A. Our Commitment to Personal Data Protection

Kuok (Singapore) Limited and its subsidiaries and associated companies (collectively “Pacific Carriers Holdings Pte Ltd.” or “PCL” or “we” or “our” or “us”) are committed to protecting your privacy. We take our responsibilities under Singapore’s Personal Data Protection Act (the “PDPA”) and other applicable personal data protection laws (collectively “Personal Data Protection Law”) seriously. We also recognize the importance of the personal data you have entrusted to us and believe that it is our responsibility to properly manage, protect and process your personal data.

The purpose of this Privacy Policy is to provide you with an understanding of how we handle, collect, use, disclose and deal with personal data about you that you give us, that we receive through third parties, or otherwise is in our possession, whether now or in the future.

Please read this Privacy Policy carefully. In this Policy, “you” or “your” refers to the individual whose personal data we are receiving, collecting, using, disclosing or processing.

The contents of this Privacy Policy may change over time so please check back frequently. Any changes to this Privacy Policy will be posted on and can be viewed at our Website (https://pclsg.com/).

B. What Information Do We Receive/Collect?

“Personal data” is defined to mean data, whether true or not, about an individual who can be identified from that data, or from that data and other information to which an organization has or is likely to have access. We may collect information about you when you interact with us (including when you use our Website), when you enter into (or attempt to enter into) a transaction with us, and/or when you otherwise provide your information to us.

Personal data which we may receive or collect include but may not be limited to :

• Name
• Home address
• Location information of yourself and/or your computer or device
• Contact information
• Transactional information
• Identification number (such as National ID, Passport Number, etc.)
• Date of birth
• Gender
• Photograph
• Bank account number

We will receive or collect your personal data in accordance with the Personal Data Protection Law.

We own and/or maintain websites such as https://pclsg.com/ and publish on social media such as LinkedIn, Facebook and Instagram (collectively or individually referred to as our “Online Services”). We may collect and store certain information automatically when you visit our Online Services. Examples include the internet protocol (IP) address used to connect your computer or device to the internet, connection information such as browser type and version, your operating system and platform, a unique reference number linked to the data you enter on our system, login details, the full URL clickstream to, through and from our Online Services (including date and time), cookie number and/or your activity on our Website, including the pages you visited, the searches you made.

C. Cookies

We may use cookies to identify you from other users on our Online Services. A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer or device. The cookie has a unique ID assigned to your device, but does not contain any of your personal information like name or email address. You can block or deactivate cookies in your browser settings.

We may use cookies for the following purposes:

• in order to record information about your online preferences and allow us to tailor our websites and services to your interests;
• to track your movements from page to page and in order to store your selected inputs so you are not constantly asked for the same information; and
• to improve your experience when you visit our websites, to enable certain web functionality and track aggregate web traffic, site performance and responses to our advertising campaigns so that we can continue to produce more engaging content for you.

By continuing to use the Website, you are agreeing to the use of cookies on the Website as outlined above. However, please note that we have no control over the cookies used by third parties.

For further information on types of cookies and how they work, visit www.allaboutcookies.org.

D. The Purposes For Which We Collect, Use Or Disclose Your Personal Data

We may collect, use, disclose and/or process your personal data for one or more of the following purposes:

1. to process transactions and to improve the quality of the service that we provide to you or your employer;
2. to communicate with you as necessary in connection with the proper running of our Group;
3. to report regulatory and tax-related information to regulatory and tax authorities in order to comply with a legal obligation;
4. administering, facilitating, processing and/or dealing in any matters relating to your use of our Online Services
5. conducting research, analysis and development activities (including but not limited to data analytics, surveys and/or profiling) to improve our products, services and/or facilities);
6. to facilitate and/or ensure the safety and security of our premises, our customers, our staff and/or visitors to our premises, including by way of the use of surveillance cameras;
7. facilitating, dealing with and/or administering external audit(s) or internal audit(s) of the business(es) of KGSg;
8. dealing with and/or facilitating a business asset transaction or a potential business asset transaction, where such transaction involves a KGSg entity as a participant. A “business asset transaction” includes the purchase, sale, lease, merger or amalgamation or any other acquisition, disposal or financing of an organisation or a portion of an organisation or of any of the business or assets of an organisation;
9. complying with relevant legal and regulatory requirements; and/or
10. any other incidental or associated purposes relating to the above or any other purpose which you may from time to time agree.

(The purposes set out in this paragraph shall be collectively referred to as the “Purposes”.)

We may collect, use, disclose or process your personal data for other purposes that do not appear above. However, we will notify you of such other purpose at the time of obtaining your consent, unless processing of your personal data without your consent is permitted by the Personal Data Protection Law.

We may also receive or collect personal data about you from sources other than yourself, for one or more of the above Purposes. We may combine information we receive from other sources with information you give to us and information we collect about you. We may use this information and the combined information for the Purposes set out above (depending on the types of information we receive).

We take reasonable steps to ensure that any personal data we collect, disclose and use is accurate and complete. However, it is important that you advise us of any changes to your personal data or if there are any errors in the personal data we hold about you. We will not be responsible for relying on inaccurate or incomplete personal data arising from your not updating us of any changes in your personal data that you had initially provided us with.

