Triterras Privacy Notice
Triterras is dedicated to protecting the confidentiality and privacy of information entrusted to it. As part of this fundamental obligation, Triterras is committed to the appropriate protection and use of personal information (sometimes referred to as “personal data”, “personally identifiable information” or “PII”) that has been collected online.
1. Applicability of our Privacy Notice
This Privacy Notice explains how we collect, use, process and protect your personal data that we have obtained. Personal data includes information that allows us to identify you, such as your name and email address.
Respecting and protecting your privacy and your personal data is very important to us. We will process your personal data in accordance with applicable data protection laws.
This Privacy Notice sets out the basis upon which any personal data we collect from you, or that you provide to us, will be processed by us or on our behalf.
Please read this notice carefully to understand our practices regarding your personal data and how we will treat it.
2. What personal data we collect and how we collect it
We collect the personal data about you specified below, in the following ways.
Information you provide to us directly
We collect personal data when you provide it to us directly, such as in the following circumstances:
- when you register for access to a restricted area;
- when you participate in any interactive features of our site; or
- when you otherwise communicate with us or via our site.
Information we collect about you indirectly
A cookie is a small data file that can be placed on your device that allows us to recognise and remember you. It is stored on your browser and your computer’s hard drive or tablet or mobile device. When you visit our site, we may collect information from you automatically through cookies or similar technology.
You can find more information about the individual cookies we use and the purposes for which we use them in our Cookies Policy [here].
3. Why we collect your personal data
We only collect, use, disclose and process your personal data when the law allows us to.
In general, we use your personal data in order to achieve our legitimate interests in ensuring we provide our services and run our business effectively; to comply with our legal obligations; or on the basis of your consent. If you do not provide us with the personal data required to comply with our legal obligations, we may not be able to provide relevant services to you.
We may use your personal data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you if you consent to receive such communication. We may contact you for direct marketing purposes via social and direct messages, post, telephone, email and SMS/MMS.
You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us.
This marketing may relate to:
- products and services we feel may interest you;
- information about other goods and services we offer that are similar to those that you have already used or enquired about; and
- upcoming events, promotions and new products/services or other opportunities as well as those of selected third parties.
If you no longer wish to receive marketing communications from us, you may:
- amend your preferences in your account;
- write to us at [email protected]; or
- click on the unsubscribe link on any marketing communication that you receive from us.
4. Who do we share your information with
We may share your personal data with the following categories of recipients:
Your personal data will be used by us and may be disclosed to related entities.
Selected Business Partners and Advertising Partners
Your personal data will be disclosed by us to our business partners and advertising partners (including their sub-contractors) who will use your data, amongst other things, to review and improve their products and services, to help them identify new products and services, for statistical analytical purposes and for the purpose of directly marketing their products and services to you, subject to you consenting to such marketing activities.
Compliance with Laws
We may disclose your personal data:
- to regulators and law enforcement agencies (including those responsible for enforcing anti-money laundering legislations);
- in response to an enquiry from a government agency;
- to banking regulatory bodies;
- where otherwise required to do so by law or subpoena or if we believe that such action is necessary to comply with the law and the reasonable requests of law enforcement; or
- to protect the security or integrity of our site.
We may disclose your personal data to third party service providers (including our professional advisors, payment processors and data storage service providers) who require access to such information for the purpose of providing specific services to us. These third parties will only be able to access your data in order to provide us with their services and may not use it for their own purposes.
Replacement Providers and Purchase or Sale of Assets
If the management and operation of Triterras is transferred from us to another company, we may disclose your personal data to the other company, so the products and services can continue to be provided to you.
In the event that we sell or buy any business assets, we may disclose your personal data to the prospective seller or buyer of such business or assets.
If Triterras or substantially all of its assets are acquired by a third party, the personal data held by us about our customers will be one of the transferred assets.
5. What are my rights?
Under the Singapore Personal Data Protection Act (“PDPA”), you have the following rights in relation to your personal data:
Right to withdraw consent
Where we have obtained your consent to process your personal data, you may withdraw this consent at any time.
Data subject access requests
You may ask us for (i) a copy of personal data we hold about you and (ii) for information about the ways in which your personal data has been or may have been used or disclosed by us within a year before the date of the request. If we provide you with access to the information we hold about you, we will not charge you for this unless permitted by law.
Right to correction
You have the right to request that we correct an error or omission in personal data that we hold about you.
Right to complain
You have the right to lodge a complaint in Singapore with the Personal Data Protection Commission. You can contact them in the following ways:
- Main Line: +65 6377 3131
- Fax: +65 6577 3888
- Post: 10 Pasir Panjang Road, #03-01 Mapletree Business City Singapore 117438
You may also have other rights in relation to your personal data, depending on (amongst other things) the jurisdiction where you are based.
We will take reasonable precautions necessary to protect your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks.
Such measures will vary depending on the (i) nature of the personal data, (ii) form in which the personal data has been collected, and (iii) possible impact to the individual concerned if an unauthorised person obtained, modified or disposed of the personal data, and will involve, as applicable, physical, organizational and electronic security measures.
The security of your personal data is important to us. However, no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal
data, we cannot guarantee the security of your data transmitted over the internet and we do not warrant the security of any information, including personal data, which you transmit to us over the internet.
7. International transfers of data
Our data storage servers are located across the Asia-Pacific region and are managed by third-party service providers in the cloud. Your information, including personal data, may be transferred to, stored at and accessed from destinations or computers both within and outside your home jurisdiction where the data protection laws may differ than those from your home jurisdiction.
We will put in place safeguards to protect your personal data in respect of these transfers, as required by applicable law. In particular, in the event that we transfer your personal data outside of Singapore, we will take all reasonable steps to ensure that it is provided with a comparable standard of protection.
8. How long will we keep your personal data?
We will not keep your personal data for longer than is necessary for the purposes for which we have collected it, unless the law or a request of a judicial or governmental authority requires us to keep it for a longer period (for example, because of a request by a tax authority or in connection with an ongoing litigation).
9. Links to Other Sites
Our site may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Notice of every site you visit.
10. Changes to this Privacy Notice
We may update our Privacy Notice to reflect changes to our data and information privacy practices from time to time. We will notify you of any changes by posting the new Privacy Notice on this page.
11. Contacting Us
If you have any questions or concerns about this Privacy Notice, wish to exercise any of your rights under data protection law, or have any other issue with your personal information, please contact our Data Protection Officer at:
#23-04, Republic Plaza
9 Raffles Place