PRIVACY NOTICE

Who are we?

Morphos International Pte Ltd, 51 Changi Business Park Central 2, Level 04-05, The Signature, Singapore 486066 (“we“, “our” or “us”) take the security of your personal data very seriously and are committed to protecting and respecting the privacy of the users (“you” or your”) of our Morphos platform (the “Platform”).

What is this privacy notice for?

We may handle your personal data in connection with your use of the Platform. This privacy notice (together with our Terms of Use) set out, for the Platform, our collection and sharing practices, the uses to which personal data is put, the ways in which we protect it in accordance with the data protection laws and your privacy rights. Please read it carefully.

This privacy notice covers the processing of your personal data on the Platform including the processing we do for our own purposes as well as the processing we do on behalf of our clients (who may be your current or potential employer or institute). If you are utilising the platform at the direction of one of our clients, certain sections of this notice may not apply to you. Personal data collected from users who are minors is dealt with in accordance with applicable law.

1. WHAT DATA DO WE COLLECT?

We collect information directly from you and in some instances from your employer. 

When you (or your employer) sign up to the Platform you may provide certain personal data including:

• contact information such as your name, email address, and phone number;
• any personal data regarding another individual that you provide in the course of using the services;
• employment information such as your HR/employee ID, length of time that you have worked in your employer organisation, job title, work location, department, employment start date and next pay date;
• details of your correspondence with us;
• technical information, such as your Internet Protocol (IP) address used to connect your computer to the internet, your login information, browser type and version, screen resolution, flash version, time zone setting, browser plug-in types and versions, operating system, platform and traffic data, cookies data, web logs and other communication data, and details of the resources that you access, which we collect from you when you access the Platform; and
• any other information you provide to us.

If you supply us with personal data about other people (for example if you are a representative from an employer client providing information about the employees), you represent that you have the authority to provide this information on their behalf and you should direct them to this privacy notice. In these instances, you further represent that the individuals to whom this information relates have been informed of and understand the reason(s) for obtaining the information and the manner in which this information will be used and disclosed, and have consented to such use and disclosure.

2. HOW DO WE USE THE DATA WE COLLECT?

The personal data we collect enables us to provide you and your employer with access to the Platform and its features and enable you to interact with the Platform.

In particular, we use your personal data to:

• enable you to access and use the Platform, including to verify your identity when signing up to the Platform and verifying your account;
• verify your identity when subsequently logging in and using the Platform;
• contact you when necessary (including about changes to our service) and respond to your requests and enquiries;
• provide technical assistance or allow any third party authorised by us to do so;
• manage troubleshooting problems, detect and protect against error;
• market products and services to you, including ours, those of our affiliates, and those of other third parties, provided that, where required, we have obtained your consent to do so;
• fulfil legal and regulatory requirements;
• detect and prevent fraud, suspicious activities, and other illegal activities;
• analyse and improve products and services, collect feedback, enhance the Platform, and evaluate the effectiveness of our marketing activities and overall services;
• perform statistical analyses on users of the Platform and track your use of the Platform; and
• on an aggregated and anonymised basis, share the data and statistical analyses with our clients.

If you are utilising the Platform at the direction of your current or potential employer or institute, you should separately refer to their privacy notice for information on how they use the personal data that they collect and use via the Platform.

Tracking users’ use of the Platform

We use various tools, and collect various information, to assess how you use and interact with the Platform, including information about your visit, such as your IP address, details of your computer systems, device ID, browser detail and location, connections, or any information that we may collect through the use of cookies, web beacons/gifts, Flash LSOs, and Behavioural targeting/re-targeting. In most cases this data will be collected automatically. You can find more information about our use of this type of technology in our Cookies Notice.

