Fujikin Singapore

Data Protection Policy Last updated: 1st January 2023

This Data Protection Policy applies to all personal data collected by FUJIKIN SINGAPORE PTE. LTD. ("we", "us" or "our").

The purpose of this Data Protection Policy is to inform you of how we collect, use, disclose and/or process your Personal Data in accordance with the Singapore Personal Data Protection Act 2012 ("PDPA").

By interacting with us, submitting information to us, purchasing any products and services offered by us, you hereby agree and consent to us collecting, using, disclosing and/or sharing your Personal Data and disclosing such Personal Data to our authorised service providers and relevant third parties in the manner set forth in this Data Protection Policy.

This Data Protection Policy supplements but does not supersede or replace any other consents you may have previously provided to us in respect of your Personal Data, and your consent herein are in addition to any rights which we may have at law to collect, use and/or disclose your Personal Data.

We reserve the right to update, amend or make changes to this Data Protection Policy at any time, including to conform to new laws and regulations or changes in business standards. The updated Data Protection Policy will take effect when made available on our website, and will apply to all Personal Data collected including any Personal Data that was provided to us previously. To the maximum extent permissible under applicable law, you agree to be bound by the prevailing terms of this Data Protection Policy as may be updated from time to time on our website, and/or as may be notified by us. Hence, please check back regularly for updated information on our handling and processing of your Personal Data.

1

PERSONAL DATA

1.1

In this Data Protection Policy, "Personal Data" refers to 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 we have or are likely to have access, including data in our records as may be updated from time to time.

1.2

Depending on the nature of your interactions with us, Personal Data you may provide to us include, but may not be limited to the following information:

1.2.1

Your name;

1.2.2

Your email address;

1.2.3

Your contact details, including phone number;

1.2.4

Your NRIC, FIN, Passport or other identification number;

1.2.5

Your mailing address; and/or

1.2.6

Any other information relating to any individuals.

2

COLLECTION

2.1

Generally, we may collect Personal Data:

2.1.1

that you voluntarily provide to us;

2.1.2

from third parties; or

2.1.3

through your use and purchase of our products and services.

What Personal Data we collect will depend on the purposes for which the Personal Data is collected and what you have chosen to provide.

2.2

We may collect your Personal Data, directly or indirectly, through various channels, including when:

2.2.1

you submit any form, including but not limited to application and registration forms or other forms relating to any of our products or services;

2.2.2

you submit an employment or job application, or when you provide documents and/or information including your resume and/or curriculum vitae in connection with any appointment, role or position;

2.2.3

you enter into any agreement or provide other documentation or information in respect of your interactions with us;

2.2.4

you visit our websites, transact with us, contact us or request that we contact you through various communication channels, including but not limited to telephone calls, letters, face-to-face meetings, social media platforms, e-mails, fax and via our websites;

2.2.5

you request to be included in an email or other mailing list, or when you respond to promotions, marketing events or initiatives or our request for additional Personal Data;

2.2.6

your images are captured via CCTV cameras or face recognition system while you are within our office premises, or via photographs or videos taken by us or our representatives;

2.2.7

we seek information from third parties about you and receive your Personal Data in connection with your relationship with us, including for our products and services or job applications, for example, from business partners, public agencies, your ex-employer, referral intermediaries and the relevant authorities;

2.2.8

you submit your Personal Data to us for any other reason.

2.3

Where the collection of your Personal Data is based on your consent, you may withdraw your consent and request us to stop using and/or disclosing your Personal Data for any or all of the purposes by submitting your request to us in writing at the contact details provided below (see Paragraph 11 below). However, please note that should you withdraw your consent to our collection, use or disclose of your Personal Data for any purpose, it may impact our ability to proceed with or continue to provide you with our products or services, administer any contractual relation or agreement already in place, or perform or conclude an existing or prospective agreement. Please note that your withdrawal of consent will not prevent us from exercising our legal rights (including any remedies, or undertaking any steps as we may be entitled under the law).

2.4

In certain circumstances, you may also provide us with Personal Data of persons other than yourself (such as your family members). If you do so, you represent and warrant that you have brought this Data Protection Policy to his/her attention, informed him/her of the purposes for which we are collecting his/her Personal Data and that he/she has consented to your disclosure of his/her Personal Data to us for those purposes and accepted this Data Protection Policy. You agree to indemnify and hold us harmless from and against any and all claims by such individuals relating to our collection, use and disclosure of such personal data in accordance with the terms of this Data Protection Policy.

