Privacy Policy

WHO WE ARE

Pacific Impact Development Pte Ltd (Pacific Impact) and its subsidiaries were established to promote the development of private sector infrastructure in developing countries of South Asia and South-East Asia.

This Privacy and Personal Data Protection Policy applies to Pacific Impact, its subsidiaries, affiliates, and any other entities that may be set up in the future to execute development services for its projects in active countries. This includes, but is not limited to, entities such as SPIRE, SPIRE Cambodia, Pacific Impact Energy Corp, Pacific Impact Power Corp, and any other company established by Pacific Impact for the purpose of conducting business activities and operations related to its projects in the Philippines, Cambodia, Singapore, and other active countries. Personal data collected, used, and disclosed by these entities shall be processed in accordance with this policy and all applicable data protection regulations, including the Personal Data Protection Act (PDPA) in Singapore and relevant local laws in other jurisdictions.

WHAT WE DO WITH PERSONAL DATA AND WHY WE COLLECT IT

Pacific Impact respects the confidentiality and security of personal data and the privacy of individuals and is committed to complying with Singapore’s Personal Data Protection Act (2020) (“PDPA”)

We collect and process only the personal data that is necessary to fulfil the specific purpose for which it is collected. Personal data will be kept only for as long as necessary to meet the identified business needs and legal obligations.

Pacific Impact is committed to protecting the confidentiality of personal data and will not share, sell, or rent any personal data for commercial purposes. Any sharing of personal data will only be done in accordance with the terms outlined in this policy, including sharing with third-party service providers or contractors when necessary for operational purposes, in compliance with applicable data protection regulations.

FRAMEWORK AND APPLICABILITY

Pacific Impact collects Personal Data insofar as required in connection with the business and/or the activities conducted by Pacific Impact (including in relation to Pacific Impact business dealings and interactions with Participants). Once there is no business or legal purpose for retaining the Personal Data as referred to in the foregoing, Pacific Impact will delete the Personal Data. Pacific Impact does not collect Personal Data randomly or indiscriminately without purpose. Insofar as is required under the PDPA, this Policy shall be applicable to Pacific Impact Development Pte Ltd (including its directors, officers, employees, companies and projects), and to other participants and organizations (“Participants”) involved with the Pacific Impact Development Pte Ltd companies and/or projects in all jurisdictions, and which shall include the following:

  • Developer – Pacific Impact under a “Developer Services Agreement” (or similar) with respect to the development of a portfolio of projects;
  • Co-Developer – Co-development party contracted with Pacific Impact under a joint development agreement or joint venture agreement (or similar) with respect to the development of a particular project or portfolio of projects;
  • Fund Manager – Fund management party contracted with Pacific Impact under a “Management Services Agreement” (or similar) with respect to the development of a particular project or portfolio of projects;
    • Director, officer, or employee of a Developer;
    • Director, officer, or employee of a Co-Developer; or
    • Director, officer, or employee of a Fund Manager

Pacific Impact, its Developers, Co-Developers and Fund Managers shall be considered for the purposes of this policy as each part of the Pacific Impact Development Pte Ltd Group, within which Pacific Impact Development Pte Ltd shall collect, share and disclose Personal Data, subject to this Policy.

PERSONAL DATA

“Personal Data” as defined in this Policy means any data or information about an individual from which they can be identified.

Examples of Personal Data which an individual may provide include, but is not limited to (depending on the nature of their interaction with Pacific Impact):

  • their name, national identification number (e.g., NRIC number in Singapore) passport number or other identification number, telephone number(s), mailing address, email addresses and any other information relating to them which they have provided Pacific Impact. This includes, but is not limited to, information provided in job applications, investment proposals, customer inquiries, land ownership verification, KYC verification, and shareholder documentation, including when such data is submitted to banks or other financial institutions for compliance with regulatory requirements.

  • information about the individual’s use of our websites and services, including cookies, IP addresses, email subscription and membership details (where applicable). This may also include details on how individuals interact with online content.

  • the individual’s employment related information, including resumé or curriculum vitae, employment history, testimonials and referrals, previous drawn income/income levels, education background, medical history and disabilities and legal and bankruptcy history (if applicable). This may also include information relevant to an individual’s employment eligibility and qualifications, such as background checks; and

  • the individual’s payment related information, such as the individual’s bank account/ credit card details, and/or their credit history. This may also include details for processing payments, verifying financial eligibility, or other financial transactions related to services provided by Pacific Impact.

