1. About Us

1. This is the Privacy Policy ("Policy" or “Privacy Policy”) of SGHINDI PTE.

LTD. ("SGHINDI") and its subsidiaries.

2. You have been directed to this Policy because a company within the

SGHINDI Group is collecting, using or disclosing your personal data.

3. In this Policy, when we use "we", "us" or "our", we refer to the company

(SGHINDI PTE. LTD.) which is collecting your personal data, or which is

operating the website which you are accessing or using.

4. We own and/or operate website(s) such

as https://www.sghindi.com and/or any mobile apps that may be

published by us (the said website and mobile apps may be collectively or

individually referred to as the “Website”).

5. SGHINDI is a limited company registered in Singapore (Co. Reg.

202039010D) at 10 JALAN BESAR, #11-02, SIM LIM TOWER,

Singapore 208787.

2. The purpose of this Policy

1. The purpose of this Privacy Policy is to inform you and provide you with

an understanding of how we, our affiliates, related corporations and

associated companies globally, handle, collect, use, disclose and deal

with personal data about you that you give us, that we receive through

third parties or that is in our possession. Please read this Privacy Policy

carefully.

2. We are committed to safeguarding the privacy and security of your

personal data. We take our responsibilities under Singapore’s Personal

Data Protection Act (the “PDPA”) seriously. We also recognise the

importance of the personal data you have entrusted to us and believe that

it is our responsibility to properly manage, protect and process your

personal data.

3. The contents of this Privacy Policy may change over time so please check

back frequently. Any changes to this Privacy Policy will be posted on and

can be viewed at our Website.

4. This Policy applies to all personal data that you may provide to us and the

personal data we hold about you. By providing us with your personal data

or by accessing, using or viewing the applicable Website or any of its

services, functions or contents (including transmitting, caching or storing

of any such personal data), you shall be deemed to have agreed to each

and all the terms, conditions, and notices in this Policy. If you do not

agree, please cease use of the relevant Website(s) and/or service(s)

and DO NOT provide any personal data to us.

5. The Website is not intended for use by children (below the age of 18)

without parental supervision. We do not and do not intend to, transact

through the Website directly with anyone we know to be under the age of

18, if they do not have parental permission or supervision.

6. By providing any personal data to us, you declare and affirm that you are

at least 18 years of age (or under the supervision and guidance of

parents) and above and agree to the terms set out in this Privacy Policy.

3. Personal data which is collected

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 other information to which an organisation has or is likely to

have access.

2. When you use our Website, any service we provide or in your interaction

with us, the personal data we may collect include but is not limited to :-

(a) Data collected directly from you. This may be done through our

Website, over the phone, by email, or in person when you meet our staff

or representatives. The personal data collected may include, but is not

limited to:

• your contact information, including your (first and last) name, (billing

and/or delivery) address, birthdate and email address and/or your

telephone number. We need your e-mail address and/or telephone

number so that we may contact you if we have questions or

information for you regarding your order or the service that we are

providing or will provide to you;

• other information required to be able to process your order or to

provide you with the service, such as information concerning the

products you have ordered or the service we are providing to you,

the billing and/or delivery address, banking and/or credit/debit card

details;

• if you have created an online profile or account, the preferences and

interests stored in such profile or account (please see below for

further information concerning the profiles); and/or

• if you have contacted customer service, the details of this contact

and the contact history.

(b) Data collected by automated means. Various technologies may be

used on our Website and our mobile and web-based applications in order

to make them more user-friendly, effective and secure. Such technologies

may lead to data being collected automatically by us or by third parties

on behalf of us. This data does not always, but may, contain a user's

personal data or comprise of personal data. Examples of such

technologies include:

• Click-stream data. A visit to one of our Websites results in data that

is transmitted from your browser to our server being automatically

collected and stored by us or by third parties on behalf of us. This

data can include, in particular, the following:

▪ the visitor's IP address

▪ the date and time of the visit

▪ the referral URL (the site from which the visitor has come)

▪ the pages visited on our website

▪ information about the browser used (browser type and

version, operating system, etc).

• Cookies. A number of places on our Website and our mobile and

web-based applications make use of cookies. These are essentially

small text files that are stored on your computer's hard drive or your

user device by your web browser. We can use cookies to identify the

owner of a user account and to store articles in a shopping basket

during the purchasing process. In other words, cookies help to make

our website or our (mobile and web-based) applications more user-

friendly, more effective and more secure. The cookies usually used

by us are so-called "session cookies", which are automatically

deleted at the end of the visit to the relevant website. By default, web

browsers enable the use of cookies but this function can also be

disabled. However, this will result in some services not being

available. It is also possible to manually delete cookies after their

use via the web browser. More information may be available from

your web browser provider.

