WTS Taxise

WTS Taxise Privacy Statement

The WTS Group is a global network of tax practices. Taxise Asia LLC and its subsidiary, Taxise Asia Consulting Pte. Ltd (collectively, “WTS Taxise”), are part of the WTS Group. Each member firm of the WTS Group is a legally separate and independent entity. Where services are provided to you by other member firms of the WTS Group, the entity providing the services would be responsible for your personal data. You can find details of the member firms of the WTS Group here.

WTS Taxise is committed to respecting and protecting your privacy and being responsible custodians of the personal data that we collect from you in the course of providing legal and other services to you. This Privacy Statement explains how WTS Taxise uses collects, uses, shares or otherwise processes personal data in the course of operating our business, particularly in relation to our marketing and promotional practices and the operation of our website. This Privacy Statement does not supersede nor replace any consents you may have previously provided to WTS Taxise in respect of your personal data, and your consents herein are additional to any rights to which WTS Taxise may have at law to process your personal data.

1. What data do we collect?

1.1   “Personal data” is any information that relates to you and identifies you either directly from that information or indirectly by reference to other information that we have access to. It does not cover information that is considered anonymous, de-identified or aggregated by applicable law or is available publicly.

1.2   The personal data that we collect, and how we collect it, would depend on how we interact with you. Categories of personal data that we collect include the following:

1. 1. 1. personal identification information – such as name, mailing address, email address, telephone number, social media identifiers and government-issued identification numbers;
      2. professional and education information – such as job title, employer, photographic content including you, professional qualifications, education history, language proficiency and professional membership;
      3. marketing, communication preferences and related information – such as feedback and survey responses;
      4. geolocation – such as city, state, province, prefecture and other sub-national level administrative units and country;
      5. audio and visual information – such as your voice and likeness as captured in photographs, video or audio recordings when you attend our events, visit our office or leave us a voicemail;
      6. health information – such as accessibility requirements and dietary restrictions;
      7. billing and financial information – such as billing address, bank account and payment information;
      8. service information – such as details of services that you have purchased from us; and
      9. other categories of information you choose to provide – such as information relating to race, ethnicity, age, marital status, family, pension or social security membership and military service.

2. What are the grounds for processing your personal data?

2.1   Certain jurisdictions require businesses to have legal grounds for processing personal data. Where applicable laws require WTS Taxise to justify processing activities we have carried out, we would rely on the following grounds:

1. 1. 1. consent – WTS Taxise would obtain your consent to process your personal data for one or more specified purposes, where we are required to do so;
      2. performance of a contract – WTS Taxise may need to collect and use your personal data to enter into a contract with you and/or to perform a contract that you have entered into with us;
      3. legitimate interests – WTS Taxise may use your personal data for our legitimate interests (including that of the delivery and the promotion of our services). WTS Taxise would only rely on legitimate interests where it is fair and reasonable to do so;
      4. legal obligation – WTS Taxise may process personal data as necessary to comply with our legal or regulatory obligations (such as compliance with anti-money laundering regulations and for conflict checking purposes);
      5. legal claims – WTS Taxise may process personal data where it is necessary for the establishment, exercise or defence of legal claims; and
      6. employment relationship – WTS Taxise may use your personal data for deciding whether or not to enter into an employment, contractor, trainee or intern relationship with you if you apply for a position with us. WTS Taxise may also use your personal data for the purposes of performance evaluation or termination of employment.

3. How do we collect your data?

Personal data we collect from you

3.1  Most of the personal data that we collect about you would be information that you provide to us voluntarily. We collect and process data when:

1. 1. 1. you sign up to receive news services – we would ask you to provide your contact and other relevant information, and your communication preferences;
      2. you register to attend one of our in-person or virtual events – we would ask you to provide your contact, guest and other relevant information, including dietary restrictions;
      3. you use our services – we would ask for the information that we need to provide those services, including contact details, billing information, information necessary to conduct anti-money laundering and conflict checks. For avoidance of doubt, such information may include personal data that relates to a third party whose information is relevant to the instruction;
      4. you apply for a job with us – we would ask you for information relevant to your application; and
      5. you visit our office – we may collect information that we need in order to identify you and complete necessary security checks. We may also collect your image on CCTV.

We assume that any personal data you provide to us is accurate, complete and up to date.

