The Myers-Briggs Pte. Ltd. Company Privacy Policy

Effective Date: 19 October 2018

This website is owned and operated by The Myers-Briggs Company Pte Ltd (“TMBC,” “we,” or “us”), a company incorporated under the laws of Singapore. We work diligently to protect the privacy, confidentiality, and security of the Personal Information (defined below) that we receive. This Privacy Policy applies to TMBC and its associated/affiliated businesses, and describes the principles and practices that apply to the Personal Information that we collect from individuals online or offline (“you”), such as individuals who browse through our Sites (defined below), register on the Sites, use the services provided on the Sites, interact with the Sites, communicate with us through telephone, email, text, or other communications means, participate in our interviews, surveys, or promotions, read or receive our newsletters, or apply for employment with us.

Privacy Principles

This Privacy Policy is based on the following privacy principles:

  • Access – In those instances where we control your data, we will provide you with (i) the opportunity to confirm whether we are processing your Personal Information; (ii) a way to obtain a copy of your Personal Information that we process; (iii) the ability to restrict or object to processing of your Personal Information; and (iv) the ability to correct, amend, or delete Personal Information that is inaccurate; all within a reasonable amount of time from the time you submit such a request.
  • Accountability for Onward Transfer – We will not disclose your Personal Information to third parties other than as described in this Privacy Policy or our written agreements with you, and our agreements with third parties with whom we share Personal Information will reflect our privacy principles.
  • Accuracy – We take reasonable steps to ensure that the Personal Information we have is accurate or rectified without delay if it is determined to be inaccurate.
  • Choice – We will provide you with mechanisms that will allow you to opt out of (i) our direct marketing campaigns; and (ii) the disclosure of your Personal Information to third parties who are not acting as our agents.
  • Data Integrity and Purpose Limitation – You will be able to (i) view the Personal Information that we have about you; (ii) correct or modify your Personal Information if it is inaccurate or incomplete; and (iii) limit the collection of data to such data that is relevant to the products and services we provide to you or on your behalf.
  • Data Minimization – We process only that Personal Information which is adequate, relevant, and necessary to achieve the purposes for which it is collected.
  • Integrity, Confidentiality, and Security – We take reasonable measures to protect the security of your Personal Information, and our agreements with third parties with whom we share Personal Information require similar protections.
  • Lawfulness, Fairness, and Transparency – We will process your Personal Information only when we have a legal basis for doing so, and we will process your Personal Information in a manner that is fair and transparent to you.
  • Notice – We will not collect or transfer your Personal Information without your knowledge. We inform you of such collection and transfer through this Privacy Policy, our written agreements with you, and other disclosures we make available on the Sites.
  • Purpose Limitation – We process Personal Information only for specific, explicit, and legitimate purposes, and refrain from further processing that Personal Information in any manner that is incompatible with those purposes (subject to our reasonable archive, backup, and research practices).
  • Recourse, Enforcement, and Liability – We have processes for handling complaints relating to the processing of your Personal Information by us (see “Complaints and Disputes”).
  • Storage limitation – We keep data in personally-identifiable form only for as long as necessary to achieve the purposes for which it is being processed or until such time as it is no longer necessary for legal or business purposes (which includes our reasonable archive, backup, and research practices).

Definitions

In this Privacy Policy, the following terms are defined as set forth in this section:

  • Assessment” means an instrument, questionnaire, or series of tests that are completed by one or more Respondents to provide information about a Respondent to the Respondent, to TMBC, and to TMBC’s Customers, usually with the aim of generating one or more Reports.
  • Certified Practitioner” means an individual (i) who has successfully completed one or more of our certification programs for certain Assessments; (ii) who administers one or more Assessments to one or more Respondents; and (iii) who interprets the Reports (or other output generated by TMBC) to provide feedback to the Respondent(s) about the Reports.
  • Child” or “Children” means those individuals who are (i) in the United States and under age 13; (ii) in the European Union and under age 16; or (iii) in other countries or territories and under the minimum age of threshold to be considered an adult.
  • Customer” means an individual, business, or other entity that purchases TMBC’s Products or Services, or with which TMBC has a contractual relationship to provide Products or Services.
  • Personal Information” means any information, recorded in any form, whether true or not, about an identified individual or an individual whose identity may be inferred from the information. Personal Information includes, for example, name, email address, mailing address, telephone number, billing information, account information, photographs, videos, and other information incidental to providing or receiving Products or Services or which you may choose to provide to TMBC. It also includes other information, such as IP address, device information, or other Session Data (as defined below) that can reasonably be linked to a specific individual, computer, or other device.
  • Practitioner” means an individual who administers one or more Assessments to one or more Respondents and who interprets the Reports (or other output generated by TMBC) to provide feedback for the Respondent(s).
  • Products or Services” means the products or services promoted, sold, or available for sale on the Sites, with includes our Assessments, Reports, training sessions, consultancy services, and supplemental materials.
  • Reports” means an analysis of the scoring and responses provided in connection with an Assessment, which a Practitioner or Customer may use to interpret a Respondent’s responses to an Assessment. Some Reports, such as those generated on www.mbtionline.com, do not require an interpretation from a Practitioner.
  • Respondent” means an individual who takes, will take, or has taken an Assessment.
  • Session Data” means, as applicable, usage information, such as IP address, unique identifier of an individual’s mobile device, the type of browser, type of operating system, referring URL, date, time and duration of a visitor’s visit, the number of visits to a Site, the pages viewed, order of pages viewed, time spent on a particular page, the number of cookies accumulated, bytes sent, bytes received, protocol version, user agent, method, URI stem, URI query, or MAC address.
  • Site” means any websites that we or our parent company, The Myers-Briggs Company Inc., may develop or have developed from time-to-time and includes, without limitation: https://asia.themyersbriggs.com, www.themyersbriggs.com, elevate.themyersbriggs.com, www.mbtitype.com, and www.mbtionline.com.

“Processing”, “process”, and related expressions means any operation or set of operations which is performed on Personal Information or on sets of Personal Information, whether or not by automated means, such as collection, recording, holding, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

Your Agreement to this Privacy Policy

By creating an account, using the Site(s), and/or submitting Personal Information to us, you consent to the practices described in this Privacy Policy, and you agree that we may process such Personal Information in accordance with this Privacy Policy or as required by law. If you do not agree to any of the terms in this Privacy Policy, you must not use this Site and/or the online services.

Our online assessment administration Site(s) are developed and operated by our parent company in the United States, The Myers-Briggs Company, Inc. If you make use of such online assessment administration Site(s), you may be deemed to have consented to the processing of your Personal Information by The Myers-Briggs Company, Inc. in the United States.

Children are not permitted to use the Sites. Should we discover that a Child has sent Personal Information directly to us, we will use that information only to respond directly to that Child to inform him/her that we will not continue to process his/her Personal Information.

Changes to this Privacy Policy

We may change this Privacy Policy from time to time. If we make material changes, we will place a prominent notice on the affected Site(s) or we will send you a notice to the email address associated with your account. Users are encouraged to periodically review this page for the latest information on TMBC’s privacy and data protection practices. Your continued use of our Products and Services constitutes your acknowledgement and acceptance of any such changes.

Links to External Sites

The Sites may link to websites that are operated by third parties. Because such websites are not operated by us, they are not subject to this Privacy Policy. We recommend that you read the privacy statements that are posted on these third-party websites to understand their procedures for processing Personal Information.

What Personal Information We Collect and How

We collect only such Personal Information as necessary to (i) provide our Products or Services to you; (ii) inform you about our Products and Services; (iii) continue our research in the field; and (iv) improve our Sites, Products or Services, and your experience interacting with us. We describe below the different ways in which we collect or obtain Personal Information.

