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Terms & Data Privacy

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Terms & Data Privacy 2018-05-09T20:53:33+00:00

Terms of Use

Your use of this Site

Color Persona provides you access to the https://www.colorpersona.com and other Color Persona group sites (the “Site”) in order to help you at every stage of the profiling and personal development process and offer you the tools and services for your needs.

You will not use the Site for, or to encourage, any unlawful purpose; nor post or transmit on the Site inaccurate, incomplete or false information (including in the case of candidates, biographical information about yourself nor will you post or transmit on the Site any libelous, abusive, threatening, harmful, vulgar, obscene or otherwise objectionable material. You confirm that you will not post or transmit on the Site any material which contains any virus or other disabling devices which interfere or may interfere with the operation of the Site; or which alters or deletes any information which you have no authority to alter or delete; or which overloads the Site by spamming or flooding it. You will not use any device, routine or software to crash, delay, or otherwise, damage the operation of this Site. You further confirm that you will not take any action that affects Color Persona’s reputation, operational ability or that defames, abuses, harasses or threatens others.

Color Persona in its sole discretion shall determine your compliance with the above and shall have the right to prevent you from using the Site and/or to delete from the Site immediately and without prior notice any material that it deems not to comply or to be objectionable for any reason. As the services on the Site are made available to users and employers immediately, you do not enjoy any cancellation or “cooling-off” rights in relation to these Terms of Use.

Links to or from other Sites

As a convenience to users, this Site may contain links to external websites and you may be offered a number of automatic links to other sites, which may interest you. We accept no responsibility for or liability in respect of the content of those sites. Color Persona should not be taken as having reviewed or approved such sites or their contents, nor does it warrant that any links to such sites work or are up to date. The use of any such links is entirely at your own risk. Any third parties wishing to link to our Site may do so provided links are to the home page only of the Site and provided we are notified in advance by email to enquiries@colorpersona.com.

Security and passwords

When you register with this site or sign on when you visit the Site, you will need to use a username and password. You are solely responsible for the security and proper use of the password, which should be kept confidential at all times and not disclosed to anyone. You must notify us immediately if you believe that your password is in the possession of someone else or if it may be used in an unauthorised way. We accept no liability for any unauthorised or improper use of disclosure of any password.

Aggregate information

We may gather information and statistics collectively about all visitors to this Site which may include the information supplied by you which will help us to understand our users thereby creating a better profiling process. We will NOT disclose individual names or identify personal information. All data will be in aggregate form. We believe this information helps us determine what is most beneficial for our users and how we can continually improve our online service. We may share this kind of aggregate data with selected third parties to assist with these purposes. Personal data is processed by us in accordance with our Privacy Policy.

Intellectual property rights © Copyright Color Persona 2013

Color Persona and Color Persona Asia are trademarks of Redfire LLP. All rights are reserved.

You may not download, copy or print any of the pages of the Site except for your own personal use, and provided you keep intact all copyright and proprietary notices. No copying or distribution for any business or commercial use is allowed without authorisation. No framing, harvesting, “scraping” or other manipulation of the content of the Site is permitted. You will not attempt to decipher, disassemble, reverse engineer or modify any of the software, coding or information comprised in the Site; nor will you post to the Site any material which infringes any intellectual property rights of any third party.

Changes to or temporary unavailability of this Site

Every effort is made to keep the Site up and running smoothly and fault-free. However, Color Persona takes no responsibility for, and will not be liable for, the Site being temporarily unavailable for reasons of maintenance/improvement, or due to technical issues beyond our control. We may change, suspend or discontinue any aspect of the Site at any time, including the availability of any of the Site features, databases or content. Color Persona may amend these Terms of Use at any time by posting amended Terms of Use to the Site. You will be deemed to have agreed to the amended Terms of Use when you next use this site following any amendment.  

Termination

We may at our absolute discretion deny you access to this Site (which may include any of the services or information available through it) or any part of it at any time without explanation.

Liability and Disclaimer

The information contained on this Site is given in good faith and Color Persona uses all reasonable efforts to ensure that it is accurate. However, Color Persona gives no representation or warranty in respect of such information and all such representations and warranties, whether express or implied, are excluded.

