This Data Protection Policy (“Policy”) sets out the basis which Matco Asia Pte Ltd & Matco Asia Services Pte Ltd (“Matco”, “we, “us”, or         “our”) may collect, use, disclose or otherwise process personal data of all individuals in accordance with the Personal Data Protection              Act (“PDPA”). This Policy applies to personal data in our possession or under our control, including personal data in the possession of            organizations which we engaged to collect, use, disclose or process personal data for our purposes.


     What is Personal Data


       “Personal Data” refers to any data, whether true or not, about an individual who can be identified from that data; or from that data and          other information to which we have or are likely to have access.


     If you are a job applicant, personal data which we may collect includes, without limitation, your:


        a. name or alias, gender, date of birth, nationality, and country and city of birth;
        b. mailing address, telephone numbers, email address and other contact details;
        c. resume, educational qualifications, professional qualifications and certifications and employment references;
        d. employment and training history;
        e. work-related health issues and disabilities, and
        f. photographs.


     If you are an employee, personal data which we may collect in the context of your employment with us includes, without limitation,               your:
        a. name or alias, gender, NRIC/FIN or passport number, date of birth, nationality, and country and city of birth;
        b. mailing address, telephone numbers, email address and other contact details;
        c. employment and training history;
        d. salary information and bank account details;
        e. details of your next-of-kin, spouse and other family members;
        f. work-related health issues and disabilities;
        g. records on leave of absence from work;
        h. photographs and other audio-visual information;
         i. performance assessments and disciplinary records; and
         j. any additional information provided to us by you as a job applicant (that is, prior to being engaged as an employee).


     If you are a customer, we may collect your personal data for any or all of the following purposes;


         a. performing obligations in the course or or in connection with our provision of the goods and/or services requires by you;
         b. verifying your identify;
         c. responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
         d. managing your relationship with us;
         e. processing payment or credit transactions;
         f. sending you marketing information about our goods or services including notifying you of our marketing events, initiatives and                      promotions, lucky draws, membership and rewards schemes and other promotions;
         g. complying with any applicable laws, regulations, codes or practice, guidelines, or rules, or to assist in law enforcement and                           investigations, conducted by any governmental and/or regulatory authority;
         h. any other purposes for which you have provided the information;
          i. 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 aforementioned purposes; and
          j. any other incidental business purposes related to or in connection with the above.


     How We Collect, Use and Disclose Your Personal Data


         1. We generally do not collect your personal data unless (a) it is provided to us voluntarily by you directly or via a third party who has               been duly authorized by you to disclose your personal data to us (your“authorized representative”) after (i) you (or your authorized               representative) have been notified of the purposes for which the data is collected, and (ii) you (or your authorized representative)                 have provided written consent to the collection and usage of your personal data for those purposes, or (b) 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 authorized by law),


         2. If you are a job applicant, your personal data will be collected and used by us for the following purposes and we may disclose                 your personal data to third parties where necessary for the following purposes:


         a. assessing and evaluating your suitability for employment in any current or prospective position within the organization; and
         b. verifying your identity and the accuracy of your personal details and other information provided.


         3. If you are an employee, your personal data will be collected and used by us for the following purposes and we may disclose                     your personal data to third parties where necessary for the following purposes:


         a. performing obligations under or in connection with your contract of employment with us, including payment of remuneration and                   tax;
         b. all administrative and human resources related matters within our organization, including administering payroll, granting access to                 our premises and computer systems, processing leave applications, administering your insurance and other benefits, processing                   your claims and expenses, investigating any acts or defaults (or suspected acts or defaults) and developing human resource                         policies;
         c. managing and terminating our employment relationship with you, including monitoring your internet access and your use of our                   intranet email to investigate potential contraventions of our internal or external compliance regulations, and resolving any                             employment related grievances;
         d. assessing and evaluating your suitability for employment/ appointment or continued employment/appointment in any position                       within our organization;
         e. ensuring business continuity for our organization in the event that your employment with us is or will be terminated;
         f. performing obligations under or in connection with the provision of our goods or services to our clients;
         g. facilitating any proposed or confirmed merger, acquisition or business asset transaction involving any part of our organization, or                   corporate restructuring process; and
         h. facilitating our compliance with any laws, customs and regulations which may be applicable to us.


         4. The purpose listed in the above clauses may continue to apply even in situations where your relationship with us (for example,                     pursuant to a contract) 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 any contract with you).


     If you are a customer, we may disclose your personal data:


         a. where such disclosure is required for performing obligations in the course of or in connection with our provision of the goods or                     services requested by you; or
         b. to third party service providers, agents and other organizations we have engaged to perform any of the functions listed above for                 us.


     Withdrawing Your Consent


         5. 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 your consent to Matco by submitting your request in writing or via email to our                     Data Protection Officer at the contact details provided in clause 17.


         6. Upon receipt of your written request to withdraw your consent, we may require a reasonable time for your request to be processed               and for us to notify you of the likely consequences of the withdrawal. In general, we shall seek to process your request within ten                 (10) days of receiving it.


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


     Access and Correct Your Personal Data


         8. If you wish to make (a) 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, or (b) a correction request to correct or update your personal data which               we hold about you, you may submit your request in writing to our Data Protection Officer at the contact details provided below.


         9. We will respond to your request as soon as reasonably possible. Should we not be able to respond to your request within ten (10)                 days after receiving your request, will inform you in writing within ten (10) 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 reason(s) why we are unable to do so (except we are required to do so under the PDPA).


     How We Protect Your Personal Data


        10. We strive to protect your personal data in our possession, custody or control by maintaining appropriate administrative, technical                  and physical safeguards to protect against unauthorized access, collection, use, disclosure, copying, modification, disposal or                        similar risks both internally and to our authorized third party service providers and agents only on a need-to-know basis.


        11. 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.


     Accuracy of Your Personal Data


        12. We shall make reasonable efforts to accurately record your personal data as given by you or your authorized representatives. In                   order 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 via email at the contact details provided in clause 17.


     Retention of Your Personal Data


        13. 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.


        14. 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 purpose.


     Complaints


        15. You may send complaints or feedback regarding our handling of your personal data in writing or via email to our Data Protection                 Officer at the contact details provided in clause 17.


        16. All complaints will be evaluated by us in a timely manner. After we have completed its evaluation, the Data Protection Officer will                 respond to the person who submitted the complaint or feedback, with the results of the evaluation.

     How to Contact Us


        17. If you, at any time, have any queries on this Policy, or any other queries in relation to how we may manage, protect and/or                         process your personal data, please contact our Data Protection Officer at:


                                      Data Protection Officer
                                      Matco Asia Pte Ltd / Matco Asia Services Pte Ltd
                                      19 Joo Koon Crescent
                                      Singapore 629017
                                      Email: dpo@matcoasia.com


     Effect of Policy and Changes to this Policy


        18. This Policy 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.


        19. As part of our efforts to ensure that our policies, procedures and processes remain current and continues to fulfill its obligations                   under the PDPA, we may change this Policy at any time and from time to time, without any prior notice. Your continued use                         following the posting of an updated version of this Policy will constitute your acknowledgement and acceptance of such changes.

   Data Protection Policy