If you visit the Sites – If you visit the Sites, we automatically collect the related Session Data. Session Data is provided to us by your browser, by third-party integrations on our Sites, and through our log files, which record your activities while browsing our Sites, such as when you click on a link. We may record some of this data in one or more cookies that we send to your browser (see “Cookies and Other Technologies”).

If you register or create an account – If you register as a member or a course participant, or otherwise create an account with us, we require that you provide certain Personal Information during account registration. We collect your name, contact information, and other information, and may ask you for other optional information that helps us serve you better.

If you complete an Assessment – If a Respondent completes an Assessment, we collect the Respondent’s name, email address, contact information, Assessment responses, Session Data, and other information you may choose to provide or associate with your account. In some cases, we ask questions to which the response is optional (such as demographic questions), and these questions are identified as such. In some instances, these optional demographic questions may involve collection of special categories of Personal Information, such as information regarding your racial or ethnic origin. You are free not to respond to these optional questions. For all optional questions, our legal basis for processing your Personal Information is your explicit, informed consent.

If you participate in a survey – If you choose to participate in one of our surveys, we may collect Personal Information such as your name, email address, and any other Personal Information that you may provide in your survey responses. Participation in surveys is optional, and we give you the ability to opt out of being contacted for surveys at any time.

If you sign up to receive marketing communications – If you sign up to receive our marketing communications, we may collect information on the open rate of the communications, and whether a specific individual has clicked on a link contained in a particular communication.

If you attend our training sessions and promotional events – If you sign up for and attend our training sessions and promotional events, we may take audio, visual, or other recordings, whether via photography or otherwise, for marketing purposes, and your attendance at such training sessions or promotional events shall be deemed to be your giving of consent to the collection of your Personal Information recorded therein.

If you purchase any Products and Services, or if are a Customer or other business contact – If you purchase any Products and Services with us or are a Customer or other business contact, or if you are an employee or agent of a Customer or business contact, we may collect your name, email address, telephone number, and other contact information in the regular course of our interaction with you.

If you interact with third parties regarding our Products or Services – We may receive Personal Information about you from third parties, such as from Customers, websites where we advertise, business partners, and service providers. Some of this information pertains to a specific individual; other information can only be linked to an access point or a device.

If you apply for employment – If you choose to apply for an open position of employment we have designated as available, we may collect Personal Information such as your name, email address, and any other Personal Information that you may provide in conjunction with your application. We use this information only to consider you as a candidate for the position for which you are applying and to contact you for legitimate purposes relating to that application.

How We Use Personal Information

We use Personal Information in order to provide and enhance the Products or Services that we offer as explained below:

To respond to enquiries – We use the Personal Information collected to respond to your enquiries regarding the Products and Services that we offer.

To process feedback – We use the Personal Information collected when you send us feedback to improve and enhance the Products and Services that we offer as well as your experience interacting with us.

To provide the Products and Services – We use Personal Information to process requests, order, administer accounts, provide customer support (including account servicing such as training confirmation, reminders, postponements, cancellations etc.), communicate with you in relation to the Products and Services which are relevant to your existing relationship with us, provide you with course and product updates and upgrades, offer or supply with our Products and Services, and entering into contracts with you.

To facilitate the use of the Sites – We use Session Data to ease navigation throughout the Sites, to enhance navigation, keep track of login name and password in order to avoid requesting identity information when the visitor moves from page to page, and in general to enhance the quality of our Sites and the content provided on the Sites.

In connection with Assessments – We use the responses to Assessments to score the Assessments and to generate Reports and other data related to the Respondents to those Assessments. We sometimes combine data from multiple Respondents (for example, in team reports). We may also combine Respondent data with our general research data, or compare or associate Respondent data with other Respondent data. Certain subsets of this data are made available to our Customers, but your Personal Information is only shared with a Customer if you complete an Assessment that has been sponsored by that Customer.

To validate certification status – If you are or become a Certified Practitioner, we may share information regarding your certification, such as your name, the instruments in which you are certified/qualified, the date(s) of your certification/qualification, and the current status of your certification/qualification with individuals who inquire about such information.

