Personal Data Protection Notice

NAFTA MATERIALS PTE. LTD.

Version 1.0

Last Updated: October 29, 2024

Introduction

This Data Protection Notice (“Notice”) sets out the basis which NAFTA MATERIALS PTE. LTD. (“we”, “us”, or “our”) may collect, use, disclose, or otherwise process personal data of our customers and other individuals in accordance with the Personal Data Protection Act (“PDPA”). This Notice applies to personal data in our possession or under our control, including without limitation, personal data in the possession of organisations which we have engaged to collect, use, disclose, or process personal data for our purposes.

Definitions

  1. Customer: Any individual who has contacted us regarding goods/services or has entered into a contractual relationship with us.
  2. Personal Data: Data about an individual who can be identified from that data or from that data and other information to which we have or are likely to have access.

Types of Personal Data Collected

  • Name
  • Address
  • Email address
  • Phone number
  • Age
  • Date of birth
  • Gender
  • Marital status
  • Photographs
  • Video recordings
  • Nationality
  • Passport/identity card copies
  • Employment information
  • Cookies/IP addresses
  • Other background information such as income data, financial records, tax records

Notification to Customers

Before collecting personal data, individuals are informed of the purpose of collection or how the data will be used, and any potential disclosures. Customers are provided with clear and concise information about the company’s data protection policies at the point of collection, ensuring transparency and informed consent.

Purposes for Collection, Use, and Disclosure of Personal Data

  • Performing obligations in connection with our provision of goods and/or services requested by you
  • Administering your relationship with us
  • Verifying your identity
  • Responding to queries, feedback, and/or complaints
  • Processing payment
  • Complying with applicable laws
  • Assisting with investigations conducted by any regulatory or law enforcement agency
  • Any purpose for which you have provided us personal data
  • Any other incidental business purposes related to or in connection with the above
  • Transmitting data to third parties (e.g., third party service providers, contractors, agents) whether in Singapore or elsewhere, for any of the abovementioned purposes

Disclosure of Personal Data

We generally do not disclose personal data without first obtaining a customer’s consent. Disclosure will then be only for the specific purpose that the customer has been informed about. However, we may disclose personal data without consent in certain situations, such as:

  • Performing obligations in connection with our provision of goods and services
  • To third party service providers, contractors, agents, and other parties we have engaged to perform any of the functions in connection with the above mentioned purposes
  • To our group/related/affiliated companies
  • To companies providing services pertaining to insurance and/or reinsurance
  • To professional advisers (e.g., legal advisers, auditors, bankers)
  • To authorities (e.g., regulators, law enforcement agencies)

Updates on Data Protection Policies

Changes to data protection policies are communicated through legal documentation, the company website, and direct communication with affected customers. Updates are also provided via letters and email notifications.

Granular Consent Management

Before collecting certain types of personal data, we will provide customers with detailed options to specify their consent for different types of data processing activities. Consent can be withdrawn for any individual activity at any time.

Express Consent for Sensitive Data

For sensitive information, such as health data, financial records, racial or ethnic origin, or religious beliefs, we will obtain express written consent before processing such data.

Automated Monitoring and Surveillance

Customers are informed if any form of automated monitoring is in place, such as call recordings for training or security purposes, monitoring of internet use, or CCTV surveillance on premises.

Cookies and Tracking Technology

The company uses cookies and other tracking technologies on its website to enhance user experience and perform analytics. Users are notified through a banner and provided with the option to manage their cookie preferences.

Automated Decision-Making and Profiling

In certain instances, we may process personal data for the purpose of automated decision-making, including profiling. Customers will be given the right to request additional information, seek human intervention, or object to the profiling or automated decisions.

Consent

Clear and informed consent is obtained before collecting, using, or disclosing personal data. Customers can opt out of marketing communications at any time.

Purpose Limitation

Personal data is collected only for specific, legitimate purposes that are communicated to the customers. If the data needs to be used for a different purpose, additional consent is obtained.

Protection Obligation

We implement administrative, physical, and technical measures to protect personal data. Third-party service providers who handle personal data on our behalf are required to adhere to our data protection standards.

Accuracy Obligation

Personal data provided directly by customers is presumed to be accurate unless there is reason to believe otherwise. Customers can request corrections to their data if they believe it is inaccurate or incomplete.

Retention Limitation

Personal data is retained only for as long as reasonably necessary to fulfill the purposes for which it was collected or to comply with legal requirements. Once no longer needed, data is securely deleted or anonymized.

Transfer Limitation

Personal data is only transferred to third parties when necessary for business operations and under strict safeguards. Data is transferred outside Singapore only when necessary and with the individual’s consent.

Access and Correction

Customers can submit written requests to access their personal data held by us. We will verify the identity of the requester and provide the data as soon as reasonably practicable. Customers can also request corrections to their personal data.

Withdrawal of Consent

Customers can withdraw consent for the collection, use, or disclosure of their personal data at any time by submitting a written notice. We will inform the individual of the potential consequences of the withdrawal.

Data Protection Officer

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:

Name of DPO: Chan Aik Shin Lindy
Contact No.: +65 31581836
Email Address: naftamaterials@dpoguard.com

Effect

This Notice applies in conjunction with all other notices, contractual clauses, and consent clauses that apply in relation to the collection, use, and disclosure of your personal data by us. We may revise this Notice from time to time without any prior notice.