No liability is accepted by Color Persona for any loss or damage which may arise out of any person relying on or using any information on this Site. Color Persona shall not be liable to any person relying on or using any such information for (a) loss of revenue, loss of actual or anticipated salary; loss of actual or anticipated profits whether arising in the normal course of business or otherwise (including, without limitation, loss of profits on contracts); loss of or damage to employment prospects; loss of opportunity; loss of the use of money; loss of anticipated savings; loss of business; loss of goodwill; loss of or damage to reputation; loss of or corruption of data; loss of management or administration time, legal and other professional fees and expenses; or (b) any indirect or consequential loss or damages however caused (including without limitation by reason of misrepresentation, negligence, other tort, breach of contract or breach of statutory duty) which arise directly or indirectly from the subject matter of this Site.

You agree fully to indemnify Color Persona and keep Color Persona fully indemnified against all costs, expenses, claims, losses, liabilities or proceedings arising from use or misuse by you of this Site.

If any provision of these terms and conditions is held to be invalid by a court of competent jurisdiction, such invalidity shall not affect the validity of the remaining provisions, which shall remain in full force and effect.

Your use of the Site and downloads from it and the operation of these terms and conditions shall be governed in accordance with the laws of Singapore. The Singapore courts shall have exclusive jurisdiction over any dispute arising out of the use of this website.

https://www.colorpersona.com is the Personality profiling website for Color Persona.

In the case of any query regarding the information on this website, please contact us.

PRIVACY NOTICE

As part of our compliance with the Personal Data Protection Act 2012, Color Persona in Singapore requests you read the following information regarding how we collect your personal data and how we maintain, use, store and disclose your personal information in connection with profiling data collected. Basic information is collected so that the profile reports can be generated:

  • You complete a one-off our registration form to create an account.
  • You or Candidates complete profile questionnaire/s details to facilities the profile reports to be generated.
  • We do not share personal information or profile results to third parties without your prior consent
  • We receive any complaint or other information from or about you in the workplace
  • You provide us with any additional information about yourself

Your personal information may be used in connection with:

  • Legal matters arising and requested by the courts to provide such information
  • Our direct marketing to you.
  • Our management and resolution of any complaint, inquiry or investigation in which you are involved
  • Any insurance claim or proposal that requires disclosure of your personal information

Your personal information may be disclosed to:

  • Color Persona support staff.
  • Our insurers
  • Any person with a lawful entitlement to obtain the information

Additional information contained in our privacy policy:

Our privacy policy below contains further information about the type of information we hold and how we manage your information, including how you can, subject to some exemptions, access personal information about you that we hold and request that it be corrected. It also sets out how you can complain about any alleged breaches of the Personal Data Protection Act 2012 and how we will deal with any complaints.  

Changes to our Privacy Notice:

If at any time our Privacy Notice or privacy policy changes, the updated details will be available on the privacy policy on our website. Any information we hold about you will be governed by the most current version of the privacy policy.

Contact details for Privacy Officer can be found HERE. 

PRIVACY POLICY

Your privacy is important to Color Persona

Your privacy is important to us. This statement outlines Color Persona policy on how we collect personal information and how we maintain, use, store and disclose the personal information we hold and reflects our commitment to you. It applies to all operations within Color Persona Singapore, including visitors to our website.

It is the policy of Color Persona to respect the confidentiality of information and the privacy of individuals. Color Persona are bound by the Personal Data Protection Act 2012.

The Color Persona privacy policy will be reviewed and updated from time to time to take account of new laws and technology, changes to our operations and practices and to make sure it remains appropriate to the changing environment. Please regularly check our privacy policy so that you are aware of these updates and changes. Any information we hold will be governed by the most current version of the Color Persona privacy policy.

The Color Persona privacy policy is based on transparency

We are committed to being open and transparent about how we manage personal information.

Types of personal information held by Color Persona and when and how it is collected

Personal information means information or an opinion about you. It includes information regarding your contact details, profile results, profile reports, and other information obtained or received by us in connection with your profiling reports.

