the Mindfulness-Based Stress Reduction program, meditation and yoga; couples therapy; and related talks, seminars, workshops, courses or events (henceforth collectively known as our “Services”). In The Present also has a presence on the world wide web, at www.inthepresent.sg (referred to as “Website”). ii. We are committed to safeguarding your privacy. When you visit our Website and more generally, access any of our Services, we appreciate that you are trusting us with your personal information. We collect, use, store and disclose your personal information as explained in this document (the "Privacy Policy") in accordance with the Personal Data Protection Act ("PDPA"). Please read this Privacy Policy before using our Website, accessing our Services or providing us with any personal information, to make sure you understand how the information will be collected, used, stored and disclosed. iii. This Privacy Policy is applicable to any data processing implemented by In The Present and any In The Present Website. This Privacy Policy describes the types of personal information we may collect from you, how we may use that information, and with whom we may share it. This Privacy Policy also describes the measures we take to protect the security of the information you provide to us, including without limitation through this Website. We also tell you how you can reach us to update your personal information, ask questions you may have about our personal data protection practices and provide feedback on our personal data protection practices. iv. We reserve the right to change modify, add or delete portions of the terms of this Privacy Policy, at our sole discretion, at any time. If you do not agree with this Privacy Policy at any time, do not use our Website or access our Services or give us any of your personal information. v. YOU AGREE AND CONSENT to In The Present as well as our respective agents, authorized service providers and relevant third parties collecting, using, storing, disclosing and/or sharing your Personal Data in the manner set forth in this Privacy Policy. By using our Website, enquiring/accessing our Services, or submitting your information, you are confirming that you are bound by this Privacy Policy. You will be deemed to have read, understood and agreed to the practices and policies outlined in this Privacy Policy and you hereby consent to our collection, use and disclosure of your information as described in this Privacy Policy. vi. YOU HEREBY REPRESENT AND WARRANT that all Personal Data you have submitted or will submit to us is complete, accurate, true and correct and you are responsible for keeping your Personal Data up to date. You acknowledge that failure on your part to do so may result in our inability to provide you with the products and/or Services you have requested. To update your Personal Data, please contact our Data Protection Officer. vii. Where you provide to us Personal Data concerning individuals other than yourself, YOU HEREBY REPRESENT AND WARRANT that you have obtained all legally required consents, whether explicit or deemed, from the concerned individuals. You shall retain proof of such consent(s), and such proof is to be provided to us upon our request. viii. This Privacy Policy supplements (but does not supersede or replace) any other consents which you may have previously provided to us and it does not affect our legal rights concerning the collection, use, storage and/or disclosure of your Personal Data. Any material changes to our personal data protection practices shall be notified to you.
SECTION 1: TYPES OF PERSONAL DATA
i. “Personal Data” is defined under the PDPA to mean any data, whether true or not, about an individual who can be identified from that data or from that data and other information to which an organization has or is likely to have access. This would include, without limitation, information such as name, address, telephone number, e-mail address, credit card details and any other personal information. ii. Generally, some of our Services require us to know who you are so that we can best meet your needs. When you send us an query or request, or access any of our Services, we may ask you to voluntarily provide us with certain information that personally identifies you or could be used to personally identify you. iii. Without prejudice to the generality of the above, information collected by us from you may include but not limited to the following:
  • name, telephone number(s), mailing address, email address, gender, age and any other information relating to you;
  • business contact information from name cards;
  • comments or assessment evaluation on your experience of our Services;
  • occupational, health, personal history;
  • emergency contact details;
  • financial information such as bank accounts, credit and debit card details or other payment instrument details;
  • information received by body corporate under lawful contract or otherwise;
  • email and telephone/audio/video call data records;
  • photographs, video recordings and CCTV footage;
  • your usage of and interaction with our Website and/or Services including cookies, computer and connection information, device capability, bandwidth, statistics on page views, and traffic to and from our Website; and
  • any other information that you voluntarily choose to provide to us.
iv. Any of the information above collected from you by In The Present may constitute Personal Data under the PDPA. v. In The Present will be free to use, collect and disclose information that is freely available in the public domain without your consent. vi. Information that is business contact information such as your name, position title, business telephone number, business address, business electronic mail address or business fax number and any other similar information about you, which are not provided by you for personal purposes, will not be regarded as Personal Data under the PDPA. Your consent to us collecting, using and disclosing any business contact information will not be required.
