The objectives of this Policy are to:
- Provide a set of privacy and personal data protection standards that govern our procedures and protect the privacy of your personal data.
- Demonstrate our on-going commitment to protecting your privacy and addressing any privacy concerns that you might have.
- Describe the ways in which we collect, use, disclose and retain your personal data.
- Ensure that we comply with the PDPA.
- Facilitate our compliance with any further developments in the protection of personal data.
SECTION 2: TYPE OF PERSONAL DATA
Generally, some of the Services require us to know who you are so that we can best meet your needs. When you sign-up on the Website, access the Services, complete a transaction, verify your credit card, place an order, or through any interaction with us via employment contracts, application or registration forms, emails, telephone calls, short messaging services (“SMS”), texts or other correspondence, we may ask you to voluntarily provide us with certain information that personally identifies you or could be used to personally identify you.
Without prejudice to the generality of the above, information collected by us from you may include (but is not limited to) the following:
- contact data (name, NRIC, passport or other identification number, telephone number(s), mailing address, email address, personal interests, and any other information provided us in any forms you may have submitted to us, interaction with Alternate Tone and its agents/employees, or through signing up on our Websites);
- other information that you voluntarily choose to provide to us (such as information shared by you with us through emails);
- financial information such as bank accounts, credit and debit card details or other payment instrument details;
- information received by body corporate under lawful contract or otherwise;
- employment record; employment history; education background or income levels;
- your use of our Services, including data of trading history, volume, patterns, predictions, trends;
- email and telephone call data records;
- photographs, video and CCTV footage;
- your use of Websites and Services, including cookies, IP address, policy and usage history information; and
- your usage of and interaction with our website and/or services including computer and connection information, device capability, bandwidth, statistics on page views, and traffic to and from our website
The information collected from you by Alternate Tone may constitute Personal Data under the PDPA. “Personal Data” is defined under the PDPA to mean any data, whether true or not, about an individual who can be identified from that data or from that data and other information to which an organisation has or is likely to have access. This would include, without limitation, information such as name, address, telephone number, e-mail address, credit card details and any other personal information.
Alternate Tone will be free to use, collect and disclose information that is freely available in the public domain without your consent. Information that is business contact information such as your name, position name or title, business telephone number, business address, business electronic mail address or business fax number and any other similar information about you, which are not provided by you for personal purposes, will not be regarded as Personal Data under the PDPA. Your consent to us collecting, using and disclosing any business contact information will not be required.
SECTION 3: COLLECTION OF PERSONAL DATA
Personal Data may be collected by us through processes including, but not limited to the following:
- when a user signs-up or registers on our Websites with us for an account;
- when you access our Website or perform an online transaction;
- when you interact with any of our employees (including our wealth managers, customer service officers);
- when customer submits an application to us to purchase our products or use our Services;
- when a customer asks to be included in an email or other mailing list;
- when an individual requests that we contact him/her;
- when an individual responds to our marketing initiatives, events, seminars, promotions or surveys;
- when an individual submits his/her application form for our Forex Foundation Course; Trainee Dealer Programmes and seminars; and
- when an individual applies for employment in Alternate Tone.
Information that you submit via any of our websites shall be deemed to be collected by us with your permission. Such information may include but is not limited to your name, contact and fax numbers, home, work and email addresses, credit card details, including the three-digit code that appears on the back of your credit card, date of birth, gender and lifestyle information and other information necessary to the provision of Services.
SECTION 4: CONSENT TO COLLECTION OF PERSONAL DATA
Alternate Tone shall not collect, use or disclose your personal data unless:
- you give, or are deemed to give, consent to the collection, use or disclosure of your personal data; or
- the collection, use or disclosure of your personal data without your consent is required or authorised under the PDPA or other written law.
Alternate Tone shall not, as a condition of providing a product or service to you, require you to consent to the collection, use or disclosure of your personal data beyond what is reasonable to provide the product or Service to you.
Alternate Tone shall not obtain or attempt to obtain your consent for collecting, using or disclosing personal data by providing false or misleading information with respect to the collection, use or disclosure of your personal data, or use deceptive or misleading practices.
As part of our continuous effort to keep you informed on our new product and services, we may mail, email, telephone and contact you by any other means. Information sent to you may also include upcoming special events, seminars or other relevant information that may be of interest to you.
You may also receive mailings or other communications materials from our strategic marketing partners and/or carefully selected third parties. You will always have the option to decline any or all of these communications by following the directions included in our emails or other communications, or by contacting the Data Protection Officer of Alternate Tone directly (see Section 18 below).