Collection

We may collect personal information about you when:

  • You complete our registration forms or provide any other information in connection with online account
  • We calculate your profile results and consequently in generating your reports.
  • Your payment details such as bank accounts, credit card details are NOT stored in our system, this is to ensure further security.
  • We receive any complaint or other information from or about you in regards to the Color Persona system
  • We receive any information about any insurance investigation, litigation, registration or professional disciplinary matter, criminal matter, inquest or inquiry in which you were involved
  • You provide us with any additional information about you

General information collected from visitors to our website

We gather information about all our website users collectively, such as what areas users visit more frequently and what services users access the most. We only use such data anonymously and in the aggregate. This information helps us determine what is most beneficial for our users and how we can continually create a better overall website experience for you.

Your personal information collected on the Color Persona website

In some instances, we may need specific information about you, such as name, address, email address, telephone number etc. We will collect this information if you register for an account or sign up for a service via our website.

Purposes for which we collect, use and disclose personal information

Your personal information may be collected, used and disclosed in connection with:

  • Production of profiling results
  • Production of profile reports and charts specific to you as an individual.
  • Your results are NOT shared with other candidates without your consent
  • Where an agent is (registered user) is creating a profile report for a number of his candidates, he/she will have access to information pertaining to his candidates.
  • Where an agent is (registered user) intends to generate profiles and reports for a number of candidates, he/she must ensure the candidates have given consent.
  • Any insurance claim or proposal that requires disclosure of your personal information
  • Undertaking criminal background checks
  • For research, development, business systems and infrastructure testing, and other business purposes to assist us in providing our services to you

 Disclosures

We may disclose your personal information (including to trusted third parties) for the purposes for which it is primarily collected, used or held or for a related secondary purpose. Your personal information may be disclosed to:

  • Color Persona (Color Persona) employees and support staff. Referees
  • Our insurers
  • Any person with a lawful entitlement to obtain the information

We do not disclose information about your individual visits to the Color Persona’s website.

Management of personal information

At Color Persona, we train our staff to respect the confidentiality of customer information and the privacy of individuals. Color Persona regards breaches of your privacy very seriously and any breach will result in disciplinary action being taken, dependent upon severity. Color Persona has appointed a Privacy Officer to ensure that our management of personal information is in accordance with this policy and the Personal Data Protection Act.

How do we store and protect personal information?

Safeguarding the privacy of your information is important to us, whether you interact with us personally, by phone, mail, over the internet or another electronic medium. We hold personal information in a combination of secure computer storage facilities and take such steps as are reasonable in the circumstances to protect the personal information we hold from misuse, interference and loss, unauthorised access, modification or disclosure. We may need to maintain records for a significant period of time. However, when we consider information is no longer needed, we will remove any details that will identify you or we will securely destroy the records.  

How do we keep personal information accurate and up-to-date?

Color Persona take such steps as are reasonable in the circumstances to ensure that the personal information it holds and discloses is accurate, up-to-date and complete. We recognise that information changes frequently with changes of address and other personal circumstances. We generally recommend that the registered users update their account information as well as their candidate information such as names and email addresses as and when required via online access.

Enquiries & Complaints

You can make enquiries, requests to access/delete or correct your information, or complain about alleged breaches of the Personal Data Protection Act 2012 to our Privacy Officer at enquiries@colorpersona.com

Complaints

We aim to acknowledge receipt of all complaints within 10 working days and aim to resolve all complaints within 30 working days. This may not be possible in all circumstances depending on the contents of the complaint. In this situation, we will respond to your complaint in a reasonable time. If you are not satisfied with our response to your complaint, you can contact the Personal Data Protection Commission.

Access

Subject to some exceptions you can gain access to the personal information that we hold about you. To make a request to access your personal information, you will need to send a written letter of request and authorisation for the release of such information. Ensure you specify the information you require. There is usually an administration charge applied for such requests. Alternatively, you may log in to your account and access the same information.

Correction 

Correction of data held in our system the joint responsibility of the Agent and the candidates concerned, It is up to the agent to ensure that the information of his candidates are up to date, and in turn, it is the responsibility of the Candidate to ensure that his agent is informed of such changes of information. The ultimate responsibility for updating information in our system is the Agents.