3. DISCLOSURE OF YOUR INFORMATION

We may share your personal data to assist with managing and running the Platform and undertaking the activities set out in section 2 above, or to provide other products or services or support as requested by you or your employer. In particular, we may share this information with:

• your current or potential employer in order to assess your suitability for a job;
• other Morphos clients who are hosting learning events when you have registered your interest in participating in future learning events;
• our affiliates to enable them to provide services to you and, where we have the requisite consent, to contact you regarding additional products and services that may be of interest to you;
• third parties who handle your personal data on our behalf in order to provide the Platform, including Amazon Web Services and GoDaddy, who support the Platform, and who may access your personal data on our behalf in order to make the Platform available and in connection with providing enhanced functionality;
• law enforcement agencies, regulatory authorities and other public bodies such as courts in order to comply with our legal or regulatory obligations; and

The third parties to whom we disclose information are required by law and/or contractual requirements to keep your personal data confidential and secure. These parties may not use or disclose it except as reasonably necessary to provide their services, or to comply with, or as permitted by, applicable law.

We may disclose your personal data without your prior permission, as permitted by law, including instances when we believe it is necessary to: (a) prevent physical or financial harm; (b) enforce the Terms of Use; (c) respond to claims of suspected or actual illegal activity or violation of third party rights; (d) respond to an audit or investigate a complaint or security threat; and/or (e) comply with law or legal process.

In the event we sell some or all of our assets, it is possible your personal data could be one of the assets transferred to the purchaser. We may disclose and/or transfer your personal data to a third party purchaser in these circumstances.

4. USING YOUR INFORMATION IN ACCORDANCE WITH DATA PROTECTION LAW

Data Protection Law requires that we meet certain conditions before we are allowed to use your personal data in the manner described in this privacy notice. To use your personal data, we will rely on one of the following conditions, depending on the activities we are carrying out:

Consent

We may provide you with marketing information about our services or products where you have indicated your consent for us to do so (to the extent that we are required to collect consent under Data Protection Laws). We may contact you by mail or email, phone and electronic notifications (where you have agreed to those methods of communication) to provide you with the information on your requested service or product. We may also provide you with information, special offers, research, promotions, and similar products and services. Where you have indicated your consent to us doing so, we may also pass your details to our group companies or third party insurance and financial product providers so that they can provide you with information on the products they provide.

You may change your marketing preferences at any time by contacting us as set out in section 10 below.

Legitimate interests

It is in our legitimate interests to collect your personal data as it provides us with information that we need to provide our services to you and to make our Platform available.

This requires us to carry out a balancing test of our interests in using your personal data (for example, in order to provide you with access to the Platform and to satisfy the contractual obligations we owe to your employer), against the interests you have as a citizen and the rights you have under Data Protection Law (for example, to not have your personal data sold to third party marketing companies without your knowledge).

The outcome of this balancing test will determine whether we may use your personal data in the ways described in this privacy notice. We will always act reasonably and give full and proper consideration to your interests in carrying out this balancing test.

To provide you with the services that we have agreed to provide to you

We are permitted to hold and process some of your personal data because it is necessary to do so in order to provide you access to, and to enable you to make use of, the Platform. Without this personal data, we could not provide you with access to the Platform.

Compliance with a legal obligation

We are permitted to process your personal data where it is necessary for compliance with our legal obligations.

For legal claims

We are permitted to process your personal data where it is necessary to establish, pursue or defend a legal claim.

Substantial Public Interest

We are permitted to process your personal data where it is necessary for reasons of substantial public interest, on the basis of Data Protection Laws.

If we look to use your personal data for any other purpose not covered in this privacy notice, we will let you know about any proposed new purposes before using your personal data in this way.

5. HOW LONG WE KEEP YOUR INFORMATION FOR

Our retention periods for personal data are based on business needs and legal requirements. We retain personal data for as long as is necessary for the processing purpose(s) for which the information was collected, and any other permissible, related purpose.

We usually keep your information for as long as required to:

• to respond to any questions or complaints;
• to show that we treated you fairly;
• to demonstrate compliance with our regulatory obligations; and/or
• to maintain records according to rules that apply to us.

