Data Protection Policy

This document (“Data Protection Policy”) outlines how IPOS International Pte. Ltd., its affiliates, related organisations, representatives and/or agents (collectively referred to herein as “II”, “us”, “we” or “our”) manages the Personal Data within our possession or control.


The purpose of this Data Protection Policy is to inform you of how II manages Personal Data which is subject to the personal data protection principles under the Singapore Personal Data Protection Act (“PDPA”). Please take a moment to read this Data Protection Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data.


By interacting with us, submitting information to us, or signing up for any products and services offered by us, you agree and consent to II, as well as our respective representatives and/or agents collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to II’s authorised service providers and relevant third parties in the manner and for any of the purposes set forth in this Data Protection Policy. In addition, this Data Protection Policy will also provide you more information on the bases upon which we collect, use and/or disclose your Personal Data without your consent, where permitted by applicable law.


This Data Protection Policy supplements but does not supersede nor replace any other consents you may have previously provided to II in respect of your Personal Data, and your consents herein are cumulative and additional to any rights which II may have at law to collect, use or disclose your Personal Data. This Data Protection Policy does not affect any rights which we may have at law in connection with the collection, use or disclosure of your Personal Data.


II may from time to time update this Data Protection Policy to ensure that this Data Protection Policy is consistent with our future developments, industry trends and/or any changes in legal or regulatory requirements.


We may send you notification of modifications or revisions to this Data Protection Policy in such form as we deem appropriate, including by publishing the modified or revised Policy on our website which may be accessed at, and where required by applicable law, by posting a notice, or reaching you via other forms of communication (e.g. sending you an SMS message or email) according to such contact particulars that we may have of you in our records from time to time. You may also contact us in the manner disclosed in this Data Protection Policy to learn about our handling or processing of your Personal Data.


Subject to your rights at law, you agree to be bound by the prevailing terms of this Data Protection Policy as updated from time to time on our website, and/or as you may be notified. If you are unsure whether you are reading the most current version, please contact us. Please check back regularly for updated information on the handling of your Personal Data.


I. Personal Data


  1. In this Data Protection Policy, “Personal Data” refers to any 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, including data in our records as may be updated from time to time.
  2. Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us) your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address, bank account information and any other information relating to any individuals which you have provided us in any forms you may have submitted to us, or via other forms of interaction with you.


II. Collection of Personal Data


3. Generally, we collect Personal Data in the following ways:

  1. when you submit an application form or registration form, or other forms relating to any of our products and services;
  2. when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our services;
  3. when you interact with our customer service officers, for example, via telephone calls, letters, face-to-face meetings, social media platforms and emails;
  4. when you use our electronic services or interact with us via any of our websites or use services on any of our websites;
  5. when you request that we contact you or request that you be included in an email or other mailing lists;
  6. when you respond to our promotions, initiatives or any request for additional Personal Data;
  7. when your images are captured by us via CCTV cameras while you are within our premises, or via photographs or videos taken by us or our representatives when you attend events at our premises;
  8. when you are contacted by, and respond to, our marketing representatives and customer service officers;
  9. when we receive references from business partners and third parties, for example, where you have been referred by them;
  10. when you fill up surveys administered by our third-party surveying service providers;
  11. when we seek information from third parties about you in connection with the products and services you have applied for; and/or
  12. when you submit your Personal Data to us for any other reason.


4. When you browse our websites, you generally do so anonymously but please see the section below on cookies. We do not, at our websites, automatically collect Personal Data unless you provide such information or login with your account credentials.


5. If you provide us with any Personal Data relating to a third party (e.g. information of your spouse, children, parents, and/or employees), by submitting such information to us, you represent and warrant to us that the collection, use and disclosure of that Personal Data to us, as well as the further processing of that Personal Data by us for the purposes set out below, is lawful, and you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes. 


6. You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. If there is a change to your personal particulars such as your residential/mailing address, email address or telephone number, please promptly update us. This ensures that you will continue to receive communications from us without disruption or delay. Failure on your part to do so may result in our inability to provide you with the products and services you have requested, or processing any requests and applications you may have made to us.


