We respect your privacy
PRIVACY POLICY
In The Present Pte. Ltd. (“In The Present” or as appropriate in the context, “we”; “us”; or “our”) is a company that conducts mindfulness programs, which include talks and activities such as the Mindfulness-Based Stress Reduction (“MBSR”) program, meditation and yoga (our “Services”). In The Present also has a presence on the world wide web, at www.inthepresent.sg (referred to as “Website”).
We are committed to safeguarding your privacy. We will collect, use, store and disclose your personal data in accordance with the Personal Data Protection Act ("PDPA") as explained in this document (the "Privacy Policy"). This Privacy Policy is applicable to any data processing implemented by In The Present and any In The Present website.
This Privacy Policy describes the types of Personal Data we may collect from you, how we may use that information, and with whom we may share it. Our Privacy Policy also describes the measures we take to protect the security of the information you provide to us, including without limitation through this Website. We also tell you how you can reach us to update your Personal Data, ask questions you may have about our personal data protection practices and provide feedback on our personal data protection practices.
YOU AGREE AND CONSENT to In The Present as well as our respective agents, authorized service providers and relevant third parties collecting, using, storing, disclosing and/or sharing your personal data in the manner set forth in this Privacy Policy. By submitting your information, signing up, participating and/or attending our programs, class discussions, courses, talks, you are confirming that you are bound by this Privacy Policy. You will be deemed to have read, understood and agreed to the practices and policies outlined in this Privacy Policy and you hereby consent to our collection, use and disclosure of your information as described in this Privacy Policy.
We reserve the right to change modify, add or delete portions of the terms of this Privacy Policy, at our sole discretion, at any time. If you do not agree with this Privacy Policy at any time, do not use any of our Services or give us any of your personal data and/or information.
YOU HEREBY REPRESENT AND WARRANT that all Personal Data you have submitted or will submit to us is complete, accurate, true and correct and you are responsible for keeping your personal data up to date. You acknowledge that failure on your part to do so may result in our inability to provide you with the products and Services you have requested. To update your personal data, please contact our Data Protection Officer.
Where you provide to us personal data concerning individuals other than yourself, YOU HEREBY REPRESENT AND WARRANT that you have obtained all legally required consents, whether explicit or deemed, from the concerned individuals and you shall retain proof of such consent(s), such proof to be provided to us upon our request.
This Privacy Policy supplements (but does not supersede or replace) any other consents which you may have previously provided to us and it does not affect our legal rights concerning the collection, use and/or disclosure of your personal data. Any material changes to our personal data protection practices shall be notified to you.
SECTION 1: TYPE OF PERSONAL DATAGenerally, some of the Services require us to know who you are so that we can best meet your needs. When you complete our pre-assessment forms, enroll in our programs, courses, seminars, events or talks; register for one of our marketing events, complete a payment, access the Services, are employed by us, or through any interaction with us via application or registration forms, emails, telephone calls, short messaging services (“SMS”), texts or other correspondence, we may ask you to voluntarily provide us with certain information that personally identifies you or could be used to personally identify you.
Without prejudice to the generality of the above, information collected by us from you may include (but is not limited to) the following:(a) name, telephone number(s), mailing address, email address and any other information relating to you which you have provided us in any forms you may have submitted to us, in other forms of interaction, or through registration/enrolment on the Website;(b) business contact information from name cards, either through In The Present’s programs, courses, meetings, class discussions, events or talks;(c) comments or assessment feedback on your experience in In The Present’s programs, courses, meetings, class discussions, events or talks;(d) occupational, health, personal history;(e) other information that you voluntarily choose to provide to us on the pre and post-assessment forms;(f) financial information such as bank accounts, credit and debit card details or other payment instrument details;(g)information received by body corporate under lawful contract or otherwise;(h) email and telephone call data records;(i) photographs, video and CCTV footage; and(j) your usage of and interaction with our Website and/or Services including cookies, computer and connection information, device capability, bandwidth, statistics on page views, and traffic to and from our website.
The information collected from you by In The Present may constitute Personal Data under the PDPA.
“Personal Data” is defined under the PDPA to mean any data, whether true or not, about an individual who can be identified from that data or from that data and other information to which an organization has or is likely to have access. This would include, without limitation, information such as name, address, telephone number, e-mail address, credit card details and any other personal information.
In The Present will be free to use, collect and disclose information that is freely available in the public domain without your consent.
Information that is business contact information such as your name, position name or title, business telephone number, business address, business electronic mail address or business fax number and any other similar information about you, which are not provided by you for personal purposes, will not be regarded as Personal Data under the PDPA. Your consent to us collecting, using and disclosing any business contact information will not be required.
SECTION 2: COLLECTION OF PERSONAL DATAPersonal Data may be collected by us through processes including, but not limited to the following:(a) when you submit your registration or pre-assessment form for our MBSR Program;(b) when you submit your registration/enrolment/assessment/application form for any of In The Present’s programs, courses, meetings, class discussions, events or talks via physical copy or online;(c) when you interact with any of our employees;(d) when you respond to In The Present’s request for additional Personal Data;(e) when you ask to be included in an email or other mailing list;(f) when you request that In The Present contact you or when you write to In The Present;(g) when you attend our events or enter our premises, we may take pictures or videos or you may be captured on our closed circuit television cameras surveillance;(h) When you respond to In The Present’s marketing events, initiatives, seminars, surveys or promotions;(i) When you give comments or feedback on our courses, talks, classes, programs and events via evaluation forms given out to you at the end of such course, class, talk, programme and event;(j) when you submit your Personal Data to In The Present for any other reason.
Data collected by automated meansVarious technologies may be used on our Website or our emailing system in order to make it more user-friendly, effective and secure. Such technologies may lead to data being collected automatically by us or by third parties on behalf of us. This data does not generally, but may, contain a user’s personal data. These technologies include but are not limited to cookies, web beacons, tracing links, click stream data and web analytics. You may set up your web browser to block cookies. You may also remove cookies stored from your computer or mobile device. However, if you do block cookies, you may not be able to use certain features and functions of our web sites. Please see Section 7: Additional Privacy Statements for Website Users.