3

PURPOSE OF COLLECTION, USE AND DISCLOSURE

3.1

Generally, we collect, use, disclose and process your Personal Data for purposes connected to or relevant to our business and to manage your relationship with us, including the following purposes:

3.1.1

Verifying your identity;

3.1.2

Processing, handling and corresponding with you in relation to your enquiries, feedback, complaints, requests and applications;

3.1.3

Providing you with information, products or services that you request from us, including product delivery;

3.1.4

Providing after sales service, support or customer care;

3.1.5

Processing and management of payments and/or credit transactions;

3.1.6

Requesting feedback or participation in surveys, as well as conducting market research and/or analysis for statistical, profiling or other purposes for us to review, develop and improve the quality of our products and services;

3.1.7

Preventing, detecting and investigating crime and analysing and managing commercial risks;

3.1.8

Facilities management (including but not limited to maintaining the security of our premises such as carrying out CCTV surveillance);

3.1.9

In connection with any claims, actions or proceedings (including but not limited to drafting and reviewing documents, transaction documentation, obtaining legal advice, and facilitating dispute resolution), and/or protecting and enforcing our contractual and legal rights and obligations;

3.1.10

Resolving any dispute or investigating any complaint, claim or dispute, or any actual or suspected illegal or unlawful conduct;

3.1.11

Complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;

3.1.12

Transmitting to any unaffiliated third parties including our third-party service providers and agents, and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes;

3.1.13

Administrative purposes, including finance, IT and HR purposes, quality assurance and staff training, and compliance with internal policies and procedures, including audit, accounting, risk management and record keeping;

3.1.14

Facilitating business asset transactions including merger, acquisitions or asset sale;

3.1.15

Carrying out our legitimate business interests;

3.1.16

Any purpose that you may be notified of when your Personal Data was collected; and

3.1.17

Any other purpose that is reasonably related to any of the above and/or our provision of products and/or services to you.

3.2

Where consent has been provided, we may also use your Personal Data to send you marketing information about our products and services, including notifying you about changes to our services, new products, initiatives, and promotions. In order for us to market products, events and services which are of specific interest and relevance to you, we may analyse and rely on your Personal Data provided to us, or data collected from your interactions with us. However, no marketing, using your Personal Data in non-aggregated and/or identifiable form, would be carried out unless you have provided us with your consent to use your Personal Data for such marketing purposes. If you do not want us to use your Personal Data for the purposes of marketing you may withdraw your consent at any time by contacting us in accordance with Paragraph 11 below.

3.3

We may also collect, use, disclose and process your Personal Data for other purposes, without your knowledge or consent, where this is required or permitted by law.

3.4

When we contact or send you information for the above purposes and purposes for which you have consented, we may do so by post, e-mail, SMS, telephone or such other means. If you do not wish to receive any communication or information from us, or wish to restrict the manner by which we may contact or send you information, you may contact us in accordance with Paragraph 11 below.

4

DISCLOSURE AND TRANSFER

4.1

We will take reasonable steps to keep and protect your Personal Data against unauthorised disclosure.

4.2

We may disclose and/or transfer your Personal Data to third parties in connection with the purposes set out under Paragraph 3 above, including the following:

4.2.1

To any members of our group, including our subsidiaries, holding company, our ultimate holding company and its subsidiaries (as such terms are defined in the Companies Act 1967) (our "Group") to facilitate our business operations and administration;

4.2.2

To third party service providers, agents and other organisations we have engaged to perform services in connection with our operations;

4.2.3

To banks, credit card companies, other financial institutions and their respective service providers for the purposes of processing payment;

4.2.4

To any prospective business partner, buyer, investor, assignee or transferee (whether prospective or actual) to facilitate any business asset transaction (which may extend to any merger, acquisition or any debt or asset sale) involving our Group;

4.2.5

To relevant government ministries, regulators, statutory boards and authorities or law enforcement agencies to comply with any legal obligations imposed by any governmental authority;

4.2.6

To our professional advisers such as our consultants, auditors and lawyers; and/or

4.2.7

Any other party whom you authorise us to disclose your Personal Data to.

