In the course of conducting our information services and
technology business, Advanetwork Technology Pte Ltd (in
short "ANT") collects and processes personally
identifiable information of our clients, shareholders,
employees, suppliers, business partners, Web site visitors
and other persons (Personal Data). Maintaining the integrity
and confidentiality of Personal Data and handling it correctly
is central to the way we conduct our business activities.
This policy describes how we handle Personal Data.
Personal Data is information that can be used directly
or indirectly to indentify a living individual. Personal
Data may include sensitive categories of information,
such as information that reveals racial or ethnic origin,
political opinions, religious beliefs, trade union membership,
health or sexual orientation (Sensitive Personal Data).
This policy applies to Advanetwork Technology Pte Ltd,
and is effective as of January 1, 2008. All employees
will be required to abide by this policy.
This policy is designed to protect Personal Data under
applicable law as it currently exists. However, ANT realizes
that this policy cannot address every potential issue
and circumstance. Therefore, we acknowledge that this
policy is subject in all respects to applicable local
legal and regulatory requirements and existing agreements
and confirm that we will comply with such requirements
and existing agreements.
We will observe the privacy principles described below
of Notice, Fair Processing, Access, Security/Integrity,
Onward Transfer and Enforcement/Compliance in processing
When we collect and process Personal Data about individuals,
we will make certain information available to those individuals
on a reasonable and timely basis. This information will
include what Personal Data is being collected, who is
collecting it, how and for what purposes it is being collected,
how it is being used and to whom it will be disclosed.
2. Fair Processing
We will process Personal Data only with consent or when
such processing is permitted by applicable law. If we
need to process Sensitive Personal Data, we will obtain
explicit consent for such processing, unless such processing
is permitted by applicable law.
We will not process Personal Data in a manner incompatible
with the purposes for which it was originally collected
unless later authorized by the affected individuals or
allowed by law; we will take reasonable steps to ensure
that such data is accurate, adequate, relevant and not
excessive in relation to such purposes; and we will not
keep such data longer than is neccessary for such purposes.
We will allow individuals reasonable access to their Personal
Data to verify, correct or delete their data, where inaccurate.
We will also provide a means for individuals to exercise
all other legal rights that they may have in relation
to their Personal Data.
Personal Data will be accessible and processed only by
(i) ANT employees, suppliers, business partners and others
who require access for the performance of their obligations
to ANT; (ii) any person granted access by the individual
to whom Personal Data pertains; and (iii) those otherwise
authorized by law or court order.
We will take reasonable security procedures through appropriate
technical and organizational measures to protect against
unauthorized or unlawful access or processing, disclosure,
alteration, destruction or accidental loss of Personal
We will utilize reasonable means to keep Personal Data
accurate, complete and current in order to protect the
quality and integrity of Personal Data, however, we rely
on individuals to provide all relevant information and
to advise us of any changes to their Personal Data to
ensure that it remains accurate, complete and current.
5. Onward Transfer
When we tranfer Personal Data within ANT or to third parties
(including our suppliers and business partners), we will
observe the privacy principles of Notice (described above),
and we will require all the recipients of such data to
provide at least the same level of protection for such
data as specified by the standards stated in this policy.
We will follow internal processes for handling compliants
regarding our management of Personal Data.
We will demonstrate our compliance with this policy by:
• publishing this policy conspicuously so that it
is accessible to all interested persons
• appointing and maintaining a Privacy Officer with
responsibility for developing and implementing a privacy
• implementing procedures to execute this policy
in the conduct of our business, including training our
employees in the use of such procedures and disciplining
employees of failure to comply with this policy and its
• at least annually, reviewing this policy to ensure
that it continues to comply with prevailing privacy standards,
current applicable law and regulations and existing agreements
ANT Web Sites
In addition to all other Personal Data handled by ANT,
this policy applies to Personal Data collected through
ANT Web Sites.
As a convenience to our Web Site visitors, we sometimes
provide links to other Web Sites. These linked sites are
not under the control of ANT, and as such, we are not
responsible for their content.