III. Purposes for the Collection, Use and Disclosure of Your Personal Data


7. Generally, II collects, uses and discloses your Personal Data for the following purposes:

  1. responding to your queries, feedback, complaints and requests;
  2. verifying your identity;
  3. managing the administrative and business operations of II and complying with internal policies and procedures;
  4. facilitating business asset transactions (which may extend to any mergers, acquisitions or asset sales) involving II;
  5. matching any Personal Data held which relates to you for any of the purposes listed herein;
  6. requesting feedback or participation in surveys, as well as conducting market research and/or analysis for statistical, profiling or other purposes for us to review, develop and improve the quality of our products and services;
  7. preventing, detecting and investigating crime and analysing and managing commercial risks;
  8. facilities management (including but not limited to maintaining the security of our premises);
  9. managing the safety and security of our premises and services (including but not limited to carrying out CCTV surveillance and conducting security clearances);
  10. monitoring or recording phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation and identity verification purposes;
  11. in connection with any claims, actions or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution), and/or protecting and enforcing our contractual and legal rights and obligations;
  12. conducting investigations relating to disputes, billing or fraud;
  13. meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on II (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies and conducting audit checks, due diligence and investigations);
  14. applying for, managing and processing any funding, grants, disbursements, initiatives, or similar assistance;
  15. managing, processing and administering any payments, disbursements and/or reimbursements;
  16. facilitating and providing opportunities for business development and/or networking;
  17. health and safety management, including safe management measures, social distancing, disease control and prevention, quarantine arrangements, contact tracing and other response measures; and/or
  18. any other purpose related to or reasonably necessary for the aforesaid.

8. In addition to the purposes listed at paragraph 7 above, II collects, uses and discloses your Personal Data for the following purposes, depending on the nature of our relationship with you:

  1. If you are an existing or prospective participant (including an invited speaker or lecturer) of any of II's courses, events and programmes:
    1. providing information on our courses, events and programmes;
    2. administering and conducting information sessions, courses, events and programmes (including facilitating registration, recording attendance, processing payment and refunds for courses, conducting tests and examinations, event budgeting and contacting you for administrative purposes);
    3. assessing and processing any applications or requests made by you for any courses, events and programmes offered by us;
    4. facilitating your applications to other educational institutions which you may apply to;
    5. managing your enrolment in any courses, events and programmes provided by us or any third party;
    6. maintaining an alumni network and organising alumni activities such as information sessions and talks;
    7. creating and maintaining your profile in our system database for internal records and reference;
    8. registering you on member lists (including the IP Management Community of Practice);
    9. providing customer service and support;
    10. administering debt recovery and debt management;
    11. facilitating your use of our online portals;
    12. administering continuing professional development points;
    13. publicity, marketing, and facilitating and providing opportunities for networking between yourself and other existing or prospective participants (including invited speakers or lecturers) of our courses, events and programmes; and/or
    14. taking photograph(s) and/or video(s) of you for (i) internal dissemination within II and (ii) generating publicity materials for our courses, events and programmes; and/or
    15. any other purpose related to or reasonably necessary for the aforesaid.
  2. If you are required to take examinations and tests administered by II, including the IP Knowledge Test (for example if you are an employee of II):
    1. administering the relevant examinations and tests;
    2. notifying you of test details and updates;
    3. facilitating your use of online test portals; and/or
    4. any other purpose related to or reasonably necessary for the aforesaid.
  3. If you have submitted any applications to II and/or IPOS’ registries:
    1. conducting research and surveys on behalf of II; and/or
    2. any other purpose related to or reasonably necessary for the aforesaid.
  4. If you submit an application to us as a candidate for an employment or representative position:
    1. processing your application including pre-recruitment checks, such as in relation to your credit standing and qualifications;
    2. providing or obtaining employee references;
    3. for background screening/vetting or health check-ups;
    4. facilitating and conducting interviews;
    5. assessing your suitability for the position applied for;
    6. entering into an employment relationship with you or appointing you to any office;
    7. communicating with you as required by II to comply with its policies and processes, including for business continuity purposes;
    8. processing staff referrals; and/or
    9. any other purposes relating to or reasonably necessary for any of the aforesaid.

