Personal Data Protection Policy

Personal Data Protection is important to us

Protection of your Personal Data is important to us. ClavystBio Pte Ltd’s Personal Data Protection Policy (“Policy”) outlines how we manage the Personal Data we hold. The Policy applies to:

  1. ClavystBio Pte Ltd (Registration Number 202027056H) that invests in the health and life sciences sector; and
  2. related corporations and affiliates of ClavystBio Pte Ltd,

referred to hereunder as “ClavystBio” “we”, “us” or “our”, collectively or singularly as the context requires.

ClavystBio recognises the importance of protecting Personal Data (as defined below in paragraph 1.1.

We respect the confidentiality of Personal Data and privacy of individuals and are committed to complying with the Singapore Personal Data Protection Act (Act 26 of 2012) (“PDPA”) and other applicable data protection laws, including the European Union (“EU”) General Data Protection Regulation (“GDPR”), where applicable. Please read this Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data.

We adopt a pragmatic “Data-light, Data-tight” approach in our business conduct.

“Data-light” means that we collect Personal Data only for what is required in business or in activities conducted by our organisation and will properly destroy the Personal Data once there is no business or legal purpose. We do not collect Personal Data randomly or indiscriminately without purpose.

“Data-tight” means that we do not disclose your Personal Data unless prior consent has been obtained and we have administrative, physical and Information Technology (IT) security measures to protect your Personal Data.

This Policy supplements and does not supersede nor replace any other consents you may have previously provided to us in respect of your Personal Data. This Policy also does not affect any rights which any member of ClavystBio may have at law in connection with the collection, use or disclosure of your Personal Data.

For the avoidance of doubt, to the maximum extent permitted under applicable law, nothing in this Policy establishes any joint and several liability on the part of ClavystBio members.

Generally, we receive your Personal Data for one or more of the specific purposes identified in this Policy based on your consent obtained. Where GDPR applies, the legal basis for our processing of your Personal Data would be that it is necessary for the legitimate interests pursued by us, or a third party which is described in paragraph 3.6 of this Policy. These legitimate interests include providing services to you where you are our client, managing the relationship between ClavystBio and you and facilitating internal business purposes and administrative purposes. In some cases, the provision and processing of your Personal Data may be a statutory and/or contractual requirement, or may be necessary in order to perform any contract you have agreed with us or to perform services that you have requested.

In addition, if your Personal Data has been collected, used or disclosed by us in a particular jurisdiction which has specific requirements or exceptions to the definition of Personal Data, including sensitive Personal Data, we will comply with those requirements under the applicable data protection regulations in that jurisdiction.

1. Your Personal Data


Personal Data” refers to any data or information about you from which you can be identified either (a) from that data alone; or (b) from that data combined with other information. Examples of such Personal Data which you may provide us include (depending on the nature of your interaction with us):

  1. your name, national registration identification number, passport number or other identification number, telephone number(s), mailing address, email address, facial image in a photograph or video recording, fingerprint and any other information relating to you which you have provided us in any form you may have submitted to us, or in other forms of interaction with you;
  2. information about your use of our websites and services, including cookies, IP addresses, subscription account
  3. details and membership details;
  4. our employment history, education background, and income levels; and
  5. your payment related information, such as your bank account or credit card information, and your credit history.

2. Collection of Personal Data


Generally, we collect your Personal Data in the following ways:

  1. when you submit forms relating to any of our programmes, products or services, or submit any online queries;
  2. when you register as a member on any of our websites owned and/or operated by us;
  3. when you interact with our customer service officers or any of our staff, for example, via face-to-face meetings, business interactions in events and exhibitions, telephone calls, letters, online forms (such as any “Contact Us” forms on our websites), online reservation chat, social media platforms and emails;
  4. when you participate in our programmes, or use our services or products;
  5. when you request that we contact you;
  6. when you respond to our request for additional Personal Data;
  7. when you ask to be included in an email or other mailing list;
  8. when you respond to our promotions or other initiatives;
  9. when you respond to our market surveys;
  10. when you submit a job application or any other application;
  11. when we receive references from business partners and third parties, for example, where you have been referred by them;
  12. when you submit your Personal Data to us for any other reason; and
  13. when you browse our website. Please refer to paragraph 8 (Cookie Policy) below for more information.

We may monitor or record phone calls and customer-facing interactions for quality assurance, employee training and performance evaluation, and identity verification purposes, and while receiving feedback, responding to your queries, requests and complaints and other related purposes. Such monitoring or recording will be done in accordance with applicable law.