For research purposes – We may use aggregated Session Data to better understand how our Sites are navigated, how many visitors arrive at specific pages, which pages or content attract more viewers, the length and frequency of stays at our Sites, the different types of searches of our Sites’ content and databases, the types of browsers and computer operating systems that our visitors use, and the IP addresses from which visitors connect to our Sites, in order to improve our Sites and enhance our content. We may use IP addresses to gather broad demographic information—information that is not associated with any individual, and is therefore anonymous. We also use aggregated Assessment responses and other data to improve our Products and Services.

For maintenance purposes – We may use IP addresses and Session Data to diagnose problems with our server, and to administer our Sites.

For marketing purposes – We may use email addresses or other contact information to send mailings, newsletters, and other marketing communications regarding product information and releases that you can benefit from, including products and services offered by our selected partners. We may use your telephone number to contact you for marketing purposes. We may use pixel tags to monitor the open rate of our communications. This helps us understand the effectiveness of the communications that we send. We give you the ability to opt out of marketing communications at any time.

For research and survey analysis – The information that we collect through our surveys is not used other than to garner survey results and statistical analysis.

To process employment applications – When you apply for employment with us, we will use your Personal Information provided in your application to process your application and determine your suitability for the role applied for.

We may for the above purposes, contact you via mail (including email), telephone, SMS or other communication (text or image) applications for mobile devices, and facsimile.

To Whom We Disclose and Transfer Personal Information

From time to time, we may disclose Personal Information to someone other than the individual who provided the Personal Information, as further described below:

Customers – TMBC provides its Customers with the information that they need to properly administer or interpret Assessments. If you take an Assessment at the direction of one of our Customers, that Customer will receive from TMBC one or more Reports based on the Assessment you took and the responses you provided to that Assessment so that the Customer may properly counsel or advise you or provide you with other services.

Gift Recipients – If you purchase Products or Services for use by another individual (for example, as a gift), then we may provide the recipient of such Products or Services with your Personal Information.

Service Providers – We may engage certain third parties to perform functions and provide services to us, including, without limitation, customer relationship management, contract management, order fulfilment, mass mailing, hosting and maintenance, database storage and management, business analytics, and direct marketing campaigns. As of the effective date of this Privacy Policy, the current list of service providers to whom we disclose Personal Information is as follows:

  • Arkadin, Inc. (for telecommunications services);
  • DHL Express (for shipping services)
  • FileMaker Pro (for platform infrastructure)
  • First Choice Couriers (for shipping services)
  • FedEx Corporation (for shipping services);
  • Marketo, Inc. (for marketing communications);
  • Microsoft Corporation (for platform infrastructure services);
  • Mimecast Services Limited (for email archive services);
  • Mozy, Inc. (for backup and archive services);
  • MYOB (for platform infrastructure)
  • OCBC Bank (for payment processing services);
  • Salesforce.com Inc. (for customer relationship management);
  • SendGrid, Inc. (for email delivery services);
  • United Parcel Service (for shipping services); and
  • Virtunet, LLC (for backup and recovery services

Pursuant to written agreements between TMBC and these service providers, each of these service providers only has access to such Personal Information as necessary to fulfil its obligation to TMBC, is not permitted to use Personal Information for any purposes other than those directed by TMBC and is required to act in a manner consistent with the privacy principles articulated in this Privacy Policy and applicable law.

If our processing of your Personal Information requires transfer of your Personal Information to countries outside Singapore or to an international organisation, we will only do so when we can ensure that the level of protection of your Personal Information will not be undermined. To achieve this, we rely on a variety of data transfer mechanisms, including adequacy determinations by the Singapore Personal Data Protection Commission (“PDPC”), appropriate safeguards such as standard contractual clauses, or binding corporate rules.

