2. Information we collect
In order for Ben Line Agencies to undertake its business and comply with applicable statutory, regulatory, contractual and quality management requirements Ben Line Agencies may collect and hold the following personal information of Individuals:
- Professional contact details (e.g. name, email address, postal address, telephone/facsimile number(s));
- Identification documentation (e.g. photographic ID, date of birth, postal address);
- Financial details (e.g. bank details).
- Other information about Individuals (e.g., individual contractors or sole proprietorships, including name, address, type, reason for engagement, conflict of interest, country, special instructions and agreements).
If Individuals contact Ben Line Agencies and choose to provide their professional contact details to Ben Line Agencies, it will collect and store personal information in a way that allows it to be related to the Individuals personally (e.g., name, email address, postal address, telephone/facsimile number(s)).
3. How and Why we use information
The use of personal information depends on individual circumstances, including but not limited to:
- Communicating with you;
- Relationship management;
- Marketing our business;
- Performing our services;
- Reporting to stakeholders;
- Compliance purposes and legal rights;
- Operating Ben Line Agencies’ business.
Where applicable, we indicate whether and why you must provide us with your personal information, as well as the consequences of failing to do so. Ben Line Agencies holds data in electronic computer systems and utilises computer and communications equipment to access this personal information. Personal information is stored on Ben Line Agencies’ systems and equipment appropriate to the use at the relevant time. We do not engage in what is known as “automated decision making” (i.e., making decision with legal or similarly significant effects solely based on automated processing of personal information).
We rely on a legal basis to process your personal information when this is required by applicable law, including:
- Consent. You have consented to the use of your personal information, for example to send you electronic marketing communications.
- Contract. We need your personal information to perform or enter into an agreement with you.
- Legal obligation. We have a legal obligation to use your Personal Data, for example to comply with tax and accounting obligations.
- Legitimate interest. We or a third party have a legitimate interest in using your personal information, such as relationship management. We only rely on this legal basis when our or a third party’s legitimate interest is not overridden by your rights and freedoms.
4. Who we share information with
In all circumstances, sharing of personal information is done so where there is a legitimate reason in connection with the uses outlined in Section 3 (How and Why we use information).
Ben Line Agencies communicates with multiple parties in the ordinary course of its business, including but not limited to its subsidiaries, affiliates, directors, officers, employees, customers, investors, vendors and other business partners. While doing so Ben Line Agencies does not use personal information for any purpose other than that for which it was provided.
Ben Line Agencies may share personal information with certain third parties who perform tasks on our behalf, however, information is only shared to the extent necessary to achieve the purpose for which it was provided. The aforementioned third parties act on Ben Line Agencies’ instructions and are contractually bound by data protection and confidentiality obligations.
Ben Line Agencies may also share personal information with third parties where there is a statutory, regulatory, contractual or quality management obligation to do so, for example to respond to requests from governmental authorities.
5. How we protect information
All personal information collected and recorded, on paper or electronically, has appropriate safeguards in place as required by statutory, regulatory, contractual or quality management obligations. Ben Line Agencies’ policies and procedures are intended to minimise the risk of loss or damage.
Ben Line Agencies has ensured key personnel within the Company have been provided familiarisation and training in relation to protecting personal information and are subject to a duty of confidentiality in respect of personal information we obtain and process.
Ben Line Agencies is able to restore personal information stored electronically in situations where data has become corrupted or lost.
Where appropriate, the Company uses encryption, access restrictions and/or security measures to protect personal information.
The Company’s control of personal information is regularly reviewed to ensure adherence with best practice and to ensure suitability of the controls over confidentiality, accuracy, security and privacy of personal information.
No means of protecting personal information is guaranteed by Ben Line Agencies.
6. Where information is processed
Ben Line Agencies is a global business and may transfer personal information to countries other than the country in which the information was originally collected, including to Singapore where we are headquartered and where some of our vendors are located. We will only transfer personal information across borders in accordance with applicable law, for example by relying on contractual protections. For more information, please contact us using the contact details outlined in Section 9 (Contact information).
7. How Long we keep information
We take measures to delete your personal information or keep it in a form that does not permit identifying you when this information is no longer necessary for the purposes for which we process it, unless we are required by law to keep it for a longer period. When determining the retention period, we take into account various criteria, such as the type of services involved, the nature and length of our relationship with you, mandatory retention periods and the statute of limitations. In accordance with the Company’s policies and procedures, personal information may be maintained for up to 7 years.
8. Your rights
Individuals may in certain jurisdictions have legal rights in relation to how Ben Line Agencies processes personal information, including but not limited to:
- Right to request rectification;
- Right to request erasure;
- Right to restrict processing;
- Right to data portability;
- Right to object;
- Right to withdraw consent. If you exercise your right to withdraw consent, we will apply your preferences going forward and this will not affect the lawfulness of the processing before you withdrew your consent.
- Right to lodge a complaint with the data protection authority in your country or residence, place of work, or where the alleged data protection violation occurred.
You may request exercising these rights by contacting us using the contact details outlined in Section 9 (Contact information). Before meeting your request, we may ask you to provide reasonable information to verify your identity. Please note that there are exceptions and limitations to each of these rights, and that it depends on your location and applicable law whether you can exercise them.
9. Contact information
Ben Line Agencies Limited
Address: 200 Cantonment Road, #13-05, Southpoint, Singapore 089763
For any other enquiry, please click on Contacts
10. Changes to the policy
Ben Line Agencies reserves the right to make changes to this policy as required.
This policy was last updated 18 April 2022.