As used in this Notice:

“customer” means an individual who

• has contacted us through any means to find out more about any goods or services we provide,
• may, or has, entered into a contract with us for the supply of any goods or

“personal data” means data, whether true or not, about a customer who can be identified:

• from that data,
• from that data and other information to which we have or are likely

Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include name, identification numbers such as NRIC, FIN, work permit and birth certificate, residential address, email address, telephone number, nationality, gender, date of birth, marital status, bank account/payment details, Video and audio recordings of the event and employment information.

Other terms used in this Notice shall have the meanings given to them in the PDPA (where the context so permits).

We generally do not collect your personal data unless

• it is provided to us voluntarily by you directly or via a third party who has been duly authorised by you to disclose your personal data to us (your “authorised representative”) after
  1. you (or your authorised representative) have been notified of the purposes for which the data is collected, and
  2. you (or your authorised representative) have provided written consent to the collection and usage of your personal data for those purposes, or
• collection and use of personal data without consent is permitted or required by the PDPA or other laws. We shall seek your consent before collecting any additional personal data and before using your personal data for a purpose which has not been notified to you (except where permitted or authorised by law).

If you have supplied third party personal data to us, you represent and warrant that you have obtained the consent of the insured person(s) you enrolled, except to the extent such consent is not required under relevant laws:

1. to collect their personal data,
2. to disclose their personal data to us, and
3. we and third parties to use any of their personal data in the manner and for the purposes described herein.

• Providing goods or services to you in relation to your transactions with Nettbox Pte Ltd.
• conducting due diligence or other screening activities (including background checks for job applicants) in accordance with legal or regulatory obligations or risk management procedures that may be required by law or internal compliance notice and procedures.
• complying to applicable laws, regulations, code of practice, guidelines, or rules in management of our relationship
• 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 purposes.
• responding to, handling, and processing queries, requests, applications, complaints, and feedback from you
• any other incidental business purposes related to or in connection with the above.

• where such disclosure is required for performing obligations in the course of or in connection with our provision of the services requested by you; or
• to third party service providers, agents, law enforcement agencies, public agencies with reference to the above-mentioned purposes.

The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to your employment contract should you be hired) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under a contract with you).

While we do our best to make our goods or services available to you, we may not be able to do so if you do not provide us with certain mandatory Personal Data that is necessary to provide the goods or services to you. Similarly, while we endeavour to accede to your requests or instructions where possible, we may not be able to accept your request or instructions if you refuse to give us Personal Data that is necessary to process or administer your request.

The consent that you provide for the collection, use and disclosure of your personal data will remain valid until such time it is being withdrawn by you in writing. You may withdraw consent and request us to stop collecting, using and/or disclosing your personal data for any or all the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below

Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within ten (10) business days of receiving it.

Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our goods or services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing .

Please note that withdrawing consent does not affect our right to continue to collect, use and disclose personal data where such collection, use and disclose without consent is permitted or required under applicable laws.

• an access request for access to a copy of the personal data which we hold about you or information about the ways in which we use or disclose your personal data,
• a correction request to correct or update any of your personal data which we hold about you, you may submit your request in writing or via email to our Data Protection Officer at the contact details provided below.

Please note that a reasonable fee may be charged for an access request. If so, we will inform you of the fee before processing your request.

We will respond to your request as soon as reasonably possible. In general, our response will be within thirty (30) business days. Should we not be able to respond to your request within thirty (30) days after receiving your request, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request. If we are unable to provide you with any personal data or to make a correction requested by you, we shall generally inform you of the reasons why we are unable to do so (except where we are not required to do so under the PDPA).

To safeguard your personal data from unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption, and disclosing personal data both internally and to our authorised third party service providers and agents only on a need-to-know basis.

You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

We generally rely on personal data provided by you (or your authorised representative). To ensure that your personal data is current, complete and accurate, please update us if there are changes to your personal data by informing our Data Protection Officer in writing or via email at the contact details provided below.

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.

We will cease to retain your personal data or remove the means by which the data can be associated with you 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 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.

We generally do not transfer your personal data to countries outside of Singapore. However, if we do so, we will obtain your consent for the transfer to be made and we will take steps to ensure that your personal data continues to receive a standard of protection that is at least comparable to that provided under the PDPA.

This Notice applies in conjunction with any other notices, contractual clauses and consent clauses that apply in relation to the collection, use and disclosure of your personal data by us.

We may revise this Notice from time to time without any prior notice. You may determine if any such revision has taken place by referring to the date on which this Notice was last updated. Your continued use of our services constitutes your acknowledgement and acceptance of such changes