Privacy Policy

Data Protection Policy

The purpose of this document (the "Data Protection Policy") is to inform you of how the Association of Cryptocurrency Enterprises and Start-ups, Singapore ("ACCESS") manages Personal Data that is subject to the Singapore Personal Data Protection Act 2012 (No. 26 of 2012) (the "Act"). Please take a moment to read this Data Protection Policy so that you understand the purposes for which we collect, use and disclose your Personal Data.

By interacting with us, submitting information to us, applying for membership, or registering for any of our events, programmes or services, you agree and consent to ACCESS and its representatives and agents (collectively "ACCESS", "us", "we" or "our") collecting, using and disclosing your Personal Data, and disclosing such Personal Data to our authorised service providers and relevant third parties, in the manner set out in this Data Protection Policy.

ACCESS is a non-profit industry association registered as a society in Singapore under UEN T14SS0083D. We are funded by membership subscriptions, event fees and sponsorships. We do not sell Personal Data, and we do not licence or rent it to third parties for their own marketing.

This Data Protection Policy supplements but does not supersede or replace any other consent you may previously have given to ACCESS in respect of your Personal Data. Your consent under this Data Protection Policy is additional to any rights we may have at law to collect, use or disclose your Personal Data.

ACCESS may update this Data Protection Policy from time to time to keep it consistent with developments in our activities and with changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing version of this Data Protection Policy as published on our website at https://access.org.sg/. Please check back for updated information on how we handle your Personal Data.

1. Personal Data

1.1 In this Data Protection Policy, "Personal Data" means data, whether true or not, about an individual who can be identified (a) from that data, or (b) from that data together with other information to which we have or are likely to have access, including data in our records as updated from time to time.

1.2 Examples of Personal Data you may provide to us include, depending on the nature of your interaction with us, your name, job title, organisation, work and mobile telephone numbers, mailing address, email address, biography, photograph, and any other information about individuals that you provide in forms submitted to us or through other interactions with us.

1.3 We do not require your NRIC, FIN or passport number in order for you to become a Member, attend our events or serve on a committee. Where a venue, government building, overseas delegation or travel booking requires identification particulars, we will tell you why it is needed, collect only what is required, and delete it once that purpose has been fulfilled.

2. Collection of Personal Data

2.1 We generally collect Personal Data in the following ways:

(a) when you or your organisation submits a membership application, registration form, or other form relating to our activities, events or services;

(b) when you enter into any agreement with us, or provide documentation or information in connection with your interactions with us;

(c) when you interact with our Secretariat or office bearers, for example by telephone, email, letter, social media or in person;

(d) when you use our website, membership portal, event registration pages or other online services;

(e) when you ask to be contacted, or ask to be included on a mailing list;

(f) when you respond to our announcements, consultations or calls for participation;

(g) when you are nominated by your organisation as a membership contact, billing contact, committee representative or working group participant;

(h) when you volunteer for, are nominated to, or are appointed to a committee, sub-committee, working group or office bearer position;

(i) when you submit an application for employment, internship or a volunteer role, including a resume or curriculum vitae;

(j) when your image is captured in photographs, video or audio recordings taken by us or our representatives at our events, or by CCTV at a venue we are using;

(k) when you complete a survey administered by us or by a service provider on our behalf;

(l) when we receive a referral or introduction from a member, partner association, sponsor or other third party;

(m) when we identify you through publicly available professional sources, such as company websites, professional networking platforms, regulatory registers and industry directories, in the course of membership outreach or policy engagement; and

(n) when you submit your Personal Data to us for any other reason.

2.2 You may generally browse our website anonymously. We do not automatically collect Personal Data through our website unless you provide it or log in with your account credentials. We do collect technical data such as IP address, browser type and pages visited, as described in Clause 6.

2.3 If you provide us with Personal Data relating to a third party, for example your colleagues, a speaker you are nominating, or a delegate you are registering, you represent to us that you have obtained that person's consent to provide their Personal Data to us for the relevant purposes.

2.4 You should ensure that the Personal Data you submit to us is complete, accurate and current. If it is not, we may be unable to administer your membership, register you for an event, or provide the services you have requested.

3. Purposes for the Collection, Use and Disclosure of Your Personal Data

3.1 Generally, ACCESS collects, uses and discloses your Personal Data for the following purposes:

(a) responding to your queries, feedback, complaints and requests;

(b) verifying your identity and your authority to act for your organisation;

(c) managing the administrative and operational affairs of ACCESS and complying with our Constitution, by-laws and internal policies;

(d) maintaining the register of Members and office bearers required under the Societies Act 1966 and our Constitution, and making the filings required by the Registry of Societies;

(e) convening and administering board meetings, committee meetings, annual general meetings and extraordinary general meetings, including notices, nominations, elections, proxies, voting, attendance records and minutes;

(f) requesting feedback or participation in surveys, and conducting research and analysis to help us review and improve our activities and services;

(g) preparing and submitting industry position papers, consultation responses and representations to the Monetary Authority of Singapore and other authorities on behalf of the sector;

(h) managing the safety and security of venues and events, including access control and security clearances where a venue requires them;

(i) in connection with any claim, action or proceeding, including obtaining legal advice and facilitating dispute resolution, and protecting and enforcing our contractual and legal rights;

(j) conducting investigations relating to disputes, billing or fraud;

(k) complying with any applicable law, regulation, code of practice or guideline binding on ACCESS, including responding to regulatory queries, making disclosures to regulatory bodies, and conducting audits and due diligence; and

(l) any purpose reasonably related to the above.