Foreign Distributors – We may provide Personal Information to our distributors in foreign markets. We only do so when we believe that providing such information will permit us to improve the Products or Services provided to Customers in that distributor’s territory, and only when the distributor’s use of such Personal Information is in accordance with the privacy principles described in this Privacy Policy. As of the effective date of this Privacy Policy, TMBC’s distributors in foreign markets include:

  • Assesta, Ltd. (South Korea);
  • The Myers-Briggs Limited (Albania; Andorra; Austria; Belarus; Belgium; Bosnia Herzegovina; Bulgaria; Croatia; Czech Republic; Cyprus; Denmark; Estonia; Finland; France; Germany; Gibraltar; Greece; Greenland; Hungary; Iceland; Ireland; Italy; Kosovo; Latvia; Liechtenstein; Lithuania; Luxembourg; Macedonia; Malta; Moldova; Monaco; Montenegro; Norway; Poland; Portugal; Romania; Russia; San Marino; Serbia; Slovak Republic; Slovenia; Sweden; Switzerland; The Netherlands; Turkey; Ukraine; United Kingdom; Vatican City; and Yugoslavia);
  • The Myers-Briggs Company Pte. Ltd. (Brunei; Cambodia; Indonesia; Malaysia; Mongolia; Myanmar; and Singapore);
  • The Myers-Briggs Company Pty Ltd. (Australia; Bangladesh; China; Hong Kong; India; Nepal; Pakistan; Sri Lanka; and Taiwan);
  • Fellipelli Consultoria e Diagnosticos (Argentina; and Brazil);
  • Global Jobs Capacitacion S.P.A. (Chile);
  • HDS Diagnostico Y Desarollo de Talento (Mexico);
  • Heart to Heart Communication Consulting and Human Development (Egypt);
  • Innovative HR Solutions (Bahrain; Kuwait; Oman; Qatar; Saudi Arabia; and the United Arab Emirates);
  • Jopie Van Rooyen and Partners (Angola; Benin; Botswana; Burkina Faso; Burundi; Cameroon; Cape Verde; Central African Republic; Chad; Comoros; Republic of the Congo; Democratic Republic of the Congo; Cote d’Ivoire; Djibouti; Equatorial Guinea; Eritrea; Gabon; The Gambia; Ghana; Glorioso Islands; Guinea; Guinea-Bissau; Kenya; Lesotho; Liberia; Madagascar; Malawi; Mali; Mauritania; Mauritius; Mayotte; Mozambique; Namibia; Niger; Nigeria; Reunion Island; Rwanda; Sao Tome and Principe; Senegal; Seychelles; Sierra Leone; Somalia; South Africa; South Sudan; Sudan; Swaziland; Tanzania; Togo; Uganda; Zambia; and Zimbabwe);
  • JPP Co., Ltd. (Japan);
  • Levy Consulting (Israel); and
  • Psychometrics Canada, Ltd. (Canada).

To defend or enforce our rights – TMBC may use Personal Information to defend or enforce its legal rights, to respond to a breach of its Terms of Service (or other applicable legal terms), to prevent fraudulent activity, or where it is necessary to pursue available remedies. If a Customer neglects to pay amounts due and owing to TMBC, TMBC may send that Customer’s name, contact information, and account information to a third-party service provider for collection of overdue payments.

For marketing purposes – Audio and visual recordings or photography containing your Personal Information that have been collected at our training sessions and promotional events with your consent, whether express or deemed, may be disclosed to third parties for marketing and promotional purposes.

Co-Marketing Partners – We may collaborate with other companies to offer you additional Products or Services. We may share Personal Information that is necessary for these other companies to provide the Products or Services that you have requested. This Privacy Policy does not cover the processing of your Personal Information by these companies. We encourage you to read a company’s Privacy Policy before requesting any affected Products or Services.