Alternate Tone may collect and use personally identifiable information that you volunteer, or other behavioral data and big data generated. In addition to that, permission will be deemed given for communication from us that are necessary to fulfill transactions and services requested by you.
Photographs, videos and CCTV footage may constitute personal data if an identifiable individual is captured. Alternate Tone will either seek your written consent for the collection, use and disclosure of photographs, videos and/or CCTV footage of you, or state in the invitation to you of an event/seminar, that photographs/videos/CCTV footage will be taken at the event/seminar for publicity on Alternate Tone’s print and electronic media. Appropriate and obvious notices shall also be put up at the reception or entrance of our event/seminar to inform attendees on the event/seminar day.
SECTION 5: PURPOSES FOR WHICH WE COLLECT AND USE PERSONAL DATA
Alternate Tone may collect, use or disclose your personal data only for purposes:
- that a reasonable person would consider appropriate in the circumstances; and
Alternate Tone collects and uses the Personal Data that you provide to us depending on your relationship with us (e.g. as an applicant, student or other person relating to Alternate Tone ).
In general, Alternate Tone may collect, use and/or disclose your Personal Data for the following purposes:
- maintaining records of Alternate Tone’s interactions with you, through telephone recordings, documentation (hard copy and electronic), and
- internal reporting and analysis related to Alternate Tone ’s business operations;
- responding to your queries and requests and handling complaints;
- updating you on developments in our services and special happenings;
- assessing and processing any applications, requests and instructions for products and services offered by Alternate Tone ;
- establishment and maintenance of relationship with Alternate Tone and/or within Alternate Tone ’s related companies;
- marketing and promotion activities of Alternate Tone;
- taking of photographs and/or videos (whether by our staff or third party photographers and/or videographers) during events or seminars organised by Alternate Tone or its affiliates for publicity purposes;
- if consented to in the registration form and/or other methods of consent notification, providing marketing, advertising and promotional information via postal mail, electronic mail, SMS or MMS, fax and/or voice calls;
- any other purposes which Alternate Tone may inform you of in writing from time to time, but for which Alternate Tone will seek your separate consent; and
- any other purposes related to the above purposes.
Where you have specifically provided Alternate Tone with additional consents, Alternate Tone may also collect, use and/or disclose your Personal Data for the following purposes:
- providing you benefit, including without limitation promotions, loyalty and reward programmes and sending you details of products, services, special offers and rewards, either to our customers generally, or which may be of interest to you;
- matching your Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with the provision or offering of products and services, whether by any Alternate Tone company, or other third parties;
- fulfilling your referral requests;
- administering contests and competitions;
- developing special offers and marketing programmes.
If you have provided your Singapore telephone number(s) and have indicated that your consent to receiving marketing or promotional information via your Singapore telephone number(s), then from time to time, Alternate Tone may contact you using such Singapore telephone number(s) (including via voice calls, SMS, fax or other means) with information about Alternate Tone’s products and services.
SECTION 6: DISCLOSURE OF PERSONAL DATA
Alternate Tone will only disclose Personal Data:
- for the primary purpose for which it was collected as outlined in Section 5 above;
- for purposes that a reasonable person will consider appropriate in the circumstances;
- where you have consented; or
- where permitted under the PDPA or other applicable law or if required by law.
In addition, Alternate Tone would disclose Personal Data in the following circumstances:
- in response to a request from law enforcement authorities or other government officials;
- to comply with a court order or direction from a government agency or regulatory authority ordering the disclosure of the Personal Data; and
- where the disclosure is necessary for investigations or legal proceedings.
SECTION 7: ADDITIONAL PRIVACY STATEMENTS FOR WEBSITE AND SERVICE USERS
7.1 Persons who have visited and signed up on our Websites (“Users”) Note:
This section applies to all Users.
- As part of the signing-up process that is available to Users on this Website, certain information, including Personal Data or sensitive personal information is collected from the Users.
- If you have inadvertently submitted any such information to Alternate Tone prior to reading the privacy statements set out herein, and you do not agree with the manner in which such information is collected, processed, stored, used or disclosed, then you may access, modify and delete such information by using options provided on the Website. In addition, you can, by sending an email to email@example.com inquire whether Alternate Tone is in possession of your Personal Data, and you may also require Alternate Tone to delete and destroy all such information.