• Flash cookies. A particular form of cookie is the flash cookie. In

contrast to normal cookies, these cookies are not created and saved

by the web browser but are governed by the Adobe Flash plug-in.

These can contain more information than normal cookies and cannot

be deleted or disabled via the browser; this is only possible if you

follow instructions available from the Adobe Flash Player website.

You can also obtain more information about these cookies on that

website.

• Web beacons and tracking links. Web beacons (also known as

pixel tags and clear GIFs) involve graphics that are not apparent to

the user. Tracking links and/or similar technologies consist of a few

lines of programming code and can be embedded in our website or

our (mobile) applications. In conjunction with cookies, these are

primarily used for statistical analysis purposes. This technology can

also be used for tracking traffic patterns on websites, as well as

finding out if an e-mail has been received and opened and to see if

there has been any response.

• Web analytics. Web analytics is the term given to a method for

collecting and assessing the behaviour of visitors to websites and

(mobile) applications. This includes the analysis of traffic patterns in

order, for example, to determine the frequency of visits to certain

parts of a website or (mobile) application, or to find out what

information and services our visitors are most interested in. For

these purposes, we primarily make use of click-stream data and the

other techniques listed above. Web analytics are carried out by

Google Analytics and/or other selected parties. You can find out

more information about the processing of web analytics data by

Google Analytics in paragraph 9 below.

3. Hence, depending on the circumstances or the nature of the transaction

with you, the personal data we may collect from you includes :

• name

• home address

• age

• gender

• birthdate

• identification number (such as national ID, passport details

etc.)(collection of this will be in compliance with the PDPA and

depends on the circumstances or transaction at hand)

• image and/or photograph

• credit/debit card information

• location Information of yourself and/or your computer or device

• contact Information

• transactional information

• usage and preferences

• bank account number

• your purchase and/or your transactions with us

• your signature (such as when you sign off on a parcel delivery)

We will collect your personal data in accordance with the PDPA.

4. We may receive information about you from third parties such as if you

use any websites or social media platforms operated by third parties (for

example, Facebook, Instagram, Twitter etc.) and, if such functionality is

available, you have chosen to link your profile on our Website with your

profile on those other websites or social media platforms.

4. The purposes for which we collect, use or disclose your personal data

1. SGHINDI, will/may collect, use, disclose and/or process your personal

data for one or more of the following purposes :

(a) processing and/or dealing with your interest in our products and/or

services;

(b) considering, processing, dealing with and/or managing, your

booking, reservation, request/application for, of or your purchase of,

our products and/or services (the “Transaction”);

managing Transaction(s) by or with you;

(d) administering, facilitating, managing, processing and/or dealing

with your relationship with us, your transaction(s) with us, your being

our loyalty card member or rewards member, any transactions or

activities carried out by you on the Website or at our

premises/establishments or with us, your requests, including but not

limited to dealing with your adhoc queries, requests or bookings,

dealing with your preferences, dealing with your membership needs,

dealing with your delivery needs, processing orders and payment

transactions, implementing transactions and the supply of products

and/or services to you that you have requested. Without limiting the

generality of the foregoing, should you make a reservation or

transaction that includes third party individual(s) or on behalf of third

party individual(s) or for third party individual(s), you consent to us

disclosing personal data that identifies you, to the said third party

individual(s) (such as but not limited to your name);

(e) administering, facilitating, processing and/or dealing in any

matters relating to your use or access of the Website, including

identifying you for login to the Website, our portals and other online

services provided by or on behalf of us. Without limiting the generality

of the foregoing, if you:

(i) gain access to or sign in to the Website, using your login

credentials of a Social Networking Site, or

(ii) use any features of a Social Networking Site such as its

widgets, plug-ins and browser push notifications, made available

to you on our Website, it may result in information or your personal

data being collected or shared between us and the third party. For

example, if you use Facebook’s “Like” feature, Facebook may

information on Facebook. (“Social Networking Site” refers to an

online or digital platform owned or operated by a third party, that

is used by people to build social networks or social relations, or to

interact, with other people, such as but not limited to Facebook,

Instagram, Twitter). By your proceeding pursuant to (i) or (ii)

above, you consent to such collection, use or disclosure of your

personal data;