We will also keep your information for as long as it is needed for legal, regulatory or technical reasons (such as where data has to be held in relation to historic insurance claims). We may also keep it for research or statistical purposes. If we do, we will make sure that your privacy is protected and only use it for those purposes. To the extent your current or potential employer has instructed us to process your personal data on their behalf, we will retain data in accordance with their instructions.

6. SENDING DATA OUTSIDE OF THE EEA

We are an Singapore based company with staff located in Singapore, and therefore, your personal data will be processed outside the European Economic Area (“EEA”).

If we do transfer personal data outside of the EEA we will make sure that it is protected in the same way as if it was being used in the EEA and may be required to take specific additional measures to safeguard the relevant personal data. Certain countries outside the EEA have been approved by the European Commission as providing essentially equivalent protections to the Data Protection Laws (see the full list here) and therefore no additional safeguards are required to export personal data to these jurisdictions. In countries which have not had these approvals, we will establish legal grounds justifying such transfer, such as European Commission-approved model contractual clauses, or other legal grounds permitted by applicable legal requirements.

You can contact us as set out in section 10 below to find out more about safeguards we have in place for any transfers of your personal data outside of the EEA or if you would like to see a copy of the specific safeguards applied to the export of your personal data.

7. WHAT STEPS DO WE TAKE TO PROTECT YOUR INFORMATION?

All information you provide to us is stored on our or our subcontractors’ secure servers and accessed and used subject to our security policies and standards. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Platform, you are responsible for keeping this password confidential. We ask you not to share a password with anyone and may suspend or terminate your access to the Platform if you do so.

We restrict access to your personal data to those employees of ours, our affiliates, and third party service providers who reasonably need it to provide products or services. We have implemented commercially reasonable physical, electronic, procedural, administrative, and technical safeguards in a way that complies with the security requirements of data protection laws to protect your personal data, located in the countries where we are based from unauthorised access. However, as effective as our security measures are, no security system is impenetrable. We cannot guarantee the security of these systems, nor can we guarantee that information supplied by you or on your behalf cannot be intercepted while being transmitted over the Internet.

8. WHAT RIGHTS AND OBLIGATIONS DO YOU HAVE WITH RESPECT TO YOUR DATA?

You have a number of rights under data protection laws in relation to the way we process your personal data. These are set out below. You may contact us using the details in section 11 below to exercise any of these rights. We will respond to any request received from you within one month from the date of the request.

These rights are subject to certain exemptions to safeguard the public interest (e.g. the prevention or detection of crime) and our interests (e.g. the maintenance of legal privilege), and may not all be available in the country in which you are based.

Updating information

Keeping your information accurate and up-to-date is very important. Inaccurate or incomplete information could impair our ability to deliver relevant services to you. We will use reasonable endeavours to ensure that your personal data is accurate. In order to assist us with this, you should notify us of any changes to your personal data by updating your profile on the Platform or by contacting us as set out in section 10 below.

Intentionally providing false or misleading information or using another person’s email address or personal data for the purposes of falsely obtaining any products or services through the Platform, may lead to termination or forfeiture of the product or services and/or of access to the Platform and may result in legal action.

9. CHANGES TO THIS PRIVACY NOTICE

We may change the content of the Platform and how we use cookies and consequently this privacy notice and our cookies notice and any other document to which they refer are subject to change at any time. If we make material updates to this privacy notice, we will update the date it was last changed and will clearly indicate this via a banner on the Platform and via email. Any changes we make to this privacy notice become effective immediately when we post the revised privacy notice on the Platform. We recommend that you review this privacy notice regularly for changes.

This privacy notice was last updated on 19 May 2023.

10. HOW TO CONTACT US

You can contact us at any time at [email protected] if you have any questions about this privacy notice or our privacy practices in general. You can also contact our data protection officer at:

Data Protection Officer
Morphos International Pte Ltd
51 Changi Business Park Central 2, Level 04-05
The Signature, Singapore 486066

How to complain

Please let us know if you are unhappy with how we have used your personal data or are not satisfied with our handling of any request by you in relation to your rights. You can contact us using the contact details above. You also have the right to complain to the relevant supervisory authority.