Sensitive personal data, such as passport or national identification number, health information, financial details, and other special categories of data, will only be collected with explicit consent, when necessary for specific purposes

COLLECTION OF PERSONAL DATA

Pacific Impact will collect personal data only after obtaining the necessary consent, either explicit or implied, depending on the nature of the interaction. Generally, Pacific Impact and its entities collect Personal Data in the following ways:

  • when individuals submit soft or hard copy forms, materials or information to Pacific Impact or relating to Pacific Impact;when individuals register or submit details or provide interactions in connection with websites, communications or online platforms owned or operated by or on behalf of Pacific Impact or any applicable data processors;

  • when individuals use or download Pacific Impact, data controller or data processor information;

  • when individuals interact with Pacific Impact’s employees and staff and/or its Participants and/or applicable data controllers and/or data processors, including during face-to-face meetings, email or by way of the telephone or other means of communication or interaction;

  • when individuals attend stakeholder and community engagement sessions and submit their details on an attendance list

  • when individuals enter into a contract, agreement or arrangement with Pacific Impact or its Participants and/or applicable data controllers and/or data processors;

  • when individuals disclose or establish any online accounts, profiles, communications or interactions with Pacific Impact and/or its Participants and/or applicable data controllers and/or data processors;

  • when individuals submit a request for Pacific Impact and/or its Participants and/or applicable data controllers and/or data processors to contact them;

  • when individuals respond to requests to submit additional Personal Data;

  • when individuals subscribe or ask to be included in an email or other mailing or communications list;

  • when individuals respond to marketing or publicity initiatives;when individuals respond to surveys or questionnaires;

  • when individuals submit applications to Pacific Impact and/or its Participants and/or applicable data controllers and/or data processors (including in relation to job applications, service proposals etc.);

  • when Pacific Impact and/or its Participants and/or applicable data controllers and/or data processors receives references or information from business partners and/or third parties (including, where individuals have been referred);

  • when individuals request that Pacific Impact and/or its Participants and/or applicable data controllers and/or data processors contacts them for any reason;

  • when individuals submit their Personal Data to Pacific Impact and/or its Participants and/or applicable data controllers and/or data processors for any other reason.

Pacific Impact collects personal data for specific, legitimate business purposes, and will only collect data that is necessary to fulfil those purposes. We ensure that the scope of data collected is proportionate to the purposes for which it is collected and avoid unnecessary data collection.

Where individuals provide any Personal Data of a third party (including information of their business partners, shareholders, their dependent, spouse, children and/or parents) to Pacific Impact and/or its Participants and/or applicable data controllers and/or data processors, they represent and warrant that they have obtained the consent of that third party for the collection, use and disclosure of their Personal Data for the purposes set out above.

All individuals should ensure that all Personal Data submitted to Pacific Impact and/or its Participants and/or applicable data controllers and/or data processors is complete, accurate, true and correct. Failure on their part to do so may result in Pacific Impact’s (and/or applicable data controllers’ and/or data processors’) inability to utilise the Personal Data in the way it was intended when submitted.

HOW WE USE YOUR DATA

Pacific Impact and its’ Participants are in the business of infrastructure development across multiple jurisdictions. Accordingly, Pacific Impact and its Participants (and applicable data controllers and/or data processors) generally come into possession of Personal Data in the course of its business, transactions and dealings with potential parties, stakeholders, contractors, vendors, promotors and/or participants in connection with its projects and activities. Without limiting the foregoing, Pacific Impact and/or any of its Participants (and/or applicable data controllers and/or data processors) may collect, use and disclose Personal Data for the following purposes:

  1. to verify the individual’s personal particulars and process transactions or requests;
  2. (to evaluate the proposals for working with Pacific Impact and to conduct relevant investigatory background checks on the individual;
  3. to manage or facilitate business or other transactions (which may extend to any merger, acquisition or sale) or to evaluate proposals, opportunities, projects and business dealings involving Pacific Impact and/or its Participants or in relation the projects/activities they are involved in;
  4. to administer and manage the applicable relationship between the individual and Pacific Impact or any of the Participants and/or applicable data controllers and/or data processors, including the verification of the individual’s identity and/or the identity of the individual’s proxy (as may be applicable);
  5. to communicate Pacific Impact’s codes, policies, procedures, terms and conditions and other information or administrative function (including in relation to any changes or developments or for emergency contacts or business continuity purposes);
  6. to manage Pacific Impact’s and/or the Participants’ business operations and activities, as well as to comply with their other internal policies and procedures;
  7. to inform the individual of Pacific Impact’s performance, activities, projects and/or initiatives (including provision through the sending of circulars, reports, newsletters, communications or the provision of responses to inquiries, marketing, alerts, activity update or publicity materials);
  8. to conduct research for profiling, analysis, statistics and planning;
  9. to update records, including in relation to the databases of Pacific Impact and/or the Participants; monitoring and maintaining a copy of the individual’s record of previous transactions and/or interactions with Pacific Impact and/or the Participants, as applicable;
  10. to collect, use and disclose Personal Data in association with and amongst the Participants or joint-venture or alliance partners for the purposes of furthering the applicable business, transaction and/or dealing to which the Personal Data pertains;
  11. to communicate and respond to the individual’s queries, requests and complaints, if any;
  12. to handle disputes and complaints and conduct and facilitate investigations and proceedings when required;
  13. to protect and enforce Pacific Impact’s and/or Participants’ reputation or their contractual and legal rights and obligations (including in relation to carrying out CCTV surveillance and conducting security clearances and investigatory background checks with third party service providers);
  14. to prevent, detect and investigate crime (including fraud and money- laundering), and to analyze and manage other commercial and/or reputational risks;
  15. to prevent, detect and investigate crime and managing the safety and security (including in relation to carrying out CCTV surveillance and conducting security clearances and investigatory background checks with third party service providers);
  16. to comply with any applicable rules, laws and regulations, codes, policies, procedures, guidelines or schemes;
  17. to assist in law enforcement and investigations by relevant authorities;
  18. in relation to employment, engagement of or contracting with an individual by Pacific Impact and/or a Participant:
    • to evaluate the individual’s suitability, including pre-recruitment checks and checking on provided references for more detailed background screening/vetting;
    • to collect information about the individual’s suitability for the position applied for;
    • to organise training and staff development programs;
    • to maintain and manage employee relations, including annual performance assessments/appraisals;
    • to administer and manage benefits and payment/payroll processing;
    • to provide the individual with the relevant/correct tools as required for the individual to do and carry out their job responsibilities;
  19. in relation to general business, filing, reporting, disclosure or transaction purposes;
  20. for provision to Pacific Impact’s service providers, contractors, communications and online platforms (and/or applicable data controllers or data processors) for the above and/or below mentioned purposes; and
  21. in relation to any related or other purpose.

Additional Purposes
Pacific Impact may also notify individuals of other additional purposes for which Pacific Impact collects, uses or discloses Personal Data that is not specified in this Policy. If so, Pacific Impact will collect, use and disclose Personal Data for these additional purposes as well, unless Pacific Impact has specifically notified the individual otherwise.

From time to time, the individual’s Personal Data may also be disclosed by Pacific Impact to the following third parties outside of Pacific Impact and/or its Participants:

  1. agents, contractors, sub-contractors, third party service providers and specialist advisers contracted by Pacific Impact and/or the Participants to provide administrative, financial, research, operational or other services, such as telecommunications, information technology, payment, payroll, processing, training, market research, investigatory services, storage and archival;
  2. insurers or insurance investigators and credit providers;
  3. In the event of default or disputes, any debt collection agencies or dispute resolution centres;
  4. any business partner, investor, assignee or transferee (actual or prospective) (which may extend to any merger, acquisition or asset sale);
  5. professional advisors such as our auditors and lawyers;
  6. relevant government regulators or authority or law enforcement agencies;
  7. anyone to whom Pacific Impact’s rights and obligations may be transferred;
  8. banks, credit card companies and their respective service providers; and
  9. any other party as may be notified and/or consented to by the individual.

It is Pacific Impact’s general policy that it requires that third party organisations outside of Pacific Impact and/or its Participants which handle or obtain Personal Data, such as external service providers to Pacific Impact, to acknowledge the confidentiality, security and sensitivity of this personal data and undertake to respect any individual’s right to privacy and comply with the PDPA.

The Participants or joint-venture or alliance partners may also collect, use and disclose Personal Data for their own independent purposes, for which the applicable Participants and joint-venture or alliance partners shall be responsible for its relevant collection, usage and disclosure, and its relevant obligations under law and the PDPA, as applicable.

If, in the future, there is a re-organisation in Pacific Impact’s corporate structure, there might be a need to transfer all information to new entities or third parties. All individuals will be notified of this or they would be a prominent notice on the Pacific Impact website.

International Transfers
Personal data may be transferred between countries within the Pacific Impact entities or to third-party service providers, including locations outside of the jurisdiction in which the data was originally collected. In such cases, we will ensure that data is transferred securely and in compliance with applicable data protection laws, including the Personal Data Protection Act (2020)

INTERACTION WITH PACIFIC IMPACT WEBSITE; USE OF COOKIES

Pacific Impact relies predominantly on its website and email mailing list programs, which are used to inform individuals about projects, services and/or news we supply/publish. When individuals interact with Pacific Impact on Pacific Impact’s website and/or communications or online platforms operated on or on behalf of Pacific Impact, certain information will be collected or analyzed.

In the event that cookies or similar tracking technologies are used, we will provide options for managing your preferences. We will seek your consent, as required by applicable data protection laws, and ensure that only data necessary for improving your user experience on our site will be collected.

