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Privacy Policy

Privacy Policy Last Updated: 16 July 2019

1. This document (“Privacy Policy“) is part of the “Additional Policies” referred to in the Terms of Use, at, as amended from time to time (“TOU“). The Privacy Policy covers the information practices, including how Trusted Services Pte. Ltd. (Company Registration Number: 199101481N), a company incorporated in Singapore and having its address at 456 Alexandra Road Fragrance Empire Building #14-01/02 Singapore 119962 contact e-mail-address:, collects, uses, discloses, processes or handles the personal data that you (as User and on behalf of your Company) may provide in the course of the use of the Board.Vision, or in connection with your dealings with, through, or on the same.

2. All terms in this Privacy Policy shall have the same meaning as in the TOU. Additionally, for the purposes of this Privacy Policy:


(a) “personal data” as referred herein means data, whether true or not, about an individual who can be identified — (a) from that data; or (b) from that data and other information to which we have or are likely to have access (which includes, for avoidance of doubt User Credentials);

(b) “data intermediary” means an organisation which processes personal data on behalf of another organisation but does not include an employee of that other organisation;

(c) “processing” in relation to personal data, means the carrying out of any operation or set of operations in relation to the personal data, and includes any of the following: (a) recording; (b) holding; (c) organisation, adaptation or alteration; (d) retrieval; (e) combination; (f) atransmission; and (g) erasure or destruction; and

(d) “EU GDPR” means General Data Protection Regulation (EU) 2016/679.

3. Except where a different meaning is set out, the terms in this Privacy Policy have the same meaning as in the TOU. This Privacy Policy may be amended or updated from time to time, and the latest version will be posted at and take effect from the date and time of posting.

4. Purposes for which personal data is collected, used, disclosed, processed or handled – In respect of all personal data you provide to us (including on or through Board.Vision), you consent to (and we inform you herewith about) the collection, use, disclosure, processing or handling, by us or, as the case may be, our affiliates (including any data intermediary of ours, related companies or affiliates) of such personal data, for the following purposes (and for the purposes of the EU GDPR, on the legal basis identified expressly below):


(a) responding to your queries, requests and feedback (and in respect of the EU GDPR, based on your respective consent);

(b) to maintain your account with us and process payments or verify your identity / entitlement to use Board.Vision or any part thereof (and in respect of the EU GDPR, based on the need to carry out these activities to perform our obligations under the contract concluded with you);

(c) to provide you with Board.Vision, and certain Third Party Services (and in respect of the EU GDPR, based on our legitimate interest to perform our business);

(d) to complement and supplement the provision of services to you under a separate agreement relating to the preparation of any of the following documents as part of an agreement for the provision by TSV of corporate secretarial services (and in respect of the EU GDPR, based on the need to perform our contractual obligations);

(e) to communicate with you to inform you of changes to Board.Vision, or our policies, terms and conditions and other administrative information (and in respect of the EU GDPR, based on our legal obligations as well as based on our legitimate interest in doing so);

(f) to comply with our obligations under the TOU or enforce our rights under (or in connection with) the same (and in respect of the EU GDPR, based on the need to perform our obligations under the contract concluded with you);

(g) to carry out the specific purpose for which your personal data was volunteered or provided to us (and in respect of the EU GDPR, based on your respective consent declaration);

(h) to comply with any applicable law, judgment, order, code, standard or regulation and participate in (or co-operate with) legal, regulatory or administrative proceedings or directions or to assist in law enforcement and investigations by relevant authorities (and in respect of the EU GDPR, based on our legal obligations);

(i) to protect and safeguard the operation of Board.Vision including preventing, detecting, reporting and supporting / assisting in investigations into any crime (including fraud, theft, money laundering, terrorism misuse or abuse of Board.Vision), cybersecurity incidences or risks, or any of the same where suspected (and in respect of the EU GDPR, based on our legitimate interests);

