Your personal data is important to NXGEN Asia Pte Ltd (“NXGEN”, “we”, “our” or “us”).
The purpose of this document (“Privacy Policy”) is to inform you of how NXGEN manages personal data in accordance with the Personal Data Protection Act 2012 of Singapore (“PDPA”) and other applicable data protection laws. Our personal data protection practices are aligned with the Data Protection Trustmark standard SS 714:2025. Please read this Privacy Policy so that you understand the purposes for which we collect, use and disclose your personal data, the legal bases on which we do so, and the rights available to you.
By interacting with us, accessing our websites, submitting information to us (whether through our websites or otherwise), or signing up for any products or services offered by us, you acknowledge that you have read and understood this Privacy Policy and, where we rely on consent, you consent to NXGEN and our respective agents collecting, using, disclosing and sharing your Personal Data, and disclosing such Personal Data to our service providers and relevant third parties in the manner set out in this Privacy Policy.
This Privacy Policy supplements but does not supersede or replace any other consent you may have provided to us, nor does it affect any rights we may have at law in connection with the collection, use or disclosure of your Personal Data. We may update this Privacy Policy from time to time, including to ensure consistency with our future development, industry trends, the SS 714:2025 standard and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of this Privacy Policy as updated from time to time on our website. Please check back regularly for updated information on the handling of your Personal Data.
1.1 In this Privacy Policy, “Personal Data” refers to any data, whether true or not, about an individual who can be identified:
a. from that data; or
b. from that data and other information to which we have or are likely to have access, including data in our records as may be updated from time to time.
1.2 The Personal Data you may provide to us includes, depending on the nature of your interaction with us, your name, NRIC/FIN, passport or other identification number, date of birth, gender, nationality, contact numbers, residential and/or mailing addresses, email address, and any other information relating to you or to individuals which you have provided in any forms submitted to us or via other forms of interaction. We collect only Personal Data that a reasonable person would consider appropriate in the circumstances and that is necessary for the purposes set out in this Privacy Policy.
2.1 Generally, we may collect your Personal Data in the following ways:
a. when you submit any online queries, including through the “Contact Us” page on our website;
b. when you submit forms relating to any of the products (“Relevant Products”) and/or services (“Relevant Services”) we represent, offer, sell or distribute;
c. when you purchase or use Relevant Products and/or Relevant Services;
d. when you interact with our customer service officers or any of our staff, for example via face-to-face meetings, business interactions at events and exhibitions, telephone calls, letters, emails, online forms and/or our social media channels;
e. when you are contacted by, and respond to, our marketing representatives and agents;
f. when you respond to our promotions and other initiatives, or participate in our promotional activities;
g. when you subscribe or ask to be included in our email or other mailing lists;
h. when you request that we contact you;
i. when you enter into an agreement and/or business relationship with us;
j. when you respond to our request for additional Personal Data;
k. when you submit a job application to NxGEN;
l. when we receive references from business partners and third parties, for example where you have been referred by them;
m. when your images are captured by us via CCTV cameras while you are within our premises, or in photographs or videos taken by us or our representatives when you attend events hosted by us at non-public spaces; and
n. when you submit your Personal Data to us for any other reason.
2.2 When you browse our websites, you generally do so anonymously, but please see Clause 10 (Use of Cookies) and Clause 11 (IP Address).
2.3 If you provide us with any Personal Data relating to a third party (e.g. information of your spouse, children, parents and/or employees), or where you refer a third party to us for the purpose of us offering Relevant Products and/or Relevant Services to that third party, you represent and warrant that you have obtained the consent of that third party for you to provide us with their Personal Data, and for us to collect, use and disclose it, for the purposes set out in this Privacy Policy.
3.1 In general, NxGEN collects, uses and discloses your Personal Data for purposes reasonable and appropriate in the circumstances, including the following:
a. to provide you with Relevant Products and/or Relevant Services that have been requested;
b. to profile, review, develop, manage and enhance the Relevant Products and/or Relevant Services, including by analysing customer needs;
c. to communicate with you and respond to your queries, requests and complaints;
d. to provide ongoing information about Relevant Products and/or Relevant Services;
e. to handle disputes and to conduct and facilitate investigations and proceedings;
f. to protect and enforce our contractual and legal rights and obligations;
g. to prevent, detect and investigate crime, including fraud and money laundering, and to analyse and manage other commercial risks;
h. to manage the business operations of NxGEN and to comply with our contractual obligations to third parties (including third parties on whose behalf we may be collecting, using and disclosing your Personal Data) and/or internal policies and procedures;
i. to process your job application;
j. to facilitate any proposed or actual business transaction (which may extend to any reorganisation, merger, acquisition or sale) involving NxGEN or TeleChoice;
k. to facilitate any proposed or actual business assignment, transfer, participation or sub-participation of any of our rights and obligations in respect of your relationship with us;
l. to comply with any applicable rules, laws and regulations, codes of practice or guidelines, or to assist in law enforcement and investigations by relevant authorities; and
m. purposes which are reasonably related to the aforesaid.
