We recognize our responsibilities in relation to the collection, holding, processing, use and/or transfer of Personal Data (as defined below). Your privacy is of utmost importance to us.
The security of your Personal Data is important to us. At each stage of data collection, use and disclosure, Pontem has in place physical, electronic, administrative, and procedural safeguards to protect the Personal Data stored with us. However, do note that no transmission of Personal Data over the internet can be guaranteed to be 100% secure – accordingly and despite our efforts, Pontem cannot guarantee or warrant the security of any information you transmit to us, or to or from our online services. Pontem shall not have any responsibility or liability for the security of information transmitted via the internet.
This Policy describes how Pontem may collect, use, disclose, process, and manage your Personal Data, and applies to any individual’s Personal Data which is in our possession or under our control.
“Personal data” means data, whether true or not, about an individual who can be identified (i) from that data, or (ii) from that data and other information to which the organization has or is likely to have access. Some examples of Personal Data that Pontem may collect are:
We have pages on social media sites like Instagram, Facebook, Medium, Twitter, YouTube and LinkedIn. When you interact with our social media pages, we will collect Personal Information that you elect to provide to us, such as your personal particulars including contact details (collectively, “Social Information”). In addition, the companies that host our social media pages may provide us with aggregate information and analytics about our social media activity.
Pontem may collect, use and/or disclose your Personal Data for its business purposes, including operations for these purposes. These may include, without limitation, the following:
We may use your Personal Data to offer you products or services, including special offers, promotions, contests or entitlements that may be of interest to you or for which you may be eligible. Such marketing messages may be sent to you in various modes including but not limited to electronic mail, direct mailers, short message service, telephone calls, facsimile and other mobile messaging services. In doing so, we will comply with all applicable data protection and privacy laws.
In respect of sending telemarketing messages to your telephone number via short message service, telephone calls, facsimile and other mobile messaging services, please be assured that we shall only do so if we have your clear and unambiguous consent in writing or other recorded form to do so or if you have not otherwise made the appropriate registration of that number with the Do Not Call Registry. If we have an ongoing relationship with you and you have not indicated to us that you do not wish to receive telemarketing messages sent to your telephone number, we may send you telemarketing messages to that number related to the subject of our ongoing relationship via short message service, facsimile and other mobile messaging services (other than a voice or video call).
You may at any time request that we stop contacting you for marketing purposes via selected or all modes.
To find out more on how you can change the way we use your Personal Data for marketing purposes, please contact us.
Nothing in this section shall vary or supersede the terms and conditions that govern our relationship with you.
We may from time to time and in compliance with all applicable laws on data privacy, disclose your Personal Data to any personnel of Pontem or to third parties (including without limitation banks, financial institutions, credit card companies, credit bureaus and their respective service providers, companies providing services relating to insurance and/or reinsurance to us, and associations of insurance companies, agents, contractors or third party service providers who provide services to us such as telecommunications, information technology, payment, data processing, storage and archival, and our professional advisers such as our auditors and lawyers, and regulators and authorities), located in any jurisdiction, in order to carry out the purposes set out above. Please be assured that when we disclose your Personal Data to such parties, we require them to ensure that any Personal Data disclosed to them are kept confidential and secure.
For more information about the third parties with whom we share your Personal Data, you may, where appropriate, wish to refer to the agreement(s) and/or terms and conditions that govern our relationship with you or our customer. You may also contact us for more information (please see section 1.9 below).
We wish to emphasize that Pontem does not sell Personal Data to any third parties, and we shall remain fully compliant of any duty or obligation of confidentiality imposed on us under the applicable agreement(s) and/or terms and conditions that govern our relationship with you or our customer or any applicable law.
You are responsible for ensuring that the Personal Data you provide to us is accurate, complete, and not misleading and that such Personal Data is kept up to date. You acknowledge that failure on your part to do so may result in our inability to provide you with the products and services you have requested. To update your Personal Data, please contact us (please see section 1.9 below for contact details). Where you provide us with Personal Data concerning individuals other than yourself, you are responsible for obtaining all legally required consents from the concerned individuals and you shall retain proof of such consent(s), such proof to be provided to us upon our request.
We may transfer, store, process and/or deal with your Personal Data in any jurisdiction. In doing so, we will comply with all applicable data protection and privacy laws.
You may set up your web browser to block cookies from monitoring your website visit. You may also remove cookies stored from your computer or mobile device. However, if you do block cookies you may not be able to use certain features and functions of our web sites.
Our websites may contain links to other websites which are not maintained by Pontem. This Policy only applies to the websites of Pontem. When visiting these third-party websites, you should read their privacy policies which will apply to your use of such websites.
Your Personal Data is retained as long as the purpose for which it was collected remains and until it is no longer necessary for any legal or business purposes.
please submit a written request (with supporting documents, (if any) to our Compliance Officer at:
3 FRASER STREET, #05-25, DUO TOWER, SINGAPORE (189352). Our Compliance Officer shall endeavour to respond to you within 30 days of your submission. 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 in a position to continue to provide our services or products to you or administer any contractual relationship in place. Such withdrawal may also result in the termination of any agreement you may have with us. Our legal rights and remedies are expressly reserved in such event.
We may charge you a fee for processing your request for access. Such a fee depends on the nature and complexity of your access request. Information on the processing fee will be made available to you.
To contact us on any aspect of this Policy or your Personal Data or to provide any feedback that you may have, please contact our Compliance Officer at: 3 FRASER STREET, #05-25, DUO TOWER, SINGAPORE (189352).
This Policy and your use of the Website shall be governed and construed in accordance with the laws of Singapore. You agree to submit to the exclusive jurisdiction of the Singapore courts.
We reserve the right to amend this Policy from time to time to ensure that this Policy is consistent with any developments to the way Pontem uses your Personal Data or any changes to the laws and regulations applicable to Pontem. We will make available the updated Policy on the Website. You are encouraged to visit the Pontem Website from time to time to ensure that you are well informed of our latest policies in relation to Personal Data protection. All communications, transactions, and dealings with us shall be subject to the latest version of this Policy in force at the time.
This section applies if you are an individual located in the European Union or European Economic Area. Subject to applicable law, you have the following additional rights in relation to your Personal Data:
If you believe that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your residence, your place of work or the place of the alleged infringement. You may exercise any of your rights in relation to your Personal Data by contacting our Compliance Officer at: 3 FRASER STREET, #05-25, DUO TOWER, SINGAPORE (189352)
This Policy applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your Personal Data by us. We may revise this Policy from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Policy was last updated.
Last updated: July 28, 2023