SECTION 2: COLLECTION OF PERSONAL DATA
i. Personal Data may be collected by In The Present through processes including, but not limited to the following:
  • when you submit your enquiry/registration/intake/appointment booking/assessment/evaluation form via physical copy or online for any of our Services;
  • when you interact with any of our employees in writing, conversation, via telephone/audio/video calls, or short messaging services (“SMS”), texts or other correspondence;
  • when you respond to our request for additional Personal Data;
  • when you ask to be included in an email or other mailing list;
  • when you request that we contact you or when you write to us;
  • when you attend our events or enter our premises, we may take pictures or videos or you may be captured on our closed circuit television cameras surveillance;
  • when you respond to our marketing initiatives, surveys or promotions;
  • when you give comments or feedback on our Services;
  • when you complete a payment for any of our Services; and
  • when you submit your Personal Data to us for any other reason.
Data collected by automated means
ii. Various technologies may be used on our Website or our emailing system in order to make it more user-friendly, effective and secure. Such technologies may lead to data being collected automatically by us or by third parties on behalf of us. This data does not generally, but may, contain a user’s Personal Data. These technologies include but are not limited to cookies, web beacons, tracing links, click stream data and web analytics. You may set up your web browser or device to reject or block cookies or disable access to your information. You may also remove cookies stored from your computer or mobile device. However, if you do reject or block cookies or disable access, you may not be able to use certain features and functions of our Website. Please see Section 7: Additional Privacy Statements for Website Users.
SECTION 3: consent to collection of personal data
i. In The Present will not collect, use or disclose your Personal Data unless (a) you give, or are deemed to give, consent to the collection, use or disclosure of your Personal Data; or (b) the collection, use or disclosure of your Personal Data without your consent is required or authorized under the PDPA or other written law. ii. In The Present will not, as a condition of providing a Service to you and/or enabling you to participate in our Services, require you to consent to the collection, use or disclosure of your Personal Data beyond what is reasonable to provide the Service to you and/or enabling you to participate in our Services. iii. In The Present will not obtain or attempt to obtain your consent for collecting, using or disclosing Personal Data by providing false or misleading information with respect to the collection, use or disclosure of your Personal Data, or use deceptive or misleading practices. 
 iv. As part of our continuous effort to keep you informed on our projects, causes and our Services, we may mail, email, telephone, SMS and contact you by any other means. Information sent to you may also include upcoming special events, courses, programs, classes, talks, workshops or other relevant information that may be of interest to you. You may also receive mailings or other communications materials from our affiliates and/or carefully selected third parties. You will always have the option to decline any or all of these communications by following the directions included in our emails or other communications, or by contacting In The Present directly via email (see Section 16: How to Contact Us). v. In The Present may collect and use personally identifiable information that you volunteer, or other behavioral data and big data generated. In addition to that, permission will be deemed given for communication from us that are necessary to fulfil transactions and services requested by you. vi. Photographs, video recordings and CCTV footage may constitute Personal Data if an identifiable individual is captured. In The Present will either (a) seek your written or recorded consent for the collection, use and disclosure of photographs, video recordings and/or CCTV footage of you; or (b) state in the invitation to you of our talk, seminar, workshop, course, program, event, activity, or video call, that photographs/video recordings/CCTV footage will be taken at such instance for publicity on In The Present’s print and electronic media; or (c) place appropriate and obvious notices at the reception or entrance of our talk, seminar, workshop, course, program, event or activity, or at the beginning of a video call to inform attendees.