SECTION 3: CONSENT TO COLLECTION OF PERSONAL DATAIn The Present will not collect, use or disclose your personal data unless (a) you give, or are deemed to give, consent to the collection, use or disclosure of your personal data; or (b) the collection, use or disclosure of your personal data without your consent is required or authorized under the PDPA or other written law.
In The Present will not, as a condition of providing a Service to you and/or enabling you to participate in our Services, require you to consent to the collection, use or disclosure of your personal data beyond what is reasonable to provide the service to you and/or enabling you to participate in our Services.
In The Present will not obtain or attempt to obtain your consent for collecting, using or disclosing personal data by providing false or misleading information with respect to the collection, use or disclosure of your personal data, or use deceptive or misleading practices.
As part of our continuous effort to keep you informed on our projects, causes and our Services, we may mail, email, telephone and contact you by any other means. Information sent to you may also include upcoming special events, courses, programs, classes, talks or other relevant information that may be of interest to you. You may also receive mailings or other communications materials from our affiliates and/or carefully selected third parties. You will always have the option to decline any or all of these communications by following the directions included in our emails or other communications, or by contacting In The Present directly via email (see Section 18 below).
In The Present may collect and use personally identifiable information that you volunteer, or other behavioral data and big data generated. In addition to that, permission will be deemed given for communication from us that are necessary to fulfil transactions and services requested by you.
Photographs, videos and CCTV footage may constitute personal data if an identifiable individual is captured. In The Present will either seek your written consent for the collection, use and disclosure of photographs, videos and/or CCTV footage of you, or state in the invitation to you of a program, course, meeting, class discussion, event or talk, that photographs/videos/CCTV footage will be taken at the program, course, meeting, class discussion, event or talk for publicity on In The Present’s print and electronic media. Appropriate and obvious notices will also be put up at the reception or entrance of our program, course, meeting, class discussion, event or talk to inform attendees on the program, course, meeting, class discussion, event or talk day.
SECTION 4: PURPOSES FOR WHICH WE COLLECT AND USE PERSONAL DATAIn The Present may collect, use or disclose your personal data only for purposes (a) that a reasonable person would consider appropriate in the circumstances; and (b) where you have been informed in accordance with this Section 5 of this Privacy Policy, to the extent applicable.
In The Present collects and uses the Personal Data that you provide to us depending on your relationship with us (e.g. as a client, participant, through our Website or other person relating to In The Present).
In GeneralIn general, In The Present may collect, use and/or disclose your Personal Data for the following purposes:(a) maintaining records of MBSR’s interactions with you, through documentation (hard copy and/or electronic);(b) responding to your queries and requests and handling complaints;(c) updating you on developments in In The Present’s Services, and special happenings such as In The Present’s programs, courses, meetings, class discussions, events or talks;(d) managing commercial and financial risks, including preventing, detecting and investigating crime, including fraud and any form of financial crime;(e) assessing and processing any applications, registrations, enrolments, and requests regarding In The Present’s programs, courses, meetings, class discussions, events or talks;(f) establishment and maintenance of relationship with In The Present and/or affiliates of In The Present;(g) marketing and promotion activities of In The Present;(h) taking of photographs and/or videos (whether by In The Present staff or third party photographers and/or videographers) during programs, courses, seminars, events or talks organized by In The Present or its affiliates for publicity purposes;(i) if consented to in the application/enrolment/registration form and/or other methods of consent notification, providing marketing, advertising and promotional information including without limitation promotions, reward programs and sending you details of programs; courses; classes; talks; modules; events; informational and motivational material related to In The Present’s business, via postal mail, electronic mail, SMS or MMS, fax and/or voice calls;(j) if consented to in the application/enrolment/registration form and/or other methods of consent notification, matching your Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision or offering of products and services, whether by In The Present, or other third parties;(k) any other purposes which In The Present may inform you of in writing from time to time, but for which In The Present will seek your separate consent; and(l) any other purposes related to the above purposes.
If you are a program, course, seminar, event or talk attendee/participantIf you are a program, course, meeting, class, event or talk attendee/participant, In The Present may collect, use and/or disclose your Personal Data for the following purposes:(a) assessing your fitness and suitability for any of our programs, course, meeting, class or talk;(b) evaluating your progress as a program, course, meeting, class, event or talk attendee/participant;(c) providing courses and training;(d) videos and images may be used for publicity on In The Present’s newsletters, and social media accounts or platforms; and(e) contacting you for surveys or interviews relating to the above subject matter.
In The Present may also be disclosing the Personal Data that you have provided to us to our affiliates which may be sited locally or outside.
If you have provided your Singapore telephone number(s) and have indicated that your consent to receiving marketing or promotional information via your Singapore telephone number(s), then from time to time, In The Present may contact you using such Singapore telephone number(s) (including via voice calls, SMS, fax or other means) with information about In The Present’s Services and/or your participation, attendance, engagement or otherwise in MBSR’s Services.
SECTION 5: DISCLOSURE OF PERSONAL DATAIn The Present will only disclose Personal Data:(a) for the primary purpose for which it was collected as outlined in Section 4 above;(b) for purposes that a reasonable person will consider appropriate in the circumstances;(c) where you have consented; or(d) where permitted under the PDPA or other applicable law or if required by law.
Subject to applicable laws, In The Present may disclose your personal data for the purposes set out above to parties such as those described below:(a) In The Present’s affiliates which may also include entities and activities overseas;(b) banks, financial institutions, credit card companies, payment gateways and their respective service providers;(c) companies providing services relating to insurance/ reinsurance to us, and associations of insurance companies; and(d) our professional advisers such as our auditors and lawyers.
When In The Present discloses your personal data to third parties, In The Present will ensure that they are contractually bound to protect your personal data in accordance with applicable laws and regulations (as set out in herein), save in cases where your personal data is shared with governmental agencies and regulators, or where your personal data is publicly available, or where use/disclosure of your personal data is otherwise legally mandated and exempted.
If your personal data has to be transferred overseas, In The Present will, where legally required, inform you of the extent to which your personal data will be protected, in the foreign jurisdiction(s) to which it will be transferred.
In addition, In The Present would disclose Personal Data in the following circumstances: (a) in response to a request from law enforcement authorities or other government officials; (b) to comply with a court order or direction from a government agency or regulatory authority ordering the disclosure of the Personal Data; and (c) where the disclosure is necessary for investigations or legal proceedings.