3.2 In addition, ACCESS collects, uses and discloses your Personal Data for the following purposes:

(a) If you have registered for our events, programmes or courses:

(i) assessing and processing your registration or application;

(ii) creating and maintaining a participant record in our database for internal reference;

(iii) providing participant support;

(iv) invoicing and collection, and administering debt recovery where applicable;

(v) administering and conducting the event or programme, including registration, badging, venue access, catering arrangements, recording attendance, processing payment, and contacting you on administrative matters;

(vi) preparing delegate lists and, where applicable, sharing them with co-organisers and participants so that the session can function;

(vii) producing publicity and post-event materials, including write-ups, photographs and recordings, in accordance with Clause 3.6; and

(viii) any purpose reasonably related to the above.

(b) If you are a director, office bearer or committee member of ACCESS:

(i) facilitating your nomination, election and appointment;

(ii) recording your attendance, contributions and voting at meetings, and preparing minutes;

(iii) updating your particulars in the relevant statutory registers and filings;

(iv) arranging local transport and overseas travel in connection with your role; and

(v) any purpose reasonably related to the above.

(c) If you participate in a working group, sub-committee or industry consultation:

(i) constituting the group and circulating participant lists to its members;

(ii) coordinating meetings, drafting and review cycles;

(iii) attributing or acknowledging contributions in industry submissions and publications, where you have agreed to be named; and

(iv) any purpose reasonably related to the above.

(d) If you are an employee or representative of a Member or prospective Member:

(i) processing the membership application and assessing suitability for membership;

(ii) administering the membership, including subscriptions, renewals and access to member benefits;

(iii) recording your attendance at our meetings, seminars and events;

(iv) providing member service and support; and

(v) any purpose reasonably related to the above.

(e) If you are a speaker, moderator, sponsor or exhibitor:

(i) coordinating your participation, including scheduling, briefing and logistics;

(ii) publishing your name, title, organisation, biography and photograph in event collateral, on our website and on social media;

(iii) acknowledging sponsors and partners in our materials and annual report; and

(iv) any purpose reasonably related to the above.

(f) If you submit an application to us as a candidate for employment, internship or a volunteer role:

(i) processing your application and conducting interviews;

(ii) obtaining references and conducting background checks;

(iii) assessing your suitability for the position; and

(iv) any purpose reasonably related to the above.

(g) If you are an employee, officer or owner of a vendor or service provider engaged or being considered by ACCESS:

(i) managing tenders and quotations, processing orders, and managing the supply of goods and services;

(ii) processing and paying invoices;

(iii) managing our operations; and

(iv) any purpose reasonably related to the above.

3.3 Additional purposes. Where permitted under the Act, ACCESS may also collect, use and disclose your Personal Data to:

(a) inform you about our events, programmes, publications, member benefits and calls for participation;

(b) circulate newsletters, regulatory updates and consultation alerts relevant to the sector;

(d) any purpose reasonably related to the above.

3.4 Marketing to Singapore telephone numbers. Where you have provided a Singapore telephone number and consented to receiving promotional information at that number, we may contact you by voice call, text or other means with information about our events and activities. We comply with the Do Not Call provisions of the Act, and will not send such messages to a number registered on the Do Not Call Registry unless you have given clear and unambiguous consent in writing or an exemption applies.

3.5 Withdrawal of marketing consent. Every newsletter and promotional message we send includes an unsubscribe option. You may also write to us at any time to change the lists you are on. We will continue to send you administrative communications relating to your membership, meetings you are entitled to attend, and transactions you have with us.

3.6 Event photography and recording. We photograph and may record our events, and use the resulting material in event write-ups, newsletters, our website, social media, our annual report and promotion of future events. We will tell you in the registration materials or by signage at the venue when an event is being photographed or recorded. If you would prefer not to appear, please tell the Secretariat or the event team, and we will do our best to accommodate you and will remove published material within our control on request. Sessions held under Chatham House Rule or on a closed-door basis are not recorded for publication; where we record such a session in order to prepare internal minutes, we will say so in advance.

3.7 Other notified purposes. In relation to particular activities or interactions, we may separately notify you of other purposes for which we collect, use or disclose your Personal Data. Where we do, we will collect, use and disclose your Personal Data for those additional purposes as well, unless we notify you otherwise.