Feedback

Color Persona have several areas on our website where you can submit feedback, under the ‘Contact Us’ section. Any feedback that is submitted through this area becomes the property of Color Persona. We may use this feedback, such as success stories or responses to surveys, for marketing purposes, or to contact you for further feedback on the site.

GDPR – General Data Protection Regulation

The summary below highlights our Data handling process (these are covered in detail in our Terms & conditions and disclaimers). The terms and conditions tab covers in detail the PDA Singapore (Personal Data Protection) act 2012 and also covers the general requirements of the GDPR regulations. The key areas relating to GDPR have been highlighted below. Color Persona is GDPR compliant.

Our business summary

Color Persona provides an online personality profile tools. Agents are required to register an account on our portal, and subsequently, the Agent will send out questionnaire links to his candidates. The candidate will then complete the questionnaire and information is collected pertaining to the responses in different behavioural situations using a rating system between 1 to 10. The data is processed and stored in the database as numbers and scores and average values. The information is collected on behalf of the Agent, who owns the candidate’s information collected, and responsible for the same.

** It is important to note that we strongly recommended that the registered Agents are GDPR compliant. Color Persona cannot enforce agents to be GDPR compliant.

Key highlights

Although GDPR refers to Personal data protection regarding data being held or collected outside of the E.U, Color Persona (part of REDFIRE LLP), registered and operating from Singapore, we provide profiling services internationally. We collect two types of information from Entities:

  1. Agent / User registration details necessary when a user registers an account with us use our back-office system. The information includes:
    • Name, business email, Business contact number and address
    • Credit purchase data such as the name, amount and total credits purchased.
    • We DO NOT collect payment information such as credit card or payment account details. Payment transactions are carried out on the Payment gateway portal such as PAYPAL.
    • The Generated reports are purged so that that Profile reports are removed from the Color Persona system.
  2. Candidate information is collected when the candidates complete a questionnaire and the subsequently amalgamated scores are calculated once to generate a PDF report which is emailed to the Agent and/or the Candidate. The candidates explicitly consent to Color Persona and the Agent for collecting and using the information in the process of generating the profile reports. The information collected is Name, Gender, Country, Job Title and email address. This information is used in the generation of the PDF profile report.

Relationship and data ownership & Providing Entities data.

Color Persona is the processor of the collected data from the candidate and Agent, and stores and maintains the back-office system that enables Agents/users to process the data for the candidates. Color Persona is responsible for the safe storage of the Agent and candidate’s information.

The Agent or User is the Owner (Entity 1) of the candidate information and consequently responsible for providing the information for their candidates in the system if requested by the candidate. If the candidate wants their data to be deleted from the system, then the candidate must tender a request to the Agent, who in turn must request the deletion, in writing to Color Persona. This is because the Data is owned by the Agent and the Candidate must also give authorisation for the deletion of the data, and the Agent must be aware of this request from the candidate. In brief, both parties must be aware and agree to the data deletion request. For the Personify feature, the Agent must get agreement from the candidates, if he/she intends to share the Candidates Name and communication preferences with other team members when processing team profiles and disseminating team profiles to team members.

* Note, the Agent is responsible for the information shared with other team members, the candidates’ employers or any other 3rd parties. It is recommended that Agents be fully GDPR compliant.

Agent account deletion:

The agent can deactivate his/her account so that it can be activated later, OR the agent can request the deletion of ALL data pertaining to the Agent account from the system. The request must be done in writing to support@colorpersona.com

The Candidates (Entity 2) information held in the system is ultimately owned by the Agent/User. The Candidate must request in writing to the Agent for access to their data held about him/her. Deletion of the Candidates data also needs to be requested in writing to the Agent, but in this case, the agent must request the deletion of data for the candidate to Color Persona. This is to ensure both parties agree for the data deletion.

Third Parties

  • Color Persona DOES NOT share Agent or candidate information held in the database to third parties.
  • Color Persona will Delete information held on our system for an Agent account, the request must be in writing to support@colorpersona.com.
  • The Agent has Full access to his/her own as well as the candidate’s data.
  • The agent and candidate cannot delete data from the system and must request this in writing to support@colorpersona.com.
  • If the information is required for candidate or Agent, then the Agent can do this from their own account without involving Color Persona.
  • The Agent is responsible for sharing candidate’s information to 3rd parties. The agent must get authorisation from the candidate before sharing information with 3rd parties

Cookie Policy

What are ‘Cookies’?
 Cookies are small pieces of information that are stored by your browser on your computer’s hard drive. They are often used as a mechanism for websites to remember things that a website browser has done there in the past, for example, clicking on particular buttons, logging in, or having read pages on that site in the past.

