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Reenova Group Privacy Policy

About this policy

The Reenova Group is committed to safeguarding your personal data.

In this policy, “the Reenova Group” means Reenova Investment Holding Limited and each of its subsidiaries (as defined in the Companies Act, Singapore Cap. 50). When we use “we”, “us” or “our”
in this policy, we mean the Reenova Group.

Changes to this policy

We review and update our privacy policy periodically and the latest version is available at
http://www.reenovagroup.com/contact-us/. This policy was last updated on 1st August 2019.

By providing us with your personal data, you consent that your personal data be stored and used by us for the purposes and in the matter described herein.

What personal data we collect

We only collect personal data that is relevant to our contractual business and/or employment
relationship with you.

If you are a shareholder, director, corporate officer, manager, employee or appointed contractor of
any business entity, we may collect your personal data if it is relevant to our business relationship
with you or in that entity.

The personal data we collect includes:

• personal particulars (e.g. name, contact details, date of birth, identity card/passport details)
• contact information (e.g. address, telephone numbers, email address, fax numbers)
• education details (e.g. names of schools and institutions, types of qualification)
• medical details (e.g. prior medical history)
• financial details (e.g. income, expenses, credit card information)
• employment details (e.g. employment history, salary, benefits, title, tenure)
• personal opinions that you make known to us
• marital status and spousal information
• information about next-of-kins
• any other data not specified above

How we collect personal data

We may collect personal data directly from you. We may sometimes collect information about you through third party when they are duly authorized by you to provide personal data from you. This may
be done in person when you meet our staff or representatives, or over the phone, by email or through websites.

We may also collect your personal data about you from third party sources without directly involving you. For example, we may obtain your personal data from your family members or a government agency. We may also obtain your personal data from market research organisations or publicly available resources such as telephone directories or business directories.

The Reenova Group is likely to collect personal data in the following situations:

• when you apply for a job with us
• when you enter a business relationship with us
• when you provide any services to us
• when you perform any duties in the course of employment with us
• when you visit our web sites
• when you attend our annual general meetings or results briefing sessions
• when you contact us with feedback, queries or complaints
• when you request us to send you information or notify you of developments in the company via post, emails or telephone calls.

How we use personal data

The key purpose for which we need your personal data is to process your application or request, to proceed with any contractual employment or business relationship with you or to contact you to
provide any information to you pertaining to the Reenova Group.

These include:

• processing your job application
• processing your employment related information with various government agencies
  (for e.g., application for employment passes, Central Provident Fund applications, etc.)
• processing any employment related benefits for you or your next of kin wherever applicable
  (for e.g., insurance companies, hospitals, health care providers, etc.)
• to facilitate your performance of business, employment or contractual relationships with us
• to facilitate your performance and provision of services to us
• to facilitate your attendance at our annual general meetings or results briefing sessions
• to handle your feedback, queries or complaints

We may also use personal data for other purposes connected or relevant to our business, such as:

• complying with our legal and regulatory obligations and requirements
• accounting, risk management and record keeping

We do not provide your personal data to third parties outside the Reenova Group for purposes other than those set out above or purposed related to those set out above. We do not sell your personal data to any third parties.

Cookies

Our web sites use cookies. A cookie is a small text file placed on your computer or mobile device when you visit a web site. Cookies collect information about users of the web site and their visit, such as their Internet protocol (IP) address, how they arrived at the web site (for example, through a search engine or a link from another web site) and how they navigate within the web site. We use cookies to facilitate your internet sessions, offer you services according to your preferred settings, track visitor use of our web sites and to compile statistics about web site activities.

You can set up your web browser to block cookies. You may also remove cookies stored from your computer or mobile device. However, if you do block cookies, you may not be able to use certain features and functions of our web sites.

Other web sites

Our web sites may contain links to other web sites which are not maintained by the Reenova Group.
This privacy policy only applies to the web sites of the Reenova Group, and not third-party web sites.

Feedback and suggestions

If you send us feedback, comments or suggestions, we may use your personal data in order to respond to you.

Complaints

When we receive a complaint we may have to disclose the complainant’s identity to whoever the complaint is about. 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.

Other purposes

If we need to use your personal data for any other purposes, we will notify you and obtain your consent beforehand. You will be given the opportunity to withhold or withdraw your consent for the use of your personal data for these other purposes.

Who has access to personal data

We may from time to time disclose your personal data to those personnel within the Reenova Group who have a need to know. We may also disclose or share your personal data with third parties. These third parties include:

• service providers which provide products and services requested by you
• our service providers (such as our IT systems maintenance provider)
• our professional advisors (such as accountants, lawyers and auditors and bankers)
• your representatives (such as your lawyer, executor, administrator or trustee)

We will also disclose your personal data to third parties in order to comply with legal obligations or
industry requirements. This includes disclosures to:

• legal, regulatory, governmental, tax and law and regulatory enforcement authorities

From time to time, we may need to process or deal with your personal data outside Singapore and/or your home country. In doing so, we take precautions to ensure that all third parties to whom we disclose your personal data will keep your personal data confidential and comply with applicable data protection and privacy laws.

How long we will retain your personal data

We will retain your personal data for as long as we need to do so for business or legal purposes.

Access to and correction of your personal data

You have the right to:

• request to be provided with your personal data which is in our possession
• ask for information about the ways in which we have (or may have) used your personal data in the
  one-year period preceding your request

We may charge you a fee for responding to your requests. If a fee is to be charged, we will inform you
of the amount beforehand and will respond to your request once payment is received.

You also have the right to:

• make corrections to your personal data which is in our possession
• withdraw your consent to our use of your personal data.

If you wish to contact us for any such purposes, please see How To Contact Us at the end of this policy.

We will use reasonable efforts to provide, correct or delete our records of your personal data. We may be prevented by law from complying with your request. We may also decline your request if the law permits us to do so.

What happens if you do not allow us to use your personal data
In many circumstances, we need to use your personal data in order for us to process your application or request. If you do not provide us with the required personal data, or if you withdraw your consent to our use of your personal data for these purposes, it may not be possible for us to proceed further with your application or request to us.

Other rules and processes

In some cases, there may be specific rules or processes that govern our use of your personal data, which are not stated in this policy. If any such rules or processes do apply, we will make them known to you in advance.

How to Contact Us

To contact us on any aspect of this policy or your personal data, you can email to the Personal Data Protection Officer (PDPO) at enquiry@reenovagroup.com or write in to:

Personal Data Protection Officer

Reenova Investment Holding Limited
83 Clemenceau Avenue
#10-03 UE Square
Singapore 239920

All complaints and feedback will be evaluated by the Personal Data Protection Officer (PDPO) in a timely manner. After the PDPO has completed his evaluation, he will respond to the person who submitted the complaint or feedback in writing, with the results of the evaluation.