Mergers & Acquisition; Bankruptcy – If any or all of TMBC’s assets are acquired by or merged with those of another entity, or in the unlikely event of a bankruptcy, we may disclose, share or transfer some or all of your Personal Information to or with this entity in preparation of the transaction, as part of the due diligence, or after the transaction has been consummated, so that the successor entity can continue providing our services to you. If the recipient of the Personal Information has privacy practices that do not meet the substance of this Privacy Policy, you will be given the opportunity to exercise your rights with respect to your Personal Information.

Law Enforcement; Litigation – Certain government regulations may require that we disclose information that we hold. In such cases, we will use reasonable efforts to disclose only the Personal Information required under applicable law, such as in response to a facially valid court order, warrant or subpoena issued or made by a court, person or body. We may use or disclose Personal Information (a) if we believe in good faith that a law, regulation, rule or guideline requires it; or (b) to a person who needs the information because of an emergency that threatens the life, health or security of an identified group or person.

Aggregated data – Other than as stated above, if TMBC provides a third-party with Personal Information, it will be in the form of aggregated data and used for product development, research, or statistical analysis. Aggregated data are created from records that are stripped of all personal identifiers, such as aggregated Assessment responses, or on-site behaviour.

The public – Certain of our Sites offer publicly-accessible blogs or community forums and any Personal Information you provide on these blogs or forums may be read, collected, and used by others who access those Sites. We encourage you to be thoughtful of what Personal Information you choose to provide on such Sites.

For the avoidance of doubt, TMBC does not rent or sell Personal Information to any third party organisations. TMBC will only disclose your Personal Information to third parties in the ways that are described in this Privacy Policy. TMBC also limits the information it collects to the minimum necessary to provide service such as offering customer service or sending you marketing emails.

Cookies and Other Technologies

A cookie is a small text file that a website sends to a visitor’s browser and that sends back information each time the visitor makes a request from the website. A cookie contains a unique identification number that identifies the visitor’s browser, but not necessarily the visitor. Cookies can be accepted, rejected, or identified by configuring a browser’s preferences or settings. Some cookies are strictly necessary for us to deliver the Sites or Products or Services, and those cookies cannot be disabled. Pixel tags or clear gifs are tiny graphics with a unique identifier that are embedded invisibly on a webpage and are used to track a visitor’s movements on a website. We use the information gathered by clear gifs to help us better manage content on the Sites. Cookies and pixel tags are used to help recognize a returning visitor, and to help customize the visitor’s online experience. Unless a visitor specifically informs us of his/her identity (e.g., by registering with us), we will not know who the individual visitor is.

The Sites use cookies as follows:

  • to collect Session Data and other session information;
  • to process orders and to store order and shopping cart information;
  • to store and hash usernames and passwords so that users do not have to re-enter this information each time they log in; and
  • to collect analytics relating to visitors’ use of the Site.

For more information about our specific use of cookies on the Sites, please visit the “Cookies” section on the relevant Site(s).

The Sites do not respond to “do not track” signals or other similar mechanisms.

How We Retain Personal Information

As a general principle, we keep data in personally-identifiable form only for as long as necessary to achieve the purposes for which it is being processed or until such time as it is no longer necessary for legal or business purposes (which includes our reasonable archive, backup, and research practices). In practice, that generally means we may retain your Personal Information: (i) for as long as your account remains active; (ii) for as long as you continue to do business with us; or (iii) for as long as we are required to by applicable law. When your account becomes inactive (as determined by us in our sole discretion), or if you cease doing business with us, we may retain your Personal Information for an additional period for our reasonable archive and backup purposes. The duration of our retention of your Personal Information may be set forth more specifically in our written agreement(s) with you, or our applicable Terms of Service or other legal terms. At all times, both while you are an active Customer, Practitioner, Respondent, or other registered user and thereafter, we may retain Assessment responses and other data in non-personally-identifiable format for as long as the information is needed for our research, statistical analysis, product development, or other commercial purposes.

How We Protect Personal Information

We follow generally-accepted industry standards to protect Personal Information, both during transmission and once we receive it. We use administrative, physical, and technical measures designed to protect Personal Information from unauthorized access, loss, misuse, disclosure, alteration, or destruction.