- Users’ personally identifiable information, which they choose to provide on the Website when they sign up, is used:
- to help the Users describe/identify themselves;
- request for more information from Alternate Tone;
- register an Account if User so decides;
- and if User consents, for Alternate Tone to inform User about portal content updates, any of Alternate Tone ’s new products and other updates.
Other information that does not personally identify the Users as an individual, is collected by Alternate Tone from Users (such as, your computer’s internet protocol (IP) address which provides us with information that helps us learn about your browser and operating system) and is exclusively owned by Alternate Tone. Alternate Tone may also use such information in an aggregated or non-personally identifiable form for research, statistical analysis and business intelligence purposes, and may sell or otherwise transfer such research, statistical or intelligence data in an aggregated or non-personally identifiable form to third parties and affiliates. In particular, Alternate Tone reserves with it the right to use anonymized User demographics information for the following purposes:
- Analyzing software usage patterns for improving product design and utility.
- Analyzing such information for research and development of new technologies.
- Using analysis of such information in other commercial product offerings of Alternate Tone .
- Sharing analysis of such information with third parties for commercial use.
The Website uses temporary cookies to store certain data (that is not sensitive personal data or information) that is used by Alternate Tone and its service providers for the technical administration of the Website, research and development, and for User administration. In the course of serving advertisements or optimizing services to Users, Alternate Tone may allow authorized third parties to place or recognize a unique cookie on the User’s browser. The cookies however, do not store any Personal Data of the User. You may adjust your internet browser to disable cookies. If cookies are disabled you may still use the Website, but may be limited in the use of some of the features.
Alternate Tone will communicate with the Users through email, telephone and notices posted on the Website or through other means available through the service, including SMSs, text and other forms of messaging]. The Users can change their e-mail and contact preferences at any time by sending an email to firstname.lastname@example.org.
At times, Alternate Tone conducts a User survey to collect information about Users’ preferences. These surveys are optional and if Users choose to respond, their responses will be kept anonymous. The demographic information that Alternate Tone collects in the registration process and through surveys is used to help Alternate Tone improve its Services to meet the needs and preferences of Users. This may include targeting advertising through marketing newsletters to Users about our Services.
Alternate Tone may keep records of electronic communications and telephone calls received and made for making appointments or other purposes for the purpose of administration of Services, customer support, research and development.
All Alternate Tone employees and data processors, who have access to, and are associated with the processing of sensitive personal data or information, are obliged to respect the confidentiality of every Users’ Personal Data or sensitive personal information.
ix. To the extent necessary to provide Users with the Services, Alternate Tone may provide their Personal Data to third party contractors who work on behalf of or with Alternate Tone to provide Users with such Services, to help Alternate Tone communicate with Users or to maintain the Website. Generally, these contractors do not have any independent right to share this information, however certain contractors who provide services on the Website, including the providers of online communications services, may use and disclose the personal information collected in connection with the provision of these Services in accordance with their own privacy policies. In such circumstances, you consent to us disclosing your personal information to contractors, solely for the intended purposes only.
x. Users may choose to unsubscribe from marketing communications that they receive from Alternate Tone by clicking the ‘unsubscribe’ link provided at the end of every such promotional communication.
v. Alternate Tone does not control or endorse the content, messages or information found in any Services and, therefore, Alternate Tone specifically disclaims any liability with regard to the Services and any actions resulting from your participation in any Services, and you agree that you waive any claims against Alternate Tone relating to same, and to the extent such waiver may be ineffective, you agree to release any claims against Alternate Tone relating to the same.
vi.You may choose to unsubscribe from marketing communications that you receive from Alternate Tone by clicking the ‘unsubscribe’ link provided at the end of every such promotional communication.
ix. If you wish to opt-out of receiving non-essential communications such as promotional and marketing-related information regarding the Services, please send us an email at email@example.com.
7.3 Casual Visitors Note:
- No sensitive personal data or information is automatically collected by Alternate Tone from any casual visitors of this website, who are merely perusing the Website.
- If you, as a casual visitor, have inadvertently browsed any other page of this Website prior to reading the privacy statements set out herein, and you do not agree with the manner in which such information is collected, processed, stored, used, disclosed or retained, merely quitting this browser application should ordinarily clear all temporary cookies installed by Alternate Tone . All visitors, however, are encouraged to use the “clear cookies” functionality of their browsers to ensure such clearing / deletion, as Alternate Tone cannot guarantee, predict or provide for the behavior of the equipment of all the visitors of the Website.
SECTION 8: SHARING AND TRANSFER OF PERSONAL DATA
In general, the third-party providers used by us, such as data intermediaries and aggregators, will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to us.