(f) monitoring, processing and/or tracking your use of the Website in

order to provide you with a seamless experience, facilitating or

administering your use of the Website, and/or to assist us in improving

your experience in using the Website;

(g) administering, facilitating, processing and/or dealing in any

transactions, payments, debt collection, or activities carried out by

you on the Website or at our premises or with us;

(h) providing services to you as our customer, as a member of our

loyalty programme(s)/ card programme(s)/ rewards programme(s) or

when requested by you; dealing with or administering your

participation in contests, gamification, social events organised by us;

(i) registering you as a customer of any of our products or services,

and/or to deal with, process and/or administer the account that you

may open with us, whether a membership account or otherwise,

including to facilitate your transactions or activities at our premises,

the Website, or your transactions or activities with us;

(j) carrying out your instructions or responding to any enquiry or

complaint given by (or purported to be given by) you or on your behalf

including responding to your enquiries and complaints; or responding

to or dealing with your interactions with us or your requests; or

responding to or dealing with your feedback, comments or reviews. If

you have contacted us with any complaints, feedback, comments,

suggestions, we will use and disclose your personal data (including

your contact history) to respond to you and provide you with the best

service possible. If you are the complainant and you do not want us

to disclose your identity to the party you are complaining about, you

must let us know immediately. However, it may not always be possible

to handle your complaint on the basis of anonymity;

(k) contacting you or communicating with you via phone/voice call,

text message and/or fax message, email and/or postal mail for one or

more of the Purposes stated herein. You acknowledge and agree that

such communication by us could be by way of the mailing of

correspondence, documents 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 external cover of envelopes/mail

packages;

(l) sharing or disclosing (at our discretion) your suggestions,

comments, feedback or content (including audio, video etc.)

(collectively “Feedback”) that you provide through Social Networking

Sites, to the Website or to us (including at our premises), with other

users of the Website or with the public, for publicity and/or promotion

purposes with a view to marketing or showcasing the business,

products or services of SGHINDI, and/or to acquiring customers,

and/or for the purpose of providing the public with your Feedback

which may be useful for the public’s patronage decision or for the

public’s information or otherwise. This includes us disclosing your

name together with your Feedback. Without limiting the generality of

the foregoing, in the above regard, your Feedback and name may/will

be published or shared by us on public media platforms such as the

newspaper, the Internet, in our (including our affiliates’) annual

reports (if any) etc., and/or incorporated as part of SGHINDI’s

marketing collaterals/materials or corporate video to be disclosed to

the public, and you hereby consent to the same. Do not provide us

with Feedback if you do not wish for such Feedback to be disclosed

to the public. If you wish to give us your Feedback without it being

disclosed to the public, please separately contact our Customer

Department at support@sghindi.com and head the subject of your

feedback content with the word “Confidential”;

(m) understanding and/or managing your interests, concerns and

preferences;

(n) carrying out due diligence, statutorily required activities or other

screening activities (including background checks, anti-money

laundering checks, know your client checks) in accordance with legal

or regulatory obligations applicable to us (whether Singapore or other

countries), the requirements or guidelines of governmental authorities

which we determine are applicable to us (whether Singapore or other

countries) or any SGHINDI Group company, and/or our risk

management procedures that may be required by law (whether

Singapore or other countries) or that may have been put in place by

us or our affiliates/associated companies;

(o) to prevent or investigate any fraud, unlawful activity or omission or

misconduct, whether or not there is any suspicion of the

aforementioned; dealing with conflict of interests; or dealing with

and/or investigating complaints;

(p) complying with or as required by any applicable law, governmental

or regulatory requirements of any jurisdiction applicable to us or our

affiliates/associated companies, including meeting the requirements

to make disclosure under the requirements of any law binding on us

or our affiliates/associated companies, and/or for the purposes of any

guidelines issued by regulatory or other authorities (whether of

Singapore or other countries), with which we or our

affiliates/associated companies are expected to comply;

(q) complying with or as required by any request or direction of any

governmental authority (whether Singapore or other countries) which

we are expected to comply with; or responding to requests for

information from public agencies, ministries, statutory boards or other

similar authorities. For the avoidance of doubt, this means that we

may/will disclose your personal data to the aforementioned parties

upon their request or direction;

(r) conducting research, (including customer research), surveys,

market surveys, analysis and development activities (including but not

limited to data analytics, and/or profiling), obtaining your feedback to

our products, services or facilities, to :

(i) improve or develop our products, services and/or facilities in

order to enhance any continued interaction between yourself and

us connected or in relation to your relationship with us, the

Website, or your Transaction(s);

(ii) improve any of our products or services or facilities, whether

now or in the future; or

(iii) improve our understanding of your interests, concerns and

preferences.

