Data Protection Policy

Last updated on 3 Aug, 2023   

This Privacy Policy applies to the website(s) and mobile applications (together, the “Sites”) provided by Rainmaking Innovation (SG) Pte. Ltd., a company with registered office at 160 Robinson Road, #14-04 Singapore (068914), and the other companies in its group including Rainmaking Innovation Japan LLC (collectively “we”, “us”), and to our processing1 of the personal data2 you share with us when we act as data controllers3.

The Sites include https://rainmakingapac.com/ and additional websites or mobile applications produced and managed by us.  

We know that your privacy is important to you and take user privacy very seriously. We are committed to protecting your personal data in accordance with this Privacy Policy.

We reserve the right, at our sole discretion, to alter and update this Privacy Policy from time to time. We therefore invite you to review the current version of the Privacy Policy each time you return to our Sites.

Some terms are defined throughout this Policy. Simply click on the terms in bold to obtain their definition or refer to the definitions at the bottom of this Policy.

Information we collect and how we use it

Depending on your nature of interaction with us. we might collect personal data from you such as your name, passport or other identification number, nationality, gender, date of birth, marital status, telephone number(s), mailing address, email address, photographs and other audio-visual information, your employment, education and financial information, relationship to us, reason for contacting us, topics you are interested in and any other information you choose to share. By browsing our Sites or sending us information, you explicitly consent to us processing your personal data in accordance with this Privacy Policy. We might use your personal data to fulfil your request, provide services to you and send you marketing communications.

We collect personal data from you when you browse our Sites, request information from us and/or supply information to us, such as when you fill out our form(s), opt in to receive emails from us, agree to participate in surveys, lucky draws or contests, apply for a role with us, or when we receive your personal data from third parties such as, our Approved Training Organisations.

Personal data we collect might include your name, passport or other identification number, nationality, gender, date of birth, marital status, telephone number(s), mailing address, email address, photographs and other audio-visual information, your employment, education and financial information, relationship to us, reason for contacting us, topics you are interested in, any other background information provided with an application or form, and any other information contained in messages you send us.

By browsing our Sites and submitting this information to us (either directly or through a third party), you explicitly agree to us using your personal data for the purposes and in the manner described in this Privacy Policy. Please do not send us any information you do not wish us to use. Please note that this Privacy Policy complements, and does not limit or replace, the purposes for which you provide us with your personal data that may be expressly stated in any application or form for submission of personal data to us.

If you disclose the personal data of any third party to us, you represent that you have obtained the consent of the relevant third party to have their personal data processed by us for the relevant purposes set out in this Privacy Policy.

We will use your personal data for the purposes set out below, any other administrative or operational purposes, and/or as permitted by applicable laws:

  • to fulfil your request; 
  • provide you with the information you requested; 
  • manage your relationship with us; 
  • provide the services requested by you; 
  • enable your use of the services which we provide, including, where necessary, contacting you (whether by SMS, email or otherwise); 
  • perform obligations in the course of or in connection with our provision of the services requested by you; 
  • verification and identification purposes, including verifying your identity when you attend the assessments conducted by us; 
  • enable the Police Licensing Regulatory Department to carry out the necessary licensing for the private security industry; 
  • assist you with your job placement and security clearances when you engage our Business & Employment Services Division; 
  • process your request for a loan or fixed deposit when you approach our Financial Services Division; 
  • evaluative purposes, including processing your job application pursuant to our recruitment activities; 
  • enable your participation in our surveys, lucky draws and contests; 
  • process your payment/interest/reservation of retail items with us; 
  • deal with enquiries made by you; 
  • maintaining and updating of the data; 
  • administrative or operational purposes; 
  • tax filing preparation; 
  • process credit notes and refunds; 
  • collect fees, charges and expenses for services provided; 
  • facilitate the making and payment of claims, including payments by cheque, bank transfers or other means; 
  • carry out billing, accounting, auditing and the maintenance of proper book-keeping to explain our operations and business; 
  • the disclosure of the relevant books, documents, records and information (in hard or soft copy) to the auditors for the preparation of financial reports; and/or 
  • the disclosure of the relevant books, documents, records and information (in hard or soft copy) to the relevant government authorities pursuant to any written law; 
  • comply with any applicable laws, regulations, code of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority; 
  • transmitting to any unaffiliated third parties including our third party service providers and agents, and relevant governmental and/or regulatory authorities world-wide, for the aforesaid purposes; and 
  • any other incidental business purposes related to or in connection with the above. 
  • Send you marketing communications. 
  • If you have applied for a job with us, your data will be processed for the purposes of evaluating and processing your application and candidacy for the position to which you have applied. We may also use your information to analyse and improve our recruiting and onboarding processes. 
  • Communicate with you about our events and to send you publications that we think may be of interest to you.

