This Data Protection Notice (“Notice”) sets out the basis which Mercara Global (MG) (“we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data of our customers, including visitors of our website. This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations which we have engaged to collect, use, disclose or process personal data for our purposes.

Personal Data

1. As used in this Notice:“customer” means an individual who (a) has contacted us through any means to find out more about any services we provide, or (b) may, or has, entered into a contract with us for the supply of any services by us; and“personal data” means data, whether true or not, about a customer who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.

2. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include name, residential address, email address, telephone number, nationality, gender, date of birth, financial information and identification number.

3. Other terms used in this Notice shall have the meanings given to them in the Singapore Personal Data Protection Act 2012 (where the context so permits).

Collection, use and disclosure of personal data

4. We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after (i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or (b) collection and use of personal data without consent is permitted or required by the applicable data protection laws or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).

5. We may collect and use your personal data for any or all of the following purposes:
(a) performing obligations in the course of or in connection with our provision of services requested by you;
(b) verifying your identity;
(c) responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
(d) managing your relationship with us;
(e) sending you promotional and marketing materials relating to our products and services;
(f) complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority; and
(g) transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes.

6. We may disclose your personal data:(a) where such disclosure is required for performing obligations in the course of or in connection with our provision of the services requested by you; or(b) to third party service providers, agents and other organisations we have engaged to perform any of the functions with reference to the above mentioned purposes.

7. The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under a contract with you).

Withdrawing your content

8. The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.

9. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within 30 business days of receiving it.

10. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing.

11. Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

Access to and correction of personal data

12. If you wish to make (a) an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data, or (b) a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.

13. Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.

14. We will respond to your request as soon as reasonably possible. In general, our response will be within 30 business days. Should we not be able to respond to your request within 30 days after receiving your request, we will inform you in writing within 30 days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the applicable data protection laws).

Protection of personal data

15. To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as [authentication and access controls (such as good password practices, need-to-basis for data disclosure, etc.), up-to-date antivirus protection, regular patching of operating system and other software, usage of one time password (OTP) / 2 factor authentication (2FA) / multi-factor authentication (MFA) to secure access, and security review and testing performed regularly].

16. You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

Accuracy of personal data

17. We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.

Retention of personal data

18. We may retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws.

19. We will cease to retain your personal data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the personal data was collected, and is no longer necessary for legal or business purposes.

Our website

20. When you browse our website, you generally do so anonymously and we do not at our website automatically collect personal data, including your email address, unless you provide such information.

21. Your IP address. Our website may automatically collect your IP address when you browse or visit our website. An IP address is a number that is automatically assigned to your computer when you are connected to the Internet. When you visit our website, your IP address is automatically logged in our server. We use your IP address to help diagnose problems with our server, and to administer our website. From your IP address, we may identify the general geographic area from which you are accessing our website; however, we will not be able to pinpoint the exact geographic location from which you are accessing our website. Generally, we do not link your IP address to anything that will enable us to identify you unless it is required by applicable laws and regulations.

22. Cookies. Our website may automatically store cookies on your device when you browse or visit our website. A cookie is an element of data that a website can store on your device. We use cookies in some parts of our website to store user preferences and record session information. This may also be used to help personalise services on our website. You can adjust settings on your browser so that you will be notified when you receive a cookie. Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser. However, your ability to use our website or the functionality may be subsequently affected. Please refer to your browser documentation to check if cookies have been enabled on your device or for adjusting your browser settings to not to receive cookies.

23. Our website may contain links to other sites and resources that are operated or provided by third parties with different data protection practices. We have no control over and do not take any responsibility for these third party websites and their personal data handling practices, and you are encouraged to review the personal data policies of websites you choose to visit which are linked from our website.

Transfers of personal data outside of Singapore

24. Where you have engaged us to carry out any work outside Singapore, the transfer of your personal data records to these jurisdictions may be necessary to give effect to your instructions and that you request and consent to our transmission of your personal data outside Singapore. Personal data may therefore be exported to, processed and accessed in countries whose laws provide a different level of protection, which may not necessarily be comparable to that provided in Singapore. However, where we do so, we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the applicable data protection laws.

Data protection officer

25. You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, via email to contact@mercara.global

Effect of notice and changes to notice

26. This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.

27. We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.