This Data Protection Notice (“Notice”) sets out the basis which Thurlestone Shipping (Singapore) Pte. Ltd.. (the “Company“ we”, “us”, or “our”) may collect, use, disclose or otherwise process personal data relating to directors, shareholders, autorised bank signatories and secretaries of the Company and all individuals who wish to contract or to establish a business relationship with us. Protecting the confidentiality
and integrity of personal data is a critical responsibility that the Company takes seriously at all times. The Company will ensure that personal data is always processed fairly, in accordance with the provisions of the Personal Data Protection Act (“PDPA”) and any other applicable data protection legislation.

1. PERSONAL DATA
1.1. As used in this Notice, “personal data” means data, whether true or not, about an individual who can be identified: (a) from that data; or (b) from that data and other information to which we have or are likely to have access.

1.2. Depending on the nature of your interaction with us, some examples of personal data which we may collect from you include name, identification numbers such as NRIC, passport, work permit and birth certificate, residential address, email address, telephone number, nationality, gender, date of birth, marital status and financial information.

2. COLLECTION, USE AND DISCLOSURE OF PERSONAL DATA
2.1. 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 authorised by you to disclose your personal data to us (your “authorised representative”) after
(i) you (or your authorised representative) have been notified of the purposes for which the data is collected, and
(ii) you (or your authorised 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 applicable 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 authorised by law).

2.2. We may collect and use your personal data for any or all the following purposes:
2.2.1. verifying your identity;
2.2.2. responding to, handling, and processing queries, requests, applications, complaints, and feedback from you;
2.2.3. managing your relationship with us, including but not limited to, reflecting your directorship with us and communicating with you as necessary in connection with the Company’s affairs;
2.2.4. facilitating the internal administration of the Company;
2.2.5. complying with any applicable laws, regulations, codes of practice, guidelines, or rules, or to assist in law enforcement and investigations conducted by any governmental and/or regulatory authority;
2.2.6. transmitting to any unaffiliated third parties including our third party service providers and agents, banks and relevant governmental and/or regulatory authorities, whether in Singapore or abroad, for the aforementioned purposes; and
2.2.7. any other incidental business purposes related to or in connection with the above.

2.3. We may disclose your personal data:
2.3.1. to third party service providers, agents, banks and other organisations we have engaged to perform any of the functions with reference to the above mentioned purposes.

3. PROTECTION OF PERSONAL DATA
3.1. We have implemented appropriate technical and organizational security measures designed to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorized access, and other unlawful or unauthorized forms of processing, in accordance with the applicable laws.

3.2. You are responsible for ensuring that any personal data you send to us are sent securely.

4. ACCURACY OF PERSONAL DATA
4.1. We generally rely on personal data provided by you (or your authorised representative). 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 at the contact details provided in section 9 below.

5. YOUR RIGHTS
5.1. Subject to applicable law, you may have a number of rights regarding the processing of your personal data, including:
5.1.1. The right to be informed about the processing of your personal information;
5.1.2. The right to have your personal information corrected if it is inaccurate and to have incomplete personal information completed;
5.1.3. The right to object to processing of your personal information;
5.1.4. The right to restrict processing of your personal information;
5.1.5. The right to withdraw your consent and the right to have your personal information erased (the “right to be forgotten”);
5.1.6. The right to request access to your personal information and to obtain information about how we process it;
5.1.7. The right to move, copy or transfer your personal information (“data portability”);
5.1.8. Rights in relation to automated decision making which has a legal effect or otherwise significantly affects you.

5.2. The above-mentioned rights do not apply in all circumstances. To exercise one or more of these rights, or to ask a question about these rights please contact our Data Protection Officer at the contact details provided in section 9 below.

6. WITHDRAWAL OF CONSENT
6.1. 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 consent and request us to stop collecting, using and/or disclosing your personal data for any or all of the purposes listed above by submitting your request in writing or via email to our Data Protection Officer at the contact details provided below.

6.2. Upon receipt of your written request to withdraw your consent, we may require reasonable time (depending on the complexity of the request and its impact on our relationship with you) for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we shall seek to process your request within seven (7) business days of receiving it.

6.3. Whilst we respect your decision to withdraw your consent, please note that depending on the nature and scope of your request, we may not be in a position to continue providing our services to you and we shall, in such circumstances, notify you before completing the processing of your request. Should you decide to cancel your withdrawal of consent, please inform us in writing or via email to our Data Protection Officer at the contact details provided below.

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

7. RETENTION OF PERSONAL DATA
7.1. We will only retain your personal data for as long as necessary to meet any of the purposes for which it was collected or as required or permitted by applicable laws.

8. TRANSFERS OF PERSONAL DATA OUTSIDE OF SINGAPORE
8.1. We may transfer your personal data to third parties that are not based in Singapore, for example, to a subsidiary or parent company, in connection with the purposes set out in this Notice. Whenever we transfer your personal data to other countries, we will ensure a similar degree of protection is afforded by putting in place suitable safeguards.

8.2. Please contact our Data Protection officer if you want further information on the specific mechanism used by us when transferring your personal data out of Singapore.

9. DATA PROTECTION OFFICER
9.1. You may contact our Data Protection Officer if you have any enquiries or feedback on our personal data protection policies and procedures, or if you wish to make any request, in the following manner:
By post,:
Attention: Data Protection Officer
Thurlestone Shipping (Singapore) Pte. Ltd.
8 Eu Tong Sen Street, #22-89 The Central (Office Tower 1), Singapore 059818

By telephone:
+65 6593 3780

By email:
DPO@thurlestone-shipping.com.sg

10. EFFECT OF NOTICE AND CHANGES TO NOTICE
10.1. This Notice 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.

10.2. We may revise this Notice from time to time. We will inform you via email of any material change of
this Notice.