9. Furthermore, where permitted under the PDPA and/or where you have provided your consent to II separately, II may also collect, use and disclose your Personal Data for the following additional purposes:

  1. providing or marketing services, products and benefits to you, including but not limited to special events and promotions from II;
  2. matching Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision, marketing or offering of products and services by II;
  3. administering and organising contests, lucky draws, promotional events, competitions and marketing campaigns, and personalising your experience at II’s touchpoints;
  4. conducting market research, analytics and surveys to enable II to understand and determine customer preferences and demographics for us to offer you products and services as well as special offers and marketing programmes which may be relevant to your preferences and profile; and/or
  5. any other purpose related to or reasonably necessary for the aforesaid.

10. If you have provided your Singapore telephone number(s) and have indicated that you consent to receive marketing or promotional information via your Singapore telephone number(s), then from time to time, II may contact you using such Singapore telephone number(s) (including via voice calls, text, fax or other means) with information about our products and services.

11. In relation to particular products and services or your interactions with II, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.

IV. Disclosure of Personal Data

12. II will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, your Personal Data may be disclosed by II, for the purposes listed above (where applicable), to the following entities or parties, whether they are located overseas or in Singapore:

  1. entities within the II corporate group (for the avoidance of doubt, including without limitation the affiliates and related corporations of IPOS International Pte. Ltd.);
  2. companies providing services relating to medical screening, insurance, marketing and consultancy to II;
  3. agents, contractors or third-party service providers who provide operational services to II, such as courier services, telecommunications, information technology, payment, printing, billing, payroll, processing, technical services, training, market research, call centre, security, employee recognition or other services to II;
  4. agents, contractors or third-party service providers (including but not limited to external tutors and lecturers) who provide services in connection with the courses, programmes and events organised, conducted and administered by II;
  5. our partners or collaborators in our courses, events and programmes (including but not limited to the National University of Singapore);
  6. any business partner, investor, assignee or transferee (actual or prospective) to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving any of II;
  7. external banks, credit card companies and their respective service providers;
  8. our professional advisers such as consultants, auditors and lawyers;
  9. relevant government ministries, regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority;
  10. other existing or prospective participants (including invited speakers or lecturers) of our courses, events and programmes; and
  11. any other party whom you authorise us to disclose your Personal Data to.
V. Deemed Consent

13. In addition to the matters set forth above, subject to and in accordance with applicable law, you shall be deemed to have consented to us collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to our authorised service providers and relevant third parties:

  1. where in response to a request for your Personal Data in connection with identified purposes, you voluntarily provide such Personal Data to us for such purpose(s) and it is reasonable that you would voluntarily provide such Personal Data; or
  2. where the collection, use or disclosure of your Personal Data is reasonably necessary for the conclusion and/or performance of a contract between you and us or us any other organisation entered into at your request, which may include recipients of your Personal Data not indicated in this Data Protection Policy.
VI. Other Bases for Handling or Processing Your Personal Data

14. In addition to and without limiting the consents you have provided to our collection, use and disclosure of your Personal Data for the purposes set out elsewhere in this Data Protection Policy, where permitted by applicable law, we may also in accordance the requirements thereof also collect, use and/or disclose your Personal Data as further detailed below without consent, where we meet the requirements of applicable law:

  1. for our legitimate interests or the legitimate interests of any other person, including but not limited to the purposes expressly set forth in this Data Protection Policy; and
  2. for improving our existing or developing new products, services, methods, processes or business, learning and understanding the preferences and personalising the experiences and recommendations of you or another individual, based on your Personal Data records with us (regardless whether you are an existing or prospective customer).
VII. Third-Party Sites

15. Our website may contain links to other websites operated by third parties, such as our business partners. We are not responsible for the privacy practices of websites operated by third parties that are linked to our website. We encourage you to learn about the privacy policies of such third-party websites. Once you have left our website, you should check the applicable terms, conditions and policies of the third-party website to determine how they will handle any information they collect from you.