3.2 Without prejudice to Clause 3.1, if you are a vendor, a prospective vendor or a contractor (or an employee thereof), we collect, use and disclose your Personal Data:
a. to manage the outsourcing relationship;
b. to conduct background checks and due diligence;
c. to process any payments of invoices and claims, including payments to accounts payable;
d. to ensure the security of our premises; and
e. for any other purpose directly relating to any of the above.
3.3 Without prejudice to Clause 3.1, if you submit an application to us as a candidate for employment, we collect, use and disclose your Personal Data:
a. to process your application, including pre-recruitment checks;
b. In relation to particular Relevant Products and/or Relevant Services, or in your interactions with us, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. In such cases, we will collect, use and disclose your Personal Data for those additional purposes as well, unless we have specifically notified you otherwise.
4.1 We collect, use and disclose your Personal Data only where we are satisfied that we have a valid basis to do so under the PDPA. Depending on the circumstances, we may rely on:
a. your consent, given expressly or, where permitted under the PDPA, deemed by your conduct, by contractual necessity, or by notification (where we have taken reasonable steps to notify you of the purpose and you do not opt out within a reasonable period);
b. the legitimate interests exception, where the collection, use or disclosure is in our legitimate interests or those of another person, the benefit is not outweighed by any adverse effect on you, and we have conducted and documented an appropriate assessment;
c. the business improvement exception, for purposes such as improving or developing our products, services and operations, and understanding customer needs; and
d. any other exception, or where collection, use or disclosure without consent is required or authorised, under the PDPA or other applicable law.
4.2 Where we rely on consent, you may withdraw it in the manner set out in Clause 15 (Your Rights).
5.1 Your Personal Data will be protected and kept confidential. Subject to the provisions of any applicable law, your Personal Data may, depending on the product or service concerned and for the purposes listed above (where applicable), be disclosed to the following parties, who are required to protect it to a standard comparable to our own:
a. companies within the NXGEN group, our associated companies and our joint venture partners;
b. agents, contractors, third-party service providers and specialist advisers engaged to provide NXGEN with administrative, operational or other goods and services, such as telecommunications, information technology, payment, payroll, processing, training, market research, storage or archival services;
c. any third-party business partners who offer goods and services or sponsor contests or other promotional programmes, whether in conjunction with us or not;
d. insurers and credit providers;
e. where relevant, any debt collection agencies or dispute resolution centres;
f. any business partner, investor, assignee or transferee (actual or prospective) to facilitate a business transaction (which may extend to any reorganisation, merger, acquisition or sale) involving NXGEN or TeleChoice;
g. our professional advisers, including our auditors and lawyers;
h. any relevant government, statutory or regulatory authority (including a securities exchange) or law enforcement agency, in order to comply with any laws, rules or regulations, or any order, notice, directive or judgment of any court, tribunal, arbitration or mediation body;
i. anyone to whom we assign or transfer, or may assign or transfer, any of our rights and duties;
j. banks, credit card companies and their respective service providers; and
k. any other party as may be consented to by you, or as specified by you or the contract.
5.2 Where we engage third-party service providers to process Personal Data on our behalf, we do so under written contracts that require them to process Personal Data only for authorised purposes and to implement reasonable security arrangements to protect it.
If you have provided us with your Singapore telephone number(s) and have indicated that you consent to receiving marketing or other promotional information via such number(s), then from time to time we may contact you using those number(s) (including via voice calls, text, fax or other means) with information about our products and services (including discounts, special offers and event invitations), even if the number(s) are registered with the DNC Registry. You may at any time advise us in writing if you no longer wish to be contacted at your telephone number(s) for such purposes, and we will give effect to your request within the timeframe required by law.
7.1 We make reasonable security arrangements to protect Personal Data in our possession or under our control against unauthorised access, collection, use, disclosure, copying, modification, disposal, loss or similar risks. These measures include administrative, physical and technical controls such as access controls, network and endpoint security, encryption where appropriate, staff confidentiality obligations, and regular review of our security arrangements.
7.2 While we take reasonable steps to protect your Personal Data, no method of transmission over the Internet or method of electronic storage is completely secure. We therefore cannot guarantee absolute security, and any transmission of Personal Data is at your own risk.
We endeavour to ensure that Personal Data collected by us is accurate and complete where it is likely to be used by us to make a decision affecting you, or is likely to be disclosed to another organisation. To help us keep your Personal Data accurate and up to date, please inform us promptly of any changes to the Personal Data you have provided, or request a correction in accordance with Clause 15 (Your Rights).
9.1 We maintain a data breach management plan to assess, contain, remediate and record any suspected or actual data breach involving Personal Data in our possession or under our control.
9.2 Where a data breach is assessed to be notifiable under the PDPA — that is, where it results in, or is likely to result in, significant harm to affected individuals, or is of a significant scale — we will notify the Personal Data Protection Commission (“PDPC”) as soon as practicable, and in any case within three (3) calendar days, of establishing that the breach is notifiable. Where the breach is likely to result in significant harm to you, we will also notify you of the breach in the manner and within the timeframe required under the PDPA, unless an exception applies.
