Privacy Notice

Dear Leader,

Thank you for your interest in our privacy notice. Please take your time to read it, starting with the informal paragraphs here and then followed by the formal paragraphs below.

Privacy, and how to manage it, has become an important challenge in our society of the  21st century. What we discuss and do online leaves a digital footprint of data, and we are learning together how to manage that, as society. Recent scandals involving Facebook and other companies have underlined how important that is to us.

Most countries around the world have enacted legislation about the protection of personal data. Possibly the most advanced legislation has been enacted recently by the European Union, in the form of their General Data Protection Regulation or GDPR. While GDPR applies to EU residents, it is also seen to be setting a leading example to other countries around the world. It is influencing how organizations and businesses in many countries go about making changes to the way they do their work.

At TransformationFirst.Asia, we acknowledge and appreciate the EU for taking the lead in shifting awareness on what is good practice about privacy and personal data. We think that EU is modeling the way by enacting GDPR and leading a positive change that influences others to follow their example.

While only some of our clients are EU residents, and we are not obliged to apply GDPR to clients outside the EU, we decided that we want to follow that same high standard set by the EU for all the clients we work with. That is why, in this privacy notice, you will see that the way in which we take care of your information is designed to comply with the GDPR, as well as with the law of Singapore, where our leadership practice is incorporated.

As you read through the paragraphs below, keep in mind that it is important that you know what data are, or may be, collected about you, for what purpose, and that you have specific rights in relation to how that data is collected, used, kept, and erased. Additionally, GDPR also requires that the language used is easily understandable.

Thanks for reading this far, and I encourage you to read the paragraphs below as well.

You are welcome to write us at support@transformationfirst.asia or set up a call with me at https://coachwouter.as.me if you have questions about it.

Kind regards,

Coach Wouter and the TransformationFirst.Asia tea

1.   INTRODUCTION  

This privacy notice provides you with details of how we collect and process your personal data through your use of our sites https://transformationfirst.asia and https://tfa-academy.simplero.com, including any information you may provide through our site when you purchase a product or service, sign up to our newsletter or take part in a prize draw or competition.

By providing us with your data, you warrant to us that you are over 13 years of age.

TransformationFirst.Asia Pte Ltd is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).  

Contact Details

Our full details are:

Full name of legal entity: TransformationFirst.Asia Pte Ltd

Email address: support@transformationfirst.asia 

Postal address: 305 Alexandra Road #05-10, Singapore 159942

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Personal Data Protection Commission (PDPC), the Singapore supervisory authority for data protection issues (https://www.pdpc.gov.sg/). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at support@transformationfirst.asia.

2.  WHAT DATA DO WE COLLECT ABOUT YOU

Personal data means any information capable of identifying an individual. It does not include anonymised data.

We may process certain types of personal data about you as follows:

Identity Data may include your first name, maiden name, last name, username, marital status, title, date of birth and gender.

Contact Data may include your billing address, delivery address, email address and telephone numbers.

Financial Data may include your bank account and payment card details.

Transaction Data may include details about payments between us and other details of purchases made by you.

Technical Data may include your login data, internet protocol addresses, browser type and version, browser plug-in types and versions, time zone setting and location, operating system and platform and other technology on the devices you use to access this site.

Profile Data may include your username and password, purchases or orders, your interests, preferences, feedback and survey responses.

Usage Data may include information about how you use our website, products and services.

Marketing and Communications Data may include your preferences in receiving marketing communications from us and our third parties and your communication preferences.

We may also process Aggregated Data from your personal data but this data does not reveal your identity and as such in itself is not personal data. An example of this is where we review your Usage Data to work out the percentage of website users using a specific feature of our site. If we link the Aggregated Data with your personal data so that you can be identified from it, then it is treated as personal data.

Sensitive Data

We may collect the following sensitive data about you in order to deliver some of our leadership coaching, mentoring, and training programs, if you decide to join these programs:

Information about your philosophical beliefs or health (these are two categories of sensitive data mentioned in the EU's General Data Protection Regulation or GDPR).

This information would only be collected where it is relevant for the purpose of our leadership coaching, mentoring, and training programs, such as in the case of personality profiles, leadership style preferences, world views, attitudes and behaviors, or resilience in growing leadership abilities.