In the course of or in connection Alternate Tone ’s business operations, which includes, providing products and services to customers, Alternate Tone may transfer Personal Data to the following parties for the following purposes:
- to our vendor data aggregators for the collection and storing of Personal Data from Data Subjects;
- to our data intermediaries for the processing of Personal Data, including financial data from users of our Websites
- To government and non-government authorities, agencies and/or regulators as required under law or under directions or orders from the government and non-government authorities, agencies and/or regulators for security, regulatory approvals or permits;
- To event organisers and service providers to facilitate the planning of seminars/ publicity events / functions that Alternate Tone organises or is involved in;
- Professional, financial and legal advisors, tax advisors, auditors, insurers and insurance brokers.
However, certain third-party service providers, such as payment gateways and other payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions.
For these providers, we recommend that you read their privacy policies so you can understand the manner in which your personal information will be handled by these providers.
In particular, remember that certain providers may be located in or have facilities that are located a different jurisdiction than either you or us. So if you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.
As an example, if you are located in Canada and your transaction is processed by a payment gateway located in the United States, then your personal information used in completing that transaction may be subject to disclosure under United States legislation, including the Patriot Act.
Alternate Tone requires that the parties to whom we transfer Personal Data and our service providers implement adequate levels of protection in order to protect Personal Data. We also require that these parties only process Personal Data strictly for purposes for which we engage them for and consistent with the purposes that we have described in the Section 5 “Purposes for which we collect and use Personal Data” or with other purposes for which consent has been sought and obtained.
SECTION 9: CONFIDENTIALITY AND SECURITY
Your Personal Data is maintained by Alternate Tone in electronic form on its equipment, and on the equipment of its employees. Such information may also be converted to physical form from time to time. Alternate Tone takes all necessary precautions to protect your personal information both online and off-line, and implements reasonable security practices, precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed, including certain managerial, technical, operational and physical security control measures that are commensurate with respect to the information being collected and the nature of Alternate Tone ’s business.
No administrator at Alternate Tone will have knowledge of your password. It is important for you to protect against unauthorized access to your password, your computer and your mobile phone. Be sure to log off from the Website when finished. Alternate Tone does not undertake any liability for any unauthorised use of your account and password. If you suspect any unauthorized use of your account, you must immediately notify Alternate Tone by sending an email to firstname.lastname@example.org You shall be liable to indemnify Alternate Tone due to any loss suffered by it due to such unauthorized use of your account and password.
Alternate Tone makes all Personal Data accessible to its employees, agents or partners and third parties only on a need-to-know basis, and binds only its employees to strict confidentiality obligations.
Notwithstanding the above, Alternate Tone is not responsible for the confidentiality, security or distribution of your personal information by our partners and third parties outside the scope of our agreement with such partners and third parties. Further, Alternate Tone shall not be responsible for any breach of security or for any actions of any third parties or events that are beyond the reasonable control of Alternate Tone including but not limited to, acts of government, computer hacking, unauthorised access to computer data and storage device, computer crashes, breach of security and encryption, poor quality of Internet service or telephone service of the User and/or Subscriber etc.
SECTION 10: AGE OF CONSENT
By using the Websites, you represent that you are at least the age of majority in your state or province of residence, or that you are the age of majority in your state or province of residence and you have given us your consent to allow any of your minor dependents to use this site.
Alternate Tone strongly encourages parents and guardians to supervise the online activities of their minor children and consider using parental control tools available from online services and software manufacturers to help provide a child-friendly online environment. These tools also can prevent minors from disclosing their name, address, and other personally identifiable information online without parental permission. Although the Alternate Tone Websites and Services are not intended for use by minors, Alternate Tone respects the privacy of minors who may inadvertently use the internet or the mobile application.
SECTION 11: ACCURACY
Alternate Tone will take reasonable efforts to ensure that any Personal Data collected is accurate and up to date by updating its records whenever changes to information come to its attention. Alternate Tone will disregard information which seems, on a reasonable basis, to be inaccurate or out of date by reason of the time which has elapsed since it was collected or by reason of any other information in its possession.
SECTION 12: RETENTION OF PERSONAL DATA
Alternate Tone only retains Personal Data for as long as the retention is required for the purposes for which we collected the Personal Data, the purposes described in this Policy and for our business and legal purposes. Generally, we do not retain Personal Data for a period of longer than  years after the original purposes for which the Personal Data was collected have ceased to be applicable, unless otherwise required by law or other mandatory directions by court or government authorities or for purposes of legal proceedings or other similar proceedings or investigations.