SECTION 4: PURPOSES FOR WHICH WE COLLECT AND USE PERSONAL DATA
i. In The Present may collect, use or disclose your Personal Data only for purposes (a) that a reasonable person would consider appropriate in the circumstances; and (b) where you have been informed in accordance with this Section 5 of this Privacy Policy, to the extent applicable. ii. In The Present collects and uses the Personal Data that you provide to us depending on your relationship with us (e.g. as a client, participant, through our Website or other person relating to In The Present). In General iii. In general, In The Present may collect, use and/or disclose your Personal Data for the following purposes:
  • maintaining records of interactions with you, through documentation (hard copy and/or electronic);
  • responding to your queries, your ask for referral, other requests, and/or complaints;
  • updating you on developments in In The Present’s Services, and special happenings such as In The Present’s talks, seminars, workshops, courses, programs, events or activities;
  • assessing and processing any registrations, enrolments, and requests regarding In The Present’s Services;
  • establishment and maintenance of relationship with In The Present and/or affiliates of In The Present;
  • marketing and promotion activities of In The Present;
  • taking of photographs and/or videos (whether by In The Present staff or third party photographers and/or videographers) during talks, seminars, workshops, courses, programs, events or activities organized by In The Present or its affiliates for publicity purposes;
  • if consented in the enquiry/registration/intake/appointment booking/assessment/evaluation forms and/or other methods of consent notification, to providing marketing, advertising and promotional information including without limitation promotions, reward programs and sending you details of talks, seminars, workshops, courses, programs, events or activities, informational and motivational material related to In The Present’s business, via postal mail, electronic mail, SMS or MMS, fax and/or voice calls;
  • if consented in the enquiry/registration/intake/appointment booking/assessment/evaluation form and/or other methods of consent notification, to matching your Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision or offering of products and Services, whether by In The Present, or other third parties;
  • managing commercial and financial risks, including preventing, detecting and investigating crime, including fraud and any form of financial crime;
  • any other purposes which In The Present may inform you of in writing from time to time, but for which In The Present will seek your separate consent; and
  • any other purposes related to the above purposes.
If you are a person or organization (the “Client”) accessing our Services, including a program, course, workshop, seminar, event, talk, coaching, consultancy, training or therapy
iv. If you are a Client, In The Present may collect, use and/or disclose your Personal Data for the following purposes:
  • assessing your fitness and suitability for any of our Services;
  • administrating a referral, where appropriate or requested by the Client;
  • provision of the Service(s) that you have requested from In The Present;
  • evaluating your progress as a Client;
  • publicity on In The Present’s newsletters, social media accounts or platforms, where videos and images may be used; and
  • contacting you for surveys or interviews relating to the above subject matter.
v. In The Present may also disclose the Personal Data that you have provided to us to our affiliates, which may be sited locally or outside. vi. If you have provided your Singapore telephone number(s) and have indicated your consent to receiving marketing or promotional information via your Singapore telephone number(s), then from time to time, In The Present may contact you using such Singapore telephone number(s) (including via voice calls, SMS, fax or other means) with information about In The Present’s Services and/or your participation, attendance, engagement or otherwise in In The Present’s Services.
SECTION 5: DISCLOSURE OF PERSONAL DATA
i. In The Present will only disclose Personal Data:
  • for the primary purpose for which it was collected as outlined in Section 4 above;
  • for purposes that a reasonable person will consider appropriate in the circumstances;
  • where you have consented; or
  • where permitted under the PDPA or other applicable law or if required by law.
ii. Subject to applicable laws, In The Present may disclose your Personal Data for the purposes set out above to parties such as those described below:
  • In The Present’s affiliates which may also include entities and activities overseas;
  • banks, financial institutions, credit card companies, payment gateways and their respective service providers;
  • appointment scheduling platforms;
  • companies providing services relating to insurance/reinsurance to us, and associations of insurance companies;
  • other mental health professionals; and
  • our professional advisors such as our auditors and lawyers.
