This document “Data Protection Policy” applies to all personal data collected by InnoBay Group.

The purpose of this Data Protection Policy is to inform you of how InnoBay Group manages Personal Data which is subject to the personal data protection principles under the Singapore Personal Data Protection Act (No. 26 of 2012). Please spend some time to read this Data Protection Policy so that you know and understand the purposes for which we collect, use and disclose your Personal Data.

By any interaction with us, submitting of information to us, or signing up for any products and services offered by us, you agree and consent to InnoBay Group in collecting, using, disclosing and sharing amongst themselves your Personal Data, and disclosing such Personal Data to relevant third parties as per listed in this Data Protection Policy.

This Data Protection Policy supplements but does not supersede nor replace any other consents you may have previously provided to InnoBay Group in respect of your Personal Data, and your consents herein are additional to any rights which InnoBay Group may have at law to collect, use or disclose your Personal Data.

InnoBay Group may update this Data Protection Policy to ensure that this Data Protection Policy is consistent with any future developments, industry trends and/or any changes in legal or regulatory requirements.

1. Personal Data

1.1 In this Data Protection Policy, “Personal Data” refers to any 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, including data in our records as may be updated from time to time.

1.2 Examples of such Personal Data you may provide to us include your name, telephone number(s), mobile number, mailing address, email address and any other information relating to any individuals which you have provided us in physical and/or electronic means.

2. Personal Data Collection

2.1 Usually, we collect Personal Data in the following ways: (a) when you submit an application form, sign up form, contact us form, registration form, or other forms relating to any of our products and services; (b) when you are contacted by, and respond to, our marketing personnel; (c) when you respond to our online/offline promotions, initiatives or to any request for additional Personal Data; (d) when you request that we contact you or request that you be included in an email or other mailing list to receive relevant information; (e) when you use our electronic services, or interact with us via any of our websites or use services on any of our websites; (f) when we receive references from third parties and business partners; (g) when you submit your Personal Data to us for reasons other than mentioned above.

2.2 We do not, at our websites, automatically collect Personal Data unless you provide such information or login to access any of our services.

2.3 If you provide us with any Personal Data relating to a third party (e.g. spouse), by submitting such information to us, you represent and warrant to us that you have obtained the consent of the third party to provide us with their Personal Data for the respective reasons.

2.4 You should ensure that all Personal Data submitted to us is complete, accurate, true and correct.

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

3.1 Usually, InnoBay Group collects, uses and discloses your Personal Data for the following purposes: (a) running the daily administrative and business operations of InnoBay Group; (b) allowing us to verify your identity; (c) allowing us to respond to your queries, feedback, complaints and requests; (d) for feedback or participation in surveys, market research and/or analysis for statistical, profiling or other purposes for us to review, develop and continue to improve the quality of our products and services; (e) in connection with any claims, actions and/or protecting and enforcing our contractual, legal rights and obligations; (f) conducting investigations relating to disputes, billing or fraud; (g) meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on InnoBay Group; (h) purposes which are reasonably related to the above.

3.2 InnoBay Group may also collect, use and disclose your Personal Data for the following additional purposes: (a) providing marketing services, products and benefits to you, including but not limited to special events and promotions from InnoBay Group; (b) comparing Personal Data with other data collected for other purposes and from other sources (including third parties) in connection with offering of products and services by InnoBay Group that may interest you; (c) purposes which are reasonably related to the above.

3.3 If you have provided your Singapore telephone number(s) and have indicated that you consent to receiving marketing or promotional information via your Singapore telephone number(s), then from time to time, InnoBay Group may contact you using such Singapore telephone number(s) (including via voice calls, text, fax or other means) with information about our products and services.

3.4 In relation to particular products and services or in your interactions with InnoBay Group, we may also have specifically notified you of other purposes for which we collect, use or disclose your Personal Data. If so, we will collect, use and disclose your Personal Data for these additional purposes as well, unless we have specifically notified you otherwise.

4. Disclosure of Personal Data

4.1 InnoBay Group will take reasonable steps to protect your Personal Data against unauthorised disclosure. Subject to the provisions of any applicable law, your Personal Data may be disclosed by InnoBay Group, for the purposes listed above (where applicable), to the following entities or parties, whether they are located in Singapore or overseas: (a) the various entities within InnoBay Group; (b) our professional advisers such as consultants, auditors and lawyers; (c) agents, contractors or third party service providers who provide operational services to InnoBay Group, such as courier services, telecommunications, information technology, payment, printing, billing, payroll, processing, technical services, training, market research, call centre, security or other services for InnoBay Group; (d) companies providing services relating to marketing and consultancy to InnoBay Group; (e) any other party whom you authorise us to disclose your Personal Data to.

5. Data Security and Integrity

5.1 InnoBay Group will take reasonable efforts to protect Personal Data in our care or our control by making reasonable security arrangements to prevent unauthorised access, collection, use, disclosure, copying, modification, disposal or similar risks. However, we cannot fully guarantee the security of any Personal Data we may have collected from or about you, or that for example no harmful code will enter our websites (for example Trojan horses, adware, viruses, bugs or spyware).

5.2 While we make every effort to protect your Personal Data, we cannot fully ensure the security of the information you transmit to us via the Internet or when you use our online portals, and we urge you to take every precaution to protect your Personal Data when you are on the Internet. We highly recommend that you change your passwords often, use a combination of letters and numbers, and ensure that you use a secure browser.

5.3 If applicable, you commit to keep your username and password secure and confidential and shall not disclose or permit it to be disclosed to any unauthorised person, and to inform us as soon as reasonably practicable if you suspect your credentials have been compromised. We are not liable for any damages resulting from any security breaches, on unauthorised and/or fraudulent use of your username and password.

6. Contacting Us

6.1 If you: (a) have any questions or feedback relating to your Personal Data or our Data Protection Policy; (b) would like to withdraw your consent to any use of your Personal Data as set out in this Data Protection Policy; or (c) would like to obtain access and make corrections to your Personal Data records, you can contact our Data Protection Officer below: Email: dpo@innobaygroup.com Contact Number: +65 6686 3287

7. Governing Law

7.1 This Data Protection Policy and your use of our websites shall be governed in all respects by the laws of Singapore.