(j) to conduct or facilitate audits for the purposes of meeting legal requirements, compliance or industry standards, or as may be desirable to enhance the standing, quality, scope and capacity of Board.Vision (and in respect of the EU GDPR, based on our legitimate interests as well as based on our legal obligations);

(k) to manage our infrastructure and business operations and to comply with internal policies and procedures (and in respect of the EU GDPR, based on our legitimate interests as well as based on our legal obligations);

(l) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving any TSV group entity (and in respect of the EU GDPR, and taking into account potential additional legal requirements necessary for any personal data processing in connection therewith);

(m) (only where we have separately obtained your opt-in consent) matching and profiling your user profile to provide you with content, articles and information which may be of interest and relevance to you and to improve your user experience with Board.Vision;

(n) analysing your use of Board.Vision in anonymous form for internal business purposes and to improve Board.Vision;

(o) (only where we have separately obtained your opt-in consent) sending you updates and information which you may have requested; and

(p) such other purposes as may be reasonably related to the above.


5. National Identification Numbers – You may, from time to time, during the course of the use of Board.Vision, be asked to supply your NIN (as User) insofar as its collection is permissible in individual cases under applicable law. Where so, you agree and acknowledge that it is necessary to establish your identity to a high degree of fidelity due to the risk of commercial fraud and for compliance with legal requirements. You will cooperate to give the NIN and will not unreasonably withhold such information without due cause.

6. Consents – The use of Board.Vision, is subject to the condition that you hereby warrant and represent to us that any personal data which has been provided for any purposes stated in this Privacy Policy is with, at all times, full consent of the individual identified by the personal data, such consent not having been revoked except where adequate and reasonable advance notice of the same has been given and duly acknowledged by us. You agree and acknowledge that the withdrawal of any consents may impact the ability to proceed with or use any of Board.Vision including our ability to comply with any obligations under the TOU and such withdrawal of consent will be on the basis that you will release us from any obligations in connection with the same, and that you will indemnify, and hold harmless all Indemnitees from and against any claim, demand, loss, damage, cost, or liability (including reasonable legal fees) which any of the Indemnitees may suffer or suffers in connection with or arising from such withdrawal. NOTE: Where your consent is not required under applicable law, and/or where intended uses of personal data use can be justified by other means/ by other provisions of applicable law, we are entitled to and do exercise the use of such other available bases in place of consent. In such cases, withdrawal of consent shall not affect our rights to process your personal data based on other grounds for justification (e.g. legal obligations, need of processing of personal data for the performance of a contract).

7. Duration of data storage – We store personal data as long as its storage is necessary for the fulfilment of the purposes of its collection, including as specified under the TOU, until the consent for its processing is withdrawn or until we receive an objection to the respective personal data processing and afterwards only for the period of retention required under applicable commercial law, tax law or other applicable laws.

8. Accuracy, Completeness and Updating of personal data – The use of Board.Vision, is subject to the condition that (and you hereby warrant and represent to us that) any personal data has been provided for any purposes stated in this Privacy Policy is, at all times, accurate, complete, and kept up to date by you at all times. You can provide us with updates to any information in accordance with the terms of this Privacy Policy.

9. Your obligations to ensure security and confidentiality – You are solely responsible for maintaining the security and confidentiality of any personal data provided or made available by or through you (including, without limitation, any User Credentials) on your devices, and where any component of Board.Vision is installed or accessed via any device, you agree that you will safeguard the access to the use of the same on that device by applying security measures as may be reasonably appropriate. You are solely responsible for the lawfulness of any transfer of personal data per se via Board.Vision.

10. Your rights – Where available under applicable law, you may have the right to obtain upon request (1) information (free of charge or subject lawfully to a fee) about your personal data processed by us, and to obtain the rectification of inaccurate personal data, (2) to erasure of your personal data, (3) to restriction of the processing of your personal data and (4) to receive your personal data in a manageable format. Where so, we will be guided by applicable law and respond to your requests in accordance with the same.


