Privacy Policy
Twobirds · Singapore
This Privacy Notice (the "Notice") is issued by Twobirds, an unincorporated community of independent practitioners based at 7 Temasek Boulevard, #12-07 Suntec Tower One, Singapore 038987 (hereinafter "Twobirds", "we","us" or "our").
This Notice records the manner in which personal data submitted to Twobirds, whether through this website ("the Website"), by correspondence, or by telephone, is collected, used, retained and disclosed by Twobirds, in accordance with the Personal Data Protection Act 2012 (No. 26 of 2012) of Singapore (the "PDPA") and its subsidiary legislation.
By submitting personal data to Twobirds, the User acknowledges receipt of this Notice and consents to the collection, use and disclosure of such data on the terms herein set forth.
Definitions and Interpretation
1.1
In this Notice, unless the context otherwise requires, the following expressions shall have the meanings ascribed to them: "Personal Data" bears the meaning given to it under section 2(1) of the PDPA; "User" means any natural person who submits Personal Data to Twobirds; "Engagement" means a written instruction to Twobirds for the provision of professional services.
1.2
References to the singular include the plural and vice versa; words importing one gender shall include all genders; and references to any statute or statutory provision shall include any subsequent amendment, re-enactment or substitution thereof.
Collection of Personal Data
2.1
Twobirds collects Personal Data only where the User has voluntarily furnished the same, whether by submitting an enquiry through the Website, by transmitting correspondence to hello@2birds.asia, or by telephoning Twobirds on +65 8595 3945.
2.2
The Personal Data so collected typically comprises the User's full name, electronic mail address, telephone number, name of employer or instructing organisation (if any), and the substance of the User's communication, together with the date and time of receipt thereof.
2.3
The Website employs no analytics, advertising or third-party tracking cookies. No information is collected passively from the User's browsing of the Website.
Purposes of Use
3.1
Personal Data collected pursuant to Article II shall be used solely for the following purposes (the "Permitted Purposes"): (a) responding to the User's enquiry; (b) preparing a fee quotation or scope of work; (c) carrying out the Engagement if one is concluded; (d) maintaining the working records of the practice; and (e) compliance with any obligation imposed on Twobirds by law, regulation or professional rule.
3.2
Twobirds shall not use Personal Data for any purpose materially beyond the Permitted Purposes without first obtaining the User's prior written consent.
Disclosure to Third Parties
4.1
Twobirds shall not sell, rent or transfer Personal Data to third parties for those third parties' own marketing or commercial purposes.
4.2
Incidental access to Personal Data may be afforded to providers of the electronic mail, document storage, accounting and payment processing services on which Twobirds relies in the ordinary course of its practice, each of which is bound by its own contractual obligations of confidentiality and data protection.
4.3
Personal Data may be disclosed where required by an order of a court of competent jurisdiction, or by any law, regulation or professional-conduct rule binding upon Twobirds.
Retention of Personal Data
5.1
Where the User's communication does not result in an Engagement, Twobirds shall close the relevant file no later than twelve (12) months after the last substantive correspondence, and shall remove personally identifying particulars from its active records no later than twenty-four (24) months thereafter.
5.2
Where the User's communication results in an Engagement, Twobirds shall retain the Engagement file for the period required by Singapore tax, accounting and professional-conduct rules, presently five (5) years from the closure of the Engagement.
Rights of the User
6.1
The User shall have the right, exercisable at any time by written request to Twobirds, to: (a) be informed of the Personal Data held about the User by Twobirds; (b) request the correction of any inaccuracy therein; and (c) request the deletion of such data, subject to any retention obligation set forth in Article V or imposed upon Twobirds by law.
6.2
Twobirds shall respond to any such request within a reasonable period, ordinarily not exceeding ten (10) working days from the date of receipt thereof.
6.3
In the event of dissatisfaction with the manner in which Twobirds has handled Personal Data, the User may refer the matter to the Personal Data Protection Commission of Singapore at www.pdpc.gov.sg.
Amendments to this Notice
7.1
Twobirds reserves the right to amend this Notice from time to time to reflect changes in its practice or in the law. The version then in force shall be that published on the Website. Earlier versions shall be made available on written request to hello@2birds.asia.
Governing Law and Enquiries
8.1
This Notice and any matter arising out of or in connection with it shall be governed by and construed in accordance with the laws of the Republic of Singapore.
8.2
Enquiries concerning this Notice, or the practices described herein, may be addressed to the Data Protection Contact at hello@2birds.asia.
Issued for and on behalf of
Twobirds
Practice · Singapore
Data Protection Contact
Keith Ho
Founder · hello@2birds.asia