Personal Data Protection Policy (“Policy”)

• We are an architectural and design firm working in the disciplines of architecture, urbanism, interior design, landscape design, research and branding. We are not in the business of commercialising your personal data. Any collection, use and disclosure of personal data is only incidental to the products and services we offer, and for the performance of our work.
• Nevertheless, here at Spark Architects we are committed to protecting and respecting the privacy of individuals and protecting personal data we may collect, use or disclose.
• This Policy explains how we manage and use the personal data we hold.

What personal data do we collect?

• We generally collect, use and store personal data of the following persons:
  • clients and customers;
  • job applicants and employees (e.g. from resumes or CVs);
  • subscribers to our newsletters;
  • service providers; and
  • other individuals who we may come into contact.
• The personal data we collect, use and store might include your name, email addresses, address, contact information, and any other personal data that you may share with us.
• Data protection laws generally recognise certain categories of personal data to be sensitive personal data and afforded a greater amount of protection. This may include information about your health or religion. We do not usually collect such sensitive personal data about you. If, in the rare instance we intend to collect such sensitive personal data, we will clearly inform you and obtain your consent.

How do we collect your personal data?

• The ways in which we may collect your personal data include collecting directly or indirectly from you or your authorized representatives in the course of:
  • our provision of our products or services to you;
  • you signing up for our newsletters or alerts;
  • you participating in our marketing or promotional events;
  • you contacting us with your queries, requests or feedback;
  • our conducting or completing a transaction;
  • carrying out our obligations under any contracts between you and us;
  • notifying you of changes to our services;
  • you applying for a job with us and providing your resume / CV; or
  • you posting, messaging or interacting with us on social media.

What kind of purposes do we collect your personal data for?

• We may use your personal data for a number of different purposes, which may include all or any of the following purposes:
  • performing obligations in the course of or in connection with the provision of our goods and/or services;
  • verifying your identity;
  • managing your relationship with us and providing customer service;
  • processing payment or credit transactions;
  • sending you newsletters;
  • sending you marketing information about our goods or services including notifying you of our initiatives and promotions, marketing events, and other promotions.
    conducting market research and improving customer service;
  • complying with applicable laws, regulations, rules or guidelines, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
  • any other purposes for which you have provided the information;
  • to monitor and to keep records of our communications with you and our staff; or
  • any other incidental business purposes related to or in connection with the above.
• We will only use, disclose and/or transfer your personal data for the purposes you have been notified of and consented to or which are permitted under applicable laws and regulations.
• The personal data that you may provide to us are on a voluntary basis. However, depending on the circumstance, if you do not provide information about yourself which was requested, the relevant product or service may not be provided to you.
• We do not sell or rent your personal data to third parties.

Who do we share your personal data with?

• In order for us to provide our product or service concerned, or for such other legal or business purposes, personal data may be disclosed or transferred to:
  • our related entities or organisations of Spark Architects;
  • our service providers whom we contract with to provide administrative, legal, financial, accounting or other services;
  • such authorities and other governmental agencies authorised by law to obtain the personal data; or
  • anyone whom you authorise to share the personal data with.
• Where Spark Architects transfers or discloses personal data to our service providers, we require that such organisations maintain the confidentiality of such personal data, and to put in place measures to protect personal data in compliance with the applicable laws and regulations.
• Additionally, where personal data is required to be transferred overseas for the processing of your personal data, we will ensure that suitable safeguards are in place, for example, by using approved contractual agreements, to ensure that your personal data continues to be afforded the same level of protection.

Cookies

• We may use cookies to identify you when you visit our website. A cookie is a small file of letters and numbers sent by a web server to a web browser to enable the server to collect information from the browser, such as your browser type, search preferences or the date and time of your visit of our website.
• You can adjust the setting on your browser to disable all cookies. However if you disable cookies you may not be able to access all functions of our website.

