Data Protection Policy
We at Septeni Asia Pacific Pte. Ltd. (“Septeni”) take our responsibilities under the Personal
Data Protection Act 2012 (the “PDPA”) seriously. We also recognize the importance of thepersonal data you have entrusted to us and believe that it is our responsibility to properly
manage, protect and process your personal data.
This Data Protection Policy is designed to assist you in understanding how we collect, use
and/or disclose the personal data you have provided to us, as well as to assist you in making
an informed decision before providing us with any of your personal data.
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 do not hesitate to contact
our Data Protection Officer (the “DPO”) at:
privacy@septeni.com

1

INTRODUCTION TO THE PDPA

1.1

“Personal Data” is defined under the PDPA to mean data, whether true or not, about
an individual who can be identified from that data, or from that data and otherinformation to which an organization has or is likely to have access. Common
examples of personal data could include names, identification numbers, contact
information, medical records, photographs and video images.

1.2

We will collect your personal data in accordance with the PDPA. In general, before
we collect any personal data from you, we will notify you of the purposes for whichyour personal data may be collected, used and/or disclosed, as well as obtain yourconsent for the collection, use and/or disclosure of your personal data for theintended purposes.

2PURPOSES FOR COLLECTION, USE & DISCLOSURE OF PERSONAL DATA

2.1

The personal data which we collect from you may be collected, used and/or disclosed
for the following purposes :(a)

Processing, administering and managing your relationship with Septeni;(b)Managing Septeni’s infrastructure and business operations;(c)Managing enquiries and instructions from you;

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(d)Dealing in any matters relating to the services which you have engaged
Septeni for (including the mailing of correspondence, statements, invoices,
reports or notices to you, which could involve disclosure of certain personal
data about you to bring about delivery of the same as well as on the externalcover of envelopes / mail packages);(e)Conducting customer due diligence and personal identification in accordancewith laws, regulations and policies including Septeni’s internal policies;(f)Sending you marketing, advertising and promotional information aboutother Internet advertising products and/or services that Septeni may beselling or marketing, and which Septeni believes may be of interest or benefit
to you by way of postal mail and/or electronic transmission to your e-mailaddress(es);(g)

Providing you with various proposals and advice on current and/or future
products and services from Septeni or of our partner companies;(h)Conducting market research and data analysis; and(i)Reporting and sharing with our affiliate companies located in Japan, Korea,
the United Kingdom and the United States of America.

2.2

In order to conduct our business operations more smoothly, we may also be
disclosing the personal data you have provided to us to our third party service
providers, agents and/or our affiliates or related corporations, which may be sited
outside of Singapore, for one or more of the above-stated Purposes. This is becausesuch third party service providers, agents and/or affiliates or related corporations
would be processing your personal data on our behalf for one or more of the abovestated Purposes.

3

SPECIFIC ISSUES FOR THE DISCLOSURE OF PERSONAL DATA TO THIRDPARTIES

3.1

We respect the confidentiality of the personal data you have provided to us.

3.2

In that regard, we will not disclose any of your personal data to any third parties
without first obtaining your express consent permitting us to do so. However, please

Page 2 of 6note that we may disclose your personal data to third parties without first obtaining
your consent in certain situations, including, without limitation, the following :(a)cases in which the disclosure is required based on the applicable laws and/orregulations;(b)cases in which the purpose of such disclosure is clearly in your interests, andif consent cannot be obtained in a timely way;(c)cases in which the disclosure is necessary to respond to an emergency thatthreatens the life, health or safety of yourself or another individual;(d)cases in which there are reasonable grounds to believe that the health orsafety of yourself or another individual will be seriously affected and consent
for the disclosure of the data cannot be obtained in a timely way, provided
that we shall, as soon as may be practicable, notify you of the disclosure andthe purposes of the disclosure;(e)cases in which the disclosure is necessary for any investigation orproceedings;(f)cases in which the personal data is disclosed to any officer of a prescribed law
enforcement agency, upon production of written authorisation signed by thehead or director of that law enforcement agency or a person of a similar rank,
certifying that the personal data is necessary for the purposes of the functions
or duties of the officer; and/or(g)cases in which the disclosure is to a public agency and such disclosure isnecessary in the public interest.