How does Color Persona Use Cookies?
In common with many other website operators, we use cookies on our website. We use them to enrich your experience of using the website by allowing us to tailor what you see to what we have learned about your preferences during your visits to the site. Our cookies are also used to enable us to develop our website to reflect our customer’s preferences and determining the most popular areas of our website. We do not use your cookies for advertisements.

In general, we use the following types of cookie:

Strictly Necessary Cookies: These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website.

Analytical/Performance Cookies: These allow us to recognise and count the number of visitors and analyse user statistics in order to ensure the website is at optimum performance.

Functionality Cookies: These are used to improve the functional performance of the website and make it easier for you to use. For example, they are used to remember that you have previously visited the website and asked to remain logged in to the website.

By continuing to use our website without choosing to delete/block cookies, you agree that we can place these types of cookies on your device.

Managing Cookies
You can manage cookies by activating the setting ‘on’ your internet browser that allows you to refuse the setting of all or some cookies. Please refer to the instructions or the online help files available via your relevant browser if you wish to manage cookies in this way. Alternatively, please visit www.allaboutcookies.org for further information. To manage cookies relating to targeted advertising activities, you can visit www.youronlinechoices.com.  To opt-out of being tracked by Google Analytics across all websites, you can visit tools.google.com/dlpage/gaoptout.  

Please note, if you refuse cookies this may mean that you can’t use some of the additional Cookie features of our website and may not be able to access certain parts of the website.

Changes to this Cookies policy 
We aim to meet high standards and our policies and procedures are, therefore, constantly under review. From time to time we may change how we use and place cookies. Accordingly, we recommend that you check this page periodically in order to review our current policies and practices.
 
How to contact us regarding Cookies

Email:  support@colorpersona.com

Disclaimer

Candidate Disclaimer

You understand and consent that in order to facilitate the profiling process on your behalf, the Color Persona Agent may forward your details to clients at their sole discretion, and additionally display promotional excerpts from your details on the Color Persona website. You agree and accept that your present employer may access the Color Persona websites and you unconditionally waive any and all claims you may have against Color Persona as a result of any loss you may suffer as a result of the information being displayed on these websites. You agree to comply with the Terms of Use of this website and accept Color Persona right to suspend or cancel your registration immediately at our reasonable discretion without liability to you if you breach such terms of use.

Registered Agents (user) Disclaimer

You agree and accept that the Color Persona website is open to all its customers and will contain Candidate information that you have acquired during the process of candidates completing online questionnaires. You are strictly responsible for the security of that information available to you as these are your ‘candidates’. Color Persona will not share your candidate information to third parties including other registered Agents (users) unless this is requested in writing and agreed by all parties concerned. You agree not to share, copy or transmit to a third party any candidate data unless you have candidate consent to do so. You will indemnify and hold Color Persona websites harmless for any and all liability howsoever arising (to the fullest extent allowed by law) which Color Persona may incur should you use the Color Persona database of Candidate Profiles or other data about individuals derived from this website for any other purpose other than that for which they were provided. You agree to comply with the Terms of Use of this website and accept Color Persona right to suspend or cancel your registration immediately at our reasonable discretion without liability to you if you breach such terms of use.

Profile Reports Content Disclaimer

All rights reserved by Color Persona. No part of the report can be reproduced or transmitted to third parties in any form, without prior agreement by the Agent and the Candidate. 

The information contained within Profile reports created by Color Persona has been carefully compiled based on the answers given the by the candidate during the Questionnaire completion stage. The content is unique and tailored to the individuals with corresponding general statements and coloured charts, in relation to the answers given by the candidate.  We stress that Color Persona or the publishers cannot be held responsible for any decisions arising from the use of the contents of the reports, nor any inferences or interpretations arising therefrom. 

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