SECTION 6: ADDITIONAL PRIVACY STATEMENTS FOR WEBSITE AND SERVICE USERS6.1 Persons who have visited and submitted pre-assessment forms on the Website (“Subscriber”) Note:This section applies to all Subscribers.(a) As part of the assessment of fitness/suitability of any of MBSR Services, certain information, including Personal Data or sensitive personal information is collected from the Subscribers.(b) All the statements in this Privacy Policy apply to all Subscribers, and all Subscribers are therefore required to read and understand the privacy statements set out herein prior to submitting any Personal Data or sensitive personal information to In The Present, failing which they are required to leave the Website immediately.(c) If you have inadvertently submitted any such information to In The Present prior to reading the privacy statements set out herein, and you do not agree with the manner in which such information is collected, processed, stored, used or disclosed, then you may access, modify and delete such information by using options provided on the Website. In addition, you can, by sending an email to info@inthepresent.sg, inquire whether In The Present is in possession of your Personal Data, and you may also require In The Present to delete and destroy all such information.(d) Subscribers’ personally identifiable information, which they choose to provide on the Website when they sign up, is used to help the Subscribers describe/identify themselves; submit information required for In The Present to provide its Services to Subscribers, and if Subscriber consents, for In The Present to inform Subscriber about any of In The Present’s new courses, programs, classes, talks, services, events and other updates. Other information that does not personally identify the Subscribers as an individual, is collected by In The Present from Subscribers (such as, your computer’s internet protocol (IP) address which provides us with information that helps us learn about your browser and operating system) and is exclusively owned by In The Present. In The Present may also use such information in an aggregated or non-personally identifiable form for research, statistical analysis and business intelligence purposes.(e) The Website uses temporary cookies to store certain data (that is not sensitive personal data or information) that is used by In The Present and its service providers for the technical administration of the Website, research and development, and for Subscriber administration. In the course of serving advertisements or optimizing services to Subscribers, In The Present may allow authorized third parties to place or recognize a unique cookie on the Subscriber’s browser. The cookies however, do not store any Personal Data of the Subscriber. You may adjust your internet browser to disable cookies. If cookies are disabled you may still use the Website, but may be limited in the use of some of the features.(f) In The Present will communicate with the Subscribers through email, telephone, SMSs, text and other forms of messaging. The Subscribers can change their e-mail and contact preferences at any time by sending an email to info@inthepresent.sg.(g) In The Present may keep records of electronic communications received and made for making appointments or other purposes for the purpose of administration of the Services, Subscriber support, research and development.(h) All In The Present employees and data processors, who have access to, and are associated with the processing of sensitive personal data or information, are obliged to respect the confidentiality of every Subscribers’ Personal Data or sensitive personal information.(i) To the extent necessary in doing the Services, In The Present may provide the Personal Data to third party contractors who Services on behalf of or with In The Present to provide Subscribers with such Services, to help In The Present communicate with Subscribers or to maintain the Website. Generally, these contractors do not have any independent right to share this information, however certain contractors who provide services on the Website, including the providers of online communications services, may use and disclose the personal information collected in connection with the Services in accordance with their own privacy policies. In such circumstances, Subscribers consent to us disclosing their personal information to contractors, solely for the intended purposes only.(j) Subscribers may choose to unsubscribe from marketing communications that they receive from In The Present by sending an email to info@inthepresent.sg requesting to unsubscribe.
6.2 Casual Visitors NoteNo sensitive personal data or information is automatically collected by In The Present from any casual visitors of our Website, who are merely perusing the Website. Nevertheless, certain provisions of this Privacy Policy are applicable to even such casual visitors, and such casual visitors are also required to read and understand the privacy statements set out herein, failing which they are required to leave this Website immediately.
If you, as a casual visitor, have inadvertently browsed any other page of the Website prior to reading the privacy statements set out herein, and you do not agree with the manner in which such information is collected, processed, stored, used, disclosed or retained, merely quitting this browser application should ordinarily clear all temporary cookies installed by MBSR. All visitors, however, are encouraged to use the “clear cookies” functionality of their browsers to ensure such clearing / deletion, as In The Present cannot guarantee, predict or provide for the behavior of the equipment of all the visitors of the Website.
You are not a casual visitor if you have willingly submitted any Personal Data or personal information to In The Present through any means, including email, post or through responding to requests on the Website. All such visitors will be deemed to be, and will be treated as, Users for the purposes of this Privacy Policy, and in which case, all the statements in this Privacy Policy apply to such persons.
SECTION 7: SHARING AND TRANSFER OF PERSONAL DATAIn the course of or in connection In The Present’s Services and operations, In The Present may transfer Personal Data to the following parties for the following purposes:(a) To affiliates of In The Present for purposes of expanding the Services;(b) To government and non-government authorities, agencies and/or regulators as required under law or under directions or orders from the government and non-government authorities, agencies and/or regulators for security, regulatory approvals or permits;(c) Financial institutions or payment gateways for purposes of payment processing and transactions related to In The Present’s provision of Services;(d) Professional, financial and legal advisors, tax advisors, auditors, insurers and insurance brokers.However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions. For these providers, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers.
In particular, remember that certain providers may be located in or have facilities that are located a different jurisdiction than either you or us. So if you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located. Once you leave our Website(s) or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy or our website’s Terms of Service.
In The Present requires that the parties to whom we transfer Personal Data and our service providers implement adequate levels of protection in order to protect Personal Data. We also require that these parties only process Personal Data strictly for purposes for which we engage them for and consistent with the purposes that we have described in the Section 4 “Purposes for which we collect and use Personal Data” or with other purposes for which consent has been sought and obtained.
SECTION 8: CONFIDENTIALITY AND SECURITYYour Personal Data is maintained by In The Present in paper or electronic form on its equipment, and on the equipment of its employees. Such information may also be converted to physical form from time to time. In The Present takes all necessary precautions to protect your personal information both online and off-line, and implements reasonable security practices, precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed, including certain managerial, technical, operational and physical security control measures that are commensurate with respect to the information being collected and the nature of In The Present’s business.
In The Present makes all Personal Data accessible to its employees, agents or partners and third parties only on a need-to-know basis, and binds only its employees to strict confidentiality obligations.