We may collect personal data and may disclose such information to third party service providers in aggregate for marketing and promotional purposes. However, in these situations, we do not disclose to these entities any information that could be used to personally identify you.

You do not have to provide us with any personal data. However, if you do not, we may be unable to handle your request or to provide you with the services you are requesting.

We will not keep personal data for longer than is necessary to fulfil the purposes for which it was collected, or as required or permitted by applicable laws, and will take reasonable steps to securely dispose of personal data if it is no longer needed.

Please note that we are not responsible for any information you may disclose publicly in any chat rooms, message boards, or similar web pages, including those hosted on or linked to our Sites. You should keep in mind that, whenever you publicly disclose information about yourself online (for example, via message boards or chat rooms), such information could be collected and used by people whom you do not know. In addition, certain message boards and similar user forums may display IP addresses along with the message poster’s name and message. We bear no responsibility for any action or policies of any third parties who collect any information users may disclose on the message boards, chat areas or other user forums, if any, on the Sites.

Who we share your personal data with

We may share your personal data with other companies in our group, as well as, with other third parties that might be located in a different country than your country of residence. We will not share or sell your data to any third party for their own use.

We may share your personal data with others, such as: 

  • other offices in our group – for a complete list of our offices, please refer to  https://rainmakingapac.com/; 
  • third party service providers, agents and other organisations we have engaged, such as marketing service providers (if you have subscribed to our marketing communications), IT systems providers, recruitment service providers, background check providers, data cleansing providers, and event organisers], so they can provide services to us; 
  • our advisors; and 
  • law enforcement authorities or other government bodies when we are required to do so.

Third parties, other than law enforcement authorities or government bodies, will only handle your personal data on our behalf for the purposes described in this Policy. We will not sell or otherwise share your personal data with such third parties for their own use.

The companies in our group and other third parties we share your information with may be located in other countries, including countries that do not offer the same protection to your personal data as the country in which you reside. Where that is the case, we ensure that your personal data is protected by using appropriate legal mechanisms.

Links to other websites

Our Sites may contain links to third party websites that are governed by their own terms and privacy policies. We do not bear any liability and responsibility for the content or your use of these websites.

The Sites may contain links to third party websites, including social network sites. Such websites are governed by their own terms of use and privacy policies, which you should review before browsing or submitting information to them. We are not responsible for the privacy practices of such websites. In addition, a link to a third-party website does not mean that we endorse or accept any responsibility for the content or the use of such a website. We shall not bear any liability and responsibility for such content or for your use of these websites.

Security of your personal data

We have implemented appropriate technical and organisational security measures in order to protect your personal data from loss, misuse, alteration, or destruction.

We have implemented appropriate administrative, physical and technical measures in order to protect your personal data from loss, misuse, alteration, or destruction. Despite these precautions, however, we cannot guarantee that unauthorised persons will not obtain access to your information.

You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures. 

Your Rights

Depending on where you reside you might have the right to request access to, rectification or erasure of your personal data and to object to or ask for the restriction of the processing of your personal data. You might also have the right to withdraw your consent and request that we stop processing or delete your personal data. To exercise your rights, please submit your request by writing to our Data Protection Officer at the contact details provided below.