10.1 When you interact with us on our website, we automatically receive and record information on our server logs from your browser. We may assign one or more cookies to your device. A cookie is a small text file placed on your device, which may be used to collect information and statistics relating to your access to our website, including how you arrive at our website, your browser type and operating system, your IP address, and your click-stream information and time stamp (for example, which pages you viewed, when they were accessed and the time spent per page). The cookie provides a unique identifier to your device so that, on each subsequent visit from the same device, our server can recognise a returning visitor and enhance the functionality of our website for you.
10.2 The cookies placed by our server are readable only by us, and cannot access, read or modify any other data on your device.
10.3 Most browsers automatically accept cookies, but cookies can be enabled or disabled by modifying your browser settings. If you choose not to allow us to place a cookie on your device, you may be restricted from some services offered on our website, and some interactive features may be similarly restricted or rendered inoperable.
11.1 An IP address is a number automatically assigned to your device when you connect through an Internet Service Provider.
11.2 When you visit our website, your IP address is automatically logged on our server. We may use your IP address to help analyse trends, administer our website and track users’ movements. From your IP address we may identify the general geographic area from which you access our website, but not your exact location. Generally, we do not link your IP address to anything that can identify you, unless required by applicable laws and regulations.
Our websites may contain links to other websites operated by third parties, such as our business partners. We have no control over, and are not responsible for, the privacy practices of third-party websites linked to our websites. We encourage you to review the privacy policies of such third-party websites. Once you leave our website, you should check the applicable privacy policy of the third-party website to understand how it will handle any information it collects from you.
Where it is necessary to transfer Personal Data to third-party service providers, some of which may be located outside Singapore, we will take appropriate steps to ensure that the recipient is bound by legally enforceable obligations to provide the transferred Personal Data with a standard of protection at least comparable to that under the PDPA. We will ensure that such transfers comply with section 26 under the PDPA and the requirements of other applicable data protection laws.
14.1 We retain your Personal Data only for as long as it is necessary to fulfil the purposes for which it was collected, or as required or permitted by applicable law. In most cases, this is up to seven (7) years, unless a longer or shorter period is required or permitted by applicable law or is necessary to establish, exercise or defend legal claims.
14.2 When Personal Data is no longer required for any business or legal purpose, we will cease to retain it, or remove the means by which it can be associated with you, by securely destroying, deleting or anonymising it.
15.1 Subject to applicable law, you may request access to, and/or correction of, your Personal Data in our possession or under our control. We will respond to your request as soon as reasonably possible. If we are unable to respond within thirty (30) days of receiving your request, we will inform you in writing of the time by which we will be able to respond.
15.2 You may withdraw your consent to the collection, use and/or disclosure of your Personal Data in our possession or under our control, by giving us reasonable notice. Upon receipt of your withdrawal, we will inform you of the likely consequences. Please note that, depending on the nature of your request, NXGEN may not be able to continue its existing relationship with you or to provide certain Relevant Products and/or Relevant Services.
15.3 Where mandated under the applicable data protection laws, the exercise of the rights described above will be free of charge. In all other situations, we may charge a reasonable fee to cover the cost of verifying the request and locating, retrieving and copying any material requested; where a fee applies, we will inform you in advance and process the request only after you agree to the fee.
16.1 If you have any query or complaint regarding our collection, use or disclosure of your Personal Data, or wish to exercise any of your rights under Clause 15, you may contact our Data Protection Officer using the details set out in Clause 18.
16.2 We will acknowledge your query or complaint promptly and endeavour to resolve it within thirty (30) days. If more time is required, we will inform you of the reason and the expected timeframe. If you are not satisfied with the outcome, you may refer the matter to the PDPC.
17.1 NXGEN has appointed a Data Protection Officer who is responsible for ensuring our compliance with the PDPA and this Privacy Policy.
17.2 We maintain internal data protection policies and practices that are approved by management, communicated to relevant staff, and reviewed periodically. We provide training to our staff on the proper handling of Personal Data, and conduct data protection impact assessments and risk reviews where appropriate, with management-approved plans to address identified risks. These measures are aligned with the Data Protection Trustmark standard SS 714:2025.
If you have any questions about this Privacy Policy or any queries relating to your Personal Data, or you would like to withdraw your consent or to access and/or correct your Personal Data records, you may:
a. email our Data Protection Officer at privacy@nxgen.asia; or
b. write to us at:
Data Protection Officer
NXGEN Asia Pte Ltd
6 Serangoon North Avenue 5, #03-16
Singapore 554910
This Privacy Policy will be reviewed from time to time. We may update it to take account of new laws and technology, changes to our operations and practices, legislations, and the changing business environment. If you are unsure whether you are reading the most current version, please contact us.
This Privacy Policy shall be governed in all respects by the laws of Singapore.
Version as at 1 September 2026