Personal Data Protection Policy

1. Your Personal Data

Last Updated: 21 Mar 2020

Your privacy is important to us. This Personal Data Protection Policy sets out how Crown Group Pte Ltd, (collectively referred to herein as “Company”, “us”, “we” or “our”) comply with the provisions of the Personal Data Protection Act 2012 of Singapore (“PDPA”).

We also want you to understand the way in which we collect, use, disclose and/ or retain your Personal Data. This Personal Data Protection Policy sets out:

• our policies on how we manage your Personal Data;

• the types of Personal Data we collect, use, disclose and/ or retain;

• how we collect, use, disclose and/ or retain your Personal Data; and

• the purpose(s) for which we collect, use, disclose and/ or retain your Personal Data.

You agree and consent to us, the Company, and our clients to collect, use and disclose and/ or retain your Personal Data in the manner set forth in this Personal Data Protection Policy.

This Personal Data Protection Policy supplements but does not supersede nor replace any other consent which you may have previously provided to us nor does it affect any right that we may have at law in connection with the collection, use, disclosure and/ or retention of your Personal Data.

From time to time, we may update this Personal Data Protection Policy to ensure that our Policy is consistent with developments and trends in the Services sector and/ or any regulatory changes. Should any revision(s) be made to this Personal Data Protection Policy, updates will be made accordingly. Subject to your legal rights in Singapore, the prevailing terms of the Personal Data Protection Policy shall apply.

This Personal Data Protection Policy forms a part of the terms and conditions governing your relationship with us and should be read in conjunction with such terms and conditions (“Terms and Conditions”). In the event of any inconsistency between the provisions of the Personal Data Protection Policy and the Terms and Conditions, the provisions of the Terms and Conditions shall prevail.

In this Personal Data Protection Policy, “Personal Data” refers to any data and/or information about you from which you can be identified by, either (a) from that data; or (b) from that data and other information to which we may have legitimate access to.

Examples of such Personal Data include but are not limited to:

• your name, NRIC, passport or other identification number, telephone number(s), mailing address, email address and any other information relating to you which you have provided in any forms you may have submitted to use, or in other forms of interaction with you;

• your photos;

• your employment history, education background, and income levels;

• Personal Data of your family members, such as next of kin, spouses, and children;

• information relating to payments, such as your bank account number

• information about your usage of and interaction with our website and/ or services including computer and connection information, device capability, bandwidth, statistics on page views and traffic to and from our website

2. Collection of your Personal Data

Generally, we may collect your Personal Data through the following ways:

• when you submit a job application to us;

• when you engage us for services;

• when you respond to our request for additional Personal Data;

• when you ask to be included in an email or other correspondence;

• when you interact with any of our employees;

• when you request that we contact you; and

• when you submit your Personal Data to us for any other reason.

3. Purposes for the Collection, Use and Disclosure of Your Personal Data

Generally, we may collect, use, disclose and/ or retain your Personal Data for the following purposes:

• to manage your job application needs including recruitment, processing and termination with us;

• to provide you with services offered by the Company;

• to provide you with insurance coverage services;

• to assist you with your enquiries;

• to process payment for damages (if any);

• to improve customer services, such as resolving complaints and handling requests and enquiries;

• to conduct research, surveys and interviews;

• to keep you updated on our events; and

• to comply with applicable laws and regulations.

• Providing services and features

– create, administer and update your account;

– verify your identity;

– enable features that personalise your App, such as lists of your favourite kiosk location and transaction history;

– perform internal operations necessary to provide our Services, including troubleshooting software bugs and operational problems, conducting data analysis, testing and research, monitoring and analysing usage and activity trends;

– protect the security or integrity of the Services and any facilities or equipment used to make the Services available;

– enable communication between our users

– enable us to manage and allocate fleet resources

4. Personal Data of Minors

As a parent or legal guardian, please do not allow minors under your care to submit Personal Data to Crown Group. In the event that such Personal Data of a minor is disclosed to Crown, you hereby consent to the processing of the minor’s Personal Data and accept and agree to be bound by this Policy and take responsibility for his/her actions.

We use Personal Data to resolve customer support issues. For example, we may:

– investigate and address concerns;

– monitor and improve our customer support responses;

– respond to questions, comments and feedback; and

– inform you about steps taken to resolve customer support issues.

5. Marketing and Promotions

We may use your Personal Data to market Crown Groups’ and its’ partners, sponsors and advertisers’ products and services, events or promotions, such as:

• send you alerts, newsletters, updates, mailers, promotional materials, special privileges, festive greetings; and

• notify, invite and manage your participation in our events or activities;

• we may communicate such marketing to you by, push notification and by email.

If you wish to unsubscribe to the processing of your Personal Data for marketing and promotions, please click on the unsubscribe link in the relevant email or message. Alternatively, you may also update your preferences in our App settings.

6. Disclosure of your Personal Data

We may disclose your Personal Data to our clients for purposes mentioned above, subjected to the requirements of applicable laws:

• From time to time, we may contact you via mail, electronic mail, telephone (call or SMS-Text), facsimile or social medial platforms, to inform you about our services

• third-party service providers who provide services, such as telecommunications, mailing, information technology, payment, data processing, training, carding,

storage and archival, to the Organisation;

• our professional advisers such as our auditors and lawyers;

• relevant government regulators, statutory boards or authorities or law enforcement agencies to comply with any laws, rules, guidelines and regulations or schemes imposed by any government authority;

• your prospecting / previous employment companies for reference checks;

• any other person in connection with the purposes set forth above.

7. Accuracy of your Personal Data

• We take all reasonable measures to ensure that your Personal Data remains accurate, complete and up to date.

• You may also keep us informed when there are any updates to your Personal Data by contacting us directly.

8. Withdrawal of Consent

• If you wish to withdraw your consent to any use or disclosure of your Personal Data as set out in this Personal Data Protection Policy, you may contact us via

hanim.abdrahman@crowndigital.io

• Please note that if you withdraw your consent to any or all use or disclosure of your Personal Data, depending on the nature of your request, we may no longer be in a position to continue to provide employment and employability services to you.

9. Access and Correction of your Personal Data

• You may request access to or make corrections to your Personal Data records by writing to our Data Protection Office via email at hanim.abdrahman@crowndigital.io

10. Contacting Us

• If you have any questions or complaints relating to the use or disclosure of your Personal Data, or if you wish to know more about our data protection policies and practices, please contact our Data Protection Office via email at hanim.abdrahman@crowndigital.io

If you have any questions about this Privacy Policy and/or the handling of your personal data by us, please contact our Data Protection Officer at:

Name: Ms Hanim Abdul Rahman

Email: hanim.abdrahman@crowndigital.io

Postal Address: 114 Lavender Street, CT Hub 2, #01-22, Singapore 338729

For more information about PDPA generally, please visit the Personal Data Protection Commission’s website at http://www.pdpc.gov.sg