Notwithstanding the above, In The Present is not responsible for the confidentiality, security or distribution of your personal information by our partners and third parties outside the scope of our agreement with such partners and third parties. Further, In The Present shall not be responsible for any breach of security or for any actions of any third parties or events that are beyond the reasonable control of In The Present including but not limited to, acts of government, computer hacking, unauthorized access to computer data and storage device, computer crashes, breach of security and encryption, poor quality of internet service or telephone service of the Website user or Subscriber etc.
SECTION 9: AGE OF CONSENTBy using the Website, you represent that you are at least the age of majority in your state or province of residence, or that you are the age of majority in your state or province of residence and you have given us your consent to allow any of your minor dependents to use this site.
In The Present strongly encourages parents and guardians to supervise the online activities of their minor children and consider using parental control tools available from online services and software manufacturers to help provide a child-friendly online environment. These tools also can prevent minors from disclosing their name, address, and other personally identifiable information online without parental permission. Although the In The Present Website is not intended for use by minors, In The Present respects the privacy of minors who may inadvertently use the internet.
SECTION 10: ACCURACYIn The Present will take reasonable efforts to ensure that any Personal Data collected is accurate and up to date by updating its records whenever changes to information come to its attention. In The Present will disregard information which seems, on a reasonable basis, to be inaccurate or out of date by reason of the time which has elapsed since it was collected or by reason of any other information in its possession. To help us maintain the accuracy of your Personal Data, we encourage you to inform us when there are any changes to your Personal Data which you have provided us by writing to our Data Protection Officer. We will correct or complete your Personal Data as set out in Section 12 below. If you have any concerns, feedback or complaints about the use and/or sharing of your Personal Data, you may contact us at info@inthepresent.sg.
SECTION 11: RETENTION OF PERSONAL DATAIn The Present only retains Personal Data for as long as the retention is required for the purposes for which we collected the Personal Data, the purposes described in this Policy and for our business and legal purposes. Generally, we do not retain Personal Data for a period of longer than six (6) years after the original purposes for which the Personal Data was collected have ceased to be applicable, unless otherwise required by law or other mandatory directions by court or government authorities or for purposes of legal proceedings or other similar proceedings or investigations.
For individuals who have submitted their personal data but who do not proceed with the participation or enrolment in any of our programs, courses, meetings, classes, events or talks, In The Present will retain your Personal Data for no longer than 1 (one) year for the purposes of reviewing, evaluating, promoting and/or marketing our programs, courses, meetings, classes, events or talks, unless you inform us otherwise as set out in Section 12 below.
SECTION 12: ACCESS, CORRECTION, UPDATE OR WITHDRAWAL OF PERSONAL DATAYou may request for information from In The Present on what Personal Data of yours we have and how we have used and shared your Personal Data during the last one (1) year before the date of your request; or withdraw your consent to our continued use and disclosure of your Personal Data; or seek access to your Personal Data (to a reasonable extent and as permitted by the Act) at any time by writing to our Data Protection Officer. You may also withdraw your consent for specific forms of communication and on specific communications via the unsubscribe options as stated on our email or other marketing messages.
We will endeavor to acknowledge the receipt of your request within 5 working days after the date of receipt of your request if it is sent by e-mail, or within 10 working days after the date of receipt of your request if it is sent by post. We will carry out your request within 14 days from the date of acknowledgement. Please note that it may take up to 30 working days for any request for consent withdrawal to be reflected in our systems. As it is important to us that the Personal Data that we have about you is accurate and complete, it may be necessary for us to request for supporting documentation from you. We will contact you if we require supporting documentation from you.
In withdrawing your consent, you acknowledge that we may not be able to provide or continue providing certain Services to you and that we may cease such provision accordingly without any liability.
There may be circumstances where In The Present will not correct, delete or update your Personal Data, including: (a) where the Personal Data is opinion data that is kept solely for evaluative purpose; and (b) the Personal Data is in documents related to a prosecution if all proceedings relating to the prosecution have not been completed.
In The Present shall have the right to request for information for the purposes of verification of your identity and for more information about your request. In The Present will charge a reasonable administrative fee to respond to the request set out above.
SECTION 13: TRANSFER OF PERSONAL DATA OUTSIDE OF SINGAPORECertain In The Present’s vendors, or service providers may be operating outside Singapore. By providing information to us through our enrolment/registration/participation forms at our programs, courses, classes, talks; use of our Website or otherwise, you are consenting to the transfer of that information to be processed and used in accordance with the terms of this Privacy Policy. In such a situation, In The Present will ensure that the Personal Data so transferred will be accorded a standard of protection comparable to the protection provided under the PDPA.
SECTION 14: DO NOT CALL PROVISIONSIn The Present will not be sending any specified messages and/or otherwise marketing communications through SMS, text or phone calls. If you have provided your Singapore telephone number(s), then from time to time, In the Present may contact you using such Singapore telephone number(s) (including via voice calls, text, or other means) including, among other things, with information reasonable for us to provide our Services to you and/or enabling you to participate in our Services.
SECTION 15: CHANGES TO THIS PRIVACY POLICYIn The Present may update this Privacy Policy at any time, with or without advance notice. In the event there are significant changes in the way In The Present treats your personally identifiable information, or in the Privacy Policy itself, In The Present will display a notice on the Website or send you an email, as provided for above, so that you may review the changed terms prior to continuing to use the Services. As always, if you object to any of the changes to our terms, and you no longer wish to use the Services, you may contact info@inthepresent.sg. Unless stated otherwise, In The Present’s current Privacy Policy applies to all information that In The Present has about you and/or your account. If a Website user or Subscriber uses the Services; or accesses the Website after a notice of changes has been sent to such user or Subscriber, or published on the Website, such user or Subscriber hereby provides his/her/its consent to the changed terms.
SECTION 16: HOW TO CONTACT USShould you have questions about this Privacy Policy or In The Present's information collection; use and disclosure practices, or if you would like to access, correct, amend or delete any personal information we have about you; register a complaint; or simply want more information, please contact us at info@inthepresent.sg. We will use reasonable efforts to respond promptly to any requests, questions or concerns, which you may have regarding our use of your personal information. If you have any grievance with respect to our use of your information, you may communicate such grievance to:
In The Present Pte. Ltd.Email: info@inthepresent.sgEffective date: 01 January 2017Copyright 2016
PRIVACY POLICY
In The Present Pte. Ltd. (“In The Present” or as appropriate in the context, “we”; “us”; or “our”) is a company that conducts mindfulness programs, which include talks and activities such as the Mindfulness-Based Stress Reduction (“MBSR”) program, meditation and yoga (our “Services”). In The Present also has a presence on the world wide web, at www.inthepresent.sg (referred to as “Website”).