3.3

The instances listed above at paragraph 3.2 are not intended to be exhaustive. For an
exhaustive list of exceptions, you are encouraged to peruse the Second, Third andFourth Schedules of the PDPA which is publicly available at https://sso.agc.gov.sg/.

3.4

In all other instances of disclosure of personal data to third parties with your express
consent, we will endeavour to provide adequate supervision over the handling andadministration of your personal data by such third parties, as well as to provide foradequate forms of protection over such personal data.

4REQUEST FOR ACCESS AND/OR CORRECTION OF PERSONAL DATA

4.1

You may request to access and/or correct the personal data currently in ourpossession at any time by submitting your request through the following methods :Page 3 of 6

(a)
(b)

E-mail:privacy@septeni.com

Office address:

10 Anson Road, #14-06, InternationalPlaza,Singapore 079903
4.2

For a request to access personal data, we will provide you with the relevant personal
data within a reasonable time from such a request being made.

4.3

For a request to correct personal data, we will undertake the following :(a)we will correct your personal data as soon as practicable after the request has
been made; and(b)subject to paragraph 4.4, we will send the corrected personal data to every
other organisation to which the personal data was disclosed by Septeni within
a year before the date the correction was made, unless that other organisation
does not need the corrected personal data for any legal or business purpose.

4.4

Notwithstanding paragraph 4.3(b), we may, if you so consent, send the corrected
personal data only to specific organisations to which the personal data was disclosed
by us within a year before the date the correction was made.

4.5

We will also be charging you a reasonable fee for the handling and processing ofyour requests to access your personal data. We will provide you such details before
the processing of your access request.

4.6

Notwithstanding any of the other provisions of this paragraph 4, please note that weare entitled under the PDPA to refuse any personal data access or correction request
on any of the grounds specified under sections 21(3) and 22(2) respectively of thePDPA. Further grounds of refusal to process any personal data access and correction
request are contained in the Fifth and Sixth Schedules of the PDPA respectively. In
particular :(a)

we may refuse to process your access request (i) in the event that your request
would unreasonably interfere with our operations because of the repetitious
or systematic nature of the requests; (ii) in the event that the burden or
expense of providing access would be unreasonable to us or disproportionate
to your interests; (iii) in the event that the information you requested accessfor is trivial; or (iv) your request is otherwise frivolous or vexatious; and/or(b)we may refuse to process your correction request in the event that we aresatisfied on reasonable grounds that such correction should not be made.

5REQUEST TO WITHDRAW CONSENT
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5.1

You may withdraw your consent for the collection, use and/or disclosure of yourpersonal data in our possession or under our control at any time by submitting yourrequest through the following methods :(a)(b)

E-mail:privacy@septeni.com

Office address:

10 Anson Road, #14-06, International

Plaza,Singapore 079903
5.2

We will process your request within a reasonable time from such a request forwithdrawal of consent being made, and will thereafter refrain from collecting, using
and/or disclosing your personal data in the manner stated in your request.

6ADMINISTRATION AND MANAGEMENT OF PERSONAL DATA

6.1

We will take appropriate measures to keep your personal data accurate, complete
and updated.

6.2

We will also take commercially reasonable efforts to take appropriate precautions
and preventive measures to ensure that your personal data is adequately protected
and secured. Appropriate security arrangements will be taken to prevent any
unauthorized access, collection, use, disclosure, copying, modification, leakage, loss,damage and/or alteration of your personal data. However, we cannot assume
responsibility for any unauthorized use of your personal data by third parties which
are wholly attributable to factors beyond our control.

6.3

We will also take commercially reasonably efforts to ensure that the personal data in
our possession or under our control is destroyed and/or anonymized as soon as it isreasonable to assume that (i) the purpose for which that personal data was collected
is no longer being served by the retention of such personal data; and (ii) retention is
no longer necessary for any other legal or business purposes.

7

UPDATES ON DATA PROTECTION POLICY

7.1

As part of our efforts to ensure that we properly manage, protect and process yourpersonal data, we will be reviewing our policies, procedures and processes from timeto time.

7.2

We reserve the right to amend the terms of this Data Protection Policy at ourabsolute discretion. Any amended Data Protection Policy will be posted on ourwebsite and can be viewed at [ http://www.septeni.co.jp/ap/].

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7.3

You are encouraged to visit the above website from time to time to ensure that you
are well informed of our latest policies in relation to personal data protection.

Last Updated on 1st April 2019

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