LayerMx.com (our website) is provided by Muljin Pte. Ltd. ('we', 'our' or 'us'). We are the controller of personal data obtained via our website, meaning we are the organisation legally responsible for deciding how and for what purposes it is used.
We take your privacy very seriously. Please read this privacy policy carefully as it contains important information on who we are and how and why we collect, store, use and share any information relating to you (your personal data) in connection with your use of our website. It also explains your rights in relation to your personal data and how to contact us or a relevant regulator in the event you have a complaint.
We collect, use and are responsible for certain personal data about you. When we do so we are subject to the Personal Data Protection Act (PDPA) of Singapore. We are subject to the UK General Data Protection Regulation (UK GDPR) in the UK. We are also subject to the EU General Data Protection Regulation (EU GDPR) in relation to services we offer to individuals in the European Economic Area (EEA).
Given the nature of our website, we do not expect to collect the personal data of anyone under 18 years old. If you are aware that any personal data of anyone under 18 years old has been shared with our website please let us know so that we can delete that data.
This privacy policy is divided into the following sections:
This privacy policy relates to your use of our website only.
Throughout our website we may link to other websites owned and operated by certain trusted third parties to authenticate you and provide email service processing capabilities. Those third party websites may also gather information about you in accordance with their own separate privacy policies. For privacy information relating to those third party websites, please consult their privacy policies as appropriate.
The personal data we collect about you depends on the particular activities carried out through our website. We will collect and use the following personal data about you:
You must provide this personal data to enable core functionality of the website unless we tell you that you have a choice.
Sometimes you can choose if you want to give us your personal data and let us use it. Where that is the case we will tell you and give you the choice before you give the personal data to us. We will also tell you whether declining to share that personal data will have any effect on services provided
We collect and use this personal data for the purposes described in the section ‘How and why we use your personal data’ below.
We collect personal data from you:
We also collect personal data about you from other sources as follows:
Under data protection law, we can only use your personal data if we have a proper reason, eg:
A legitimate interest is when we have a business or commercial reason to use your personal data, so long as this is not overridden by your own rights and interests. We will carry out an assessment when relying on legitimate interests, to balance our interests against your own. You can obtain details of this assessment by contacting us (see ‘How to contact us’ below).
The table below explains what we use your personal data for and why.
| What we use your personal data for | Our reasons |
|---|---|
| Creating and managing your account with us | To perform our contract with you or to take steps at your request before entering into a contract |
| Providing services to you | To perform our contract with you or to take steps at your request before entering into a contract |
| Conducting checks to identify you and verify your identity or to help prevent and detect fraud against you or us | To comply with our legal and regulatory obligations OR For our legitimate interests, ie to minimise fraud that could be damaging for you and/or us OR For our legitimate interests, ie to minimise fraud that could be damaging for you and/or us |
| Enforcing legal rights or defend or undertake legal proceedings | Depending on the circumstances:
|
| Customising our website and its content to your particular preferences based on a record of your selected preferences or on your use of our website | Depending on the circumstances:
|
| Communications with you not related to marketing, including about changes to our terms or policies or changes to the services or other important notices | Depending on the circumstances:
|
| Protecting the security of systems and data used to provide the services | To comply with our legal and regulatory obligations We may also use your personal data to ensure the security of systems and data to a standard that goes beyond our legal obligations, and in those cases our reasons are for our legitimate interests, ie to protect systems and data and to prevent and detect criminal activity that could be damaging for you and/or us |
| Statistical analysis to help us understand our customer base | For our legitimate interests, ie to be as efficient as we can so we can deliver the best service to you at the best price |
| Updating and enhancing customer records |
Depending on the circumstances:
|
| Disclosures and other activities necessary to comply with legal and regulatory obligations that apply to our business, eg to record and demonstrate evidence of your consents where relevant | To comply with our legal and regulatory obligations |
| Marketing our services to existing and former customers | For our legitimate interests, ie to promote our business to existing and former customers See ‘Marketing’ below for further information |
| To share your personal data with members of our group and third parties that will or may take control or ownership of some or all of our business (and professional advisors acting on our or their behalf) in connection with a significant corporate transaction or restructuring, including a merger, acquisition, asset sale, initial public offering or in the event of our insolvency In such cases information will be anonymised where possible and only shared where necessary | In such cases information will be anonymised where possible and only shared where necessary Depending on the circumstances:
|
We will not keep your personal data for longer than we need it for the purpose for which it is used. For example, to provide services required and for legal and compliance purposes where neccasary.
Different retention periods apply for different types of personal data.
If you stop using your account we will delete or anonymise your account data after 1 year.
The EEA, UK, Singapore and other countries outside the EEA, the UK and Singapore have differing data protection laws, some of which may provide lower levels of protection of privacy.
It is sometimes necessary for us to transfer your personal data to countries outside Singapore, the UK and EEA. In those cases we will comply with applicable Singaporean, UK and EEA laws designed to ensure the privacy of your personal data.
We will transfer your personal data to:
As we are based in Singapore we will also transfer your personal data from the EEA and UK to Singapore
Under data protection laws, we can only transfer your personal data to a country outside the UK/EEA where:
Where we transfer your personal data outside the UK we do so on the basis of an adequacy regulation or (where this is not available) [insert transfer mechanism, eg legally-approved standard data protection clauses recognised or issued further to Article 46(2) of the UK GDPR]. In the event we cannot or choose not to continue to rely on either of those mechanisms at any time we will not transfer your personal data outside the UK unless we can do so on the basis of an alternative mechanism or exception provided by UK data protection law and reflected in an update to this policy.
Any changes to the destinations to which we send personal data or in the transfer mechanisms we rely on to transfer personal data internationally will be notified to you in accordance with the section on ‘Changes to this privacy policy’ below.
A cookie is a small text file which is placed onto your device (eg computer, smartphone or other electronic device) when you use our website. We use cookies on our website. These help us authenticate you and your device and are only stored for previously authenticated users.
You generally have the following rights, which you can usually exercise free of charge:
| Access to a copy of your personal data | The right to be provided with a copy of your personal data |
| Correction (also known as rectification) | The right to require us to correct any mistakes in your personal data |
| Erasure (also known as the right to be forgotten) | The right to require us to delete your personal data—in certain situations |
| Restriction of use | The right to require us to restrict use of your personal data in certain circumstances, eg if you contest the accuracy of the data |
| Data portability | The right to receive the personal data you provided to us, in a structured, commonly used and machine-readable format and/or transmit that data to a third party—in certain situations |
| To object to use | The right to object:
|
| Not to be subject to decisions without human involvement | The right not to be subject to a decision based solely on automated processing (including profiling) that produces legal effects concerning you or similarly significantly affects you We do not make any such decisions based on data collected by our website |
| The right to withdraw consents | If you have provided us with a consent to use your personal data you have a right to withdraw that consent easily at any time You may withdraw consents by contacting us. Withdrawing a consent will not affect the lawfulness of our use of your personal data in reliance on that consent before it was withdrawn |
For further information on each of those rights, including the circumstances in which they do and do not apply, please contact us (see ‘How to contact us’ below).
If you would like to exercise any of those rights, please [complete a request form—available on our website at https://www.layermx.com/contact. When contacting us please:
provide enough information to identify yourself [(eg your full name, address and customer or matter reference number)] and any additional identity information we may reasonably request from you, and
let us know which right(s) you want to exercise and the information to which your request relates
We have appropriate security measures to prevent personal data from being accidentally lost, or used or accessed unlawfully. We limit access to your personal data to those who have a genuine need to access it.
We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.
We may change this privacy policy from time to time—when we make significant changes we will take steps to inform you, for example via email.