We require your explicit consent for processing sensitive data, so when you submit your details, we will send you a further communication asking for you to confirm your consent to this processing.

Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.

3.  HOW WE COLLECT YOUR PERSONAL DATA

We collect data about you through a variety of different methods including:

Direct interactions: You may provide data by filling in forms on our sites (or otherwise) or by communicating with us by post, phone, email, or otherwise, including when you:

order our products or services;

create an account on our sites;

subscribe to our services or publications;

request resources or marketing be sent to you;

enter a competition, prize draw, promotion or survey; 

enter information into our online coaching, mentoring, training or community platforms; or

give us feedback.

Automated technologies or interactions: As you use our sites, we may automatically collect Technical Data about your equipment, browsing actions and usage patterns. We collect this data by using cookies, server logs and similar technologies. We may also receive Technical Data about you if you visit other websites that use our cookies. Please see our cookie policy at https://transformationfirst.asia/cookie-policy for further details.

Third parties or publicly available sources: We may receive personal data about you from various third parties and public sources as set out below:

Technical Data from the following parties:

• analytics providers such as Google based outside the EU;

• advertising networks [such as Facebook based outside the EU]; and

Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.

4.  HOW WE USE YOUR PERSONAL DATA  

We will only use your personal data when legally permitted. The most common uses of your personal data are:

Where we need to perform the contract between us.

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal ground for processing your personal data, other than in relation to sending marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by emailing us at support@transformationfirst.asia

Purposes for processing your personal data  

Set out below is a description of the ways we intend to use your personal data and the legal grounds on which we will process such data. We have also explained what our legitimate interests are where relevant.

We may process your personal data for more than one lawful ground, depending on the specific purpose for which we are using your data. Please email us at support@transformationfirst.asia if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Marketing communications 

You will receive marketing communications from us if you have:

(i) requested information from us or purchased goods or services from us; or

(ii) if you provided us with your details when you entered a competition or registered for a promotion or free resources; and

(iii) in each case, you have not opted out of receiving that marketing. 

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by logging into the website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or OR by emailing us at support@transformationfirst.asia at any time.

Where you opt out of receiving our marketing communications, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Change of purpose  

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to find out more about how the processing for the new purpose is compatible with the original purpose, please email us at support@transformationfirst.asia.

If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

5.  DISCLOSURES OF YOUR PERSONAL DATA  

We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above:

Service providers who provide IT and system administration services.

Professional advisers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

Tax, customs, and other authorities based in Singapore and other relevant jurisdictions who require reporting of processing activities in certain circumstances.

Third parties to whom we sell, transfer, or merge parts of our business or our assets.

We require all third parties to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such third parties to process your personal data for specified purposes and in accordance with our instructions.

6.  INTERNATIONAL TRANSFERS  

Countries outside of the European Economic Area (EEA) do not always offer the same levels of protection to your personal data, so European law has prohibited transfers of personal data outside of the EEA unless the transfer meets certain criteria.

Many of our third parties service providers are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we do our best to ensure a similar degree of security of data by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission; or

Where we use certain service providers, we may use specific contracts or codes of conduct or certification mechanisms approved by the European Commission which give personal data the same protection it has in Europe; or

Where we use providers based in the United States, we may transfer data to them if they are part of the EU-US Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.

If none of the above safeguards is available, we may request your explicit consent to the specific transfer. You will have the right to withdraw this consent at any time.

Please email us at support@transformationfirst.asia if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

7.  DATA SECURITY  

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know such data. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

8.  DATA RETENTION  

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers for tax purposes.

In some circumstances you can ask us to delete your data: see below for further information.

In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

9.  YOUR LEGAL RIGHTS  

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These include the right to:

Request access to your personal data.

Request correction of your personal data.

Request erasure of your personal data.

Object to processing of your personal data.

Request restriction of processing your personal data.

Request transfer of your personal data.

Right to withdraw consent.

You can see more about these rights at:

Singapore law: https://www.pdpc.gov.sg/Individuals/Individuals-Overview

EU law: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you wish to exercise any of the rights set out above, please email us at support@transformationfirst.asia.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

10. THIRD-PARTY LINKS  

Our websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our websites, we encourage you to read the privacy notice of every website you visit.

11. COOKIES  

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see https://transformationfirst.asia/cookie-policy