3.2  There may be instances where, in the course of providing our services, you may provide us with personal data of third party individuals who are not aware of our involvement or of our processing of their personal data (for example, personal data of employees of a target entity in an acquisition in which you are the acquirer). WTS Taxise would likely not have direct contact with these third party individuals whose personal data we are processing, or it may for other reasons (for example, to maintain confidentiality) not be appropriate for us to provide them with this Privacy Statement setting out how we would process their personal data. If you provide personal data to WTS Taxise about third party individuals, you confirm that you have complied with all relevant legal or regulatory obligations that may apply to your provision of that personal data to us and, in particular, obtained all necessary consents for us to receive and process such personal data.

• Personal data we collect from third parties

3.3  We may also receive your personal data indirectly from the following sources:

1. 1. 1. other member firms of the WTS Group;
      2. our clients whom we are providing services to, when we handle personal data on their behalf;
      3. government authorities; and
      4. publicly available sources of information, such as public social media profiles, publications and other websites or materials available through search engines.

3.4  We would also receive information about you from Google Analytics, a web analytics service provided by Google, Inc. whose servers are in the United States of America.

4. How would we use your data?

4.1  WTS Taxise would only use your personal data fairly and where we have a lawful reason to do so. 

4.2  Our use of your personal data depends on how and where you interact with us. WTS Taxise collects your data for the following purposes: 

Uses of personal data	Our lawful basis for the use of your personal data
To provide news and information services (including email briefings, client updates, marketing communications and other information or material that may interest you) and to invite you to events that we and other member firms of the WTS Group organise.	Where you have consented and expressed a preference to receive such marketing or promotional communications.
To send to you details of surveys, campaigns or other initiatives that we coordinate.	Where you have consented and expressed a preference to receive such marketing or promotional communications.
To operate suppression lists to ensure that you do not receive communications if you object or unsubscribe.	To respect your rights and comply with our legal obligations.
To collect insights into how you interact with our services (including by generating and analysing statistics) so that we can personalise our communications with you and improve our websites and services.	Where you have consented or where it is necessary so that we can deliver our websites and services effectively.
To obtain feedback or references in relation to services provided to you. For example, we may share corporate contact details with legal directories for the purpose of obtaining a refence in relation to services provided to you.	Where you have consented to be contacted for this purpose.
To maintain contact with former employees, former interns and other alumni.	To promote networking and communication between WTS Taxise and its former employees, former interns and other alumni.
To conduct client due diligence and conflict checks when onboarding a new client.	To comply with our legal and regulatory obligations (including compliance with anti-money laundering legislation, fraud and crime prevention).
To provide legal advice and related relevant services, to manage and administer our business relationships (including to communicate with our clients, their employees and representatives, to manage billing and payments and to keep records).	To fulfil our contract with our client(s) and to comply with legal and regulatory obligations (including accounting, tax and data privacy).
To maintain security and manage access to our office, systems and our website.	To comply with legal obligations and because we have legitimate interests in maintaining the security of our office, website and networks.
To enforce our terms of engagement, and other terms and conditions.	To protect our legal interests.
To share personal data in connection with acquisitions and transfers of our business. We may seek to acquire other businesses or merge with them. If a change happens to our business, the part of our business that is sold, acquired or is the merged entity (as the case may be) may use your personal data in the same way as set out in this Privacy Statement.	To comply with legal obligations and to facilitate the transaction.
To manage our supply chain (including identifying and maintaining contact with service providers).	Where necessary for the efficient running of our business.
To comply with our legal obligation to respond to legal process or requests for information issued by government authorities or other third parties, or to protect your, our or others’ rights, to the extent that we believe reasonably necessary or appropriate.	To comply with legal obligations.
To further other purposes that we have identified at the point of collection.	Where you have consented.

4.3  We would only process special category data^[1] where the processing is necessary for the purposes of providing our client with advice regarding obligations or an individual with advice regarding their rights in the field of employment and/or social security, or where it is necessary to do so in order to establish, exercise or defend legal claims.

4.4   We may use anonymous, de-identified or aggregated information that does not reasonably identify you for any purpose, as permitted by applicable law.

Processing your personal data if you are not our client

4.5   If you are not our client, we may need to process your personal data in order to provide services (such as the provision of legal advice) to our client. Your personal data may be provided to us through the course of the matter – for example, provided to us as part of a disclosure process, by another third party, etc. Where this is the case, your personal data may be used in legal proceedings on behalf of our client.