When we need to transfer information out of our firewall, we use industry-standard technological means to protect Personal Information while in transit through the Internet. We use encryption and a comprehensive authentication protocol to provide reasonable security.

No method of transmission over the Internet, or method of electronic storage, is fully secure, however. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.

Your Rights

We respect your rights as a data subject. In those instances when we are a data controller determining the purposes and means of the processing of Personal Information, we provide you with the rights described below. In those instances where we are a data processor or data intermediary, we will reasonably assist the data controller in facilitating your ability to exercise the rights below.

Right of access – You have the right to obtain confirmation as to whether or not your Personal Information is being processed. If your Personal Information is being processed, you have the right to access your Personal Information and the following information: (a) the purposes of the processing; (b) the categories of Personal Information concerned; (c) the recipients or categories of recipients to whom your Personal Information has been or will be disclosed (including international organisations and recipients in other countries); (d) where possible, the period for which your Personal Information will be stored or the criteria used to determine that period; (e) the existence of your right to request that the data controller rectify or erase your Personal Information, or restrict processing of your Personal Information, or to object to processing of your Personal Information; (f) your right to lodge a complaint with the PDPC; (g) the source of your Personal Information (if it was not obtained from you directly); and (h) the existence of any automated decision-making (including profiling) along with meaningful information about the logic of such automated decision-making and its consequences.

Right to rectification – You have the right to rectify inaccurate Personal Information concerning you. We generally rely on personal data provided by you (or your authorised representative). In order to ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer at the contact details provided below. Taking into account the purposes of the processing, in some instances you will have the right to have incomplete Personal Information completed by providing supplementary written statements to us.

Right to erasure – You have the right to request erasure of your Personal Information when one of the following applies: (a) your Personal Information is no longer needed to achieve the purpose(s) for which it was originally collected or processed; (b) the processing of your Personal Information is based on your consent, you choose to withdraw that consent, and we have no other legal basis for ongoing processing; (c) you object to the processing and we have no overriding legitimate grounds for ongoing processing; (d) your Personal Information has been processed unlawfully; or (e) your Personal Information must be erased for compliance with applicable law. In those instances where you exercise this right against TMBC as the data controller, we will accommodate your request to the extent practicable, and to the extent that it does not otherwise conflict with any of our other obligations. We reserve the right to retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our contractual agreements.

Right to withdraw consent – The consent that you provide for the processing of your Personal Information will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop processing your Personal Information for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing the Products and Services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing or via email to our Data Protection Officer. Please note that withdrawing consent does not affect our right to continue processing Personal Information where such processing without consent is permitted or required under applicable laws.

Right to restriction of processing – You have the right to restrict processing of your Personal Information where one of the following applies: (a) you contest the accuracy of your Personal Information, in which case processing will be restricted for a period allowing the data controller to verify or rectify the accuracy of your Personal Information; (b) processing of your Personal Information is unlawful; (c) processing of your Personal Information is no longer necessary for the purpose(s) for which it was collected or processed but you require it for the establishment, exercise, or defence of legal claims; or (d) you object to the processing, in which case processing will be restricted for a period allowing the controller to demonstrate whether legitimate grounds exist that override your objection.

Right to data portability – Where technically feasible, and as related to Personal Information you have provided to a data controller based on your consent or a contract with you, you have the right to receive that Personal Information in a structured, commonly-used and machine-readable format and to transmit that Personal Information to another controller if the processing of that Personal Information is performed by automated means.

Right to object to processing – In certain instances, you may have the right to object to processing of your Personal Information. Should you so object, the controller of your Personal Information must stop processing your Personal Information unless the controller can demonstrate (i) compelling legitimate grounds for ongoing processing of your Personal Information that override your objection; or (ii) the need for the establishment, exercise, or defence of legal claims.