Without limiting the generality of the foregoing, we may/will in this

regard send you surveys or request a face to face interview survey or

request your feedback, by way of email or postal mail.

In order for us to market products and services which are of special

interest and relevance to you, we may analyse and rely on your

overall interaction with us (such as but not limited to your shopping

behaviour in e-shops, your use of loyalty programmes, your ratings

and reviews of products, your contact history with our customer

service, your newsletter clicks/ opening results, your surfing

behaviour (web tracking), the newsletter types you are subscribed to,

your participation in promotions or events, your interactions with us

and your use of (mobile) applications);

(s) the conduct of training or training purpose, so as to develop or

improve our products or services and/or our staff’s and agents’

services and/or service quality. Without limiting the generality of the

foregoing, such training may involve collection, use, disclosure or

processing of your personal data including your feedback or

comments or reviews;

(t) to facilitate and/or ensure the safety and security of our premises,

our customers, our staff and/or visitors to our premises; to deal with,

handle and/or conduct disciplinary, security, crime prevention and/or

quality assurance processes, matters and/or arrangements. Without

prejudice to the generality of the aforesaid, we wish to bring to your

attention that there are surveillance cameras installed throughout our

premises and/or our offices, for security, crime prevention, safety and

training reasons and you acknowledge that your personal data will be

collected by such cameras and processed by us consequently;

(u) for marketing purpose and in this regard, SGHINDI would be

providing you with marketing, advertising and promotional

information, materials and/or documents relating to products,

contests, services and/or events (including products, services and/or

events of third party organisations with which SGHINDI may

collaborate with) that we or such third party organisations may be

selling, marketing, offering, organising, involved in or promoting,

whether such products, services and/or events exist now or are

created in the future, :

(i) by way of postal mail, electronic transmission to your email

address(es), push notifications, other forms of in-app notifications

or harnessing other technologies (such as geo-location

technology) for our mobile application(s) on your mobile device(s)

or other technologies on your computers, and/or through other

modes of communication that is not the 3 DNC Modes in

compliance with the PDPA. You may opt out of this or withdraw

from this at any time by sending a request to us. For the avoidance

of doubt, unlike (ii) below, the application of or your acceptance of

or your consent to, this Privacy Policy, constitutes your consent to

this subparagraph (i);

(ii) if you have separately expressly consented to one or more of

the following 3 DNC Modes, by way of the 3 modes of

communications of voice calls, text messages or faxes (the “3 DNC

Modes”) to your Singapore telephone number, in compliance with

the requirements of the PDPA; and/or

(iii) Notwithstanding (ii) above, regardless that you have not

separately provided express consent as aforementioned in (ii)

above, SGHINDI, as the case may be, reserves its right to send a

specified fax message (as defined in Singapore’s Personal Data

Protection (Exemption from Section 43) Order 2013) (the

“Exemption Order”) and/or a specified text message (as defined

in the Exemption Order) (i.e. a marketing fax message or

marketing text message) to your Singapore telephone number, if:

(1) there is an ongoing relationship between SGHINDI, and you,

and the purpose of the message is related to the subject of the

ongoing relationship, pursuant to the requirements and

conditions of the Exemption Order; or

(2) the law permits

For the avoidance of doubt, this subparagraph is without prejudice to

subparagraph (r) above for which you have hereby consented to us

contacting you for a survey, which you may subsequently opt out of

by sending our Data Protection Officer notice;

(v) storing, hosting, backing up (whether for disaster recovery or

otherwise) of your personal data, whether within or outside

Singapore;

(w) maintaining and/or developing our IT or business systems and

infrastructure including testing and upgrading of these systems;

(x) creating reports with respect to your Transaction(s) and/or

transactions that we have with our customers;

(y) facilitating, dealing with and/or administering external audit(s) or

internal audit(s) of the business of SGHINDI Transaction(s), and/or

our transactions with our customers;

(z) anonymisation of your personal data. In this regard, you

acknowledge that personal data that has been anonymised is no

longer personal data and the requirements of the PDPA would no

longer apply to such anonymised data;