VIII. Use of Cookies

16. Our websites and platforms make use of cookies. A cookie is a small piece of information that is placed on your computer when you visit certain websites for record keeping purposes. Cookies are stored in your browser’s file directory, and the next time you visit the website or platform, your browser will read the cookie and relay the information back to the website, platform or element that originally set the cookie.

17. Depending on the type of cookie it is, cookies may store user preferences and other information. The cookies placed by the servers hosting our websites are readable only by us, and cookies cannot access, read or modify any other data on your electronic device, nor does it capture any personal data or data which allows us to identify you individually. Web-browsers generally allow you to block cookies, and if you block the use of cookies on our websites and platforms, we will not gather any information from you using cookies.

18. Should you wish to disable the cookies associated with these technologies, you may do so by changing the setting on your browser. Unless you have adjusted your browser settings to block cookies, our system will issue cookies as soon as you visit our site or click on a link in a targeted email that we have sent you, even if you have previously deleted our cookies.

19. If you do not agree to our use of cookies and other technologies as set out in this Data Protection Policy, you should delete or disable the cookies associated with our websites and platforms by changing the settings on your browser accordingly. However, you may not be able to enter certain part(s) of our website. This may also impact your user experience while on our websites or platforms.

IX. Data Security

20. II will take reasonable efforts to protect Personal Data in our possession or our control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. However, we cannot completely guarantee the security of any Personal Data we may have collected from or about you, or that for example, no harmful code will enter our websites (for example viruses, bugs, trojan horses, spyware or adware). You should be aware of the risks associated with using websites.

21. While we strive to protect your Personal Data, we cannot ensure the security of the information you transmit to us via the Internet or when you use our online portals, and we urge you to take every precaution to protect your Personal Data when you are on the Internet. We recommend that you change your passwords often, use a combination of letters and numbers, and ensure that you use a secure browser.

22. If applicable, you undertake to keep your username and password secure and confidential and shall not disclose or permit it to be disclosed to any unauthorised person, and to inform us as soon as reasonably practicable if you know or suspect that someone else knows your username and password or believe the confidentiality of your username and password has been lost, stolen or compromised in any way or that actual or possible unauthorised transactions have taken place. We are not liable for any damages resulting from any security breaches, on unauthorised and/or fraudulent use of your username and password.

X. Contacting Us – Feedback, Withdrawal of Consent, Access and Correction of your Personal Data

23. If you:

  1. have any questions or feedback relating to your Personal Data or our Data Protection Policy, including without limitation our reliance on legitimate interests and/or deemed consent bases of collecting, using and/or disclosing your Personal Data as described in this Data Protection Policy;
  2. would like to withdraw your consent to any use of your Personal Data as set out in this Data Protection Policy; or
  3. would like to obtain access and make corrections to your Personal Data records (for which we may charge a fee to cover the cost of verifying the application and locating, retrieving and copying any material requested),
  4. you can contact our Data Protection Officer by sending an email to the following e-mail address: [email protected].

24. Please note that if your Personal Data has been provided to us by a third party, you should contact such party directly to make any queries, feedback, and access and correction requests to II on your behalf.

25. You may withdraw your consent given for any or all purposes set out in this Data Protection Policy by contacting our DPO in writing. If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, II may not be in a position to administer any contractual relationship in place, which in turn may also result in the termination of any agreements with II, and your being in breach of your contractual obligations or undertakings. II’s legal rights and remedies in such event are expressly reserved.

26. Without prejudice to the foregoing, you agree and acknowledge any withdrawal of your consents in accordance with the terms set out in this Data Protection Policy will not affect any consent which you may have provided to us in respect of the use of your Singapore telephone number(s) for the receiving of marketing or promotional information, subject to your withdrawal of consent for your receipt of the same.

XI. Governing Law

27. This Data Protection Policy and your use of our website shall be governed in all respects by the laws of Singapore.


(Version as at April 2022)