Depending on the information and/or services that individuals request, they may be asked to provide their name, email addresses and/or other information which will be stored in Pacific Impact’s (and/or applicable data controllers’ and/or data processors’) communications, marketing and/or online platforms. Such platforms may be used to inform individuals about projects, services and/or news that Pacific Impact supplies or publishes. Email marketing messages may contain tracking beacons/tracked clickable links or similar server technologies that can track subscriber activity. Where used, such marketing messages may record a range of subscriber data relating to engagement, geographic, demographics and already stored and/or other subscriber data. Other types of data that may be collected may include information on interests in Pacific Impact communications or events, accessing device type, source, operating system, internet protocol address, browser type, browser version, location, the pages of the Pacific Impact website that are visited, the time and date of any visit, the time spent on those pages and other statistics.Individual preferences for receiving any marketing emails, updates and other information, can be requested to be corrected or deleted by the individual by notifying Pacific Impact that the individual wishes to be ‘unsubscribed’. Unsubscribing can be done by clicking on the word ‘unsubscribe’ in the footer of sent marketing emails or by contacting the Data Protection Officer as set out below.

By using any of Pacific Impact’s services, including interacting with Pacific Impact or accessing Pacific Impact’s websites or online communications, all individuals acknowledge and consent their Personal Data and such other information as described above being obtained and used by Pacific Impact in accordance with this Policy.

THIRD-PARTY WEBSITES

The Pacific Impact website may contain links to other websites operated by third parties (including in relation to the Participants). Pacific Impact is not responsible for the privacy practices of websites operated by third parties that are linked to this website. Pacific Impact encourages all individuals to learn about the privacy policies of such third-party websites. Once each individual has left Pacific Impact’s website, they should check the applicable privacy policy of the third-party website to determine how such websites will handle any Personal Data. Pacific Impact requests all individuals to please contact the owner of any respective third-party websites ((including in relation to the Participants) for answers on any questions on their privacy policies.

KEEPING PERSONAL DATA ACCURATE AND UP-TO-DATE

Pacific Impact endeavors to ensure that Personal Data stored by Pacific Impact is accurate and up to date. Pacific Impact also understands that Personal Data may change frequently, such as changes of address and other personal circumstances. Accordingly, Pacific Impact encourages the individual to contact the Data Protection Officer as set out below to update their Personal Data.

Incomplete or outdated Personal Data may result in Pacific Impact’s inability to provide the individual with products and services they have requested.

ACCESS REQUESTS AND WITHDRAWAL OF CONSENT

Please contact Pacific Impact in writing via its appointed Data Protection Officer as set out below if you wish to seek access to, request a correction to, or withdraw the consent to collect and use, your Personal Data.

All individuals making such requests should identify themselves and state which Personal Data and information about its use and/or disclosure is requested. Pacific Impact may require further information from the requesting individual in order to verify their identity before disclosing any personal information or to ensure that the right information is being removed and/or corrected.

If an individual withdraws their consent to any or all purposes and depending on the nature of their request, Pacific Impact may not be in a position to continue to interact or conduct business or transactions with the individual.

Please note that if an individual’s Personal Data has been provided by a third party or person (e.g. a referrer), the individual should contact that third party or person to make such queries, complaints, and access and correction requests to Pacific Impact on the individual’s behalf.

MANAGEMENT AND PROTECTION

A Data Protection Officer to oversee management of the Personal Data in accordance with this Policy and the PDPA has been appointed by Pacific Impact.

Pacific Impact will, subject to the provisions of applicable law, take reasonable steps to protect Personal Data against unauthorised disclosure. Pacific Impact’s general policy is to ensure that its employees who handle Personal Data appreciate how to respect the confidentiality, security and sensitivity of Personal Data.

Recipients of Pacific Impact Information shall please also note the conditions of receiving information which may be considered confidential and/or privileged and/or subject to copyright material or proprietary rights.

DATA RETENTION

Personal data will be retained only for as long as necessary to fulfil the purposes for which it was collected, in accordance with legal or regulatory requirements. Once the data is no longer needed, it will be securely deleted or anonymized.

HOW TO CONTACT US

If any individual has any questions about this Policy, any complaints relating to their Personal Data or they would like to obtain access, further information and/or make corrections to their Personal Data records (for which Pacific Impact may at its discretion charge a fee to cover the cost of verifying the application and locating, retrieving and copying any material requested), please contact Pacific Impact’s designated Data Protection Officer in writing using the below details:

To:                   Pacific Impact Development Pte Ltd.

Att:                  Data Protection Officer

Contact:          admin@pacificimpactdev.com

REVIEW POLICY

If anyone is unsure whether they are reading the most current version of this Policy, please contact Pacific Impact directly.

This policy will be reviewed periodically to ensure compliance with the PDPA.

Pacific Impact may also from time to time update this Policy to take account of new laws and technology, any changes to Pacific Impact’s operations and practices and the changing business environment. In this regard, individuals should please check and peruse this Policy periodically.