Depending on where you reside, you may be entitled to certain rights regarding the personal data we hold about you. For instance, you may have the right to request access to your personal data, obtain a copy of it as well as information about how we use it. You have the right to request that we correct or update any of your personal data that we hold. You may also have the right to request that we stop processing your information and/or withdraw your consent to such processing and to ask us to delete your information.

Please write to our Data Protection Officer at the contact details provided below in the following situations:

  • To update us if there are any changes to your personal data. We generally rely on you (or your authorised representative) to ensure that the personal data held by us is current, complete and accurate.
  • In the event that we hold personal data about you and you no longer wish for this data to be processed as described in this Privacy Policy, or if you wish to cancel or oppose such processing. Please be aware that once we receive confirmation that you wish to withdraw your consent, it may take up to ten (10) working days for your withdrawal to be reflected in our systems. During this period of time, your personal data will continue to be processed in accordance with this Privacy Policy. We will inform you of the likely consequences of withdrawing your consent, and that we may no longer be in a position to provide you with our services. Such a withdrawal may therefore, result in the termination of any relationship you have with us. Please note that your withdrawal of consent will not prevent us from exercising our legal rights under applicable laws, or retaining your personal data based on our business needs as deemed legitimate under applicable laws.
  • If you wish to opt out of receiving marketing communications or future emails from us, or unsubscribe from participating in our programs.
  • If you think we are handling your information unlawfully.

        Please note that we will take reasonable steps to check your identity before handling your request. We reserve the right to estimate a fee before processing your request (representing its costs in administering your request) for supplying such information and to refuse requests which, in its opinion, occur with unreasonable frequency.

        Please note that depending on the request that is being made, we will only need to provide you with access to the personal data contained in the documents requested, and not to the entire documents themselves. In those cases, it may be appropriate for us to simply provide you with confirmation of the personal data that we have on record, if the record of your personal data forms a negligible part of the document.

        We will respond to your request as soon as reasonably practicable. Should we not be able to respond to your request within twenty (20) working days after receiving your request, we will inform you in writing within twenty (20) working days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under applicable laws).

        Where not required by applicable laws, we will not provide you with access to, or correct, such information. This may include cases where: 

        • we are satisfied on reasonable grounds that the correction should not be made; 
        • the request for access is frivolous or vexatious or the information requested is trivial; 
        • the personal data is related to a prosecution and all the proceedings related to the prosecution have not been completed; 
        • the personal data, if disclosed, would reveal confidential commercial information that could, in the opinion of a reasonable person, harm the competitive position of the organisation; or 
        • the personal data was collected, used or disclosed for the purposes of an investigation and associated proceedings and appeals have not been completed. 

        Job Applicants

        If you apply for a job with us, you will be asked to submit information to us such as your name, contact details, information about your education and work history and any other background information that might be relevant for your application or that you choose to share with us. If you do not provide this information to us, we might not be able to process your application.

        We will use this information to assess your application and candidacy for the position to which you have applied. Without limiting the generality of the foregoing, this may include: (i) evaluating your skills and experience in relation to the qualification required for the job to which you have applied; and (ii) tracking feedback and interactions we have with you throughout the recruiting process. We may also use your information when analysing our internal recruiting processes to determine (i) which recruit sources to focus on; (ii) how to improve integration and training programs for new hires with different educational backgrounds and work experience; and (iii) how to enhance our interview model to improve hiring quality. The information you provide may also be used to communicate with you about our events and to send you publications that we think may be of interest to you.

        We might share your personal data with other companies in our group, as well as, with third parties such as recruitment service providers, background check providers and IT system providers. Companies in our group and such third parties might be located in a different country than your country of residence. In particular, if you apply for a consulting role, your data will be stored in a third-party database hosted in the Netherlands.

        We will keep your application data for up to five years. If you no longer wish for us to process your data or if you wish to exercise your rights, please contact us at marketing@rainmakingapac.com.

        Children

        Our Sites are not directed at children 16 years of age or younger. We, therefore, will not intentionally collect information about anyone under the age of 16, and requests that no such information be submitted to us.

