Pro-Matrix
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Privacy Policy

1. Introduction

Pro-Matrix and its related corporations, subsidiaries, affiliated entities, and branches operating in Singapore, Malaysia, and Indonesia (collectively, the “Pro-Matrix Group”, “we”, “us” or “our”) are committed to protecting the privacy and security of personal data.

This Privacy Policy describes how we collect, use, process, disclose, transfer, store, retain and otherwise handle personal data in accordance with applicable personal data protection and privacy laws in the jurisdictions where we operate, including Singapore, Malaysia and Indonesia.

By engaging with us, accessing our website, submitting information to us, applying for employment, providing services to us, or otherwise interacting with us, you acknowledge that your personal data may be collected, used, processed, disclosed, transferred and retained by us in accordance with this Privacy Policy and applicable law.

This Privacy Policy forms part of the terms and conditions governing your relationship with the Pro-Matrix Group, where applicable.

2. Scope of this Privacy Policy

This Privacy Policy applies to personal data relating to individuals including but not limited to:

  • customers and prospective customers; 
  • vendors, suppliers, subcontractors, consultants and business partners; 
  • employees, officers and directors; 
  • job applicants and candidates for employment; 
  • visitors to our offices, project sites and premises; 
  • website users and persons who contact or interact with us; and 
  • any other individual whose personal data is provided to us or collected by us in the course of our business operations. 

3. Meaning of Personal Data

“Personal Data” means any data or information, whether true or not, in our possession or control, that relates to an identified individual or an individual who can be identified from that data alone, or from that data together with other information to which we have or are likely to have access.

Depending on the circumstances, Personal Data may include, without limitation:

  • name, NRIC / identity card number, passport number or other identification details; 
  • date of birth, gender, nationality and photograph; 
  • residential or mailing address; 
  • telephone number, mobile number and email address; 
  • employment history, educational background, qualifications and professional certifications; 
  • payroll, salary, tax, CPF / EPF / BPJS or other statutory contribution information; 
  • bank account and payment details; 
  • family or emergency contact information; 
  • signatures and correspondence records; 
  • CCTV footage, visitor logs, security access records and attendance records; 
  • audio or video recordings where permitted by law; 
  • information relating to services provided to or received from us; 
  • transaction records and contractual records; and 
  • any other information reasonably required for our business, operational, employment, legal, compliance, security, safety or administrative purposes. 

Where required or permitted by applicable law, this may also include sensitive or special categories of personal data, such as medical information or other data necessary for employment administration, workplace safety, insurance, benefits administration, legal compliance, or incident management.

4. How We Collect Personal Data

We may collect Personal Data in various ways, including when:

  • you access our website or submit enquiries, requests or feedback to us; 
  • you contact or communicate with us by email, telephone, letter, forms, social media or in person; 
  • you engage us for our products or services, or we engage you for your products or services; 
  • you enter into contracts or other arrangements with us; 
  • you submit a job application, résumé or employment-related information to us; 
  • you are employed by us or provide services to us; 
  • you visit our offices, facilities or project sites; 
  • you participate in meetings, events, training sessions, surveys or business activities organised by us; 
  • you are captured on our CCTV systems or other security systems at our premises; 
  • we conduct due diligence, reference checks, background screening or compliance checks where permitted by law; 
  • your employer, representative, referee, service provider or another authorised third party provides your Personal Data to us; or 
  • you otherwise voluntarily provide your Personal Data to us for any purpose. 

Where required by law, we will obtain consent before collecting, using or disclosing Personal Data. In other circumstances, we may process Personal Data where such processing is necessary or permitted under applicable law, including for contractual, employment, legal, administrative, security, safety or legitimate business purposes.

5. Purposes for Which We Use Personal Data

In general, we may collect, use, process, disclose and retain Personal Data for one or more of the following purposes:

5.1 Customer, Business and Operational Purposes

  • providing our products and services; 
  • responding to enquiries, requests, tenders, quotations and business opportunities; 
  • administering, managing and maintaining our relationship with customers, vendors, consultants, subcontractors and business partners; 
  • processing orders, transactions, invoices and payments; 
  • managing projects, contracts, procurement, operations and service delivery; 
  • maintaining records relating to products, services and commercial transactions; 
  • handling complaints, feedback, disputes, claims and service recovery matters; 
  • conducting business analysis, quality assurance, service review and customer satisfaction surveys; 
  • facilitating business communications and relationship management. 

