Data Protection Policy

SUMMARY

This Data Protection Policy applies to all personal data collected by the Global Notification Solutions Pte Ltd (referred to herein as the “GNS”, “us”, “we” or “our”). The purpose of this Data Protection Policy is to inform you of how GNS manages Personal Data. Please take a moment to read this Data Protection Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data. By interacting with us, submitting information to us, or signing up for any products and services offered by us, you agree and consent to GNS, as well as our respective representatives and/or agents collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to GNS’s 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 nor replace any other consent you may have previously provided to GNS in respect of your Personal Data, and your consent herein are additional to any rights which GNS may have at law to collect, use or disclose your Personal Data. GNS may from time to time update this Data Protection Policy to ensure that this Data Protection Policy is consistent with our future developments, industry trends, and/or any changes in legal or regulatory requirements. Subject to your rights at law, you agree to be bound by the prevailing terms of this Data Protection Policy as updated from time to time on our websites, applications, and digital services. Please check back regularly for updated information on the handling 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 (a) from that data; or (b) from that data and other information to which we have or are likely to have access, including data in our records as may be updated from time to time. 1.2 Examples of such Personal Data you may provide to us include (depending on the nature of your interaction with us) your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address and any other information relating to any individuals which you have provided us in any forms you may have submitted to us, or via other forms of interaction with you.

2. Collection of Personal Data

2.1 By voluntarily providing any Personal Data to us in the course of interacting with or transacting with us, calling or sending messages to us, accessing our websites and/ or submitting information to us via forms or other data collection means or processes: (a)You signify that you have read, understood and agreed to our collection, use, disclosure and/ or retention of your Personal Data in the manner set forth in this Policy. (b)You thereby consent to the collection, use and/or disclosure of such Personal Data by us for the purpose for which such Personal Data was disclosed and/or for any reasonable purpose or for which you have been notified (which includes any of the purposes set out in the section below), until and unless you notify us otherwise. (c)Where you give us Personal Data about other individuals, you confirm that you are authorised to disclose and consent, on their behalf, to the use of such Personal Data for the purpose for which such Personal Data was disclosed and/or for any reasonable purpose or for which you have been notified (which includes any the purposes set out in the section below), until and unless you notify us otherwise. 2.2 When you browse our websites, or use our applications and/or digital services, you generally do so anonymously but please see the section below on cookies. We do not, at our websites, applications and digital services, automatically collect Personal Data unless you provide such information or login with your account credentials. 2.3 You should ensure that all Personal Data submitted to us is complete, accurate, true and correct. Failure on your part to do so may result in our inability to provide you with the products and services you have requested.

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

3.1 Generally, GNS collects, uses and discloses your Personal Data as may be appropriate or reasonable in the context of your interactions with us, which may include the following purposes: (a)responding to your queries, feedback, suggestions, complaints and requests; (b)verifying your identity and customer due diligence; (c)managing our business operations; (d)for purposes related to the recruitment and/or employment of our employees; (e)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; (f)managing the safety and security of our premises; (g)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; (h)conducting investigations relating to disputes, billing or fraud; (i)meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on GNS (including but not limited to responding to regulatory complaints, disclosing to regulatory bodies and conducting audit checks, due diligence and investigations); (j)to perform a contract or other legal obligation; and/or (k)for any other purposes reasonably related to the aforesaid. The purposes for which we may/will collect, use, disclose or process your Personal Data depend on the circumstances at hand and, as such, may not appear above. 3.2 If you have provided your Singapore telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your Singapore telephone number(s), then from time to time, GNS may continue to contact you using such Singapore telephone number(s) (including via voice calls, text, fax, or other means) with information about our products and services, unless you have withdrawn your consent. 3.3 In relation to particular products and services or in your interactions with GNS, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.

4. Disclosure of Personal Data

4.1 GNS will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, your Personal Data may be disclosed by GNS, for the purposes listed above (where applicable), to the following entities or parties, whether they are located overseas or in Singapore:
 
(a)Group Companies: our associated or affiliated organisations or related corporations; (b)Data Intermediaries: our agents, contractors or third party service providers that process or will be processing your Personal Data on our behalf including but not limited to those which provide administrative or other services to us such as telecommunication companies, information technology companies, data centres, maintenance service providers, e-mail messaging services service providers, delivery service provider, handling of payment transactions service providers and marketing service providers; (c)Third parties who have a legitimate interest: our professional advisers such as auditors and lawyers, our insurers, or potential acquirers of any Group Company or business; and/or (d)Authorised third parties: any other party whom you authorise us to disclose your Personal Data to.