E. Provision of Third Party Personal Data By You

Should you provide us with personal data of any individual other than yourself, you represent, undertake and warrant to us that:

1. for any personal data of individuals that you disclose to us, you have obtained consent from the individuals whose personal data are being disclosed, to:
   
   1. permit you to disclose the individuals’ personal data to KGSg for the Purposes; and
   2. permit KGSg to collect, use, disclose and/or process the individuals’ personal data for the Purposes;
2. at our request, you will use such form(s) or document(s) provided by us in obtaining such consents from the individuals in question (for the avoidance of doubt, we are under no obligation to you to create any such form(s) or document(s));
3. any personal data of individuals that you disclose to us are accurate; and
4. for any personal data of individuals that you disclose to us, that you are validly acting on behalf of such individuals and that you have the authority of such individuals to provide their personal data to KGSg to collect, use, disclose and process such personal data for the Purposes.

 F. How Do We Store Data?

Security of your personal data is important to us. We put in place reasonable security arrangements to ensure that your personal data is adequately protected and secured. Appropriate security arrangements have been taken to prevent any unauthorized access, collection, use, disclosure, copying, modification, leakage, loss, damage and/or alteration of your personal data. However, we cannot assume responsibility for any unauthorized use of your personal data by third parties which are wholly attributable to factors beyond our control.

We will put in place measures such that your personal data in our possession or under our control is destroyed and/or anonymized as soon as it is reasonable to assume that (i) the purpose for which that personal data was collected is no longer being served by the retention of such personal data; and (ii) retention is no longer necessary for any other legal or business purposes.

G. Rights

You have the right to ask us not to use your personal data for marketing purposes. Please let us know if you want to withdraw your consent you had provided to us by emailing us at DataProtection@pacificcarriers.com.sg.

You have the right to access and/or correct any personal data that we hold about you, subject to exceptions under the law. This right can be exercised at any time by emailing us at DataProtection@pacificcarriers.com.sg.

For a request to access personal data, once we have sufficient information from you to deal with the request, we will seek to provide you with the relevant personal data within 30 days. Where we are unable to respond to you within the said 30 days, we will notify you of the soonest possible time within which we can provide you with the information requested.

For a request to correct personal data, once we have sufficient information from you to deal with the request, we will correct your personal data within 30 days. Where we are unable to do so within the said 30 days, we will notify you of the soonest practicable time within which we can make the correction.

You have the right to withdraw your consent, whether in part or as a whole, for us to use your data. However, your withdrawal of consent could result in certain consequences arising from such withdrawal. In this regard, depending on the extent of your withdrawal of consent for us to process your personal data, it may mean that we will not be able to properly execute and/or manage your purchase or lease of our property, products or services; any contract into which you have entered with us may have to be terminated; etc. Should you wish to withdraw your consent in part or whole, please send an email to our Data Protection Officer at DataProtection@pacificcarriers.com.sg and provide details of your withdrawal.

H. Transfers of Personal Data

KGSg may need to disclose your personal data to third parties, whether located within or outside Singapore, for one or more of the Purposes. In this regard, you hereby acknowledge, agree and consent that we are permitted to disclose your personal data to such third parties (whether located within or outside Singapore) for one or more of the Purposes and for the said third parties to subsequently collect, use, disclose and/or process your personal data for one or more of the Purposes. Without limiting the generality of the foregoing, such third parties include:

1. our associated or affiliated organizations or related corporations;
2. any of 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 property agents, managing agents, booking agents, payment service providers, mailing houses, telecommunication companies, information technology companies and data centres;
3. any regulatory, supervisory or governmental authorities to the extent we are required by law to do so, or in other limited circumstances (for example if required by a court order or regulatory authority, or if we believe that such action is necessary to prevent fraud); and
4. third parties to whom disclosure by us is for one or more of the Purposes and such third parties would in turn be collecting and processing your personal data for one or more of the Purposes.

When we, or our permitted third parties, transfer personal information in this manner, we will ensure that the transfer is subject to appropriate safeguards in accordance with Personal Data Protection Law.

I. Complaint Process

If you have any complaint or grievance about how we are handling your personal data or about how we are complying with Personal Data Protection Law, we welcome you to contact us with your complaint or grievance. Please contact us with your complaint or grievance by emailing us at DataProtection@pacificcarriers.com.sg.

J. General

Your consent that is given pursuant to this Privacy Policy is additional to and does not supersede any other consents that you had provided to us with regard to processing of your personal data.

For the avoidance of doubt, in the event that Personal Data Protection Law permits an organization such as us to collect, use or disclose your personal data without your consent, such permission granted by the law shall continue to apply. Further, where Personal Data Protection Law permits us to handle, retain or process your personal data without having to comply with or as exceptions to, the data protection obligations in the Personal Data Protection Law, such rights given to us to do so will continue to prevail, notwithstanding anything stated in this Privacy Policy.

If you have any queries on this Privacy Policy or any other queries in relation to how we may manage, protect and/or process your personal data, please do not hesitate to contact our Data Protection Officer at DataProtection@pacificcarriers.com.sg.