4.3

We may transfer your Personal Data to different jurisdictions in connection with the purposes described in this Data Protection Policy from the jurisdiction where it is collected (or where you are located) to any other jurisdiction that we or our Group operate in, and to third parties in other jurisdictions. You fully understand and unambiguously consent that we may transfer your Personal Data to any country (including to third parties where necessary) for the purposes set out in this Data Protection Policy or as notified to you.

4.4

Where we transfer your Personal Data to a country outside Singapore, we will take reasonable steps to ensure that your Personal Data remains adequately protected to a standard comparable to the PDPA.

5

ACCESS AND CORRECTION

5.1

You may exercise your right to access your Personal Data in accordance with the PDPA, by submitting your request to us in writing at the contact details provided below (see Paragraph 11 below). Any access request may be subject to an administrative fee at our rates then in force

5.2

In the event that you wish to correct and/or update your Personal Data in our records, you may submit your request to us in writing at the contact details provided below (see Paragraph 11 below).

5.3

We may require that you submit certain forms or provide certain information in order for us to verify your identity and process your request. We may also be permitted under applicable law to refuse a request.

6

ACCURACY

6.1

You should ensure that all Personal Data submitted to us is complete, accurate, true, up to date and correct. Failure on your part to do so may result in our inability to provide you with the products and/or services you have requested, or delays in processing your applications. Please update us if there are any changes to your Personal Data by informing our Data Protection Officer in writing at the contact details provided below (see Paragraph 11 below).

7

RETENTION

7.1

We retain your Personal Data for so long as it is necessary for the purposes it has been collected, or for so long as required or permitted by applicable laws. We will cease retention of your Personal Data, when it is no longer necessary for any legal or business purposes. In some circumstances we may anonymise your Personal Data so that it can no longer be associated with you, in which case we are entitled to retain and use such data without restriction.

8

PROTECTION AND DATA SECURITY

8.1

While we take reasonable measures and precautions to safeguard your Personal Data in our possession or under our control, you agree not to hold us liable or responsible for any loss or damage resulting from unauthorised or unintended access that is beyond our control, such as hacking or cybercrime.

8.2

You should be aware that no method of transmission over the Internet or method of electronic storage is completely secure. We do not make any warranty, guarantee, or representation that your use of our system or website is safe and protected from malware, and other vulnerabilities. We also do not guarantee the security of data that you choose to send us electronically. Sending such data is entirely at your own risk. You should be aware of the risks associated with use and access to websites, and we urge you to take every precaution to protect your Personal Data when you use our website. We recommend that you ensure that you use a secure browser when accessing our website.

9

THIRD PARTY SITES

9.1

Our website may contain links to other websites operated by third parties. We are not responsible for the privacy practices of websites operated by third parties that are linked to our website. We encourage you to learn about the privacy and/or data protection policies of such third party websites. Once you have left our website, you should check the applicable privacy and/or data protection policies of the third party website to determine how they will handle or process any information they collect from you

10

LOG DATA AND COOKIES

10.1

We collect information that your browser sends whenever you visit our website ("Log Data"). This Log Data may include information such as your computer's Internet Protocol ("IP") address, browser type, browser version, and the pages of our website that you visit, the time and date of your visit, the time spent on those pages and other statistics.

10.2

Cookies are small text files stored in your computing or other electronic devices when you visit our website. Depending on the type of cookie, it may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your computer's hard drive.

10.3

Like many websites, we may use "cookies" to:

10.3.1

track information such as the number of visitors and their frequency of use of our websites;

10.3.2

to improve and make our websites easier to use;

10.3.3

to better tailor our products and services to your interests and needs;

10.3.4

for purposes of analysis, statistical and site-related information; and/or

10.3.5

personalise the website for you, including delivering advertisements which may be of particular interest to you and to allow us to understand the effectiveness of our advertisements.

10.4

You can adjust your browser settings to refuse all cookies or to indicate when a cookie is being sent. However, if you choose to delete or disable the cookies associated with our website by changing your browser settings, you may not be able to access and use some portions of our websites and this may also impact your user experience on our website.

10.5

In addition, we may use third party services and cookies (such as Google Analytics) that collect, monitor and analyse the information about your use and interaction with our website in order to increase our website’s functionality. Please note that these third party service providers may have their own data protection and/or privacy policies addressing how they collect, use and/or disclose such information.

11

CONTACT US

11.1

You may contact our Data Protection Officer if you have any queries or feedback relating to your Personal Data or our Data Protection Policy, at the following mail address:

fspdpo@fujikin.com.sg