The International Centre for Industrial Transformation (“INCIT”) is an independent non-government, not-for-profit organization based in Singapore. INCIT was founded in 2021 in the course of a joint cooperation program with the aim to internationalize the Smart Industry Readiness Index (“SIRI”) as the internationally recognized standard for the Industry 4.0 (“i4.0”) benchmarking and transformation. INCIT’s mission is driving the global adoption of SIRI and spearheading the transformation of the industrial sectors globally.

INCIT (hereinafter “INCIT”, “us“, “we” or “our“) are committed to protecting your personal data in accordance with the Personal Data Protection Act 2012 (“PDPA”) of Singapore. This Personal Data Protection Policy (“Privacy Policy”) describes how we handle information we obtain when you access and use our services or communicate with us.

By submitting any personal data to us, you acknowledge that you have read this Privacy Policy and that you consent to us collecting, using and disclosing your personal data in accordance with the terms of this Privacy Policy. If you do not consent to the terms of this Privacy Policy, please be aware that we might not be able to render any of our services.

We reserve the right to update this Privacy Policy from time to time. Any changes to this Privacy Policy will come into effect on the date of posting. You are therefore encouraged to check this page regularly.

What is “Personal Data”?

“Personal Data” means data, whether true or not, about an individual who can be identified from that data or from that data and other information to which we have access to. Personal data which you may provide to us include the following:

• Full name;
• Mobile telephone number; or
• Personal email address.

What isn’t Personal Data?

Please note that “business contact information” is not covered by the PDPA and this Privacy Policy. “Business contact information” refers to an individual’s name, position name or title, company name, business telephone number, business address, business electronic mail address or business fax number and any other similar information about the individual, not provided by the individual solely for his/her personal purposes.

Information we may collect

We may obtain information about you through the following avenues:

INCIT Website

When you visit our website at [https://incit.org] (“Website”), your browser may provide us with data that is necessary to display our website. This data includes your: IP address; date and time of browser request; GMT difference; exact page visited within our website; HTTP status code; amount of transferred data; referrer URL; browser type, version and language; operating system and interface; screen resolution; and language settings.

We may also obtain Personal Data when you contact us or provide feedback to us via the Feedback Form and Enquiries Form and other online forms which may be used to contact us hosted on our Website.

INCIT Online Portal

If you are one of INCIT’s partners, you will have access to the INCIT Online Portal (“INCIT Online Portal”). We may collect Personal Data from you when you create a partner or member profile on the INCIT Online Portal, or when you upload documents to the INCIT Online Portal which contain Personal Data.

Ad-hoc contact

We may also collect your Personal Data when you contact us for partnership or procurement opportunities via e-mail enquiries, telephone enquiries, or written correspondence.

Social Media

If you follow us on social media networks such as Instagram, Facebook, LinkedIn or Twitter, you provide us with access to publicly available information on your social media profile, which may include your public profile information, e-mail address and friends lists and/or connections.

By submitting your Personal Data to us, you warrant that all data is complete, accurate, true and correct. Failure to ensure that such Personal Data provided to us is complete, accurate, true and correct may result in inability on our part to provide you with our services.

If you provide Personal Data to us on behalf of another person, you warrant that you have obtained consent from that person to provide such Personal Data on their behalf, and you agree to indemnify and hold us harmless from any breach of such warranty.

For what purposes do we collect, use or disclose your Personal Data?

We may collect, use or disclose your Personal Data for the following purposes:

• To provide you with our Programmes;
• To improve your experience while using our Website and INCIT Online Portal including providing customisations, features and advertising;
• To comply with legal and regulatory requirements;
• To respond to your queries, requests, feedback or complaints;
• To communicate with you for marketing, research, survey or promotional purposes;
• (f) To inform or update you of other products or services available from us and/or our partners/affiliates, where you have consented to be contacted for such purposes;
• (g) To update you on changes to our Programmes.

We will only collect and use your Personal Data with your consent or deemed consent or as otherwise permitted under the PDPA or other applicable laws and regulations, and for purposes, which you have consented to, or where we believe it is necessary to protect our legal rights. We may also use information about you in connection with legal claims, regulatory issues, audit function, merger, acquisition or funding.

For the purposes of this Privacy Policy, “Programmes” refer to the programmes offered by INCIT from time to time, including but not limited to the CSA® Programme, the Data Membership Programme, the Examination / Certification Centres for Certified SIRI Assessor Programme, and the Training Centre for Certified SIRI Assessor Programme.

Who do we share your Personal Data with?

We will not disclose and/or transfer your Personal Data without your consent. However, your Personal Data may be disclosed to the following third parties for the purposes listed above (which are non-exhaustive):

• our agents, contractors or service providers who have been engaged by us to provide services such as IT services, payment processing, data processing, marketing etc. and their respective service providers, business partners and agents;
• professional advisors engaged by us such as lawyers, auditors, advisors etc.;
• financial institutions, government authorities or law enforcement agencies or other entities as required under applicable law;
• any party to whom you authorise us to disclose your Personal Data; and
• (e) any affiliate of INCIT.