Right not to be subject to automated decision-making – In certain instances, you have the right not to be subject to decisions based solely on automated processing (including profiling) that produces legal effects concerning you or otherwise significantly affects you. As of the effective date of this Privacy Policy, we do not engage in any such automated decision-making or profiling.

Right to opt-out of marketing communications – If you are receiving marketing communications from us and you wish to unsubscribe, you may do so by clicking on the “unsubscribe” link provided in the communication or by managing your marketing communication preferences on the Site(s).

Right to block cookies – You have the right to block pixel tags and certain cookies. Most browsers automatically accept cookies. You can instruct your browser, by editing its options, to stop accepting cookies, or prompt you before accepting a cookie from the Site that you visit. If you decide not to accept our cookies, you may not be able to access portions of our Products or Services. Some cookies are strictly necessary for us to deliver the Sites or Products or Services, and those cookies cannot be disabled.

If TMBC is the controller of your Personal Information and you wish to exercise any of the rights described above, please contact us with proof of identity, as provided in the “Contact Us” section. In general, you can expect a response to your request within thirty (30) days. However, if your request is complex or involves a high volume of data, TMBC may inform you that the request could take up to an additional sixty (60) days. In some instances, fees may apply. If we are unable to provide you with any Personal Information or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA). If TMBC is not the controller of your Personal Information, TMBC will ask you to direct your request to the data controller, and TMBC will reasonably assist the data controller in facilitating the request.

Complaints and Disputes

This Privacy Policy shall be governed and construed in accordance with the laws of the Republic of Singapore.

If you have questions or complaints regarding our Privacy Policy or practices, you should first contact us as indicated in the “Contact Us” section below.

If our efforts to resolve your complaint through TMBC’s internal dispute resolution mechanisms are unsatisfactory, you agree to first attempt to settle in good faith the dispute through mediation in Singapore in accordance with the relevant Mediation Rules or Mediation Procedures for the time being in force of the Singapore International Mediation Centre (for international disputes) (“SIMC”) or the Singapore Mediation Centre (for domestic disputes) (“SMC”). Either/any party may submit a request to mediate to either SIMC or SMC, as the case may be, upon which the other party will be bound to participate in the mediation within forty-five (45) days thereof. Every party to the mediation must be represented by at least one (1) individual with authority to negotiate and settle the dispute. Unless otherwise agreed by the parties, the Mediator(s) will be appointed by SIMC or SMC, as the case may be. The mediation will take place in Singapore in the English language and the parties agree to be bound by any settlement agreement reached.

If our efforts to resolve the dispute through mediation are unsuccessful, you agree to binding arbitration administered by the Singapore International Arbitration Centre (“SIAC”) in accordance with the Arbitration Rules of the Singapore International Arbitration Centre (“SIAC Rules”) for the time being in force, which rules are deemed to be incorporated by reference in this clause. The seat of the arbitration shall be Singapore, the Tribunal shall consist of one (1) arbitrators, and the language of the arbitration shall be English.

You also have the right to complain to the PDPC. However, we would appreciate the chance to deal with your concerns before you approach the PDPC.

Contact us

If you have any question about (a) this Privacy Policy, or (b) the processing of your Personal Information, or (c) accessing, modifying, or closing your account, please contact our Data Protection Officer as indicated below. We will attempt to respond to your questions or concerns promptly after we receive them.

By email
marketing.asia@themyersbriggs.com

By phone
+65 69141033

By mail:
The Myers-Briggs Company Pte Ltd
300 Beach Road,
#29-03. The Concourse,
Singapore 199555

For purposes of the General Data Protection Regulation (“GDPR”), TMBC’s EU Representative is The Myers-Briggs Company Holdings (Europe) Limited, a subsidiary of The Myers-Briggs Company, and a company registered in England and Wales. Liam O’Connor is the designated point of contact for our EU Representative. Please contact The Myers-Briggs Company Holdings (Europe) Limited at Elsfield Hall, 15-17 Elsfield Way, Oxford OX2 8EP or dleurep@themyersbriggs.com.

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