Privacy Policy

Personal Data Protection Notice

We, at Thrilok Gold & Diamonds PTE LTD respect all our clients, visitors, job applicants, suppliers and employees and are committed to safeguarding the personal information you provide to us.

This Data Protection Notice (“Notice”) sets out the basis on which BHIMA GOLD PRIVATE LIMITED (“we”, “us”, or “our”) may collect, use, disclose, or otherwise process personal data in accordance with the Singapore Personal Data Protection (Amendment) Act 2020 (“PDPA”).

This Notice applies to personal data in our possession or under our control, including personal data in the possession of organisations which we may engage to collect, use, disclose, or process personal data for our purposes.

1. COLLECTION OF PERSONAL DATA

1. Under the PDPA, business contact information (e.g. full name, business address, business telephone number) is not considered as personal data so long as it is used strictly for business-to-business (B2B) transactions.

2. Personal information is only collected by lawful and fair means and not collected ‘just in case it may be useful in the future. We conduct regular reviews to ensure that the purposes for which the collection of personal data are still necessary and appropriate.

We collect personal data when you:

Enter into an agreement or contract with us to provide you with our services;
Respond to our electronic direct mails (EDMs) sent by us as part of our services;
Are referred to us for our services by one of our clients;
Enquire about our range of services;
Visit our websites and leave behind contact information through our enquiry email.
Communicate with us via calls, emails, or written correspondences;
Submit your resume and cover letter to us in response to our recruitment advertisements;
While conducting or completing of transactions with us.

3. We may collect, disclose or use your personal data pursuant to an exception under the Personal Data Protection Act or other written law such as during the following situations;

To respond to an emergency that threatens your life, health and safety or that of another individual; and
Necessary in the national interest, for any investigation or proceedings.

In general, subject to the applicable exceptions permitted in the PDPA, before we collect the above personal data from you, we will notify you of the purposes for which your personal data may be collected, used and/or disclosed.

2. HOW DO WE OBTAIN CONSENT?

We respect your privacy and are committed to protecting your personal data in accordance with the Singapore Personal Data Protection Act (PDPA). By using this website, creating an account, or submitting your information to us, you consent to our collection, use, disclosure, and processing of your personal data.

We collect personal data—including but not limited to your name, email address, phone number, billing/shipping address, and payment information—strictly for the following purposes:

· Processing, fulfilling, and managing your orders and transactions.

· Managing and administering your user account.

· Providing customer support and responding to your inquiries.

· Sending promotional materials and updates, subject to your explicit marketing consent. (A pop-up for consent or the same has to be included prior to the Customer agrees to the policy / terms and conditions to proceed further with using the services through Company Website / Online Purchase)

2.1 We will not sell, rent, or trade your personal data to third parties. Your personal data will only be disclosed to trusted third-party service providers, agents, or affiliates necessary to fulfill the purposes listed above (such as payment processors, delivery couriers, and cloud hosting providers). All such third parties are strictly required to maintain the confidentiality and security of your data and are prohibited from using your data for any other purpose.

2.2 You have a choice regarding our collection, use and disclosure of Personal Data. If you choose not to provide us with the personal data described in this Notice, we may not be able to fulfill our contractual duties towards you or facilitate your request or provide the service to you. You have the right to request access to a copy of the personal data we hold about you, request corrections to any inaccuracies, or withdraw your consent to our collection and use of your data at any time. Please note that if you withdraw your consent, we may not be able to continue providing certain services or processing orders for you.

2.3 By providing personal data relating to a third party (e.g. spouse, children, parents, referees and/or employees), the individual shall represent and warrant that prior consent is obtained from such third party for the collection, use or disclosure of personal data.

2.4 We usually obtain consent from you who will be dealing directly with us. If you appoint a representative to provide consent on your behalf, you are required to provide an authorisation letter indicating the appointment. Do include the full name and type of valid document used to prove the identity of the appointed representative in the authorisation letter.

2.5 Under certain circumstances, we may assume deemed consent from you when you voluntarily provide your personal data for the stated purpose, e.g. when seeking our services or applying for a job with us via email. We will not obtain your consent under the PDPA for the collection, use or disclosure of your personal data under the following circumstances.

The personal data is publicly available;
The personal data is disclosed by a public agency or disclosed to a public agency;
The personal data is necessary for any investigation or proceedings;
The personal data is necessary for legitimate interests, including evaluative purposes (e.g. determining the suitability of a job applicant for the job applied for);
The personal data is necessary for the purpose of managing or terminating an employment relationship;
The personal data is necessary for a business asset transaction.
The personal data is necessary for the purpose that is clearly in the interest of the individual or necessary to protect the vital interest of the individual;
The personal data is necessary for business improvement, such as improving, enhancing or developing new goods or services.