(aa) dealing with and/or facilitating a business asset transaction or a

potential business asset transaction, where such transaction involves

SGHINDI as a participant or involves only a related corporation or

affiliated company of SGHINDI as a participant or involves SGHINDI

and/or any one or more of SGHINDI’s related corporations or affiliated

companies as participant(s), and there may be other third-party

organisations who are participants in such transaction. “business

asset transaction” means the purchase, sale, lease, merger or

amalgamation or any other acquisition, disposal or financing of an

organisation or a portion of an organisation or of any of the business

or assets of an organisation;

(bb) record-keeping purposes and producing statistics and research

for internal and/or statutory reporting and/or record-keeping

requirements, of SGHINDI or of its affiliates/related corporations;

(cc) SGHINDI’s reporting purposes including but not limited to

reporting on SGHINDI’s business performance; and

(dd) to deal with the or as part of a bankruptcy, winding up,

reorganisation, restructuring, insolvency, receivership or an

assignment for the benefit of creditors, of SGHINDI.

(the purposes set out in this paragraph 4.1 above shall be collectively

referred to as the “Purposes”)

2. You may withdraw your consent for us to process your personal data

for marketing purpose mentioned at paragraph 4.1(u) above at any

time via one the following relevant methods:

• clicking the Unsubscribe button located at the bottom of our

emailers

• contacting us or our Data Protection Officer through the contact

details listed at paragraph 13.1

3. We may/will need to disclose your personal data to third parties,

whether located within or outside Singapore, for one or more of the

above Purposes, as such third parties, would be processing your

personal data for one or more of the above Purposes. In this regard,

you hereby acknowledge, agree and consent that we may/are

permitted to disclose your personal data to such third parties (whether

located within or outside Singapore) for one or more of the above

Purposes and for the said third parties to subsequently collect, use,

disclose and/or process your personal data for one or more of the

above Purposes. Without limiting the generality of the foregoing or of

paragraph 4.1, such third parties include:

(a) our associated or affiliated organisations or related corporations,

or any member of the SGHINDI Group;

(b) any of our agents, contractors or third party service providers that

process or will be processing your personal data on our behalf

including but not limited to those which provide administrative or other

services to us such as mailing houses, telecommunication

companies, information technology companies, data centres, hosting

and maintenance service providers, analysis services service

providers, e-mail messaging services service providers, delivery

service provider, handling of payment transactions service providers,

marketing service providers, delivery services, handling of payment

transactions and debt collection, solvency check and address check;

as well as our insurers;

(d) third parties to whom disclosure by us is for one or more of the

Purposes and such third parties would in turn be collecting and

processing your personal data for one or more of the Purposes.

Without limiting the generality of the foregoing, such third parties to

which we may/will disclose your personal data include payment, debt

collection, finance companies or banks including credit card

companies; and

(e) any actual or proposed assignee or transferee of the business of

SGHINDI, or a merged entity in the event SGHINDI is merged to

create the said merged entity.

4. We may share your information with any member of the SGHINDI Group,

which may be based in countries other than Singapore, from time to time

for one or more of the Purposes.

5. Should you provide us with personal data of your child or children, you

confirm, declare and agree that you are the parent and/or legal guardian

of such child/children, and that we may collect, use and/or disclose your

child’s or children’s personal data for the Purposes set out at paragraph

4.1 above and in the manner as set out at paragraphs 4.1 to 4.4 above.

6. You may withdraw your consent for the collection, use and/or disclosure

of your personal data in our possession or under our control by contacting

us at support@sghindi.com. We will process your request within a

reasonable time from such a request for withdrawal of consent being

made, and will thereafter not collect, use and/or disclose your personal

data in the manner stated in your request, unless an exception under the

law or a provision in the law permits us to. However, your withdrawal of

consent could result in certain legal consequences arising from such

withdrawal, including us being unable to perform the transactions

requested by you or the termination of your relationship with us

(depending on the extent of your withdrawal), as the case may be.

7. We may collect, use, disclose or process your personal data for other

purposes that do not appear above. However, we will notify you of such

other purposes at or before the time of obtaining your consent, unless

processing of your personal data without your consent is permitted by the

PDPA or by law.

8. To the extent permitted by law, we may/will also be collecting from

sources other than yourself, personal data about you, for one or more of

the above Purposes, and thereafter using, disclosing and/or processing

such personal data for one or more of the above Purposes. We may

combine information we receive from other sources with information you

give to us and information we collect about you. We may use this

information and the combined information for the Purposes set out above

(depending on the types of information we receive).

