M & C SERVICES PRIVATE LIMITED
                                                                                (Company Registration No: 197901676D)
                                                                                              (EA Licence No. 08C3413)


                                                                                      DATA PRIVACY POLICY

                                                                                 Privacy Policy Statement

This statement sets out the Privacy Policy and practices of M & C Services Private Limited (the “Company”) that will be followed with respect to the collection, use and/or disclosure of personal data provided by its clients and their shareholders. This statement is provided in accordance with the Personal Data Protection Act (Act 26 of 2012) (the “PDPA”).

Please note that this Privacy Policy complements, and does not limit or replace, the purposes for which you provide the Company with your personal data which may be expressly stated in any form for submission of personal data to the Company.

1.         Personal Data

           You hereby agree that the Company may collect, store, process, disclose, access, review and/or use personal data (including sensitive personal data) about you, whether obtained
           from you or from other sources, for the purposes set out below and/or the purpose of managing your relationship as a client with the Company:-

           (i)        providing corporate services required by you, including but not limited to, share registration services, company incorporation services, corporate secretarial services,
                      employment/dependant’s pass and permanent residence applications, regulatory filings, company restructuring services, administration of employee option schemes, listing
                      services and/or company striking off / liquidation services;

           (ii)       providing administration of payroll services;

           (iii)      dealing with enquiries made by you;

           (iv)      maintenance and updating of the data;

           (v)       tax filing preparation;

           (vi)      collection of fees, charges and expenses for services provided;

           (vii)     verification and identification purposes, including carrying out “know your client” verification checks;

           (viii)    facilitating the making and payment of claims, including payments by cheque, bank transfers or other means;

           (ix)      carrying out billing, accounting, auditing and the maintenance of proper book-keeping to explain the Company’s operations and business;

           (x)       the disclosure of the relevant books, documents, records and information (in hard or soft copy) to auditors for the preparation of financial reports; and/or

           (xi)      for compliance with any law, rule, regulation, order, judgment or decree of any court, government body, statutory authority or regulatory, administrative or supervisory body.


          If you have provided personal data of individuals other than yourself to the Company, you also confirm that you have sought the requisite consent from these
          individuals to the collection, use and disclosure of their personal data. In particular, you confirm that you have informed these individuals of the purposes for collection,
          use and disclosure of their personal data as set out above.


2.        Data Accuracy

           As the Company relies on personal data provided by you to provide you with services, you must ensure that all personal data that has been supplied to us is as accurate as
           possible. Where there are any inaccuracies, you must inform the Company of the correction to be made as soon as possible.

3.        Data Security

           The Company will take reasonable steps to protect the personal data it holds from misuse and loss and from unauthorized access, modification or disclosure.

           The Company will not keep personal data for longer than is necessary and will take reasonable steps to destroy or permanently de-identify personal data if it is no longer needed.

           To carry out the purposes listed above, the Company may engage 3rd party service providers to provide it with services and in this connection, your personal data may be disclosed
           to, processed by or used by such 3rd party service providers for such purposes. In such cases, we will take reasonable steps to ensure that such 3rd party service providers keep
           your personal data confidential and secure.

4.        Access and Correction

           You are entitled to have access to the personal data about you that is in the possession or under the control of the Company and information about the ways in which the personal
           data has been or may have been used or disclosed within a year before the date of the request. This can be done by you making a written application to the Designated Person (as
           defined below) requesting for any such information. The Company reserves the right to charge a fee (representing its costs in administering your request) for supplying such
           information and to refuse requests which, in its opinion, occur with unreasonable frequency.

           The Company will also, where you have requested that it correct an error or omission in the personal data about you that is kept with the Company, correct such data as soon as
           practicable.

           The Company may however choose not to provide you with access to or correct such information, in accordance with the exceptions under the PDPA. This would include cases
           where:

           (i)        The Company is satisfied on reasonable grounds that the correction should not be made;

           (ii)       The request for access is frivolous or vexatious or the information requested is trivial;

           (iii)      The personal data is related to a prosecution and all the proceedings related to the prosecution have not been completed;

           (iv)      The personal data, if disclosed, would reveal confidential commercial information that could, in the opinion of a reasonable person, harm the competitive position of the
                      Company; and

           (v)       The personal data was collected, used or disclosed for the purposes of an investigation and associated proceedings and appeals have not been completed.

5.        Transborder Data Flows

           If your personal data is transferred to a country or territory outside Singapore, we will ensure that the recipients thereof provide a standard of protection to your personal data so
           transferred that is comparable to that which is provided herein.

6.        Enquiries and Complaints

           The Company has designated the person whose details are set out below as the person (“Designated Person”) who will be responsible for ensuring the Company’s compliance with
           applicable data protection laws. If you have any queries or requests or wish to make any applications concerning your personal information or data, please contact the Designated
           Person at:

           Telephone No : +65 6228-0562
           Email : general@mncsingapore.com



 
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