Updated: 23 May 2018

Privacy Statement

This Privacy Notice explains how Personal Data (defined below) is collected, used and disclosed by us, TinkerTax LLP, in relation to your access and use of our online Service (the “Service”), which are provided through TinkerTax website and/or web applications (collectively, “Site”). This Privacy Notice applies to all Personal Data collected or submitted to TinkerTax through the use of the Service. By accessing, using and providing us with any Personal Data, you are: (i) expressly consenting and (ii) responsible for obtaining the express consent of your employees or the persons whose Personal Data you are disclosing with respect, to the manner in which we collect, use, disclose and transfer Personal Data as set out below.

Nature of Personal Data Collected

We limit the collection of Personal Data to that which we need to administer and improve the Site, to provide our Service to you, and to fulfill any legal and regulatory requirements.

The categories of Personal Data (collectively, “Personal Data”) that we collect may include, but are not limited to your name and email address.

How Personal Data is Collected

We do not require you to provide any Personal Data in order to have general access to the Site. However, in order to access or use certain information, features or Service, you may be required to provide Personal Data. The circumstances under which Personal Data is primarily collected may include, but are not limited:

1. When you register an account to access and use the Service;
2. When you make payment for the Service;
3. When you enter your email to request for certain information in our website; and
4. When you provide us with comments or suggestions, request information about our Service via phone, email or other forms of communication.

How Personal Data is Used and Disclosed

We use and disclose the Personal Data you provide us to perform the Service you have requested. We limit the purposes for which we use and disclose Personal Data to:

1. Providing the Service to you;
2. Sharing Personal Data with third parties (including related parties of TinkerTax and overseas parties) that may be involved in the delivery of TinkerTax Services to you;
3. Administering and improving the Service which includes the Site;
4. Providing you with information about the Service, new Services or products or upcoming events;
5. Responding to your queries, requests and instructions;
6. Troubleshooting i.e. analysing and solving problems arising from your use of the Service;
7. Complying with legal requirements, the requests of public agencies, law enforcement and regulatory officials, or orders of court;
8. Sending you email notifications;
9. Processing payments you authorize for the Service;
10. Fulfilling any other purposes for which we have obtained your consent.

All financial transactions effected are handled by our service providers which include banks and credit companies, each of whom have their respective privacy notices.

We will not: (a) without your express consent, provide Personal Data to any third parties for the purpose of direct marketing; (b) disclose Personal Data except to those to whom disclosure is necessary to effect the purposes of the Service and who are similarly bound to hold Personal Data in confidence; or (c) disclose Personal Data unless required to do so by law or in the good faith belief that such preservation or disclosure is reasonably necessary to: (i) comply with legal process; (ii) respond to claims that any of the Personal Data or content violates the rights of third parties; or (iii) protect TinkerTax’s rights, property, or personal safety and that of TinkerTax’s customers, users or the public.

Retention Obligations
TinkerTax will retain Personal Data we process on your behalf for as long as is needed to provide the Service to you and your employees. TinkerTax may retain and use Personal Data for as long as necessary as required by law or for other legitimate business purposes including complying withTinkerTax’s legal obligations, resolving disputes, and enforcingTinkerTax’s agreements.

Access and Correction Obligations

You and/or your employees may access, review, update and correct Personal Data through your respective Accounts or by contacting us. TinkerTax shall respond to an access request as soon as reasonably possible and make a correction as soon as practicable. A reasonable fee may be charged by TinkerTax to provide access to archived Personal Data as mentioned above.

Protection Obligations

The security of Personal Data, is very important to TinkerTax. TinkerTax will maintain reasonable security arrangements in respect of Personal Data to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. However, despite such reasonable efforts, we cannot guarantee the security of Personal Data transmitted through the Internet. TinkerTax will implement technical and organizational measures in accordance with good industry practice such as encryption, alphanumeric passwords and user access controls that can be customised according to your preferences. You are solely responsible for keeping all passwords confidential and configuring the appropriate access control settings.

Transfer Obligations

Personal Data may be accessed by or transferred to our servers anywhere in the world, as is necessary to facilitate the provision of the Service by TinkerTax to you. Your Personal Data may also be accessed by or transferred to our affiliates and data processors and/or intermediaries for the purposes of providing you with the Service. When transferring Personal Data outside of your jurisdiction, TinkerTax will take reasonable steps to ensure that the privacy and security of Personal Data is accorded a standard of protection comparable to the protection under your local data protection laws. By providing TinkerTax with Personal Data, you consent (and have obtained the consent of your employees or the persons whose Personal Data you are disclosing) to such transfer and/or access.

Anonymization of Personal Data

TinkerTax may anonymize Personal Data so that the resulting data lacks any means to identify the user (“Anonymized Data”). TinkerTax may use the Anonymized Data for any commercial or non-commercial purpose including but not limited to the following:

1. to aggregate the Anonymized Data with other data;
2. to modify the Anonymized Data (whether aggregated or not) so as to create a derivative work;
3. to publicly publish the Anonymized Data (whether aggregated, modified or not) either directly or indirectly through third parties; and
4. to commercialize the Anonymized Data (whether aggregated, modified or not) by licensing, selling and/or marketing the Anonymized Data (whether aggregated, modified or not) to third parties.

Ownership of the Anonymized Data (including all intellectual property rights), as modified by TinkerTax, shall vest in and be owned absolutely by TinkerTax.

Changes to Privacy Notice

TinkerTax may revise this Privacy Notice from time to time due to legislative changes, changes in technology or our privacy practices or new uses of personally identifiable information not previously disclosed in this Privacy Notice. Material revisions will be effected by posting a notice on the Site prior to the change becoming effective or by sending you an email or other notification. Your continued access and/or use of the Service will indicate your acceptance of those changes. We encourage you to periodically refer to this Privacy Notice for the latest information on our privacy practices.

Contact Information

Questions or comments related to this Privacy Notice and/or complaints should be submitted to the following designated person:

Ng Thiam Hock
[email protected]