5. Use of Cookies

5.1 A cookie is a small piece of information that is placed on your computer when you visit certain websites. The cookies placed by the servers hosting our websites are readable only by us, and cookies cannot access, read or modify any other data on an electric device, nor does it capture any data which allows us to identify you individually. All web-browsers offer the option to refuse any cookie, and if you refuse our cookie then we do not gather any information on that visitor. 5.2 Should you wish to disable the cookies associated with these browsers, you may do so by changing the setting on your browser. However, you may not be able to enter certain part(s) of our websites.

6. Data Security

6.1 Only authorised employees, representatives, agents and contractors, who have agreed to keep Personal Data secure and confidential, have access to it. GNS will take reasonable efforts to protect Personal Data in our possession or our control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. However, we cannot completely guarantee the security of any Personal Data we may have collected from or about you, or that for example no harmful code will enter our websites, applications, and digital services (for example viruses, bugs, trojan horses, spyware or adware). You should be aware of the risks associated with using websites, applications, and digital services. 6.2 While we strive to protect your Personal Data, we cannot ensure the security of the information you transmit to us via the Internet, when you browse our websites, or use our applications and/or digital services, and the method of electronic storage. We urge you to take every precaution to protect your Personal Data when you are on the Internet, when you browse our websites, or use our applications and/or digital services. We recommend
that you change your passwords often, use a combination of letters and numbers, and ensure that you use a secure browser. 6.3 If applicable, you undertake to keep your username and password secure and confidential and shall not disclose or permit it to be disclosed to any unauthorised person, and to inform us as soon as reasonably practicable if you know or suspect that someone else knows your username and password or believe the confidentiality of your username and password has been lost, stolen or compromised in any way or that actual or possible unauthorised transactions have taken place. We are not liable for any damages resulting from any security breaches, on unauthorised and/or fraudulent use of your username and password.

7. Data Retention and Disposal

7.1 We may retain your Personal Data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by applicable laws. 7.2 As soon as it is reasonable to assume that such retention no longer serves the purpose for which the Personal Data was collected, and is no longer necessary for legal or business purposes, we will cease to retain and use destruction methods that fully and irrevocably destroy the Personal Data.

8. Transfer of Personal Data Overseas

8.1 We may from time to time, depending on the circumstances under which you provided Personal Data to us, have a business need to transfer it (or a copy of it) out of Singapore in which you gave it to us and to our affiliates or related companies in different countries. 8.2 We have agreements with our affiliates and related companies to ensure that Personal Data about or relating to you is treated by our affiliates and related companies with the same degree of care as is required by this Data Protection Policy.

9. Contacting Us – Feedback, Withdrawal of Consent, Access and Correction of your Personal Data

9.1 You can contact us at enquiries@artiusglobal.com or call (65) 6914 2685, if you: (a) have any questions or feedback relating to your Personal Data or our Data Protection Policy; (b) would like to withdraw your consent to any use of your Personal Data as set out in this Data Protection Policy; or (c) would like more information on or access and make corrections to your Personal Data records. 9.2 Upon request, we will correct an error or omission in your Personal Data that is in our possession or control and we will notify you when the correction is completed.
 
9.3 Upon reasonable notice being given by you to withdraw any consent given or deemed to have been given in respect of our collection, use or disclosure of your Personal Data and subject to 9.4, we will cease (and cause any of our data intermediaries, representative and/or agents to cease) collecting, using or disclosing your Personal Data unless it is required or authorised under applicable laws. 9.4 If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, GNS may not be in a position to administer any contractual relationship in place, which in turn may also result in the termination of any agreements with GNS, and your being in breach of your contractual obligations or undertakings. GNS’s legal rights and remedies in such event are expressly reserved. 9.5 When contacting us, please state the purpose for which you are contacting us, your name and an email address or mailing address at which we can contact you, and the nature of our relationship with you. We will endeavour to respond to you as soon as possible within 30 days. If we are unable to do so for any reason, we will inform you accordingly and the time by which we will respond to the request.

10. Governing Law

10.1 This Data Protection Policy, your browsing of our websites, and use of our applications and/or digital services shall be governed in all respects by the laws of Singapore.

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