If you provide Personal Data of a third party (e.g. information of your dependent, spouse, children and/or parents) to us, you represent and warrant that the collection, use and disclosure of that Personal Data to us, as well as the further processing of that Personal Data by us for the purposes set out in this Policy, is lawful.

3. Use and Disclosure of Personal Data


In general, we will, subject to applicable law, use and disclose your Personal Data for the following purposes:

  1. provide you with the products or services or information that you have requested;
  2. help us review, develop, improve, manage the delivery of, and to the extent this requires the use of Personal Data, enhance our programmes, products and services, including analysing future customer needs, conducting market research and data analytics (which does not involve automated profiling or result in automated decision-making activity which is regulated under the GDPR);
  3. communicate with you and respond to your queries, requests and complaints;
  4. provide ongoing information about our programmes and services which may be of interest to you;
  5. handle disputes and conduct and facilitate investigations and proceedings;
  6. protect and enforce our contractual and legal rights and obligations;
  7. prevent, detect and investigate crime, including fraud and money-laundering, and analyse and manage other commercial risks;
  8. manage our infrastructure and business operations and comply with internal policies and procedures;
  9. facilitate business asset transactions (which may extend to any merger, acquisition or asset sale) involving ClavystBio; and
  10. comply with any applicable rules, laws and regulations, codes of practice or guidelines or assist in law enforcement and investigations by relevant authorities.


In addition, we may use and disclose your Personal Data for the following purposes (among others), depending on the nature of our relationship with you:

  1. If you are a prospective tenant or a tenant of any of our properties:
    1. conduct due diligence checks;
    2. prepare lease and/or license documentation and any other documents as may be required;
    3. perform administration of the lease and/or licence;
    4. perform financial transactions such as rental payments;
    5. communicate with you changes and development to our policies, terms and conditions and other administrative information; and
    6. any other purpose related to any of the above.
  2. If you are a prospective user or a user of co-working space :
    1. conduct due diligence checks;
    2. prepare agreements and any other documents as may be required for your use of our co-working space;
    3. perform administration of agreements that you have with us, including access to our co-working space;
    4. perform financial transactions such as payments;
    5. communicate with you changes and development to our policies, terms and conditions and other administrative information; and
    6. any other purpose related to any of the above.
  3. If you are a vendor, a prospective vendor or a contractor:
    1. evaluate your proposal;
    2. conduct background checks on you;
    3. communicate with your deployed staff, after award of contract, who are in our properties to carry out work or services, and for any emergency or/and security concerns; and
    4. any other purpose related to any of the above.
  4. If you submit an application to us as a candidate for employment:
    1. process your application including pre-recruitment checks;
    2. provide or to obtain references for background screening/vetting;
    3. collect information about your suitability for the position applied for;
    4. organise training and staff development programmes;
    5. assess your performance;
    6. administer benefits and payroll processing;
    7. provide you with tools to facilitate or as required for you to do your job;
    8. communicate with you to comply with our policies and processes, including for business continuity purposes; and
    9. any other purposes related to the aforesaid.


The above purposes are not exhaustive, and depending on the nature of your relationship with us , we may collect, use and disclose your Personal Data for additional purposes which you will be notified of, in accordance with applicable terms and conditions.


When you apply for or hold a co-brand product or programme which is offered jointly by us and our co-brand partner(s), we may also collect, use and disclose your Personal Data for the purpose of sharing your Personal Data with the co-brand partners for offering, marketing and promoting to you any products, services, programmes, offers or events which the co-brand partner thinks may be of interest to you. We will only share your Personal Data with the co-brand partners where permitted by applicable law.


Your Personal Data will be protected and kept confidential, but subject to the provisions of any applicable law, your Personal Data may, depending on the programmes, products or services concerned, be disclosed to third parties . Your Personal Data will, in each case, only be disclosed to the extent necessary and proportionate.

In the event that your Personal Data is shared with a third party that acts with a member of ClavystBio as joint controllers under GDPR, we will, to the extent required by law, provide you with additional information on the responsibilities of each joint controller, any particular means by which you can enforce your rights and the primary contact person for such requests in relation to your rights.