iii. When In The Present discloses your Personal Data to third parties, In The Present will ensure that they are contractually bound to protect your Personal Data in accordance with applicable laws and regulations (as set out in herein), save in cases where your Personal Data is shared with governmental agencies and regulators, or where your Personal Data is publicly available, or where use/disclosure of your Personal Data is otherwise legally mandated and exempted.
iv. If your Personal Data has to be transferred overseas, In The Present will, where legally required, inform you of the extent to which your Personal Data will be protected, in the foreign jurisdiction(s) to which it will be transferred.
v. In addition, In The Present would disclose Personal Data in the following circumstances: (a) in response to a request from law enforcement authorities or other government officials; (b) to comply with a court order or direction from a government agency or regulatory authority ordering the disclosure of the Personal Data; and (c) where the disclosure is necessary for investigations or legal proceedings.
Disclaimers and Limitation of Confidentiality
vi. Each Client accessing our Services understands that In The Present may fulfill its Services with the assistance, consultation and advice of other mental health professionals. In some instances, In The Present may need to share with such mental health professionals confidential information about a Client, such as his/her health or personal history, or other related information (“Confidential Information”) for administrative purposes. During such consultation, In The Present and its employees, teachers, trainers, officers and advisors (the “Personnel”) will make every effort to avoid revealing the Client’s identity, unless (a) consent has been obtained from the Client prior to the consultation, or (b) for the specific purpose of referral at the Client’s request or acceptance. vii. There are some situations where In The Present is permitted or required to disclose Confidential Information without either the Client’s consent or authorization, these include but are not limited to the following:
  • If a Client threatens to harm himself/herself or another, In The Present and/or its Personnel may be obligated to seek assistance for him/her or to contact family members or others, who can help provide protection, and will limit the disclosure to what is necessary;
  • If a Client is involved in a court proceeding and a request is made for information concerning In The Present’s Services;
  • If a Client is involved in, or contemplating litigation, he/she should consult with his/her attorney to determine whether a court would be likely to order In The Present and/or its Personnel to disclose any such Confidential Information;
  • If a government agency is requesting the information for health oversight activities, In The Present may be required to provide it to them; and
  • If a Client files a complaint or lawsuit against In The Present and/or its Personnel, In The Present may disclose relevant information regarding that Client in order to defend itself and/or its Personnel.
viii. All rights in the Confidential Information are reserved by the Client. No rights or obligations other than those expressly recited herein are granted or to be implied herein and from In The Present’s Terms and Conditions of Enrolment. All information is provided in good faith, but no party shall be liable to the other party for any claims arising whatsoever from any inaccuracy or error in the Confidential Information provided and each party is responsible to conduct its own due diligence in that regard.
SECTION 6: ADDITIONAL PRIVACY STATEMENTS FOR WEBSITE AND SERVICE USERS
Persons who have visited and submitted Personal Data on the Website (“Subscriber”) Note:
i. This section applies to all Subscribers.
  • As part of the assessment of fitness/suitability of any of In The Present’s Services, certain information, including Personal Data or sensitive personal information is collected from the Subscribers.
  • All the statements in this Privacy Policy apply to all Subscribers, and all Subscribers are therefore required to read and understand the privacy statements set out herein prior to submitting any Personal Data or sensitive personal information to In The Present, failing which they are required to leave the Website immediately.
  • If you have inadvertently submitted any such information to In The Present prior to reading the privacy statements set out herein, and you do not agree with the manner in which such information is collected, processed, stored, used or disclosed, then you may access, modify and delete such information by using options provided on the Website. In addition, you can, by sending an email to inthepresent.sg@gmail.com, inquire whether In The Present is in possession of your Personal Data, and you may also require In The Present to delete and destroy all such information.
  • Subscribers’ Personal Data, which they choose to provide on the Website, is used to help the Subscribers describe/identify themselves; submit information required for In The Present to provide its Services to Subscribers; and if Subscriber consents, for In The Present to inform Subscriber about any of In The Present’s new courses, programs, seminars, talks, workshops, events, services and other updates. Other information that does not personally identify the Subscribers as an individual, is collected by In The Present from Subscribers (such as, your computer’s internet protocol (IP) address which provides us with information that helps us learn about your browser and operating system) and is exclusively owned by In The Present. In The Present may also use such information in an aggregated or non-personally identifiable form for research, statistical analysis and business intelligence purposes.
