We have adopted the Australian Privacy Principles (APPs) contained in the Privacy Act 1988 (Cth) (the Privacy Act) and will comply with the Privacy Act 1988 (Cth) (Australia), the Personal Data Protection Act 2012 (PDPA) (Singapore), the Data Privacy Act of 2012 (DPA) (Philippines), the Personal Data Protection Act 2010 (PDPA) (Malaysia), and the Personal Data Protection Act B.E. 2562 of Thailand (Thailand PDPA) and relevant laws of your home jurisdiction (“Applicable Laws”) (to the extent it is required to do so under such legislation) when we process (meaning the performance of one or some operations of collecting, editing, utilizing, storing, providing, sharing or spreading personal information in cyberspace for commercial purposes) your personal data. The Applicable Laws govern the way in which we collect, process, use, disclose, store, secure, transfer and dispose of your Personal Information.
A copy of the Australian Privacy Principles may be obtained from the website of The Office of the Australian Information Commissioner at www.oaic.gov.au. A copy of the PDPA (Singapore) may be obtained from the website of the Singapore Personal Data Protection Commission at www.pdpc.gov.sg. A copy of the DPA (Philippines) may be obtained from the website of the Philippines? National Privacy Commission at www.privacy.gov.ph. A copy of the PDPA (Malaysia) may be obtained from the website of the Malaysian Personal Data Protection Department at www.pdp.gov.my/jpdpv2/?lang=en. Copies of legal instruments on data protection and privacy of Vietnam may be found on the website of Vietnam’s Authority of Broadcasting and Electronic Information at http://abei.gov.vn/van-ban-qppl/10089.
What is Personal Information and how do we collect it?
Personal Information is information or an opinion about an identifiable individual. Examples of Personal Information we collect include: names, usernames, job titles, usage of the systems we manage, addresses, email addresses and phone numbers.
This Personal Information is obtained in many ways including interviews, correspondence, by telephone and by email, via our website and website application, from media and publications, from other publicly available sources, from cookies and from third parties. We don’t guarantee website links or policy of authorised third parties.
How do we process, use and/or disclose Personal Information?
We collect and/or process your Personal Information in both electronic format or such other format otherwise deemed appropriate by the MATCHBOX Exchange group of companies and its authorized third parties for the primary purpose of providing our services to you and to our clients, providing information to our clients, suppliers and intermediaries in the course of operating our services, and for marketing. You hereby agree that we may also process and/or use your Personal Information for secondary purposes closely related to the primary purpose, in circumstances where you would reasonably expect such use or disclosure. You may unsubscribe from our mailing/marketing lists at any time by using the “unsubscribe” function in a communication, or contacting us in writing.
Before we collect and/or process Personal Information we will explain to you which information will be collected, where information will be processed, why we are collecting the information and how we process and/or plan to use it and we will inform you about your rights in relation to our collection, use and disclosure of your Personal Information and the period for us to retain your Personal Information. If you are an employee or representative of one of our current or prospective clients or suppliers, we will usually only collect whatever Personal Information is provided to us by you or your employer in the course of dealing with us, and use it only for the purpose of those dealings.
You are under no obligation to provide your Personal Information to us. However, without receiving certain information from you, we may not be able to provide our services to you or the customer or entity that you represent.
Use of our website
When you visit our website, and the platforms and systems accessed through it, we may automatically collect information about you, including details of access, IP addresses, web statistics and other information which is required to ensure that the site and systems are functioning properly.
Collection from Third Parties
Where reasonable and practicable to do so, we will collect your Personal Information only from you. If you provide us with the Personal Information of any other individual, you confirm that you have notified that individual of the purposes to which you are providing us with that individual’s Personal Information and that you have obtained that individual’s consent to providing us with that Personal Information. If we collect your Personal Information from a third party source without your consent, we will inform you of the name and other details of such third party source.
Disclosure of Personal Information
Your Personal Information may be disclosed in a number of circumstances including the following:
• To our related parties, contractors, service providers and suppliers we use to support the operations of our business;
• To our other clients and intermediaries that may need to deal with you for purposes consistent with our business;
• Where you consent to the use or disclosure; and
• Where required or authorised by law.
Otherwise, we do not sell, trade or transfer Personal Information.
Disclosure and/or transfer outside your home jurisdiction
Your personal information is not made available to any third parties outside of the MATCHBOX Exchange group, except to authorized service providers that need to process such information to provide the commissioned services or to other third parties as permitted or required by Applicable Laws or an authorized authority’s decision.
European Union General Data Protection Regulation
If you are a citizen of a European Union (EU) country or we collect personal data about you from a source in the EU, we aim to provide the standards of privacy protection required by the EU’s General Data Protection Regulation (GDPR) from 25 May 2018. Additionally, EU based organisations that share subject data with us may require that we meet GDPR standards. Our commitments in this Policy are generally consistent with the GDPR requirements applying to a Controller of subject data, and where required we will meet GDPR obligations in full. If you have a query about your rights or our obligations for GDPR purposes, please contact us.
Storage and security of Personal Information
Since MATCHBOX Exchange relies on a group-wide data processing system to process personal data relating to its employees, contractors, agents, customers, vendors; your personal information may – in the context of the above-mentioned purposes of data processing – also be stored in and transferred to the MATCHBOX Exchange group’s and its service provider’s locations abroad, if necessary.
To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced necessary and appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption and the use of privacy filters to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorised third party service providers and agents is only on a need-to-know basis.
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.
Your Personal Information will be kept for an appropriate period of time considered by the MATCHBOX Exchange group as suitable for our purposes set forth herein and will be deleted upon expiry of this period, unless otherwise permitted or required by Applicable Laws. When your Personal Information is no longer needed for the purpose for which it was obtained, we will take reasonable steps to destroy or permanently de-identify your Personal Information (unless we are required or authorised by law to retain it).
Your rights and choices regarding, and access, to your Personal Information
You may access the Personal Information we hold about you and require us to update and/or correct it if it is wrong or out of date, or delete, subject to certain exceptions to safeguard the public interest (e.g. the prevention or detection of crime), our interests (e.g. the maintenance of legal privilege) or technical reasons. If you wish to access your Personal Information, please contact us on the details below.
We will endeavour to provide a complete list of your Personal Information, correct or delete your Personal Information on receipt of your request. We may charge an administrative fee for providing a copy of your Personal Information.
In order to protect your Personal Information we may require identification from you before releasing the requested information and will implement your request or let you exercise any of these rights in most cases in a timely manner.
Maintaining the Quality of your Personal Information
It is important to us that your Personal Information is up to date. We will take reasonable steps to make sure that your Personal Information is accurate, complete and up to date. If you find that the information we have is not up to date or is inaccurate, please advise us as soon as practicable so we can update our records and ensure we can continue to provide quality services to you.
You may withdraw your consent for us to retain your Personal Information anytime you like, except only in case your consent withdrawal is restricted by Applicable Laws.
MATCHBOX Exchange Pte Ltd
Centennial Tower, Level 18, 3 Temasek Avenue 039190
MATCHBOX Exchange Pty Ltd
Level 22, 120 Spencer Street, Melbourne, Victoria 3000, AU
If you are not satisfied with how we handle your complaint or enquiry, you may contact one or more of the following bodies:
Singapore Personal Data Protection Commission
+65 5377 3131
Philippine National Privacy Commission
Malaysian Personal Data Protection Department
PDPA Expert Committee at the Office of the Personal Data Protection Committee.
Vietnam Competition and Consumer Protection Agency (amongst others).