We may also subcontract processing of Personal Data to, or share your Personal Data with third parties located in countries other than Singapore. You agree that we may transfer your Personal Data to our affiliates, subsidiaries and/or other third parties located outside of Singapore, as long as the Personal Data is transferred and handled in accordance with this Privacy Policy and all applicable laws. We will take all appropriate steps to ensure that any party in a country or territory outside Singapore to whom we transfer Personal Data is bound by legally enforceable obligations, to provide to the transferred Personal Data a standard of protection, which is comparable to the protection under the PDPA.

We may disclose and/or transfer your Personal Data to a third party only if:

• the disclosure or transfer is necessary for the provision of our Programmes, in connection with legal proceedings, advice or rights, or required by any law or regulation to which we are subject; and
• if a contract (e.g. a data processing agreement or a similar transfer control mechanism) has been concluded between us and the relevant third party provides for safeguards at a similar protection as provided by this Privacy Policy or by applicable law (including the PDPA);

All such third parties to whom Personal Data is disclosed and/or transferred are required to:

• maintain the confidentiality of your Personal Data in accordance with applicable laws (including the PDPA) and our contract (if applicable);
• use and process Personal Data only in accordance with our instructions and for purposes authorized by us; and
• take appropriate technical, physical and organizational security measures to protect the Personal Data.

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of service to another provider, your information may be transferred as part of such a transaction.

How do we manage, protect and store your Personal Data?

We have appointed a Data Protection Officer who will oversee and ensure management of Personal Data in accordance with the PDPA. The contact details of our Data Protection Officer are listed below.

• Protection

We take breaches of privacy very seriously and will take all reasonable steps and employ appropriate security measures like rendering data anonymous or at least using pseudonyms to ensure that your Personal Data is securely stored and protected against unauthorised and illegal access, collection, use, disclosure, copying, modification, disposal or similar risks.

Unauthorised entry or use, hardware or software failure, and other factors, may compromise the security of your Personal Data. INCIT does not warrant or guarantee in any way that your Personal Data or communications will always remain private and/or safe. INCIT hereby disclaims any responsibility or liability directly or indirectly arising out of or in connection with, any loss, theft, or unauthorised access, collection, use, disclosure, copying, modification, disposal or similar actions with regard to any personal data held or maintained by us, except to the extent caused by our fault or negligence.

• Accuracy and Correction

We endeavour to ensure that your Personal Data collected is accurate and complete if the Personal Data is likely to be used by us to make a decision that affects you or is likely to be disclosed by us to another organisation.

To help us maintain the accuracy of your Personal Data, if there is any change or update in your Personal Data, please update us accordingly. If you have created a profile on our Website or the INCIT Online Portal, please update your profile accordingly. If you wish to correct any of your Personal Data which we have and which you cannot correct via the Website or the INCIT Online Portal, please write to our Data Protection Officer at the contact details below, and we will correct or update your Personal Data as soon as reasonably practicable.

• Retention

We will only retain Personal Data for as long as the retention is required for (i) the purposes for which such Personal Data was collected and (ii) for legal and business purposes. Otherwise, we will exercise measures to ensure such Personal Data is disposed of or discarded in a secure manner that would prevent further processing, unauthorized access, or disclosure to any other party or public.

What are your rights?

• Right to withdraw consent

You may withdraw your consent for the collection, use and disclosure of your Personal Data at any time by giving us reasonable notice. You may withdraw your consent by sending a written request by email or by post to our Data Protection Officer at the address below. Upon receiving your written request, we will inform you of the likely consequences of the withdrawal of your consent, and will cease to collect, use and disclose your Personal Data therefrom, unless otherwise permitted or required by the PDPA or any other applicable laws and regulations.

Please note that if you withdraw your consent to any or all use or disclosure of your Personal Data, depending on the nature of your request, we may not be able to offer or to provide to you our products or services or administer any contractual relationship in place.

• Right of access and correction

You may request for information regarding your Personal Data that is in our possession or under our control, as well as information about the ways in which your Personal Data has been or may have been disclosed by us within a year before the date of your request. Your request should contain the following information which will allow us to identify you and facilitate your request:

• Your name or user name (as applicable); and
• The types of personal data you have provided to us and which pertain to the request.

Your request should be addressed to our Data Protection Officer at the address below.

Please note that INCIT reserves the right to charge an administrative fee to respond to your request for access / correction. Prior to processing and responding to your request, INCIT will notify you of the administrative fee chargeable. INCIT shall not be obliged to accede to your request for access to your personal data unless payment of the administrative fee is made.

Who should you approach?

If you have any feedback or enquiries relating to your Personal Data or if you wish to know more about our data protection policies and practices, please contact us at the following:

Email Address: [email protected]

Postal Address: International Centre for Industrial Transformation Ltd

10 Collar Quay, Level 37. Singapore 049315

Attn: Personal Data Protection Officer

For more information about the PDPA, please visit http://www.pdpc.gov.sg.

This Privacy Policy shall be governed in all respects by the laws of Singapore.

This Privacy Policy was last updated in 1 November 2022.