  • The Website uses temporary cookies to store certain data (that is not sensitive personal data or information) that is used by In The Present and its service providers for the technical administration of the Website, research and development, and for Subscriber administration. In the course of serving advertisements or optimizing services to Subscribers, In The Present may allow authorized third parties to place or recognize a unique cookie on the Subscriber’s browser. The cookies, however, do not store any Personal Data of the Subscriber. You may adjust your internet browser to disable cookies. If cookies are disabled you may still use the Website, but may be limited in the use of some of the features.
  • In The Present will communicate with the Subscribers through email, telephone, SMSs, text and other forms of messaging. The Subscribers can change their e-mail and contact preferences at any time by sending an email to inthepresent.sg@gmail.com.
  • In The Present may keep records of electronic communications received and made for making appointments or other purposes, for the purpose of administration of the Services, Subscriber support, research and development.
  • All In The Present employees and data processors, who have access to, and are associated with the processing of sensitive personal data or information, are obliged to respect the confidentiality of every Subscribers’ Personal Data or sensitive personal information.
  • To the extent necessary in delivering the Services, In The Present may provide the Personal Data to third party contractors who services on behalf of or with In The Present to provide Subscribers with such Services, to help In The Present communicate with Subscribers or to maintain the Website. Generally, these contractors do not have any independent right to share this information, however certain contractors who provide services on the Website, including the providers of online communications services, may use and disclose the personal information collected in connection with the Services in accordance with their own privacy policies. In such circumstances, Subscribers consent to In The Present disclosing their personal information to these contractors, solely for the intended purposes.
  • Subscribers may choose to unsubscribe from marketing communications that they receive from In The Present by sending an email to inthepresent.sg@gmail.com requesting to unsubscribe.
Casual Visitors Note
ii. No sensitive personal data or information is automatically collected by In The Present from any casual visitors of our Website, who are merely perusing the Website. Nevertheless, certain provisions of this Privacy Policy are applicable to even such casual visitors, and such casual visitors are also required to read and understand the privacy statements set out herein, failing which they are required to leave this Website immediately. iii. If you, as a casual visitor, have inadvertently browsed any other page of the Website prior to reading the privacy statements set out herein, and you do not agree with the manner in which such information is collected, processed, stored, used, disclosed or retained, merely quitting this browser application should ordinarily clear all temporary cookies installed by In The Present. All visitors, however, are encouraged to use the “clear cookies” functionality of their browsers to ensure such clearing/deletion, as In The Present cannot guarantee, predict or provide for the behavior of the equipment of all the visitors of the Website. iv. You are not a casual visitor if you have willingly submitted any Personal Data to In The Present through any means, including email, online forms/posts or through responding to requests on the Website. All such visitors will be deemed to be, and will be treated as, Subscribers for the purposes of this Privacy Policy, and in which case, all the statements in this Privacy Policy apply to such persons.
SECTION 7: SHARING AND TRANSFER OF PERSONAL DATA
i. In the course of or in connection with In The Present’s Services and operations, In The Present may transfer Personal Data to the following parties for the following purposes:
  • To affiliates of In The Present for purposes of expanding the Services;
  • To government and non-government authorities, agencies and/or regulators as required under law or under directions or orders from the government and non-government authorities, agencies and/or regulators for security, regulatory approvals or permits;
  • Financial institutions or payment gateways for purposes of payment processing and transactions related to In The Present’s provision of Services;
  • Scheduling platforms for the purposes of booking or managing appointments related to In The Present’s provision of Services;
  • Professional, financial and legal advisors, tax advisors, auditors, insurers and insurance brokers.
ii. However, certain third-party service providers, such as appointment scheduling platforms, payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions. For these providers, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers.
iii. In particular, remember that certain providers may be located in or have facilities that are located a different jurisdiction than either you or us. So if you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located. Once you leave our Website(s) or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy or our Website’s Terms of Use.
iv. In The Present requires that the parties to whom we transfer Personal Data and our service providers implement adequate levels of protection in order to protect Personal Data. We also require that these parties only process Personal Data strictly for purposes for which we engage them for and consistent with the purposes that we have described in Section 4: Purposes For Which We Collect and Use Personal Data or with other purposes for which consent has been sought and obtained.