4.6   WTS Taxise would process your personal data in these circumstances as:

• • 1. this is in our legitimate interests, our client’s legitimate interests or those of another third party; and/or

1. 1. 1. we may be required to process that personal data to comply with our legal or regulatory obligations.

5. How do we share and transfer your data?

5.1   WTS Taxise does not sell your personal data and we would not share your personal data with third parties except under the following circumstances:

1. 1. 1. we may disclose your personal data to other member firms of the WTS Group for the purpose of providing our services and to facilitate our internal business processes (such as administration and billing);
      2. we may disclose personal data relating to our clients, their employees and agents to other practitioners (such as advocates and solicitors, mediators, arbitrators, consultants or experts) engaged in a matter. We may also disclose personal data to third party legal practices or tax practices for the purpose of obtaining foreign legal advice; 
      3. we may share personal data with our suppliers and service providers (such as event organisers and partners, document production and management services, and providers of information technology and system administration services to us);
      4. when necessary, we may share personal data with a court of competent jurisdiction, government, taxation or other regulatory authority, or law enforcement agency or similar body. In these circumstances, we would strive to take reasonable effort to notify you before we disclose information that may reasonably identify you, unless prior notice is prohibited by applicable laws or is not possible or reasonable in the circumstances; and
      5. we may share your personal data when you have consented to us doing so.

5.2   We would only transfer your personal data outside of the European Economic Area (“EEA”),^[2] under the following circumstances:

1. 1. 1. where the transfer is to a country or other territory which has been assessed by the European Commission as ensuring an adequate level of protection for personal data; or
      2. with your consent.

5.3   When we provide personal data to parties outside of the EEA, we have in place a transfer agreement in the form approved by the European Commission, and we would comply with any transfer requirements applicable under local laws. 

6. How do we store your data?

6.1   WTS Taxise protects your personal data and implement commercially reasonable administrative, technical and physical safeguards and measures to protect it against unauthorised or unlawful processing and against any accidental loss, destruction or damage. This would include, when required or appropriate and feasible, obtaining written assurances from third parties that may access your personal data that they would protect such information with safeguards and measures designed to provide a level of protection equivalent to those adopted by WTS Taxise.

6.2   We put in place strict confidentiality agreements (including data protection obligations) with our third party service providers.

6.3   Notwithstanding the above, no information system can be 100% secured. We cannot guarantee the absolute security of your personal data. In addition, we would not be responsible for the security of information transmitted to us over networks that we do not control, including the internet and wireless networks.

Data retention

6.4   WTS Taxise would not keep your personal data for any longer than is necessary to fulfil the purposes for which we collected it, to comply with any legal, regulatory, accounting or reporting obligations, or to assert or defend against legal claims.

6.5   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 requirements.

6.6   In some circumstances we may anonymise your personal data – so that it can no longer be associated with you – for our research or statistical purposes, in which case, we may use this information indefinitely without further notice to you.

7.Marketing and promotion 

7.1   WTS Taxise would like to send you information about our services that we think you may be interested in.

7.2   If you have agreed to receive marketing or promotional information from us, you may always opt out at a later date.

7.3   You have the right, at any time, to stop WTS Taxise from contacting you for marketing or promotional purposes. WTS Taxise would not use your personal data to send marketing or promotional information to you if you have requested not to receive such material.

7.4   If you no longer wish to be contacted for marketing purposes, please e-mail to marketing@taxiseasia.com.

8. What are your data protection rights?

8.1   WTS Taxise would like to make sure you are fully aware of all of your data protection rights. You are entitled to the following:

• • 1. the right to access personal data – You have the right, in certain circumstances, to request WTS Taxise for copies of your personal data that we hold about you. We may charge you a small fee for this service. There are exceptions to this right, for example, where information is legally privileged or if providing you with the information would reveal personal data about another person.
    2. the right to have inaccurate personal data rectified – You have the right to request that WTS Taxise correct any information you believe is inaccurate. You also have the right to request WTS Taxise to complete information you believe is incomplete. If you do, we would take reasonable steps to ensure the accuracy of and rectify the information. If we have disclosed the relevant personal data to any third parties, we would take reasonable steps to inform those third parties of the rectification, where possible. Please let us know if any of your personal data changes so that we can keep it accurate and updated;
    3. the right to have personal data erased – You have the right, in certain circumstances, to request that WTS Taxise erase your personal data. There are exceptions to this right, for example, where retention is necessary to comply with any legal, regulatory or reporting obligations, or to assert or defend against legal claims;
    4. the right to restrict processing of personal data – You have the right, in certain circumstances, to block WTS Taxise’s processing of your personal data, so that we can only continue subject to restrictions. This right arises if: (i) you are disputing the accuracy of your personal data; (ii) you have raised an objection to processing; (iii) processing of personal data is unlawful and you oppose erasure and request restriction instead; or (iv) the personal data is no longer required by WTS Taxise but you require the personal data to be retained to establish, exercise or defend a legal claim;
    5. the right to object to processing of personal data – You have the right to require WTS Taxise to stop processing your personal data (including where personal data is used for marketing or promotional purposes, or other purposes more generally). If you withdraw your consent, we may not be able to provide certain services to you;
    6. the right to data portability – You have the right to require that personal data which you have provided to us and which are processed by automatic means, based on your consent or the performance of a contract with you, to be provided to you in machine-readable format so that they can be transferred to a replacement service provider; and
    7. the right not to be subject to automated decisions where the decision produces a legal effect or a similarly significant effect – You have the right not to be subject to a decision which is based on automated processing where the decision would produce a legal effect or a similarly significant effect on you.

8.2   You can exercise the above rights, where applicable, by contacting our Data Protection Officer (“DPO”). Unless otherwise stated, we would not charge you a fee to exercise any of the above rights. However, we may charge a reasonable fee if your request is unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

8.3   If you make a legitimate request, we have one calendar month to respond to you. Occasionally, it may take us longer than one calendar month if your request is particularly complex or you have made a number of requests. In such a case, we would notify you and keep you updated.

8.4   We would require you to provide satisfactory proof of your identity in order to ensure that your rights are respected and protected. This is to ensure that your personal data is disclosed only to you.

9. Links to other websites

9.1   WTS Taxise’s website contains links to other websites. This Privacy Statement applies only to our website, so if you click on a link to another website, you should refer to and carefully review their privacy statement to understand how the operators of that website may process your personal data.

9.2   Please note that WTS Taxise is not, and cannot, control or be responsible for the content or privacy practices of any third party websites (including those of other members firms of the WTS Group).

10. Changes to this Privacy Statement

10.1   WTS Taxise keeps this Privacy Statement under regular review and places any updates on this web page. This Privacy Statement was last updated on [insert date]. Please check back regularly to keep informed of updates to this Privacy Statement.

11. How to contact us

11.1   Whilst WTS Taxise is not required to designate a data protection officer under the European Data Protection Regulation (EU 2016/679) (“GDPR”), WTS Taxise has designated responsibility for overseeing compliance to the GDPR and Singapore Personal Data Protection Act 2012 (Act 26 of 2012) to our DPO.

11.2   If you have any questions about WTS Taxise’s processing of your personal data, or you would like to exercise one of your data protection rights, please do not hesitate to contact our Data Protection Officer at DPO@taxiseasia.com or send a letter to:

Taxise Asia LLC
8 Shenton Way
#36-03
AXA Tower
Singapore 068811

Attention: The Data Protection Officer

12.  How to lodge a complaint

12.1   While we hope that you would not need to, if you wish to lodge a complaint about our processing of personal data please send an email or a letter detailing your complaint to our DPO.

12.2   You also have the right to lodge a complaint with the Personal Data Protection Commission by sending an email to info@pdpc.gov.sg or a letter to:

Personal Data Protection Commission

460 Alexandra Road
#10-02
PSA Building
Singapore 119963

[1] Under Article 9(1) of the GDPR, special categories of personal data refer to “personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and […] genetic data, biometric data for the purpose of uniquely identifying a natural person, data concerning health or data concerning a natural person’s sex life or sexual orientation…”.

[2] The GDPR applies to countries within the EEA. The EEA comprises the post-Brexit 27 member-states of the European Union, Iceland, Liechtenstein and Norway. Note that Switzerland and the United Kingdom are not covered by the GDPR and are accordingly regarded as third countries for GDPR purposes.