4. Disclosure of Personal Data

4.1 ACCESS takes reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to applicable law, your Personal Data may be disclosed for the purposes set out above, to the following parties, whether located in Singapore or overseas:

(a) your employer or the Member organisation you represent, including its primary ACCESS contact;

(b) other Members and participants, where delegate lists, committee rosters and working group membership are circulated so that the group can function;

(c) co-organisers, host venues, sponsors and exhibitors for our events. Where a sponsor will receive attendee contact details, we will tell you at the point of registration and offer you the option to opt out;

(d) agents, contractors and service providers who provide operational services to ACCESS, including information technology, email and membership platforms, event registration tools, printing, courier, payment processing, bookkeeping and secretarial services;

(e) partner associations, industry bodies and event organisers with whom we run joint initiatives;

(f) training institutions, trainers and programme partners, in connection with our courses and programmes;

(g) banks, payment providers and their respective service providers;

(h) our professional advisers, including auditors, accountants, consultants and lawyers;

(i) media organisations, in connection with publicity for our events, awards and publications;

(j) relevant government ministries, regulators, statutory boards and authorities, including the Monetary Authority of Singapore, the Registry of Societies and the Inland Revenue Authority of Singapore, and law enforcement agencies, in order to comply with applicable laws, regulations and lawful requests; and

(k) any other party to whom you authorise us to disclose your Personal Data.

4.2 Parties to whom we disclose Personal Data are permitted to use it only for the purpose for which it was disclosed, in accordance with our instructions. They are not permitted to use it for their own marketing.

4.3 Where we transfer Personal Data outside Singapore, we take reasonable steps to ensure that the recipient is bound to a standard of protection comparable to that required under the Act, ordinarily through contractual commitments in our service agreements.

5. Data Security and Retention

5.1 ACCESS makes reasonable security arrangements to protect Personal Data in our possession or under our control against unauthorised access, collection, use, disclosure, copying, modification or disposal. However, we cannot completely guarantee the security of Personal Data collected from or about you, or that no harmful code will enter our website. You should be aware of the risks associated with using websites and the internet.

5.2 We cannot ensure the security of information you transmit to us over the internet, and we encourage you to take precautions when doing so. Please do not send sensitive information such as full payment card details by email.

5.3 Where you hold login credentials for our membership portal or other systems, you undertake to keep your username and password confidential, not to disclose them to any unauthorised person, and to notify us as soon as reasonably practicable if you know or suspect that they have been compromised.

5.4 Directors, office bearers and volunteers who handle Member or participant data in the course of their role are required to keep it confidential, use it only for ACCESS purposes, and return or delete it when their appointment ends.

5.5 We retain Personal Data only for as long as necessary to fulfil the purpose for which it was collected, or as required or permitted by law. Statutory and governance records, including the register of Members and office bearers, minutes, resolutions and financial records, are retained for the periods required under Singapore law. We will cease to retain Personal Data, or remove the means by which it can be associated with you, once retention no longer serves the purpose for which it was collected and is no longer necessary for legal or operational purposes.

5.6 In the event of a data breach, our Data Protection Officer will assess the incident and, where required, notify affected individuals and the Personal Data Protection Commission in accordance with the Act.

6. Cookies and Third Party Sites

6.1 Our website uses cookies and similar technologies to keep the site working, remember your preferences, and collect analytics about how the site is used so that we can improve it. You may refuse or delete cookies through your browser settings, although parts of the site may then not function correctly.

6.2 Our website may contain links to websites operated by third parties, including those of our Members, sponsors and partners. We are not responsible for the data protection practices of those websites. Some may carry our logo even though they are not operated by us. Once you leave our website, please review the applicable policy of the third party site to understand how it handles information collected from you.

7. Contacting Us: Feedback, Withdrawal of Consent, Access and Correction

7.1 If you:

(a) have questions or feedback about your Personal Data or this Data Protection Policy;

(b) wish to withdraw your consent to any use of your Personal Data set out in this Data Protection Policy; or

you may contact our Data Protection Officer at:

Email: secretariat@access.org.sg
Address: 60 Paya Lebar Road, #06-33 Paya Lebar Square, Singapore 409051

7.2 ACCESS does not charge Members, volunteers or event participants a fee for an access request. Where a request is complex or repetitive and would involve significant cost, we will inform you of any fee before proceeding. We may need to verify your identity before acting on a request, and will respond within the timelines set by the Act.

7.3 If you withdraw your consent to any or all use of your Personal Data, we may, depending on the nature of your request, be unable to administer your membership, register you for events, or maintain any contractual relationship in place, which may result in the termination of arrangements between you or your organisation and ACCESS. Our legal rights and remedies in such an event are expressly reserved.

7.4 We cannot delete Personal Data that we are required by law to retain, including the register of Members and office bearers, minutes and resolutions, filings made with the Registry of Societies, and accounting records required for audit and tax purposes.

7.5 If you are not satisfied with our response, you may lodge a complaint with the Personal Data Protection Commission of Singapore at www.pdpc.gov.sg.

8. Governing Law

8.1 This Data Protection Policy and your use of our website are governed in all respects by the laws of Singapore.