SECTION 8: CONFIDENTIALITY AND SECURITY
i. Your Personal Data is maintained by In The Present in paper or electronic form on its equipment, and on the equipment of its employees. Such information may also be converted to physical form from time to time. In The Present takes all necessary precautions to protect your personal information both online and off-line, and implements reasonable security practices, precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed, including certain managerial, technical, operational and physical security control measures that are commensurate with respect to the information being collected and the nature of In The Present’s business. ii. In The Present makes all Personal Data accessible to its employees, agents or partners and third parties only on a need-to-know basis, and binds only its employees to strict confidentiality obligations. iii. Notwithstanding the above, In The Present is not responsible for the confidentiality, security or distribution of your personal information by our partners and third parties outside the scope of our agreement with such partners and third parties. Further, In The Present shall not be responsible for any breach of security or for any actions of any third parties or events that are beyond the reasonable control of In The Present including but not limited to, acts of government, computer hacking, unauthorized access to computer data and storage device, computer crashes, breach of security and encryption, poor quality of internet service or telephone service of the Website user or Subscriber etc.
SECTION 9: AGE OF CONSENT
i. By using the Website, you represent that you are at least the age of majority in your state or province of residence, or that you are the age of majority in your state or province of residence and you have given us your consent to allow any of your minor dependents to use this site. ii. In The Present strongly encourages parents and guardians to supervise the online activities of their minor children and consider using parental control tools available from online services and software manufacturers to help provide a child-friendly online environment. These tools also can prevent minors from disclosing their name, address, and other personally identifiable information online without parental permission. Although the In The Present Website is not intended for use by minors, In The Present respects the privacy of minors who may inadvertently use the internet.
SECTION 10: ACCURACY
i. In The Present will take reasonable efforts to ensure that any Personal Data collected is accurate and up to date by updating its records whenever changes to information come to its attention. In The Present will disregard information which seems, on a reasonable basis, to be inaccurate or out of date by reason of the time which has elapsed since it was collected or by reason of any other information in its possession. To help us maintain the accuracy of your Personal Data, we encourage you to inform us when there are any changes to your Personal Data which you have provided us by writing to our Data Protection Officer. We will correct or complete your Personal Data requests as set out in Section 12 below. If you have any concerns, feedback or complaints about the use and/or sharing of your Personal Data, you may contact us at inthepresent.sg@gmail.com.
SECTION 11: RETENTION OF PERSONAL DATA
i. In The Present only retains Personal Data for as long as the retention is required for the purposes for which we collected the Personal Data, the purposes described in this Policy and for our business and legal purposes. Generally, we do not retain Personal Data for a period of longer than six (6) years after the original purposes for which the Personal Data was collected have ceased to be applicable, unless otherwise required by law or other mandatory directions by court or government authorities or for purposes of legal proceedings or other similar proceedings or investigations. ii. For individuals who have submitted their Personal Data but who do not proceed with the participation or enrolment in any of our programs, courses, workshops, talks, events, activities or our other Services, In The Present will retain your Personal Data for no longer than 1 (one) year for the purposes of reviewing, evaluating, promoting and/or marketing our programs, courses, workshops, talks, events, activities or our other Services, unless you inform us otherwise as set out in Section 12 below.