11. Transfers of your data / Data export – In submitting personal data to us, the personal data may be transferred or exported to locations in other territories outside of your location for the purposes of data processing (as defined above) by third party data intermediaries based on corresponding agreements. We endeavour, in doing so, and in each instance in accordance with applicable laws, require such data intermediaries (as defined above) to comply with all applicable laws and to provide an equivalent standard of protection for such personal data as such personal data would have received had the personal data remained in your territory. Such personal data may be stored in servers operated by third party service providers.

12. Cookies / log files – As with most other websites, we collect and use the data contained in log files. The information in the log files include your internet protocol (“IP“) address, your ISP (internet service provider), the browser you used to visit our site, the time you visited our site and which pages you visited throughout our site. When you visit or interact with our sites, services, we or our authorised service providers may use cookies, web beacons, and other similar technologies for collecting and storing information to help provide you with a better, faster, and safer web experience. Note that:


(a) A cookie is a small file containing a string of characters that is sent to your computer when you visit our websites for record keeping purposes. Cookies are stored in your browser’s file directory, and the next time you visit the website, your browser will read the cookie and relay the information back to the website or element that originally set the cookie.

(b) Depending on the type of cookie it is, cookies may store user preferences and other information, such as how a visitor arrives at our sites, what kind of browser a visitor is on, what operating system a visitor is using, a visitor’s IP address and a visitor’s click stream information and time stamp (for example, which pages they have viewed, the time the pages were accessed and the time spent per web page). There are several types of cookies: (i) Session cookies expire at the end of your browser session and allow us to link your actions during that particular browser session; (ii) Persistent cookies are stored on your device in between browser sessions, allowing us to remember your preferences or actions across multiple sites; (iii) First-party cookies are set by the site you are visiting; and (iv) Third-party cookies are set by a third party site separate from the site you are visiting.

(c) The use of cookies, web beacons and similar technologies by us on our website have different functions. They are either necessary for the functioning of our services, help us improve our performance, or serve to provide you with extra functionalities.

(d) Cookies can be disabled or removed by tools that are available in most commercial browsers. The preferences for each browser you use will need to be set separately and different browsers offer different functionality and options. Deleting cookies does not mean you are permanently opted out of any advertising program. Unless you have settings that disallow cookies, the next time you visit a site running the advertisements, a new cookie will be added.

(e) We offer certain site features and services that are available only through the use of these technologies. You are always free to block, delete, or disable these technologies if your browser so permits. However, if you decline cookies or other similar technologies, you may not be able to take advantage of certain site features or services tools. For more information on how you can block, delete, or disable these technologies, please review your browser settings.

(f) What do we use cookies for?

i. For the purposes set out above in this Privacy Policy;

ii. to help speed up your future browsing activities and boost your overall user experience on Board.Vision;

iii. to enable Board.Vision to operate, for example, cookies that enable you to log onto secure parts of Board.Vision;

iv. to track you as you navigate Board.Vision and to enable the use of any features of Board.Vision; and

v. to personalise Board.Vision for you.


13. Breach reporting – You agree that where you suspect or are aware that there may have been a data breach, you will first notify us of the same in order to provide us with an adequate opportunity, before taking any further action (including but not limited to contacting authorities or resorting to alternative action), as it is first necessary to establish whether a breach has in fact occurred, to determine the cause of the breach, to allow for remedial measures to be applied if applicable. We will conduct an initial investigation and provide you with a response as soon as possible. You agree that all information provided to us concerning the breach by you must be truthful, complete, accurate and timely, and that you will provide reasonable assistance to us to help resolve any issue or clarify any information given. You agree that you will respect our right to protect the rights and confidentiality of information relating to other data subjects, legally privileged communications and that we are entitled to take such legal actions as may be available to us.


14. Queries concerning your personal data – If you have any queries, comments or instructions relating to your personal data or this Privacy Policy, please direct them to our Data Protection Officer at the following addresses:



Address: 456 Alexandra Road #14-01/02

                 Fragrance Empire Building

                 Singapore 119962

Telephone number: (65) 6909 7100

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