We are committed to safeguarding your privacy. We will collect, use, store and disclose your personal data in accordance with the Personal Data Protection Act ("PDPA") as explained in this document (the "Privacy Policy"). This Privacy Policy is applicable to any data processing implemented by In The Present and any In The Present website.
This Privacy Policy describes the types of Personal Data we may collect from you, how we may use that information, and with whom we may share it. Our Privacy Policy also describes the measures we take to protect the security of the information you provide to us, including without limitation through this Website. We also tell you how you can reach us to update your Personal Data, ask questions you may have about our personal data protection practices and provide feedback on our personal data protection practices.
YOU AGREE AND CONSENT to In The Present as well as our respective agents, authorized service providers and relevant third parties collecting, using, storing, disclosing and/or sharing your personal data in the manner set forth in this Privacy Policy. By submitting your information, signing up, participating and/or attending our programs, class discussions, courses, talks, you are confirming that you are bound by this Privacy Policy. You will be deemed to have read, understood and agreed to the practices and policies outlined in this Privacy Policy and you hereby consent to our collection, use and disclosure of your information as described in this Privacy Policy.
We reserve the right to change modify, add or delete portions of the terms of this Privacy Policy, at our sole discretion, at any time. If you do not agree with this Privacy Policy at any time, do not use any of our Services or give us any of your personal data and/or information.
YOU HEREBY REPRESENT AND WARRANT that all Personal Data you have submitted or will submit to us is complete, accurate, true and correct and you are responsible for keeping your personal data up to date. You acknowledge that failure on your part to do so may result in our inability to provide you with the products and Services you have requested. To update your personal data, please contact our Data Protection Officer.
Where you provide to us personal data concerning individuals other than yourself, YOU HEREBY REPRESENT AND WARRANT that you have obtained all legally required consents, whether explicit or deemed, from the concerned individuals and you shall retain proof of such consent(s), such proof to be provided to us upon our request.
This Privacy Policy supplements (but does not supersede or replace) any other consents which you may have previously provided to us and it does not affect our legal rights concerning the collection, use and/or disclosure of your personal data. Any material changes to our personal data protection practices shall be notified to you.
SECTION 1: TYPE OF PERSONAL DATAGenerally, some of the Services require us to know who you are so that we can best meet your needs. When you complete our pre-assessment forms, enroll in our programs, courses, seminars, events or talks; register for one of our marketing events, complete a payment, access the Services, are employed by us, or through any interaction with us via application or registration forms, emails, telephone calls, short messaging services (“SMS”), texts or other correspondence, we may ask you to voluntarily provide us with certain information that personally identifies you or could be used to personally identify you.
Without prejudice to the generality of the above, information collected by us from you may include (but is not limited to) the following:(a) name, telephone number(s), mailing address, email address and any other information relating to you which you have provided us in any forms you may have submitted to us, in other forms of interaction, or through registration/enrolment on the Website;(b) business contact information from name cards, either through In The Present’s programs, courses, meetings, class discussions, events or talks;(c) comments or assessment feedback on your experience in In The Present’s programs, courses, meetings, class discussions, events or talks;(d) occupational, health, personal history;(e) other information that you voluntarily choose to provide to us on the pre and post-assessment forms;(f) financial information such as bank accounts, credit and debit card details or other payment instrument details;(g)information received by body corporate under lawful contract or otherwise;(h) email and telephone call data records;(i) photographs, video and CCTV footage; and(j) your usage of and interaction with our Website and/or Services including cookies, computer and connection information, device capability, bandwidth, statistics on page views, and traffic to and from our website.
The information collected from you by In The Present may constitute Personal Data under the PDPA.
“Personal Data” is defined under the PDPA to mean any data, whether true or not, about an individual who can be identified from that data or from that data and other information to which an organization has or is likely to have access. This would include, without limitation, information such as name, address, telephone number, e-mail address, credit card details and any other personal information.
In The Present will be free to use, collect and disclose information that is freely available in the public domain without your consent.
Information that is business contact information such as your name, position name or title, business telephone number, business address, business electronic mail address or business fax number and any other similar information about you, which are not provided by you for personal purposes, will not be regarded as Personal Data under the PDPA. Your consent to us collecting, using and disclosing any business contact information will not be required.
SECTION 2: COLLECTION OF PERSONAL DATAPersonal Data may be collected by us through processes including, but not limited to the following:(a) when you submit your registration or pre-assessment form for our MBSR Program;(b) when you submit your registration/enrolment/assessment/application form for any of In The Present’s programs, courses, meetings, class discussions, events or talks via physical copy or online;(c) when you interact with any of our employees;(d) when you respond to In The Present’s request for additional Personal Data;(e) when you ask to be included in an email or other mailing list;(f) when you request that In The Present contact you or when you write to In The Present;(g) when you attend our events or enter our premises, we may take pictures or videos or you may be captured on our closed circuit television cameras surveillance;(h) When you respond to In The Present’s marketing events, initiatives, seminars, surveys or promotions;(i) When you give comments or feedback on our courses, talks, classes, programs and events via evaluation forms given out to you at the end of such course, class, talk, programme and event;(j) when you submit your Personal Data to In The Present for any other reason.
Data collected by automated meansVarious technologies may be used on our Website or our emailing system in order to make it more user-friendly, effective and secure. Such technologies may lead to data being collected automatically by us or by third parties on behalf of us. This data does not generally, but may, contain a user’s personal data. These technologies include but are not limited to cookies, web beacons, tracing links, click stream data and web analytics. You may set up your web browser to block cookies. You may also remove cookies stored from your computer or mobile device. However, if you do block cookies, you may not be able to use certain features and functions of our web sites. Please see Section 7: Additional Privacy Statements for Website Users.
SECTION 3: CONSENT TO COLLECTION OF PERSONAL DATAIn The Present will not collect, use or disclose your personal data unless (a) you give, or are deemed to give, consent to the collection, use or disclosure of your personal data; or (b) the collection, use or disclosure of your personal data without your consent is required or authorized under the PDPA or other written law.