SECTION 12: ACCESS, CORRECTION, UPDATE OR WITHDRAWAL OF PERSONAL DATA
i. You may request for information from In The Present on what Personal Data of yours we have and how we have used and shared your Personal Data during the last one (1) year before the date of your request; or withdraw your consent to our continued use and disclosure of your Personal Data; or seek access to your Personal Data (to a reasonable extent and as permitted by the PDPA) at any time by writing to our Data Protection Officer. Please note that access will be granted only to the Personal Data itself and not to the full documents in which it is contained. You may also withdraw your consent for specific forms of communication and on specific communications via the unsubscribe options as stated on our email or other marketing messages. ii. We will endeavor to acknowledge the receipt of your request within 5 working days after the date of receipt of your request if it is sent by e-mail, or within 10 working days after the date of receipt of your request if it is sent by post. We will carry out your request within reasonable time from the date of acknowledgement. You acknowledge that we may require time to process your request depending on its complexity and impact, and that it may take up to 30 working days for any request for consent withdrawal to be reflected in our systems. As it is important to us that the Personal Data that we have about you is accurate and complete, it may be necessary for us to request for supporting documentation from you. We will contact you if we require supporting documentation from you. iii. In withdrawing your consent, you acknowledge that we may not be able to provide or continue providing certain Services to you and that we may cease such provision accordingly without any liability. You also acknowledge that actions already taken based on your prior consent cannot be undone. iv. There may be circumstances where In The Present will not correct, delete or update your Personal Data, including: (a) where the Personal Data is opinion data that is kept solely for evaluative purpose; and (b) the Personal Data is in documents related to a prosecution if all proceedings relating to the prosecution have not been completed. v. In The Present shall have the right to request for information for the purposes of verification of your identity and for more information about your request. In The Present will charge a reasonable administrative fee to respond to the request set out above.
SECTION 13: TRANSFER OF PERSONAL DATA OUTSIDE OF SINGAPORE
i. Certain In The Present’s vendors, or service providers may be operating outside Singapore. By providing information to us through our enquiry/registration/intake/appointment booking/assessment/evaluation forms for our programs, courses, seminars, talks, workshops, events or activities; use of our Website or otherwise, you are consenting to the transfer of that information to be processed and used in accordance with the terms of this Privacy Policy. In such a situation, In The Present will ensure that the Personal Data so transferred will be accorded a standard of protection comparable to the protection provided under the PDPA.
SECTION 14: DO NOT CALL PROVISIONS
i. In The Present will not be sending any specified messages and/or otherwise marketing communications through SMS, text or phone calls. If you have provided your Singapore telephone number(s), then from time to time, In the Present may contact you using such Singapore telephone number(s) (including via voice calls, text, or other means) including, among other things, with information reasonable for us to provide our Services to you and/or enabling you to participate in our Services.
SECTION 15: CHANGES TO THIS PRIVACY POLICY
i. In The Present may update this Privacy Policy at any time, with or without advance notice. In the event there are significant changes in the way In The Present treats your personally identifiable information, or in the Privacy Policy itself, In The Present will display a notice on the Website or send you an email, as provided for above, so that you may review the changed terms prior to continuing to use the Services. As always, if you object to any of the changes to our terms, and you no longer wish to use the Services, you may contact inthepresent.sg@gmail.com. Unless stated otherwise, In The Present’s current Privacy Policy applies to all information that In The Present has about you and/or your account. If a Website user or Subscriber uses our Services, or accesses the Website after a notice of changes has been sent to such user or Subscriber, or published on the Website, such user or Subscriber hereby provides his/her/its consent to the changed terms.
SECTION 16: HOW TO CONTACT US
i. Should you have questions about this Privacy Policy or In The Present's information collection; use and disclosure practices, or if you would like to access, correct, amend or delete any personal information we have about you; register a complaint; or simply want more information, please contact us at inthepresent.sg@gmail.com. We will use reasonable efforts to respond promptly to any requests, questions or concerns, which you may have regarding our use of your personal information. If you have any grievance with respect to our use of your information, you may communicate such grievance to: In The Present Pte. Ltd. Phone: +65-8517-5684-7179 (Whatsapp only) Email: inthepresent.sg@gmail.com Effective date: 01 January 2017 Copyright 2016