9. Our Website may have the functionalities to allow you to share your

personal data with other third parties such as other users of our website.

You are responsible for your choice(s) and are deemed to have provided

consent for any sharing of your personal data in the manner provided by

the Website.

10. We take reasonable steps to ensure that any personal data we collect,

disclose and use is accurate and complete, if your personal data is likely

to be used by us to make a decision that affects you, or disclosed to

another organisation. However, it is important that you advise us of any

changes to your personal data or if there are any errors in the personal

data we hold about you. We will not be responsible for relying on

inaccurate or incomplete personal data arising from you not updating us

of any changes in your personal data that you had initially provided us

with.

5. Provision of third-party personal data by you

1. Should you provide us with personal data of any individual other than

yourself, you represent, undertake and warrant to us that :

(a) for any personal data of individuals that you disclose to us, you

would have prior to disclosing such personal data to us obtained

consent from the individuals whose personal data are being

disclosed, to :

(i) permit you to disclose the individuals’ personal data to

SGHINDI; and

(ii) permit SGHINDI to collect, use, disclose and/or process the

individuals’ personal data for the Purposes;

(b) at our request, you will use such form(s) or document(s) provided

by us in obtaining such consents from the individuals in question (for

the avoidance of doubt, we are under no obligation to you to create

any such form(s) or document(s));

accurate; and

(d) for any personal data of individuals that you disclose to us, that

you are validly acting on behalf of such individuals and that you have

the authority of such individuals to provide their personal data to

SGHINDI and for SGHINDI to collect, use, disclose and process such

personal data for the Purposes.

6. Third Party websites

1. This Policy only applies to our Website and information that we collect

from you. Our Websites may contain links to other websites which are not

owned or maintained by us. When visiting these third-party websites or

disclosing your personal data to third parties (including buyers or sellers

on our website), you should read their privacy policies, or ask relevant

questions before you disclose your personal data. We are not responsible

for the collection, use or disclosure of your personal data by such third

parties.

7. Social Networks

1. Our Website and mobile or web-based applications may provide you with

social plug-ins from various social networks (such as Facebook and

Twitter). If you choose to interact with a social network, your activity on

our Website or via our mobile or web-based applications will also be

made available to social networks such as Facebook and Twitter.

2. If you are logged in on one of the social networks during the visit of one

of our Websites or mobile or web-based applications, the social network

might add this information to your profile. If you are interacting with one

of the social plug-ins, this information will be transferred to the social

network. In case you do not wish such a data transfer, please log off on

your social network before you enter one of our Websites or mobile or

web-based applications.

3. We cannot influence this data collection and data transfer via the social

plug-ins. Please read the privacy policies of those social networks for

detailed information about the collection and transfer of personal data,

what rights you have and how you can achieve satisfactory privacy

settings.

8. Geo-location Services

1. Our Website and mobile or web-based applications may offer location-

enabled services, such as Google Maps and Bing Maps. If you use those

mobile or web-based applications, they may receive information about

your actual location (such as GPS signals sent by a mobile device) or

information that can be used to approximate a location. You will/may be

asked if the geo-location service can be activated and you can also object

to this geo-location service within the respective mobile or web-based

application.

9. Web analytics by Google Analytics

1. Our Website and mobile or web-based applications may contain web

analytic services provided by Google Analytics. This means that when

you visit our Website or use any mobile or web-based applications, a

cookie will be stored on your computer or mobile device, except when

your browser settings do not allow for such cookies.

2. This further means that when you visit our Website or use any mobile or

web-based applications, the personal data described above in paragraph

3.1 - including the "click-stream data", the data from "web beacons and

tracking links" and information stored in Google Analytics' cookies will be

sent to Google Analytics for analysis for and on behalf of us. Please note

that if you have created an online profile at our Website or mobile or web-

based application and if you are logged on in this profile, a unique number

identifying this profile will also be sent to Google Analytics in order to be

able to match the web analytics data to this profile.

3. Google Analytics acts as our agent, which means that we solely

determine the purposes for which the data is being used. You can find

out more about the relationships between Google Analytics and us in the

Google Analytics' privacy policy.