5.2 Employment and Human Resource Purposes

  • processing job applications and evaluating candidates; 
  • verifying qualifications, references and background information where permitted by law; 
  • administering employment, internships, attachments or consultancy arrangements; 
  • payroll processing, benefits administration, insurance administration and reimbursement processing; 
  • performance management, promotion, training, workforce planning and talent development; 
  • administering leave, travel, claims, attendance and other employment-related matters; 
  • workplace safety, emergency response and employee welfare management; 
  • compliance with statutory and regulatory obligations relating to employment. 

5.3 Legal, Compliance, Safety and Security Purposes

  • complying with applicable laws, regulations, codes of practice and lawful requests from regulatory or governmental authorities; 
  • meeting audit, accounting, tax, reporting, corporate governance and risk management requirements; 
  • detecting, preventing or investigating fraud, misconduct, security incidents or other unlawful or improper activities; 
  • maintaining the safety and security of our people, premises, systems, assets and operations; 
  • monitoring access to offices, facilities and project sites; 
  • supporting legal proceedings, investigations, dispute resolution, claims management and enforcement of our legal rights. 

5.4 Marketing and Corporate Communication Purposes

  • sending corporate updates, invitations, publications, alerts or information about our products, services or events that may be relevant to you; 
  • maintaining mailing or contact lists; 
  • carrying out marketing, business development or corporate communication activities in accordance with applicable law.  

You may opt out of receiving marketing communications from us at any time by contacting us using the contact details set out below or by using the unsubscribe mechanism where available.

5.5 Other Related Purposes

  • any other purpose for which you have provided your Personal Data; 
  • any purpose reasonably related to the above purposes; or 
  • any other purpose permitted or required by applicable law.  

6. Disclosure of Personal Data

We may disclose Personal Data, where necessary and permitted by law, to the following categories of recipients:

  • members of the Pro-Matrix Group, including our subsidiaries, affiliated entities and branches; 
  • our parent company, associated companies or regional / global group entities where relevant to business operations; 
  • customers, clients, principals, developers, consultants, contractors, subcontractors, suppliers and service providers involved in the projects, products or services concerned; 
  • professional advisers, including lawyers, auditors, accountants, tax advisers, insurers, bankers and consultants; 
  • payroll processors, HR service providers, recruitment agencies, IT service providers, cloud service providers, software providers and other administrative or operational support providers; 
  • government agencies, regulators, statutory boards, courts, law enforcement authorities or other public authorities; 
  • counterparties, financiers, insurers or business partners in connection with transactions, claims or business arrangements; 
  • any person to whom disclosure is required or permitted under applicable laws or pursuant to a contractual or legal obligation; and 
  • any other person or organisation with your consent or where otherwise permitted by law.

Disclosure of personal data is limited exclusively to the context of the explicit purpose for which it was provided. We do not sell Personal Data to third parties.

7. Cross-Border Transfer of Personal Data

As the Pro-Matrix Group operates across multiple jurisdictions, your Personal Data may be transferred to, stored in, accessed from, or processed in countries other than the country in which it was originally collected, including within Singapore, Malaysia, Indonesia, and other locations where our group entities or service providers operate.


To meet the requirements of the Transfer Limitation Obligation (TLO) and where Personal Data is transferred across borders, we will take reasonable and appropriate steps to ensure that such Personal Data continues to receive a standard of protection comparable to that required under applicable law. Such steps may include contractual safeguards, internal group policies, access controls, security measures, or other legally recognised transfer mechanisms.

8. Protection of Personal Data

We take reasonable and appropriate administrative, physical and technical measures to protect Personal Data in our possession or under our control against unauthorised access, collection, use, disclosure, copying, modification, disposal, loss, misuse or similar risks.

Such measures may include, where appropriate:

  • restricted access to Personal Data on a need-to-know basis; 
  • password protection and access controls for systems and devices; 
  • secure storage of physical and electronic records; 
  • confidentiality obligations for employees and service providers; 
  • employee awareness and training; 
  • monitoring and security controls for our systems and premises; and 
  • secure disposal or destruction of records when no longer required. 

While we strive to protect Personal Data, no method of transmission or storage is completely secure. Accordingly, we cannot guarantee absolute security.

9. Accuracy of Personal Data

We take reasonable steps to ensure that Personal Data collected and maintained by us is accurate, complete and up to date, having regard to the purposes for which it is to be used.

You are encouraged to inform us promptly if there are changes to your Personal Data so that our records remain accurate and current.

