Personal Data Protection Policy

The purpose of this document (“Data Protection Policy”) is to inform you of how Klareco Communications Pte Ltd (“Klareco”) manages Personal Data (as defined below) which is subject to the Singapore Personal Data Protection Act 2012 (“the Act” or “PDPA”).

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, purchase or using any services offered by us (“Services”), you agree and consent to Klareco (including its related corporations) (collectively, the “Companies”), as well as its representatives and /or agents (collectively referred to herein as “Klareco Group”, “us”, “we” or “our”) collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to the Companies’ 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 nr replace any other consents you may have previously provided to Klareco Group 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.

Klareco Group 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 right 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://www.klarecocomms.com. Pease 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 from that data and other information to which we have or are likely to have access, including data in our records as maybe 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 numbers(s), mailing address, email address and any other information relating to any individual which you have provided us in any forms you may have submitted to us, or via other methods or interaction with you.

1.3 Please note that the data protection provides of the PDPA do not apply to business contact information (“BCI”). BCI is defined in the PDPA as an individual’s name, position name or title, business telephone number, business address, business electronic mail address or business fax number and any other similar information about the individual, not provided by the individual solely for this personal purposes.

2. Collection of Personal Data

2.1 Generally, we collect Personal Data in the following ways:

- - when you submit any form, including but not limited to application and registration forms or other forms relating to any of our services;
  - when you enter into any agreement or provide other documentation or information respect of your interactions with us, or when you use our services;
  - when you interact with our staff via telephone calls (which may be recorded), letter, face to face meetings, social media platforms and emails;
  - when you use our electronic services, or interact with us via our website, and apps or use services on our websites;
  - when you request that we contact you or request that you be included in an email or other mailing list;
  - when you submit an employment application or when you provide documents or information including your resume and/or CVs in connection with any appointment as an officer, director, representative or any other position;
  - when your images are captured by us via photographs or videos taken by us or our representative when you attend events organised by our team or purchasing our services;
  - when you are contacted by, and respond to, our marketing effort by our representatives;
  - when we receive references from business partners and third parties, for example, where you have been referred by them with our consent;
  - when we seek information from third parties about you and receive your Personal Data in connection with your relationship with us, including for our Services, job applications, for example business partners, public agencies, your ex-employer, referral intermediaries and the relevant authorities; and/or
  - 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 Services you have requested, or delays in processing your applications.

3. Collection of Personal Data

3.1 In general, we may use your personal data for the following purposes on basis of the consent given (where applicable) for:

- - conducting and completing transactions with you;
  - responding to your queries, feedbacks, complaints and requests;
  - managing the administrative and business operations of Klareco Group and complying with internal policies, reporting requirements and procedures;
  - requesting feedback or participation in surveys, as well as conducting market research for us or on our clients’ behalf, to review, develop and improve the quality of our or their services;
  - hosting, storing or backing-up your Personal Data, which may be on third party servers or data clouds;
  - legal purposes in connection with any claims, action or proceedings;
  - complying with applicable laws, regulations and other requirements (e.g. providing assistance to law enforcement agencies, regulatory authorities and other governmental agencies; performing internal audits);
  - performing evaluations (e.g. assessing suitability of employees);
  - purposes which are reasonably related to the aforesaid.

3.2 In addition, we may use your personal data for the following purposes on basis of the consent given (where applicable) for:

- - If you are an employee, officer or owner of an external service provider or vendor outsourced or prospected by Klareco Group:

(i) assessing your suitability as an external service provider or vendor for Klareco Group

(ii) managing project quotations, processing orders or managing the supply of goods and services;

(iii) managing business operations and product development; and/or

(iv) purposes which are reasonably related to the aforesaid

- - If you submit an application to us as a candidate for any employment:

(i) conducting interviews

(ii) processing your application (including but not limited to pre-recruitment checks involving your qualifications and facilitating interviews);

(iii) providing or obtaining references and for background screening;

(iv) assessing your suitability for the position applied for;

(v) onboarding successful candidates and facilitating human resource planning and management; and/or

(vi) purposes which are reasonably related to the aforesaid

3.3 In relation to Services or in your interactions with us, we may also have specifically notified you of other purchases 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 Klareco Group will take commercially reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, your Personal Data maybe disclosed, for the purposes listed above (where applicable), to the following entities or parties, whether they are located overseas or in Singapore:

- - Klareco Group’s related corporations and employees; to provide Services to you, address your questions and requests in relation to your interactions with us as well as our Services, to maintain and operate our system and/or services;
  - companies providing servies relating to medical screening, insurance and consultancy to Klareco Group;
  - agents, contractors or third-party services providers who provide operational services to Klareco Group, such as courier services, customer service, telecommunications, information technology, payment, printing, billing, payroll, technical services, training, market research, security, or other services to Klareco Group;
  - external banks, credit card companies and their respective service providers;
  - our professional advisers such as consultants, auditors and lawyers;
  - foreign embassies in relation to facilitating overseas travel arrangements;
  - relevant government ministries, regulators, statutory boards or authority or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any governmental authority; and/or
  - any other party to whom you authorise us to disclose your Personal data to.