3. TYPES OF PERSONAL DATA COLLECTED

3.1 The types of personal data we collect about an individual may include:

Contact information (Full Name, Address, Phone No., Email Address);
Personal details (Full Name, Gender, Country of Birth, Date of Birth, Country of Residence, Citizenship, Nationality);
Personal and professional details contained in the curriculum vitae and cover letter when you apply to us for a job.

4. HOW DO WE USE PERSONAL DATA

4.1 We use the personal data provided to us for one or more of the following purposes;

For services which we may offer to you or that you may request or obtain;
For identification and verification purposes in connection with any of our services that you may request from us;
To facilitate and/or deal with payment for the services provided by us;
Process billing, payment and other credit-related activities;
Conduct direct marketing activities through advertisements and EDMs on events managed by us;
Communicate with clients / potential clients and website visitors;
Respond to inquiries and feedback by an individual to improve our quality of services;
Comply with or fulfil legal obligations and regulatory requirements;

5. How do we manage the Disclosure of Personal Data?

5.1 We disclose some of the personal data provided to us to the following entities or organisations outside our Company in order to fulfil our services to you:

Government Agencies – MOM, CPF Board, IRAS, IMDA, HPB (employees only);
Third parties who require the data in order to complete the service delivery process.

5.2 We will seek fresh consent from you if the original purpose for the disclosure of the personal data has changed. Where required to do so by law, we may disclose personal data about you to the relevant authorities or to law enforcement agencies.

6. How do we handle Requests for Withdrawal of Consent?

6.1 The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you. A request for withdrawal of consent can be made in the form of an email or letter to us.

6.2 You may withdraw consent and request us to stop using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing.

6.3 Upon receipt of your written request to withdraw your consent, we may require a reasonable time depending on the complexity of the request) to process your request and notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within 15 working days of receiving it.

6.4 Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclosure without consent is permitted or required under applicable laws.

7. How do we ensure the Accuracy of Personal Data?

7.1 We will take reasonable steps to ensure that the personal data we collect about you is accurate, complete, not misleading and kept up-to-date.

7.2 If we are in an ongoing relationship with you, it is important that you update us of any changes to your personal data (such as a change in contact number, email and mailing address).

8. How do we Protect Personal Data.

8.1 We have implemented appropriate administrative, physical and technical measures (such as data encryption, firewalls and secure network protocols) to protect the personal data we hold about you against loss; misuse; destruction; unauthorised alteration/modification, access, disclosure; or similar risks.

8.2 We have also put in place reasonable and appropriate organisational measures to maintain the confidentiality and integrity of your personal data. We will only share your data with authorised persons on a 'need to know’ basis.

8.3 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 data and are constantly reviewing and enhancing our information security measures.

9. How do we Retain Personal Data.

Your personal data will be stored securely using reasonable administrative, physical, and technical safeguards (including encryption and secure servers) to prevent unauthorized access, collection, use, or disclosure. We will cease to retain your personal data or remove the means by which the data can be associated with you as soon as the purpose for which that data was collected is no longer being served and retention is no longer necessary for legal or business purposes.

11. How do we manage the Transfer of Personal Data?

Clarify if the host servers /cloud storage is within Singapore or Overseas – Providing the details of the service providers and verify in they are compliant with PDPA Guidelines Singapore.

As part of our online business operations, the personal data we collect from you may be transferred to, and stored or processed on, cloud servers or data centers managed by Amazon Web Services (AWS) located within the Asia-Pacific region (including the AWS Singapore region )

11.1 Our data is stored in the cloud, in the Asia Pacific region, via Microsoft 365 Business Premium, in compliance with the General Data Protection Regulation (GDPR).

12. Use of Cookies

12.1 We may use “cookies” to collect information about your online activity on our website. A cookie is a small text file created by the website that is stored in your computer to provide a way for the website to recognise you and keep track of your preferences. The cookie makes it convenient for you such that you do not have to retype the same information again when you revisit our website.

12.2 Most cookies we use are “session cookies”, which will be deleted automatically from the hard disk of the person computer at the end of the session.

12.3 You may choose not to accept cookies by turning off this feature in your web browser. Note that by doing so, you may not be able to use some of the features and functions in our web applications.

13. Contacting Us.

13.1 You may contact our Grievance officer via email if you have any enquiries, complaints or feedback on our personal data protection policies and procedures, or if you wish to make any requests.

13.2 Our Grievance officer can be contacted via email: grievanceofficer@bhimagold.com

13.3 We treat all enquiries, complaints, feedback and requests seriously and will deal with them confidentially and within a reasonable time.

14. Effect of Notice and Changes to Notice.

14.1 This Notice 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.

14.2 We may revise this Notice 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 Notice was last updated. Your continued use of our services constitutes your acknowledgment and acceptance of such changes.