In The Present will not, as a condition of providing a Service to you and/or enabling you to participate in our Services, require you to consent to the collection, use or disclosure of your personal data beyond what is reasonable to provide the service to you and/or enabling you to participate in our Services.
In The Present will not obtain or attempt to obtain your consent for collecting, using or disclosing personal data by providing false or misleading information with respect to the collection, use or disclosure of your personal data, or use deceptive or misleading practices.
As part of our continuous effort to keep you informed on our projects, causes and our Services, we may mail, email, telephone and contact you by any other means. Information sent to you may also include upcoming special events, courses, programs, classes, talks or other relevant information that may be of interest to you. You may also receive mailings or other communications materials from our affiliates and/or carefully selected third parties. You will always have the option to decline any or all of these communications by following the directions included in our emails or other communications, or by contacting In The Present directly via email (see Section 18 below).
In The Present may collect and use personally identifiable information that you volunteer, or other behavioral data and big data generated. In addition to that, permission will be deemed given for communication from us that are necessary to fulfil transactions and services requested by you.
Photographs, videos and CCTV footage may constitute personal data if an identifiable individual is captured. In The Present will either seek your written consent for the collection, use and disclosure of photographs, videos and/or CCTV footage of you, or state in the invitation to you of a program, course, meeting, class discussion, event or talk, that photographs/videos/CCTV footage will be taken at the program, course, meeting, class discussion, event or talk for publicity on In The Present’s print and electronic media. Appropriate and obvious notices will also be put up at the reception or entrance of our program, course, meeting, class discussion, event or talk to inform attendees on the program, course, meeting, class discussion, event or talk day.
SECTION 4: PURPOSES FOR WHICH WE COLLECT AND USE PERSONAL DATAIn The Present may collect, use or disclose your personal data only for purposes (a) that a reasonable person would consider appropriate in the circumstances; and (b) where you have been informed in accordance with this Section 5 of this Privacy Policy, to the extent applicable.
In The Present collects and uses the Personal Data that you provide to us depending on your relationship with us (e.g. as a client, participant, through our Website or other person relating to In The Present).
In GeneralIn general, In The Present may collect, use and/or disclose your Personal Data for the following purposes:(a) maintaining records of MBSR’s interactions with you, through documentation (hard copy and/or electronic);(b) responding to your queries and requests and handling complaints;(c) updating you on developments in In The Present’s Services, and special happenings such as In The Present’s programs, courses, meetings, class discussions, events or talks;(d) managing commercial and financial risks, including preventing, detecting and investigating crime, including fraud and any form of financial crime;(e) assessing and processing any applications, registrations, enrolments, and requests regarding In The Present’s programs, courses, meetings, class discussions, events or talks;(f) establishment and maintenance of relationship with In The Present and/or affiliates of In The Present;(g) marketing and promotion activities of In The Present;(h) taking of photographs and/or videos (whether by In The Present staff or third party photographers and/or videographers) during programs, courses, seminars, events or talks organized by In The Present or its affiliates for publicity purposes;(i) if consented to in the application/enrolment/registration form and/or other methods of consent notification, providing marketing, advertising and promotional information including without limitation promotions, reward programs and sending you details of programs; courses; classes; talks; modules; events; informational and motivational material related to In The Present’s business, via postal mail, electronic mail, SMS or MMS, fax and/or voice calls;(j) if consented to in the application/enrolment/registration form and/or other methods of consent notification, matching your Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision or offering of products and services, whether by In The Present, or other third parties;(k) any other purposes which In The Present may inform you of in writing from time to time, but for which In The Present will seek your separate consent; and(l) any other purposes related to the above purposes.
If you are a program, course, seminar, event or talk attendee/participantIf you are a program, course, meeting, class, event or talk attendee/participant, In The Present may collect, use and/or disclose your Personal Data for the following purposes:(a) assessing your fitness and suitability for any of our programs, course, meeting, class or talk;(b) evaluating your progress as a program, course, meeting, class, event or talk attendee/participant;(c) providing courses and training;(d) videos and images may be used for publicity on In The Present’s newsletters, and social media accounts or platforms; and(e) contacting you for surveys or interviews relating to the above subject matter.
In The Present may also be disclosing the Personal Data that you have provided to us to our affiliates which may be sited locally or outside.
If you have provided your Singapore telephone number(s) and have indicated that your consent to receiving marketing or promotional information via your Singapore telephone number(s), then from time to time, In The Present may contact you using such Singapore telephone number(s) (including via voice calls, SMS, fax or other means) with information about In The Present’s Services and/or your participation, attendance, engagement or otherwise in MBSR’s Services.
SECTION 5: DISCLOSURE OF PERSONAL DATAIn The Present will only disclose Personal Data:(a) for the primary purpose for which it was collected as outlined in Section 4 above;(b) for purposes that a reasonable person will consider appropriate in the circumstances;(c) where you have consented; or(d) where permitted under the PDPA or other applicable law or if required by law.
Subject to applicable laws, In The Present may disclose your personal data for the purposes set out above to parties such as those described below:(a) In The Present’s affiliates which may also include entities and activities overseas;(b) banks, financial institutions, credit card companies, payment gateways and their respective service providers;(c) companies providing services relating to insurance/ reinsurance to us, and associations of insurance companies; and(d) our professional advisers such as our auditors and lawyers.
When In The Present discloses your personal data to third parties, In The Present will ensure that they are contractually bound to protect your personal data in accordance with applicable laws and regulations (as set out in herein), save in cases where your personal data is shared with governmental agencies and regulators, or where your personal data is publicly available, or where use/disclosure of your personal data is otherwise legally mandated and exempted.
If your personal data has to be transferred overseas, In The Present will, where legally required, inform you of the extent to which your personal data will be protected, in the foreign jurisdiction(s) to which it will be transferred.
In addition, In The Present would disclose Personal Data in the following circumstances: (a) in response to a request from law enforcement authorities or other government officials; (b) to comply with a court order or direction from a government agency or regulatory authority ordering the disclosure of the Personal Data; and (c) where the disclosure is necessary for investigations or legal proceedings.