Protection of your personal data

• In order to protect the personal data we hold, we have implemented appropriate security measures to protect such information. This includes the regular training of employees who handle personal data, securing sensitive documents under lock and key, implementing firewalls and virus scans on computerised systems, and such other steps to prevent against misuse, loss, unauthorised access, modification or disclosure of personal data.
• Notwithstanding that we have taken such steps to protect your personal data, you will appreciate that no amount of security can guard against every form of attacks or data breaches. In this regard, we are unable to guarantee absolute security over your personal data, and you will not hold us liable for any unauthorized disclosure, loss or destruction of your personal data arising from such risks.

Retention of your personal data

• We will cease to retain your personal data when we no longer require such personal data for the purposes which we collected such personal data, or for any of our business or legal purposes.

Your choices in relation to the materials provided by us

• You have a choice about whether or not you wish to receive our newsletters or marketing information from us.
• If you do not want to receive any of such materials from us, you can follow the instructions found in each of these materials to unsubscribe or to convey your preference. Alternatively, you may drop us an email at dpo@sparkarchitects.com at any time to indicate your choice in receiving these materials.

Your rights in relation to your personal data

• Depending on the data protection laws that apply, you may have certain rights over the personal data that we hold about you. We generally set these out below for your information.
• If you wish to exercise any of these rights (if they apply to you), please email our Data Protection Officer (“DPO”) of Spark Architects at dpo@sparkarchitects.com, along with proof of your identity. We will endeavour to respond fully to your requests within one month of receipt of your request, or as such other time stipulated under the relevant data protection law.

Your right to access your personal data

• You have a right to request access to the personal data we hold about you, subject to such legal exceptions that may apply.
• Depending on the nature of the request, we may need to charge you a reasonable fee to cover the administrative costs of effecting your request.

Your right to withdraw your consent

• You have the right to withdraw your consent to the collection, use or disclosure of personal data at any time. We will inform you accordingly of the consequences of us acceding to your withdrawal, which may include the complete cessation of our products and services to you.
• Depending on the circumstances, we may require a reasonable time in order to give effect to your request for the withdrawal of consent.

Your right to correct your personal data

• We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us by informing our DPO if there are changes to your personal data.
• We encourage you to contact us as soon as possible in order to update any personal data we may hold about you.

Your right to restrict use of personal data

• You have a right to ask us to restrict the processing of some or all of your personal data if there is a disagreement about its accuracy or we are not lawfully allowed to use it.

Your right to erasure

• You may ask us to delete some or all of your personal data in certain cases. In most of these cases, we will anonymise that information, rather than delete it.

Your right to data portability

• You have the right to receive a copy of your personal data that is subject to processing by Spark Architects in a portable format, or have it transferred directly from Spark Architects to another party.
• Depending on the nature of the request, we may need to charge you a reasonable fee to cover the administrative costs of effecting your request.

Your right to object

• You have the right to object to our processing of personal data for direct marketing purposes. If you make such an objection, we will cease to process your personal data for such purposes.
• You also have the right to object to the processing of personal data for (i) based on our legitimate interests; or (ii) statistical/research purposes. However, do take note that there may be applicable legal exceptions which may allow us to continue to use the personal data notwithstanding the objection made.

Complaint procedure

• If you consider that any action of Spark Architects breaches of the relevant data protection laws or this Policy, you can make a complaint to our DPO by emailing at dpo@sparkarchitects.com. Spark Architects will endeavour to act promptly in response to a complaint.

Children’s personal data

• We are especially concerned about the protection of personal data of children.
• We therefore do not collect any personal data of children that is below 16 or under. However, if there is a need for us to obtain such information, we will obtain the explicit consent from the parent/guardian beforehand.

Changes to Policy

• We may change or update this Policy at any time. The effective date, as stated below, indicates the last time this Policy was materially revised.

Contact us

• If you have queries or concerns regarding this Policy or your personal data held with us, you can contact the Data Protection Officer of Spark Architects at dpo@sparkarchitects.com.

Last updated: 19 June 2018