For job applicants who were interviewed by the Company but were unsuccessful, Alternate Tone will retain your Personal Data for no longer than  year for the purposes of evaluating your suitability for future job openings within Alternate Tone , unless you inform us otherwise.
SECTION 13: ACCESS, CORRECTION OR UPDATE OF PERSONAL DATA
If you have any questions about the use of your Personal Data (including how your Personal Data has been used and to whom it has been disclosed), or if you wish to correct, delete or update any of your Personal Data held by Alternate Tone , you may submit a written request via email to email@example.com and request for our Request for Access of Personal Data form or Request for Update/Correction of Personal Data form.
We will endeavour to acknowledge the receipt of your request within 3 working days after the date of receipt of your request if it is sent by e-mail, or within 7 days after the date of receipt of your request if it is sent by post. As it is important to us that the Personal Data that we have about you is accurate and complete, it may be necessary for us to request for supporting documentation from you. We will contact you if we require supporting documentation from you.
There may be circumstances where Alternate Tone will not correct, delete or update your Personal Data, including: (a) where the Personal Data is opinion data that is kept solely for evaluative purpose; and (b) the Personal Data is in documents related to a prosecution if all proceedings relating to the prosecution have not been completed.
Alternate Tone shall have the right to request for information for the purposes of verification of your identity and for more information about your request. As allowed under the PDPA, Alternate Tone reserves a right to charge an administrative fee to respond to the request set out above.
SECTION 14: TRANSFER OF PERSONAL DATA OUTSIDE OF SINGAPORE
SECTION 15: YOUR REQUESTS AND FEEDBACK ON YOUR PERSONAL DATA WITH US
You may request for information from Alternate Tone on what Personal Data of yours we have and how we have used and shared your Personal Data during the last one year before the date of your request.
To learn more about how you can request for information from Alternate Tone , please see our Request for Access of Personal Data form.
You may also choose to withdraw your consent to Alternate Tone ’s use, collection, sharing or processing of your Personal Data at any time. To learn more about how you can withdraw your consent, please see our Request for Withdrawal of Personal Data form. Please understand that your withdrawal of your consent to our use of your Personal Data may affect our provision of products and services to you or our business dealings with you, depending on the nature of your relationship with us.
If you have any concerns, feedback or complaints about the use and/or sharing of your Personal Data, you may contact us at firstname.lastname@example.org.
SECTION 16: DO NOT CALL PROVISIONS
Alternate Tone shall not, and shall ensure that its agents shall not, send a specified message to a Singapore telephone number without first checking with the Do Not Call Registry established by the Personal Data Protection Commission (“PDPC”) and receiving confirmation from the PDPC that such Singapore telephone number is not listed on the Do Not Call Register.
Alternate Tone shall not, and shall ensure that its agents shall not, send a specified message to a Singapore telephone number, unless the specified message includes clear and accurate information identifying the person sending the specified message and/or the specific Alternate Tone company, and such person’s and/or such Alternate Tone company’s contact information.
The prescribed duration within which Alternate Tone must check with the Do Not Call Registry before sending a specified message to a Singapore telephone number will be 30 days. You may continue to receive marketing messages and other product information from Alternate Tone within the prescribed validity period.
Alternate Tone shall not make, cause or authorise a voice call addressed to a Singapore telephone number that conceals or withholds, or that has the effect of concealing or withholding, the calling line identity from the recipient.
Alternate Tone will not require a subscriber or users of a Singapore telephone number to consent to the sending of a specified message beyond what is reasonable for Alternate Tone to provide its products, courses and services. Alternate Tone will not obtain or attempt to obtain such consent by:
- providing false or misleading information; or
- using deceptive or misleading practices.
If a subscriber or user of a Singapore telephone number gives notice withdrawing consent for the sending of a specified message to that number, then Alternate Tone shall cease (and cause its agents to cease) sending specified messages to that number.
If a User or Subscriber uses the Services; or accesses the Website after a notice of changes has been sent to such User or Subscriber, or published on the Website, such User or Subscriber hereby provides his/her/its consent to the changed terms.
SECTION 18: HOW TO CONTACT US
[Alternate Tone Pte Ltd]
29B Seah Street, Spore 188385
Copyright © 2019 Alternate Tone Pte Ltd. All rights reserved.
Alternate Tone Pte Ltd- Music School
29b Seah St - Singapore - 188385
Tel: +65 8115 9378
Open: Mo-Fr 12:30-21:30