1. Personal Data
1.3) Depending on the nature of your interaction with us, on the Sites or through any Service we provide, the type of information that we may collect includes:
Personal data and contact information. We may collect information with personal identifiers including your name and identification information such as your NRIC number, contact information such as your address, email address or telephone number, nationality, gender, date of birth, marital status, photographs and other audio-visual information.
Employment details. We may collect information from your CV in relation to your occupation and other positions held, employment history, salary, and/or benefits or education history.
Financial information. We may collect financial information such as credit card numbers, debit card numbers or bank account information and details of any other information that allows us to transact with you and/or provide you with our Services.
Device and Technical Information. We collect device-specific and other technical information about your mobile or computer device such as the hardware model, operating system version, browser type and version, Internet Protocol (IP) address, advertising identifier, unique application identifiers, unique device identifiers, browser type, language, wireless network, and mobile network information (including the mobile phone number).
Other Anonymised Data. We may collect information that is not associated with or linked to your personal data and cannot be used to identify you or any other individuals (“Anonymised Data”).
1.4) Most information will be collected when you use the Sites or when you use the Services. However, we may also use various technologies on the Sites which may lead to information being collected automatically by us or from other sources such as advertising, sub-contractors in technical and payment services, analytics providers, search information providers and mailing lists. This information does not generally, but may, contain your personal data. In particular, information is likely to be collected as follows:
Web beacons. Web beacons (also known as “clear gifs” and “pixel tags”) are small transparent graphic images that are often used in conjunction with cookies in order to further personalize the Service for our users, collect a limited set of information about our visitors, and advertise to our users.
Web analytics. Web analytics is the method for collecting and assessing the behaviour of users on the Sites. This includes the analysis of traffic patterns in order, for example, to determine the frequency of visits to certain parts of a website or mobile application, or to find out what information and services the users are most interested in. We may also use web beacons in email communications in order to understand the behaviour of our users, such as whether an email has been opened or acted upon.
2. Collection, Use and Disclosure of Personal Data
2.1) As there are many circumstances in which we may collect information, we will endeavour to ensure that you are always aware of the information being collected, in particular by third parties. 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”, for example Facebook or any other non-Tribe related digital platform) 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 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) We may collect and use your personal data for any or all of the following purposes:
performing obligations in the course of or in connection with our provision of the Services requested by you;
verifying your identity;
responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
detecting usage patterns;
troubleshooting crashes associated with specific hardware and software used to access the Sites and Services;
administering the sites;
tracking user movements; and
gathering broad demographic information for aggregate use of the Services;
processing payment or credit transactions;
sending your marketing information about the Services including notifying you of our marketing events, initiatives and other promotions;
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;
any other purposes for which you have provided the information;
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; and
any other incidental business purposes related to or in connection with the above.
2.3) Your personal data may also be anonymised for use by Tribe, Tribe Accelerator, Tribe Academy, OpenNodes, Tribe Careers and its affiliates for other purposes.
2.4) It may be necessary for us to disclose your personal data to our affiliates or to third parties in a manner compliant with the PDPA in order to carry out the purposes set out above. We may disclose or share personal data with such parties who provide necessary services to us, such as for processing activities like verification, website hosting, data analytics and payment processing. We may disclose your personal data in the following circumstances:
where such disclosure is required for performing obligations in the course of or in connection with our provision of the Services requested by you;
third party online payment processing companies (e.g. Stripe) who will process your payments so that you can use the Services and/or make any related purchases;
our consultants and professional advisers (e.g. accounting firms, audit firms, law firms and/or other professional advisory firms) who are maintaining our records in accordance with legal requirements;
governmental, regulatory or law enforcement bodies who have a legal right to demand for your personal data, in response to a legal request such as a court order, to investigate or report an illegal activity, or to enforce our rights or defend claims;
our affiliated or related companies and/or third parties to whom we may sell, divest, transfer, assign, share or otherwise engage in a transaction that involves, some or all of the our assets (which may include your personal data), in the course of a corporate divestiture, corporate restructuring, merger, acquisition, joint venture, bankruptcy, dissolution, reorganisation, or any other similar transaction or proceeding; or
third party service providers, agents and other organisations we have engaged to perform any of the functions listed in clause 2.2 above for us.
2.5) We do not sell, rent, licence or otherwise disclose your personal data to third parties. We are careful in our selection of third party service providers, and when we disclose your personal data to such parties, we shall require them to ensure that they are bound by obligations of data protection (pursuant to contracts and/or applicable laws) similar to the obligations as set out in the PDPA.
2.6) We may also disclose aggregated information that is Anonymised Data about our users, including but not limited to the total number of our users and their overall demographics.
2.7) The Sites may have the functionalities to allow you to share personal data with other third parties such as other users of the Sites. You are responsible for your choice(s) and are deemed to have provided consent for any sharing of your personal data in the manner provided by the Sites. Please do not post or upload personal data to the Sites that you would not want to be publicly available.
2.8) 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 any contract with you).
3. Protection of Personal Data
3.1 ) We take all appropriate precautions to safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. Examples of measures we have implemented include encryption, privacy filters and up-to-date antivirus software to protect and secure all storage and transmission of your personal data.
3.2) You should be aware, however, that no method of transmission over the Internet and no electronic storage is completely secure. You understand that any message or information that you send, transmit or upload to the Sites may be read or intercepted by others, even if there is a special notice that a particular transmission is encrypted. While security cannot be guaranteed, we strive to protect the security of your personal data by constantly reviewing and enhancing our security measures. However, we cannot accept responsibility for misuse or loss of, or unauthorised access to your personal data.
To the fullest extent permitted by law, we shall not be liable in any event for any special, exemplary, punitive, indirect, incidental or consequential damages of any kind or for any loss of reputation or goodwill, whether based in contract, tort (including negligence), equity, strict liability, statute or otherwise, suffered as a result of unauthorized or unintended use, access or disclosure of your personal data.
5. Retention of Personal Data
5.1) We may retain your personal data for as long as it is necessary to fulfil the purposes for which it was collected, or as required or permitted by applicable laws.
5.2) 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.
7. Governing Law