No deviation PERSONAL DATA PROTECTION POLICY

Your privacy is important to us. This No deviation (Nd) Personal Data Protection Policy sets out how Nd 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, or disclose 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 and our authorised third parties 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.

We may update this Personal Data Protection Policy from time to time as Nd deems fit. Should any revision(s) be made to this Personal Data Protection Policy, updates will be published on our public site (www.nodeviation.com). 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.

1 Your Personal Data

1.1 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 collected by Nd 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 or credit card information;
• 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

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

• when you access our websites or perform an online transaction;
• when you interact with any of our employees;
• when you submit an application to us for services and benefits;
• when you respond to our request for additional Personal Data;
• when you ask to be included in an email or other mailing list;
• when you request that we contact you;
• when you respond to our initiatives or promotions; and
• when you submit your Personal Data to us for any other reason.
• When you browse our website, you generally do so anonymously, but please see section 6 below on cookies.

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

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

• to provide you with benefits and services that you have signed up for with us
• to provide you with training
• to assist you with your enquiries;
• to process payment for your services rendered or any other purchases;
• 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;
• to inform you about our, services, and events that we think may be of interest to you (“Marketing Materials”) via mail, electronic mail, telephone (voice or SMS-Text), facsimile or social media platforms, if you have consented to us sending you Marketing Materials; and
• to comply with applicable laws and regulations.

4 Marketing/ Optional Purposes

4.1 If you would like to withdraw your consent to us sending you Marketing Materials, you may withdraw your consent at any time by informing us through the unsubscribe options through applicable electronic channels or email us at admin@nodeviation.com. We will remove your details from our direct marketing database within one (1) month from the date of receipt of your consent withdrawal request.

4.2 Please note that notwithstanding the withdrawal or withholding of your consent to us sending you Marketing Materials, we may still send you non-marketing messages such as surveys, customer-service notices and other service-related notices.

5 Disclosure of your Personal Data

5.1 We may disclose your Personal Data to the following group of external organisations for purposes mentioned above, subjected to the requirements of applicable laws:

• 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;
• business partners that provide any related services; and
• any other person in connection with the purposes set forth above or for other purposes where you have given us your consent.

6 Use of Cookies

6.1 We may collect or analyse anonymised information from which individuals cannot be identified (“Aggregate Information”), such as number of users and their frequency of use, the number of page views (or page impressions) that occur on our websites and common entry and exit points into our websites.

6.2 We make use of “cookies” to store and track Aggregate Information about you when you enter our website(s). Such cookies are used to track information such as the number of users and their frequency of use, profiles of users and their online preferences.

6.3 Such aggregate Information collected may be used to assist us in analysing the usage of our website(s) so as to improve your online experience with us.

6.4 Should you wish to disable the cookies associated with these technologies you may do so by changing the setting on your browser. However, please note that this may affect the functionality of the website(s).

7 Third-Party Sites

7.1 This digital service may contain links to non-Government digital services whose data protection and privacy practices may differ from ours. We are not responsible on the content and privacy practices of these other digital services and we encourage you to consult the privacy notices of those digital services.

7.2 We encourage you to learn about the privacy policies of such third party website(s) by checking the policy of each site you visit and contact its owner or operator if you have any concerns or questions

8 Protection of your Personal Data

8.1 To safeguard your personal data, all electronic storage and transmission of personal data is secured with appropriate security technologies.

9 Accuracy of your Personal Data

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

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

10 Withdrawal of Consent

10.1 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 admin@nodeviation.com.

10.2 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 membership benefits and services to you.

10.3 Such a withdrawal may therefore result in the termination of any membership that you may have with us.

11 Access and Correction of your Personal Data

11.1 You may request access to or make corrections to your Personal Data records

11.2 Please submit your request to us through the following platforms:

• Nd Public Site: www.nodeviation.com
• Write to our Data Protection Office: admin@nodeviation.com

12 Retention of your personal data

12.1 We will retain your Personal Data for as long as they are required to fulfil the purposes mentioned above, or as required by applicable laws.

13 Contacting Us

13.1 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 admin@nodeviation.com