Personal Data
Protection Policy

1.1 “Personal Data” refers to any data, whether true or untrue, about an individual (a) who can be identified from that data, or (b) who can be identified from that data when such data is read together with other information which we have or are likely to have access to.

1.2 “You” and “your” refers to you or the organisation you represent, as the case may be.

2.1 In the course of our dealings with you, we may request that you provide us your Personal Data for the purposes of entering into transactions with you or to provide you with certain goods or services.

2.2 We generally collect Personal Data via one or more of the following ways: When you submit an application form or any other form to us;

• When you register for and/or use our online services, including but not limited to our Investor Portal;
• When you request that we contact you, or that we include you in our mailing list(s);
• When you respond to our requests for additional Personal Data (if any);
• When you submit a job application;
• When we receive references from third parties, including but not limited to our business partners;
• When you provide your Personal Data to us upon seeking to access our premises and properties; and
• When you submit your Personal Data to us for any other reason.

2.3 If you provide us with the Personal Data of any third parties, you are representing that you are duly authorized by such third parties to provide their Personal Data to us for the purposes set out in paragraph 2.1 or any other purposes we are notified of.

2.4 You are required to ensure that Personal Data provided to us is true, complete, and accurate.

3.1 Generally, we collect, use and/or disclose your Personal Data for one or more of the following purposes:

• Verifying your identity
• Managing our internal infrastructure and business operations, including but not limited to where required for compliance with internal policies and procedures;
• Conducting audits, reviews, and analyses of our internal processes;
  Preventing, detecting, and/or investigating crime and criminal activity;
• Managing the safety and security of our premises;
• Protecting and enforcing our contractual and legal rights and obligations;
• Ensuring our compliance with all relevant laws, regulations, guidelines, and codes of practices;
• Responding to your queries, requests, and/or complaints; and
• Any other purposes relating to the purposes stated above.

3.2 In addition, we may collect, use and disclose your Personal Data for one or more of the following purposes, depending on the scope and nature of our dealings with you:

1. If you have or apply for an account on our secure Investor Portal:
   1. Verifying your personal particulars in order to process your application;
   2. Maintaining your account with us;
   3. Communicating with you to inform you of changes to our policies and/or terms and conditions;
   4. Handling requests, enquiries, and/or complaints;
   5. Conducting market research; and
   6. Processing your Personal Data in relation to any of the purposes stated above.
2. If you submit or have submitted an application to us as a candidate for employment, work attachment, and/or an internship:
   1. Processing your application and assessing your suitability, including but not limited to carrying out pre-employment checks;
   2. Providing or obtaining employee references;
   3. Organising internal training and professional development programs;
   4. Assessing your performance;
   5. Administration of payroll and other benefits;
   6. Providing you with tools for and/or facilitating you to discharge your responsibilities;
   7. Communicating with you to comply with our policies and processes, including but not limited to communications for business continuity; and
   8. Any other purposes relating to the purposes stated above.

4.1 We will take reasonable steps to protect Personal Data against unauthorized disclosure. Subject to the provisions of any applicable law, Personal Data may be disclosed as appropriate, for the purposes listed in Clause 3 above (where applicable), to the following third parties, whether they are located in Singapore or overseas:

• our affiliates;
• agents, contractors or third party service providers that provide operational services to us, including but not limited to telecommunications, information technology, payment, payroll, processing, training, market research, storage, archival or other services;
• the Credit Bureau;
• any of our business partners, investors, assignees or transferees (actual or prospective) should such disclosure be reasonably required to facilitate business asset transactions (which may extend to any merger, acquisition or asset sale);
• any person or corporate body to whom we transfer or may transfer our rights and duties;
• banks, credit card companies and their respective service providers;
  our professional advisors, including but not limited to our consultants, auditors, and lawyers;
• relevant government regulators or authorities or law enforcement agencies, where such disclosure is required by us in order to comply with the applicable laws or rules and regulations; and
• any other party to whom you authorise us to disclose your personal data.

5.1 Our website may contain links to other websites operated by external third parties, including but not limited to our business partners. We are not responsible for the privacy and/or personal data protection practices of such third parties insofar as they are not involved in any of our transactions with you. Some third party websites may be co-branded with our logo or trademark, but are not operated or maintained by us. Once you have left our website, you should check the applicable terms, conditions and policies of the third party website to determine how these third parties will handle any information and/or personal data they collect from you.

6.1 We gather information on our website activity, such as data on the number of visitors, the pages they visit, the duration of their stay, etc. Such information is collected on an aggregate, anonymous basis, which means no Personal Data is associated with this data and gathered through the use of web server logs and cookies. We do not at our website automatically collect Personal Data unless you provide such information or login with your account credentials.

6.2 To do so, we use “cookies” and a small data file is sent from your browser to store and track aggregate information when you enter our website(s).

6.3 By accessing and using our website and services, you consent to the storage of cookies, other local storage technologies, beacons and other information on your devices. You also consent to the access of such cookies, local storage technologies, beacons and information by us or our representatives or agents.

6.4 You may wish to set your web browser to notify you of a cookie placement request. Should you wish to disable the cookies associated with these technologies, you may do so by changing your browser setting(s). However, you may not be able to assess certain parts of our website.

7.1 Should you wish to withdraw your consent to our use of any of your Personal Data, or to obtain access to and/or make corrections to your Personal Data records, please log in to the relevant account via which the Personal Data was provided to us (if any). You may also wish to contact our Personal Data Protection Officer, who can be contacted at dpo@utacgroup.com.

7.2 Please be informed that after we are notified by you of your intention to withdraw your consent to our use of your Personal Data, it may take up to 30 days for your withdrawal to be reflected.

7.3 If your Personal Data has been provided to us by a third party, you should contact such party directly to make any queries, feedback, and access and correction requests to us on your behalf.

7.4 If you withdraw your consent to our use of any of your Personal Data, depending on the nature of your request, we may no longer be in a position to continue to provide our products or services to you or administer any contractual relationship in place. This may result in the termination of any agreements between you and us and/or your being in breach of your contractual obligations or undertakings. In such event, all our legal rights and remedies are expressly reserved.

8.1 This Personal Data Protection Policy, as well as your use of this website, shall be governed by the laws of the Republic of Singapore.