        Country-specific information

        China

        This section applies to users in the People’s Republic of China (“PRC”) (for the purposes of this Privacy Policy, excluding Hong Kong SAR, Macau SAR, and Taiwan)

        This section applies to you if you are resident in the PRC. The terms set out below are supplemental to, and should be read in conjunction with, the terms in this Privacy Policy. In case of any conflict or inconsistency between the Privacy Policy and this China section, this section shall prevail for residents of the PRC only.

        The data controllers of your personal data are Rainmaking Innovation (SG) Pte. Ltd. & Rainmaking Innovation Japan LLC.

        Reference to personal data used in this section shall include references to sensitive personal information, where applicable, and shall have the same meanings given to those terms in relevant PRC data protection laws (as amended from time to time).

        Information we collect and how we use it

        Unless otherwise permitted by applicable PRC data protection laws, we will obtain consent from you if we wish to use your personal data (and sensitive personal information) for purposes other than those stated in this Privacy Policy.

        Who we share your personal data with

        With your consent, we may from time to time share or disclose your personal data as stated in this Privacy Policy.

        With your consent, we may share, transfer or store your personal data outside of the PRC, as described in this Privacy Policy, where we are satisfied that adequate levels of protection are in place to protect the integrity and security of your personal data or adequate security measures are adopted and in compliance with applicable privacy and data protection laws.

        Your Rights

        You may ask us to provide you with access to, or a copy of, your personal data, or correct the personal data we have about you. In certain circumstances, you may request that we delete your personal data.

        We will obtain your consent prior to sending you any marketing material or conducting any direct marketing activities. You may also withdraw your consent to our processing of your personal data, unsubscribe from receiving marketing information at any time, request to de-register your account, or send us complaints or inquiries about our processing of your personal data.

        Please contact us by writing to our Data Protection Officer at the contact details provided below if you would like to make such requests, or if you have any further questions about your rights and this Privacy Policy.

        Children

        Our Sites are not intended for minors under the age of 16. If you are under the age of 16 you may not use this Site. If you have concerns about your child’s privacy, or if you believe that your child may have provided us with their personal data, please contact us by writing to our Data Protection Officer at the contact details provided below. We will take steps to delete the information as soon as possible should we learn that we have collected the personal data of a child without first receiving verifiable parental consent.

        Changes

        Changes may be made to this Section from time to time. We recommend that you check back regularly for updates to this Section. If there are any changes to this Section which require your consent under applicable law, we will obtain your prior notified consent accordingly.

        USA – California

        If you are a resident of California, you may have additional rights in relation to your personal data.

        As required under the California Consumer Privacy Act (“CCPA”), the categories of personal data (referred to as “personal information” in the CCPA) collected and processed by us, the purposes for which they are processed and the third parties such data is shared with are described in this Privacy Policy.

        We have not sold and do not sell your personal data within the meaning of the CCPA.

        If you are a resident of the State of California, you may have the right to request that we disclose to you: 

        • the categories of personal data we have collected about you; 
        • the categories of sources from which such personal data was collected; 
        • the business or commercial purpose for which we have collected your personal data; 
        • the categories of third parties with whom we share your personal data; and 
        • the specific pieces of personal data we have collected about you. 

          You may also have the right to request that we delete your personal data subject to the limitations of the CCPA.

          If you wish to exercise your rights, please submit your request by writing to our Data Protection Officer at the contact details provided below. We may have to request additional information to verify your identity.

          We will not discriminate against you because you have exercised your rights under the CCPA.

          Contact

          We have designated a Data Protection Officer who will be responsible for ensuring our compliance with applicable data protection laws. If you have any query or request, or wish to make any application concerning your personal data, please contact our Data Protection Officer:

          Contact Person: Lisa Lucas David

          Email: marketing@rainmakingapac.com

          Address: 160 Robinson Road, #14-04 Singapore (068914)

          Please note that if your personal data was provided to us by a third party, you should contact such a party directly to make any queries, feedback, and access and correction requests.