4.2 The disclosures referred to above may be subject to additional legal requirements under applicable law, if we do disclose your Personal Data, we will only do so to the extent necessary, proportionate and legally permitted. We will not sell, rent or give away personal data to third parties for commercial purposes without your consent.

5. Data Security and Data Retention

5.1 We have appointed Data Protection Officers (“DPOs”) for our Klareco Group to oversee our management of personal data in accordance with Data Protection Laws.

5.2 Klareco Group will take a reasonable effort 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, you will appreciate that it is not for us to perfectly secure your personal data from cyber-attacks, such as hacking, spyware and viruses. Accordingly, you will not hold us liable for any unauthorized disclosure, loss or destruction of your personal data arising from such risks.

5.3 If the transfer of your Personal Data within our group of companies is necessary, we will take reasonable steps to ensure that your Personal Data transmitted outside of your country of residence remains adequately protected to a standard similar to that afforded by PDPA. In addition, we will ensure that such transfers comply with the requirements of the applicable data protection laws.

5.4 In the event of a security breach that involves loss of personal data from Information Technology (“IT”) systems and devices, or loss of hard copy documents containing personal data, the data handler is required to report the incident to the DPO immediately.

5.5 Affected individuals will be notified of the data security breach. Steps will be taken to investigate the cause of the breach, and the steps to take to minimise the damage – consider if the personal data was encrypted and the type of personal data which has been lost.

5.6 All Personal Data is retained for as long as it is necessary for the purposes it has been collected for in accordance with our data retention policy. Any third party who manages our personal data are also required to ensure that the Personal Data is disposed in accordance to the retention period as may be agreed in their respective engagement contract(s).

6. Contacting us – Withdrawal of consent, Access and Correction of your Personal Data

6.1 If you:

- - Have any questions or feedback relating your Personal Data or our Data Protection Policy: you can give feedback to the DPO by completing the Feedback Form.
  - Would like to obtain access to your Personal Data records:
  - Please contact the DPO in writing using the Request to Access Personal Data Form.
  - We will require you to verify your identity and to specify what data you require. We may charge a fee to cover the cost of verifying the application and locating, retrieving, reviewing, and copying any material requested. If the data sought is extensive, we will advise the likely cost in advance and can help to refine your request if required.
  - Would like to make corrections to your your Personal Data records:
  - Please contact the DPO in writing using the Request to Personal Data Correction Form.
  - Would like to withdraw your consent to any use of your Personal Data as set out in Data Protection Policy:
    - Call: (65) 6333 3449
    - Email: ksim@klareecocomms.com
    - Write to our Data Protection Officer at:
    - You can approach us via the following channels:
    - Data Protection Officer, 22 Cross Street #02-01, Singapore 048421

6.2 Please note that if your Personal Data has been provided to us by a third party (e.g. a referrer, or your company), you should contact that organisation or individual to make such queries, complaints, and access and correction request to Klareco Group on your behalf.

6.3 If you withdraw your consent to any or all use of your Personal Data, depending on the nature of your request , Klareco Group may not be in a position to continue to provide its Services to you, administer any contractual relationship in place, which in turn may also result in the termination of any agreements with Klareco Group, and your being in breach of your contractual obligations or undertaking Klareco Group legal rights and remedies in such extent are expressly reserved.

7. Links to Third-Party Website(s)

7.1 Our Companies’ websites may contain links to other third-party operated website operated by third parties over which we have no control over. We are not responsible for the privacy and/or data protection practices of such third-party operated websites that are linked o our websites. Once you have left our website by clicking a relevant link, your use of that third-party website will be governed by the privacy or data protection policy of that website.

8. Governing Law

8.1 This Data Protection Policy and your use of this website shall be governed in all respects by the laws of Singapore.

9. Updates to this Policy

9.1 This Policy will be reviewed from time to time to take account of new laws and technology, changes to our operations and practices and the changing business environment. This Policy was last updated on 28 April 2023. If you are unsure whether you are reading the most current version, please contact us.