Last updated January 24, 2022
INTRODUCTION
Welcome to the Fit for Work Limited’s privacy policy.
Fit For Work Pte. respects your privacy and is committed to protecting your personal data.
This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
This privacy policy is provided in a layered format so you can click through to the specific areas set out below. Please also use the Glossary to understand the meaning of some of the terms used in this privacy policy.
1. [IMPORTANT INFORMATION AND WHO WE ARE]
2. [THE DATA WE COLLECT ABOUT YOU]
3. [HOW IS YOUR PERSONAL DATA COLLECTED]
4. [COOKIES]
5. [HOW WE USE YOUR PERSONAL DATA]
6. [DISCLOSURES OF YOUR PERSONAL DATA]
7 [INTERNATIONAL TRANSFERS]
8. [DATA SECURITY]
9. [DATA RETENTION]
10. [YOUR LEGAL RIGHTS]
11. [GLOSSARY]
12. [CONTROLS FOR DO-NOT-TRACK FEATURES]
13. [DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS]
14. [APPROPRIATE POLICY DOCUMENT]
15. [CONTROLLER FOR YOUR DATA]
PURPOSE OF THIS PRIVACY POLICY
This privacy policy aims to give you information on how Fit For Work collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, purchase a product or service or take part in a competition.
This website is not intended for children, and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data.
This privacy policy supplements other notices and privacy policies and is not intended to override them.
WHO WE ARE:
Fit for Work is made up of different legal entities, details of which can be found here. This privacy policy is issued on behalf of the Fit for Work Group so when we mention “Fit for Work”, “we”, “us” or “our” in this privacy policy, we are referring to the relevant company in the Fit for Work Group responsible for processing your data. We will let you know which entity will be the controller for your data when you purchase a product or service with us. Fit For Work Pte. Ltd. is the controller and responsible for this website.
We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise, see link and please contact us at: info@fitforworksg.com in the first instance. If you are not satisfied with resolving your request, please contact the DPO using the details set out below.
CONTACT DETAILS
Please contact our DPO in the following ways:
Please send your inquiry by post at:
For the attention of:
Stefan Certic
74, South Bridge Road
#02-01
Wong Shee Fun Building,
Singapore 058704
If you are not satisfied with the resolution provided by DPO, you always have the right to make a complaint to your local data protection supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach the DPSA so please contact us in the first instance.
CHANGES TO THE PRIVACY POLICY AND YOUR DUTY TO INFORM US OF CHANGES
We keep our privacy policy under regular review. Historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
THIRD-PARTY LINKS
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any information about criminal convictions and offences.
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.
We will collect and process the following data about you:
Technical Data from the following parties:
Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.
Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our websites, we may collect information from you automatically through cookies or similar technology. We may also use similar tracking technologies (like web beacons and pixels) to access or store information.
For further information, visit allaboutcookies.org.
HOW DO WE USE COOKIES
We use cookies in a range of ways to improve your experience on our website, including:
WHAT TYPES OF COOKIES DO WE USE
There are a number of different types of cookies, however, our website uses:
HOW YOU CAN MANAGE COOKIES
You can set your browser to not accept cookies, and this website (https://allaboutcookies.org)the above website tells you how to remove cookies from your browser. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our website.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Review the Lawful Basis section in the Glossary to find out more about the types of lawful basis that we will rely on to process your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.
PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
| To register you as a new customer | Identity Contact | Performance of a contract with you |
| To process and deliver your order including: Manage payments, fees and charges Collect and recover money owed to us | Identity Contact Financial Transaction Marketing and Communications | Performance of a contract with you Necessary for our legitimate interests (to recover debts due to us) |
| To manage our relationship with you which will include: Notifying you about changes to our terms or privacy policy Asking you to leave a review or take a survey | Identity Contact Profile Marketing and Communications\ Location | Performance of a contract with you Necessary to comply with a legal obligation Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services) |
| To enable you to partake in a prize draw, competition or complete a survey | Identity Contact Profile Usage Marketing and Communications | Performance of a contract with you Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business) |
| To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) | Identity Contact Technical | Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) Necessary to comply with a legal obligation |
| To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you | Identity Contact Profile Usage Marketing and Communications Technical Location Special | Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our website, products/services, marketing, customer relationships and experiences | Technical Usage Profile Location | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
| To make suggestions and recommendations to you about goods or services that may be of interest to you | Identity Contact Technical Usage Profile Marketing and Communications Location | Necessary for our legitimate interests (to develop our products/services and grow our business) |
| To provide you with customized products and services | Profile Data concerning health | Performance of a contract with you Necessary for our legitimate interests (to estimate your needs and provide you with customized ergonomics services) |
MARKETING
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
PROMOTIONAL OFFERS FROM US
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us and you have not opted out of receiving that marketing.
THIRD-PARTY MARKETING
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
OPTING OUT
You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
CHANGE OF PURPOSE
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may share your personal data with the parties set out below for the purposes set out in the table above.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
In Short: We may transfer, store, and process your information in countries other than your own.
Our servers are located in Singapore. If you are accessing our Sites from outside Singapore, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your personal information [link], in and other countries.
If you are a resident in the European Economic Area, please consider that we and many of our external third parties are based outside the EEA so our and their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented :
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We share your personal data within the Fit for Work Group. This will involve transferring your data outside the EEA. We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. These rules are called “binding corporate rules”.
