PDPA

PDPA POLICY The purpose of this document (“Data Protection Policy”) is to inform you of how CitiSafe Pte Ltd manages Personal Data which is subject to the Singapore Personal Data Protection Act 2012.By interacting with us, submitting information to us, or signing up for any Products and Services offered by us, you agree and consent to CitiSafe Pte Ltd.This Data Protection Policy supplements but does not supersede nor replace any other consents you may have previously provided to CitiSafe Pte Ltd in respect of your Personal Data, and your consents herein are additional to any rights which to any of the Companies may have at law to collect, use or disclose your Personal Data.CitiSafe Pte Ltdmay 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 the Data Protection Policy as updated from time to time on our website https://citisafe.com.sg Please check back regularly for updated information on the handling of your Personal Data.

1. PERSONAL DATA

• 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.
• 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, medical information, family background (with details of spouse and children), employment history, education background, income, photographs of individual, CCTV footage images of individuals 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 Generally, we collect Personal Data in the following ways:

• a) when you submit an application form or other forms relating to any of our Products and Services;
• b) when you enter into any agreement or provide other documentation or information in respect of your interactions with us, or when you use our services;
• c) when you use our electronic services, or interact with us via any of our websites or use services on any of our websites;
• d) when you interact with our customer service officers, for example, via telephone calls, letters, face-to-face meetings and emails;
• e) when you request that we contact you, be included in an email or other mailing list;
• f) when your images are captured by us via CCTV cameras while you are within our premises, or via photographs or videos taken by us or our representatives when you attend events at our premises;g) when you respond to our promotions, initiatives or to any request for additional Personal Data;
• h) when you are contacted by, and respond to, our marketing representatives and customer service officers;
• i)when we receive references from business partners and third parties, for example, where you have been referred by them;
• j) when we seek information from third parties about you in connection with the Products and Services you have applied for; and
• k) when you submit your Personal Data to us for any other reasons.

2.2 If you provide us with any Personal Data relating to a third party (e.g. information of your spouse, children, parents, and/or employees), by submitting such information to us, you represent to us that you have obtained the consent of the third party to provide us with their Personal Data for the respective purposes.

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, CitiSafe Pte Ltd collects, uses and discloses your Personal Data for the following purposes:

• responding to your queries and requests;
• verifying your identify;
• managing the administrative and business operations of CitiSafe Pte Ltd and complying with internal policies and procedures;
• matching any Personal Data held which relates to you for any of the purposes listed herein;
• requesting feedback or participation in surveys, and/or analysis for statistical, profiling or other purposes for us to review, develop and improve the quality of our products and services;
• Providing updates on our organisation events
• taking photograph(s) and/or video(s) of you for
• internal dissemination within the company and
• generating publicity materials for our courses, events and programmes;
• legal purposes (including but not limited to obtaining legal advice and dispute resolution);
• Administering debt recovery and debt management
• Facilitating your use of our online portal.
• Notifying you of collection datesl) Any other purpose reasonably related to the aforesaid

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, CitiSafe Pte Ltd may contact you using such Singapore telephone number(s) (including via voice calls, text, or other means) with information about our Products and Services or those products and services offered by our preferred partners (including discounts and special offers).

3.3 In relation to particular Products and Services or in your interactions with us, 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.

3.4 You have a choice to withdraw your consent for receiving marketing or promotional materials/communication. You may contact us using the contact details found below.

3.5 Please note that even if you withdraw your consent for the receipt of marketing or promotional materials, we may still contact you for other purposes in relation to the Products and Services that you hold with CitiSafe Pte Ltd.

4. DISCLOSURE OF PERSONAL DATA

4.1 CitiSafe Pte Ltd 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 (where applicable), to the following:

• a) CitiSafe Pte Ltd ’s employees to provide content, Products and Services to you, address your questions and requests;
• b) our professional advisers such as auditors, consultants and lawyers
• c) external banks, credit card companies and their respective service providers
• d) Contractors or third-partyservice provider who provide delivery services
• e) (c) relevant government regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and
• f) any other party to 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 technologies,you may do so by changing the setting on your browser. However, you may not be able to enter certain part(s) of our website.

6. DATA SECURITY

6.1 CitiSafe Pte Ltd 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 (for example viruses, bugs, trojan horses, spyware or adware). You should be aware of the risks associated with using websites.

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 or when you use our online portals, and we urge you to take every precaution to protect your Personal Data when you are on the Internet. 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, onunauthorised and/or fraudulent use of your username and password

7. ACCURACY PERSONAL DATA

7.1 We make reasonable effort to ensure that personal data collected is up-to-date, accurate and complete. Alternatively, you may wish to update your personal data by sending your request as per below contact details. CitiSafe Pte Ltdwill comply with your request as soon as practicable.

8. CONTACTING US –WITHDRAWAL OF CONSENT, ACCESS AND CORRECTION OF YOUR PERSONAL DATA

8.1 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 to obtain access and make corrections to yourPersonal Data records, please contact CitiSafe Pte Ltd as follows: Name: Mr Michael Maxwell, Data Protection Officer/Managing Director
Email: admin@citisafe.com.sg
Address: Blk 20 Woodlands Link #03-30 Singapore 738733
DID: 6482 4582

8.2 Please note that if your Personal Data has been provided to us by a third party (e.g. a referrer), you should contact that organisation or individual to make such queries, complaints, and access and correction requests to CitiSafe Pte Ltd on your behalf.

8.3 If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request, CitiSafe Pte Ltd may not be in a position to continue to provide its Products and Services to you, administer any contractual relationship in place, which in turn may also result in the termination of any agreements with CitiSafe Pte Ltd, and your being in breach of your contractual obligations or undertakings. CitiSafe Pte Ltd ’s legal rights and remedies in such event are expressly reserved.

9. GOVERNING LAW

9.1 Please also visit our Terms and Conditions section establishing the use, disclaimers, and limitations of liability governing the use of our website.