4. If you do not wish information about your behaviour at our Website or any

mobile or web-based applications being collected and assessed by

Google Analytics, you can install the Google Analytics opt-out browser

add-on. This add-on instructs the Google Analytics JavaScript (ga.js,

analytics.js, and dc.js) to not send your site visit information to Google

Analytics. The browser add-on is available for most modern browsers.

The Google Analytics opt-out browser add-on does not prevent

information from being sent to the website itself or in other ways to web

analytics services.

10. Retargeting Technologies

1. Our Website and mobile or web-based applications may use retargeting

technologies within the internet. This enables us to show our visitors, who

were already interested in our shop and our products, advertisement from

us on partner websites.

2. We also work with other companies who use tracking technologies to

serve advertisements on our behalf across the Internet. These companies

may collect non-personally identifiable information about your visits to our

websites or mobile or web-based applications and your interaction with

our communications, including advertising.

3. Retargeting technologies analyse your cookies and display advertisement

based on your past surfing behaviour. For further information on cookies,

please refer to paragraph 3 of this Policy.

4. We do not store any personal data about you with this technology.

11. Security & how do we store data?

1. Security of your personal data is important to us. We will put in place

reasonable security arrangements to ensure that your personal data is

adequately protected and secured. Appropriate security arrangements

will be taken to prevent any unauthorised access, collection, use,

disclosure, copying, modification, leakage, loss, damage and/or alteration

of your personal data. However, we cannot assume responsibility for any

unauthorised use of your personal data by third parties which are wholly

attributable to factors beyond our control.

2. We will put in place measures such that your personal data in our

possession or under our control is destroyed and/or anonymised as soon

as it is reasonable 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.

12. Your Rights

1. If you have any questions about the processing of your personal data or

about our Policy, if you do not accept the amended Policy, if you wish to

withdraw any consent you have given us at any time, or if you wish to

update or have access to your personal data, you are welcome to contact

us through the contact details listed at paragraph 13.1.

2. You have the right to access and/or correct any personal data that we

hold about you, subject to exceptions under the law. This right can be

exercised at any time by contacting us through the contact URL at

paragraph 12.1. We will need enough information from you in order to

ascertain your identity as well as the nature of your request, so as to be

able to deal with your request. All requests for correction or for access to

your personal data must be in writing. We will endeavour to respond to

your request within 30 days, and if that is not possible, we will inform you

of the time by which we will respond to you.

3. We may be prevented by law from complying with any request that you

may make. We may also decline any request that you may make if the

law permits us to do so.

4. In many circumstances, we need to use your personal data in order for us

to provide you with products or services which you require or have

requested. If you do not provide us with the required personal data, or if

you do not accept an amended Policy or withdraw your consent to our

use and/or disclosure of your personal data for these purposes, it may

not be possible for us to continue to serve you or provide you with the

products and services that you require or have requested.

5. We may charge you a fee for responding to your request for access to the

personal data which we hold about you, or for information about the ways

in which we have (or may have) used your personal data. If a fee is to be

charged, we will inform you of the amount beforehand and respond to

your request after payment is received.

13. Complaints

1. You may send complaints regarding our handling of personal data in the

following ways:

(a) in writing.

Such complaints must:

– be addressed to the SGHINDI PTE. LTD. at:

(i) support@sghindi.com

(ii) Address: 10 JALAN BESAR, #11-02, SIM LIM TOWER,

Singapore 208787

– provide the name, contact number and address of the person

submitting the feedback

– provide the relevant details required such as the relevant time

period, our employees or who involved, or copies of relevant

documents.

(b) by telephone.

Such complaints must:

– be made to SGHINDI PTE. LTD at:

Telephone: +65 8801 8900 (This is a recorded line. The caller is

advised that their call will be recorded.)

2. All complaints will be evaluated by SGHINDI in a timely manner. After

SGHINDI has completed its evaluation, the SGHINDI Group Data

Protection Officer (or a duly appointed representative) will respond to the

person who submitted the complaint or feedback, with the results of the

evaluation.

14. Governing Law

1. This Policy is prepared pursuant to the PDPA and governed by the laws

of Singapore.

15. General

1. Your consent that is given pursuant to this Privacy Policy is additional to

and does not supersede any other consent that you had provided to

SGHINDI (and/or any member of the SGHINDI Group) with regard to

processing of your personal data.

2. For the avoidance of doubt, in the event that Singapore personal data

protection law permits an organisation such as us to collect, use or

disclose your personal data without your consent, such permission

granted by the law shall continue to apply.

Effective 16 January 2021