SECTION 6: ADDITIONAL PRIVACY STATEMENTS FOR WEBSITE AND SERVICE USERS6.1 Persons who have visited and submitted pre-assessment forms on the Website (“Subscriber”) Note:This section applies to all Subscribers.(a) As part of the assessment of fitness/suitability of any of MBSR Services, certain information, including Personal Data or sensitive personal information is collected from the Subscribers.(b) All the statements in this Privacy Policy apply to all Subscribers, and all Subscribers are therefore required to read and understand the privacy statements set out herein prior to submitting any Personal Data or sensitive personal information to In The Present, failing which they are required to leave the Website immediately.(c) If you have inadvertently submitted any such information to In The Present prior to reading the privacy statements set out herein, and you do not agree with the manner in which such information is collected, processed, stored, used or disclosed, then you may access, modify and delete such information by using options provided on the Website. In addition, you can, by sending an email to info@inthepresent.sg, inquire whether In The Present is in possession of your Personal Data, and you may also require In The Present to delete and destroy all such information.(d) Subscribers’ personally identifiable information, which they choose to provide on the Website when they sign up, is used to help the Subscribers describe/identify themselves; submit information required for In The Present to provide its Services to Subscribers, and if Subscriber consents, for In The Present to inform Subscriber about any of In The Present’s new courses, programs, classes, talks, services, events and other updates. Other information that does not personally identify the Subscribers as an individual, is collected by In The Present from Subscribers (such as, your computer’s internet protocol (IP) address which provides us with information that helps us learn about your browser and operating system) and is exclusively owned by In The Present. In The Present may also use such information in an aggregated or non-personally identifiable form for research, statistical analysis and business intelligence purposes.(e) The Website uses temporary cookies to store certain data (that is not sensitive personal data or information) that is used by In The Present and its service providers for the technical administration of the Website, research and development, and for Subscriber administration. In the course of serving advertisements or optimizing services to Subscribers, In The Present may allow authorized third parties to place or recognize a unique cookie on the Subscriber’s browser. The cookies however, do not store any Personal Data of the Subscriber. You may adjust your internet browser to disable cookies. If cookies are disabled you may still use the Website, but may be limited in the use of some of the features.(f) In The Present will communicate with the Subscribers through email, telephone, SMSs, text and other forms of messaging. The Subscribers can change their e-mail and contact preferences at any time by sending an email to info@inthepresent.sg.(g) In The Present may keep records of electronic communications received and made for making appointments or other purposes for the purpose of administration of the Services, Subscriber support, research and development.(h) All In The Present employees and data processors, who have access to, and are associated with the processing of sensitive personal data or information, are obliged to respect the confidentiality of every Subscribers’ Personal Data or sensitive personal information.(i) To the extent necessary in doing the Services, In The Present may provide the Personal Data to third party contractors who Services on behalf of or with In The Present to provide Subscribers with such Services, to help In The Present communicate with Subscribers or to maintain the Website. Generally, these contractors do not have any independent right to share this information, however certain contractors who provide services on the Website, including the providers of online communications services, may use and disclose the personal information collected in connection with the Services in accordance with their own privacy policies. In such circumstances, Subscribers consent to us disclosing their personal information to contractors, solely for the intended purposes only.(j) Subscribers may choose to unsubscribe from marketing communications that they receive from In The Present by sending an email to info@inthepresent.sg requesting to unsubscribe.
6.2 Casual Visitors NoteNo sensitive personal data or information is automatically collected by In The Present from any casual visitors of our Website, who are merely perusing the Website. Nevertheless, certain provisions of this Privacy Policy are applicable to even such casual visitors, and such casual visitors are also required to read and understand the privacy statements set out herein, failing which they are required to leave this Website immediately.
If you, as a casual visitor, have inadvertently browsed any other page of the Website prior to reading the privacy statements set out herein, and you do not agree with the manner in which such information is collected, processed, stored, used, disclosed or retained, merely quitting this browser application should ordinarily clear all temporary cookies installed by MBSR. All visitors, however, are encouraged to use the “clear cookies” functionality of their browsers to ensure such clearing / deletion, as In The Present cannot guarantee, predict or provide for the behavior of the equipment of all the visitors of the Website.
You are not a casual visitor if you have willingly submitted any Personal Data or personal information to In The Present through any means, including email, post or through responding to requests on the Website. All such visitors will be deemed to be, and will be treated as, Users for the purposes of this Privacy Policy, and in which case, all the statements in this Privacy Policy apply to such persons.
SECTION 7: SHARING AND TRANSFER OF PERSONAL DATAIn the course of or in connection In The Present’s Services and operations, In The Present may transfer Personal Data to the following parties for the following purposes:(a) To affiliates of In The Present for purposes of expanding the Services;(b) To government and non-government authorities, agencies and/or regulators as required under law or under directions or orders from the government and non-government authorities, agencies and/or regulators for security, regulatory approvals or permits;(c) Financial institutions or payment gateways for purposes of payment processing and transactions related to In The Present’s provision of Services;(d) Professional, financial and legal advisors, tax advisors, auditors, insurers and insurance brokers.However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions. For these providers, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers.
In particular, remember that certain providers may be located in or have facilities that are located a different jurisdiction than either you or us. So if you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located. Once you leave our Website(s) or are redirected to a third-party website or application, you are no longer governed by this Privacy Policy or our website’s Terms of Service.
In The Present requires that the parties to whom we transfer Personal Data and our service providers implement adequate levels of protection in order to protect Personal Data. We also require that these parties only process Personal Data strictly for purposes for which we engage them for and consistent with the purposes that we have described in the Section 4 “Purposes for which we collect and use Personal Data” or with other purposes for which consent has been sought and obtained.
SECTION 8: CONFIDENTIALITY AND SECURITYYour Personal Data is maintained by In The Present in paper or electronic form on its equipment, and on the equipment of its employees. Such information may also be converted to physical form from time to time. In The Present takes all necessary precautions to protect your personal information both online and off-line, and implements reasonable security practices, precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed, including certain managerial, technical, operational and physical security control measures that are commensurate with respect to the information being collected and the nature of In The Present’s business.
In The Present makes all Personal Data accessible to its employees, agents or partners and third parties only on a need-to-know basis, and binds only its employees to strict confidentiality obligations.