We require that organisations outside ClavystBio which handle or obtain Personal Data as service providers to us acknowledge the confidentiality of this data, undertake to respect any individual’s right to privacy and comply with the PDPA, the GDPR and any other applicable data protection laws. As a requirement under these laws, we may be required to have specific agreements in place with such third parties to regulate and safeguard your data protection rights. We also require that these organisations use this information only for our purposes and follow our directions with respect to this information.

4. Transfer of Personal Data


Your Personal Data may be stored in external servers located overseas or in countries outside of your country of residence. In addition, as described above, in carrying out our business, it may be necessary to share information about you with and between our related corporations and affiliates, and third-party service providers, some of which may be located in countries outside your country of residence. We will take reasonable steps to ensure that your Personal Data transferred outside of your country of residence is adequately protected. In addition, we will ensure that such transfers comply with the requirements of the applicable data protection laws.

5. Retention of Personal Data


We may retain your Personal Data for as long as it is necessary for the purposes it has been collected, and (i) in most cases, up to 7 years; or (ii) in respect of any activities that may be carried out in the EU, up to 10 years, unless otherwise permitted by applicable law or in order to defend legal claims. Where we no longer require your Personal Data for those purposes, we will cease to retain such Personal Data in accordance with our internal retention policy.

6. Your Rights


You have the following rights, under applicable data protection laws (except where the exercise of these are restricted under applicable laws – for example, due to judicial proceedings or the carrying out of investigations):

  1. to obtain from us confirmation as to whether or not your Personal Data is being processed and request a copy of your information. Where legally required, we will provide your information in an easily accessible format and assist in transferring some of this information to third parties;
  2. rectification of your Personal Data. We endeavour to ensure that all Personal Data we have about you is accurate and up-to-date. We understand that this information changes frequently with changes of address and other personal circumstances. We encourage you to contact us as soon as possible to enable us to update any Personal Data we have about you. Incomplete or outdated Personal Data may result in our inability to provide you with programmes, products and services you have requested;
  3. where the processing of your Personal Data is carried out by automated means, you have the right to receive your Personal Data you have provided us in a structured, commonly used and machine-readable format or to demand transmission to another controller;
  4. in certain circumstances, you can request to have your Personal Data deleted or restrict the processing of it;
  5. if we process your information based on our legitimate interests explained above, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is necessary for legal reasons;
  6. prevent any processing of Personal Data that is causing or is likely to cause unwarranted and substantial damage or distress to you or another individual;
  7. be informed about any use of your Personal Data to make automated decisions about you where such decisions produce legal effects or have similarly significant effects on you, and to obtain meaningful information about the logic involved, as well as the significance and the envisaged consequences of this processing; and
  8. to lodge a complaint about the way in which your Personal Data is being used to a supervisory authority.


Where we rely on your consent to use your Personal Data, you have the right to withdraw that consent at any time. This withdrawal will however not affect the lawfulness of processing based on your consent before your withdrawal.

If you withdraw your consent to any or all purposes and depending on the nature of your request, we may not be in a position to continue to provide our products or services or programmes to you. Please note, however, that if you have provided us consent in respect of the use of your Singapore telephone number(s) for receiving marketing or promotional information, any such consent provided will not be affected by your withdrawal of your other consent in accordance with the terms set out in this Policy. If you do not wish for your Singapore telephone number(s) to be used for receiving marketing or promotional information, please contact us using our contact particulars set out below and specify that you wish to withdraw your consent for such purpose.


Where we process your Personal Data based on the legitimate interests referred to in paragraph 3.3 above, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is necessary for legal reasons.


Where mandated under the applicable data protection laws, your exercise of the rights described or referred to above shall be free of charge. In all other situations, we may charge a fee to cover the cost of verifying the request and locating, retrieving and copying any material requested.


If you want to exercise any of your rights or if you wish to raise a complaint on how ClavystBio has handled your Personal Data, you may contact us using the contact details provided in paragraph 7.1 below.

7. How to Contact Us


If you have any questions about this Policy or any queries relating to your Personal Data, or you would like to obtain access and/or make corrections to your Personal Data records, please contact us :


8. Governing Law


This Policy and your use of this website shall be governed in all respects by the laws of Singapore. For the avoidance of doubt, the applicable data protection laws will apply to the processing of your Personal Data.

9. Governing Law


This Policy will be reviewed from time to time by us. We may also from time to time update this Policy to take account of new laws and technology, changes to our operations and practices and the changing business environment. If you are unsure whether you are reading the most current version, please contact us.

As at 6 August 2022