Q Framing Pte Ltd (“We”, “Us”, “Our”) is committed to the protection of the personal data that you provide to us. This Privacy Policy describes how we manage personal data in compliance with the Singapore Personal Data Protection Act 2012 (“Act”), as well as to assist you in making an informed decision before providing us with any of your personal data. We encourage you to read this Privacy Policy so that you know and understand the purposes for which we collect, use and disclose your personal data.

We may update this Privacy Policy from time to time.  Subject to your rights at law, by using our products and services, you agree to be bound by the prevailing terms of this Privacy Policy as updated from time to time.  We encourage you to check the latest version of this Privacy Policy regularly.

If you have any query on this policy, please do not hesitate to contact our Data Protection Officer (the “DPO”) at the contact details set out at paragraph 9 below.

1.    Personal Data
1.1    As used in this Policy:

• “Customer” means an individual who (a) has contacted us through any means to find out more about any goods or services we provide, or (b) may, or has, entered into a contract with us for the supply of any goods or services by us; and

• "Personal Data" refers to data, whether true or not, about an individual who can be identified from that data, or from that data in combination with other information to which we may have access.

1.2    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 and telephone/mobile number.  ​

1.3    Other terms used in this Policy shall have the meanings given to them in the PDPA (where the context so permits).

2.    Collection, use and disclosure of Personal Data
2.1    We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly after (i) you have been notified of the purposes for which the data is collected, and (ii) you 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 PDPA 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).

2.2    The Personal Data which we collect from you may be collected, used and/or disclosed for the following purposes:
a) Performing obligations in the course of or in connection with our provision of the goods and/or services requested by you;
b) Responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
c) Managing, facilitating and administering your relationship with us, including but not limited to order placement, payment and delivery;
d) If consented by you, to send you marketing and promotional information about our products and services by electronic mail;
e) To facilitate audit reviews;
f) To update, consolidate and improve the accuracy of our records; and
g) Any other incidental business purposes related to or in connection with the above.
(collectively, the “Purposes”)

2.3    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 goods and services requested by you;
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; and
c) Under certain circumstances, we may disclose your Personal Data without first obtaining your consent in situation where the disclosure is required based on the applicable laws, by law enforcement agency under any investigation or proceedings.

3.    Access and/or Correction of Personal Data
3.1    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 at paragraph 9 below.

3.2    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. 

3.3    We will respond to your request as soon as reasonably possible. In general, we will acknowledge your request within three (3) business days. Should we not be able to act on your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (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 PDPA).

3.4    Subject to the access and correction circumstances, we may send the corrected Personal Data to every other organizations or third parties to which the Personal Data was disclosed by us within a year before the date the correction was made, unless that other organization does not need the corrected Personal Data for any legal or business purposes.

4.    Withdrawing Your Consent
4.1    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. At any point of time, you may withdraw your consent for the collection, use and/or disclosure of your Personal Data under our possession by submitting your request to our Data Protection Officer with the contact details listed at paragraph 9 below.

4.2    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 ten (10) business days of receiving it. 

4.3    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 goods or 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 in the manner described in clause 4.1 above. 

4.4    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.

5.    Protection of Personal Data
5.1    To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we take reasonable efforts and appropriate administrative, physical and technical measures to ensure your data is adequately protected. 

5.2    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.

6.    Accuracy of Personal Data
6.1    We generally rely on personal data provided by you. 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 under Paragraph 9.

7.    Retention of Personal Data
7.1    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.

7.2    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.

8.    Transfers of Personal Data Outside of Singapore
8.1    We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and we will take reasonable steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.

9.    Data Protection Officer
9.1    If you have any query related to how we are handling your Personal Data, submitting feedback, requesting for access and correction of your Personal Data and withdrawal of consent, you may at any time contact us by writing:

Data Protection Officer (DPO)
E-mail: qframing@qframing.com.sg
Tel: +65 6299 4180
Please attention your email to DPO.

10.    Updates on Privacy Policy
10.1    This Policy applies in conjunction with any other policies, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.

10.2    We may revise this Policy 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 Policy was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes. 

10.3    You are encouraged to visit our website from time to time to ensure that you are well informed of our latest policies in relation to Personal Data protection.

Effective date: 31/05/2019
Last updated: 08/03/2021