10. Retention of Personal Data

We will retain Personal Data only for as long as it is necessary to fulfil the purposes for which it was collected, or as required or permitted by applicable law.

The period for which we retain Personal Data may vary depending on the nature of the data and the purpose for which it was collected, including business, employment, legal, tax, accounting, audit, regulatory, dispute resolution, safety, insurance or operational requirements.

When Personal Data is no longer required for such purposes, we will take reasonable steps to destroy, delete, anonymise or securely dispose of it in accordance with our internal policies and applicable law.

11. Withdrawal of Consent

Where we rely on your consent to collect, use or disclose your Personal Data, you may withdraw your consent by contacting us using the details set out below.

Upon receiving a request to withdraw consent, we will process the request in accordance with applicable law. Please note that withdrawal of consent may affect our ability to continue providing you with products, services, employment-related administration, or to continue our business relationship with you, depending on the nature and scope of the withdrawal request.

Withdrawal of consent will not affect our right to continue processing Personal Data where such processing is permitted or required by applicable law.

12. Access, Correction and Other Rights

Subject to applicable law, you may request:

  • access to Personal Data we hold about you; 
  • correction or update of inaccurate or incomplete Personal Data; 
  • information about how your Personal Data has been used or disclosed, where applicable; 
  • withdrawal of consent, where consent is the basis of processing; 
  • deletion, erasure, restriction, objection or other rights available under applicable law. 

To protect Personal Data, we may require you to verify your identity before processing your request.

We will respond to such requests within a reasonable period and in accordance with applicable legal requirements. Where permitted by law, we may charge a reasonable administrative fee for processing certain access requests, and will inform you of such fee in advance where applicable.

We may decline a request in whole or in part where we are entitled or required to do so under applicable law.

13. Personal Data Breach Management

We take personal data breaches seriously and have processes in place to assess, manage and respond to suspected or actual personal data breaches.

Where required by applicable law, we will notify the relevant regulatory authority and/or affected individuals of a notifiable personal data breach within the time required by law.

14. Marketing Communications

Where permitted by applicable law, we may contact you by telephone, email, post, text message or other means regarding our products, services, business updates or events that may be of interest to you.

If you do not wish to receive such communications, you may opt out at any time by contacting us or using any unsubscribe option provided in the communication.

Where marketing communications are sent to Singapore telephone numbers, we will comply with applicable Do Not Call requirements and other applicable marketing rules.

15. Website and Online Services

If you visit our website or use our online services, we may collect technical information such as IP address, browser type, device information, access times, referral source, and website usage data for system administration, security, analytics and website improvement purposes.

Where applicable, our website may also use cookies or similar technologies to improve functionality, user experience, analytics or security. You may manage your browser settings to control cookies, subject to system functionality.

If our website contains links to third-party websites, please note that we are not responsible for the privacy practices or content of such external websites.

16. Responsibilities of Individuals Providing Personal Data of Others

If you provide us with Personal Data relating to another individual, you represent and warrant that you have obtained the necessary authority, consent or other lawful basis to provide such Personal Data to us for our collection, use and disclosure in accordance with this Privacy Policy.

17. Contact Details

If you have any questions, feedback, requests or complaints regarding this Privacy Policy or our handling of Personal Data, please contact our Data Protection Officer / designated privacy contact at:

Data Protection Officer
Pro-Matrix Group
Email: dpo@promatrix.sg
Tel: 6873 8680


Where necessary, your request may be directed to the relevant Pro-Matrix entity or country office for handling in accordance with applicable local requirements.

18. Changes to this Privacy Policy

We may amend, update or revise this Privacy Policy from time to time to reflect changes in our business operations, legal or regulatory requirements, or data protection practices.

The latest version of this Privacy Policy will be published on our website or otherwise made available through appropriate channels. Your continued interaction with us after such updates shall constitute your acknowledgment of the updated Privacy Policy, to the extent permitted by law.

19. Governing Interpretation

This Privacy Policy is intended to be interpreted in a manner consistent with the applicable personal data protection and privacy laws of the jurisdictions in which the relevant Pro-Matrix entity operates. In the event of any inconsistency, the applicable mandatory provisions of local law shall prevail to the extent of such inconsistency.

Notes:

For the avoidance of doubt, this Privacy Policy is intended to support compliance with applicable personal data protection laws, including the Personal Data Protection Act 2012 of Singapore, the Personal Data Protection Act 2010 of Malaysia, and Indonesia’s Personal Data Protection (PDP Law) 2022 applicable personal data protection laws, as may be amended from time to time.