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
In Short: We aim to protect your personal information through a system of organisational and technical security measures.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have implemented appropriate technical and organisational security measures designed to protect the security of any personal information we process. However, please also remember that we cannot guarantee that the internet itself is 100% secure. Although we will do our best to protect your personal information, transmission of personal information to and from our Sites is at your own risk. You should only access the services within a secure environment.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. Most commonly we store personal data within one year of your giving a consent to process your personal data, for example by login or other use of our Sites. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for three years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see below to find out more about these rights; further information can be found in the Glossary:
If you wish to exercise any of the rights set out above, please contact us.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
YOUR LEGAL RIGHTS
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:
Request the transfer of your personal data to you or to a third party.We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
LAWFUL BASIS
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
THIRD PARTIES
INTERNAL THIRD PARTIES
Other companies in the Fit For Work Group and who provide IT and system administration services and undertake leadership reporting.
EXTERNAL THIRD PARTIES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy policy.
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
If you are under 18 years of age, reside in California, and have a registered account with the Sites, you have the right to request removal of unwanted data that you publicly post on the Sites. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Sites, but please be aware that the data may not be completely or comprehensively removed from our systems.
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.
We take serious measures to protect sensitive personal data, especially medical records in compliance with Federal Information Processing Standard Publication (FIPS) 140-2 Level 2 encryption.
This is the “appropriate policy document” for Fit for Work Ltd. setting out how we will protect Special Categories of Personal Data.
Information about you and your health is recorded when you receive our ergonomics services, to help with your care. Information includes:
To the extent that information we collect is health data or another special category of personal data subject to the GDPR, we ask for your explicit consent to process the data. We obtain this consent separately when you take actions leading to our obtaining the data, for example, when you contact our ergonomics consultants. You can use ‘withdraw your consent’ at any time by contacting us at: info@fitforworksg.com.
Accurate assessment of your working conditions requires information about your health, so it’s very important that this information is recorded. But it’s also very personal – so you need to be confident that it’s looked after securely and in line with the law.
WHY WE COLLECT SOME INFORMATION ABOUT YOUR HEALTH
Our main long-term goal is to improve the health and working conditions of employees. To carry out these duties, we need to collect, store, use and sometimes share information about you.
We process specific health data for the following purposes:
SECURITY MEASURES
We take the security of Special Categories of Personal Data very seriously. We have administrative, physical and technical safeguards in place to protect Personal Data against unlawful or unauthorised Processing, or accidental loss or damage. We will ensure, where Special Categories of Personal Data is Processed that:
| No. | Entity | Registration Details |
| 1 | Fit For Work Pte. Ltd. | Registration number 201838625E and registered office address at 74, South Bridge Road #02-01 Wong Shee Fun Building, Singapore 058704, doing business as Fit For Work |
| 2 | Fit For Work Limited | Registration number 671620 and registered office address at Geashill, Ballinlough, Dunshaughlin Co. Meath, Dunshaughlin, Meath. |
If we have let you know that you are purchasing a product or service with Fit for Work Limited located in Ireland (Fit for Work Limited), this entity will be the controller for your data. Please see above for the company’s details.
We can tell you about this before or at the time of processing your order, by reference in any invoice submitted to you, or we will notify you about this at any other time.
From time to time, we may change the controller for your data, but we will include the name of the current controller in the appropriate invoice, or we will notify you otherwise. You can always contact us to know about the name of the entity, which is the current controller for your data.
If Fit for Work Limited is the controller for your data, this privacy policy will apply together with the following terms imposed by Irish laws.
Irish Data Protection Act 2018 (DPA Ireland) allows the processing of special categories of personal data in certain circumstances, as follows.
Personal Data must be processed lawfully, fairly and in a transparent manner in relation to the Data Subject.
We will only process personal data fairly and lawfully and for specified purposes. General Data Protection Regulation ((EU) 2016/679) and DPA Ireland restrict our actions regarding personal data to specified lawful purposes. We can process special categories of personal data only if we have a legal ground for processing and one of the specific processing conditions relating to special categories of personal data applies. We will identify and document the legal ground and specific processing condition relied on for each processing activity.
| Lawful Processing basis | Processing condition for Special Categories of Personal Data |
| Data concerning health Compliance with a legal obligation (Article 6 (1)(c)) or necessary for the performance of a contract with the Data Subject (Article 6(1)(b)). | Necessary for the purposes of performing or exercising obligations or rights which are imposed or conferred by law on the controller or the Data Subject in connection with employment or social welfare law. (Article 46 DPA Ireland). Necessary and proportionate for statistical purposes. (Article 54c DPA Ireland). |
| Duties of employer |
| General duties of the employer include, but not limited to: ensuring the safety, health and welfare at work of his or her employees; and implementing the safety, health and welfare measures necessary for protection of employees, as identified through risk assessments and ensuring that these measures take account of changing circumstances and the general principles of prevention. (Part 2, Section 8 of Safety, Health and Welfare at Work Act 2005). |
Our company aims for dignified and proper working conditions for everyone and is working on an initiative to improve the working conditions of people.
We share your sensitive personal data within the Fir for Work Group. This will involve transferring your data outside the EU.
We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. These rules are called “binding corporate rules”. For further details, please contact us.
You can use ‘withdraw your consent’ to process any special categories of your data at any time by contacting us at: info@fitforworksg.com.