Notwithstanding the above, In The Present is not responsible for the confidentiality, security or distribution of your personal information by our partners and third parties outside the scope of our agreement with such partners and third parties. Further, In The Present shall not be responsible for any breach of security or for any actions of any third parties or events that are beyond the reasonable control of In The Present including but not limited to, acts of government, computer hacking, unauthorized access to computer data and storage device, computer crashes, breach of security and encryption, poor quality of internet service or telephone service of the Website user or Subscriber etc.
SECTION 9: AGE OF CONSENTBy using the Website, you represent that you are at least the age of majority in your state or province of residence, or that you are the age of majority in your state or province of residence and you have given us your consent to allow any of your minor dependents to use this site.
In The Present strongly encourages parents and guardians to supervise the online activities of their minor children and consider using parental control tools available from online services and software manufacturers to help provide a child-friendly online environment. These tools also can prevent minors from disclosing their name, address, and other personally identifiable information online without parental permission. Although the In The Present Website is not intended for use by minors, In The Present respects the privacy of minors who may inadvertently use the internet.
SECTION 10: ACCURACYIn The Present will take reasonable efforts to ensure that any Personal Data collected is accurate and up to date by updating its records whenever changes to information come to its attention. In The Present will disregard information which seems, on a reasonable basis, to be inaccurate or out of date by reason of the time which has elapsed since it was collected or by reason of any other information in its possession. To help us maintain the accuracy of your Personal Data, we encourage you to inform us when there are any changes to your Personal Data which you have provided us by writing to our Data Protection Officer. We will correct or complete your Personal Data as set out in Section 12 below. If you have any concerns, feedback or complaints about the use and/or sharing of your Personal Data, you may contact us at info@inthepresent.sg.
SECTION 11: RETENTION OF PERSONAL DATAIn The Present only retains Personal Data for as long as the retention is required for the purposes for which we collected the Personal Data, the purposes described in this Policy and for our business and legal purposes. Generally, we do not retain Personal Data for a period of longer than six (6) years after the original purposes for which the Personal Data was collected have ceased to be applicable, unless otherwise required by law or other mandatory directions by court or government authorities or for purposes of legal proceedings or other similar proceedings or investigations.
For individuals who have submitted their personal data but who do not proceed with the participation or enrolment in any of our programs, courses, meetings, classes, events or talks, In The Present will retain your Personal Data for no longer than 1 (one) year for the purposes of reviewing, evaluating, promoting and/or marketing our programs, courses, meetings, classes, events or talks, unless you inform us otherwise as set out in Section 12 below.
SECTION 12: ACCESS, CORRECTION, UPDATE OR WITHDRAWAL OF PERSONAL DATAYou may request for information from In The Present on what Personal Data of yours we have and how we have used and shared your Personal Data during the last one (1) year before the date of your request; or withdraw your consent to our continued use and disclosure of your Personal Data; or seek access to your Personal Data (to a reasonable extent and as permitted by the Act) at any time by writing to our Data Protection Officer. You may also withdraw your consent for specific forms of communication and on specific communications via the unsubscribe options as stated on our email or other marketing messages.
We will endeavor to acknowledge the receipt of your request within 5 working days after the date of receipt of your request if it is sent by e-mail, or within 10 working days after the date of receipt of your request if it is sent by post. We will carry out your request within 14 days from the date of acknowledgement. Please note that it may take up to 30 working days for any request for consent withdrawal to be reflected in our systems. As it is important to us that the Personal Data that we have about you is accurate and complete, it may be necessary for us to request for supporting documentation from you. We will contact you if we require supporting documentation from you.
In withdrawing your consent, you acknowledge that we may not be able to provide or continue providing certain Services to you and that we may cease such provision accordingly without any liability.
There may be circumstances where In The Present will not correct, delete or update your Personal Data, including: (a) where the Personal Data is opinion data that is kept solely for evaluative purpose; and (b) the Personal Data is in documents related to a prosecution if all proceedings relating to the prosecution have not been completed.
In The Present shall have the right to request for information for the purposes of verification of your identity and for more information about your request. In The Present will charge a reasonable administrative fee to respond to the request set out above.
SECTION 13: TRANSFER OF PERSONAL DATA OUTSIDE OF SINGAPORECertain In The Present’s vendors, or service providers may be operating outside Singapore. By providing information to us through our enrolment/registration/participation forms at our programs, courses, classes, talks; use of our Website or otherwise, you are consenting to the transfer of that information to be processed and used in accordance with the terms of this Privacy Policy. In such a situation, In The Present will ensure that the Personal Data so transferred will be accorded a standard of protection comparable to the protection provided under the PDPA.
SECTION 14: DO NOT CALL PROVISIONSIn The Present will not be sending any specified messages and/or otherwise marketing communications through SMS, text or phone calls. If you have provided your Singapore telephone number(s), then from time to time, In the Present may contact you using such Singapore telephone number(s) (including via voice calls, text, or other means) including, among other things, with information reasonable for us to provide our Services to you and/or enabling you to participate in our Services.
SECTION 15: CHANGES TO THIS PRIVACY POLICYIn The Present may update this Privacy Policy at any time, with or without advance notice. In the event there are significant changes in the way In The Present treats your personally identifiable information, or in the Privacy Policy itself, In The Present will display a notice on the Website or send you an email, as provided for above, so that you may review the changed terms prior to continuing to use the Services. As always, if you object to any of the changes to our terms, and you no longer wish to use the Services, you may contact info@inthepresent.sg. Unless stated otherwise, In The Present’s current Privacy Policy applies to all information that In The Present has about you and/or your account. If a Website user or Subscriber uses the Services; or accesses the Website after a notice of changes has been sent to such user or Subscriber, or published on the Website, such user or Subscriber hereby provides his/her/its consent to the changed terms.
SECTION 16: HOW TO CONTACT USShould you have questions about this Privacy Policy or In The Present's information collection; use and disclosure practices, or if you would like to access, correct, amend or delete any personal information we have about you; register a complaint; or simply want more information, please contact us at info@inthepresent.sg. We will use reasonable efforts to respond promptly to any requests, questions or concerns, which you may have regarding our use of your personal information. If you have any grievance with respect to our use of your information, you may communicate such grievance to:
In The Present Pte. Ltd.Email: info@inthepresent.sgEffective date: 01 January 2017Copyright 2016